10 11 12 13 14 16 17 18 19 20 21 22 23 24 DIGITALLY RECORDED WORN STATEMENT w 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 EFTA00110989

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LIMITED OFFICIAL USE 1 APPEARANC ies) =) hy Q " OR GENERAL wi w K 8 WITN te) ive) ho i ° io No rar No EFTA00110990

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LIMITED ies) w oO wo i=) N ive) oO co wo No Nm No ion) OFFICIAL USE 3 MR. Ee : The recorder is on. My Department of Justice Office of the Inspector General New York Field Office and these are my credentials. All right. This interview with federal Bureau of sons lieutenant Po is being conducted as part of an official U.S. Department of Justice Office of the Inspector General investigation. Today’s date is July 12, 2021, and the time is 1:06 p.m. This interview is being conducted at the federal correctional institution Dan located in Danbury, Connecticut. This is the training center. What is it the -? MR. QJ: «see center? MR. a : What does it stand for do MR. a : Yeah. It’s the training Janbury on the EFTA00110991

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LIMITED No No iN ies) w fos) wo ioe) fee) © ion) OFFICIAL USE 4 FCI Danbury property. Also will be recorded by me, SSA | sstsi‘izéwd Could e ial Ag oO identify themselves for ryone ple the record and To start, Thank you sir. This is an official DOJ OIG investigation to the death of inmate Jeffrey Epstein and the surrounding circums voluntarily provide answers to our q tions. Will agree to a voluntary interview with the DOJ OIG? MR. a : Yes. MR. Ee : Thank you sir. This isa form that we have for our voluntary interviews. We give this can stop the interv You don’t have to an You can leave. un wer our questi EFTA00110992

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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 EFTA00110993

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LIMITED OFFICIAL USE w ~] ive) 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 nece mean that you’ve done anything wrong. It’s fa sarily 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. EFTA00110994

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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 EFTA00110995

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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! EFTA00110996

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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 EFTA00110997

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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 EFTA00110998

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LIMITED OFFICIAL USE 11 oO io wo MR. 709? MR. You’re talking a right? MR. o K o wu J > re) when and Bs | oO Se) 5 D KR 1) = p n 0 is = Hh b ial n rt 12] fh bh bh ie] o wu a) n = 5 @ 3 ct with the BOP? I a I ; o K fe) in * Be whole time? - 2019, ‘18 think December 17th I did a temp. MR. a : December of 2017? And when did you le left December ‘19. ecember of 2019? EFTA00110999

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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 EFTA00111000

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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. EFTA00111001

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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. EFTA00111002

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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 EFTA00111003

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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. EFTA00111004

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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? EFTA00111005

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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 EFTA00111006

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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. EFTA00111007

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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? EFTA00111008

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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. EFTA00111009

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LIMITED OFFICIAL USE 22 1 MR. QJ: «9 vr-hn. 2 MR. a : I’m just tryin When we talk to you, we just need to lock down to -. Q ies) 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. ae: 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 EFTA00111010

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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 EFTA00111011

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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 EFTA00111012

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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 EFTA00111013

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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 EFTA00111014

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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: Nah. 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 EFTA00111015

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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 EFTA00111016

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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 EFTA00111017

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LIMITED OFFICIAL USE 30 1 MR. QJ: and that’ 2 there’s only - for the morning watch is there 7) because yeah ies) only an ops lieutenant? wi aw So you were the first one 6 in on that day? And you said you arrived when? 7 MR. QJ: 9m 6:00. 9 10 4:00. Correct? nN ive) We didn’t - haven’t had a 4 reason to yet. I just assumed you would I don’t remember. was ‘19, t oO a o co Fs) Lal rt wo a3 Yeah-yeah-yeah. No just because of the - you know this was probably one 21 of the biggest things that’s ever happened. 22 MR. a: Yeah but that’s why I’m like are they asking about it That’s why EFTA00111018

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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. EFTA00111019

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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 EFTA00111020

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LIMITED OFFICIAL USE 1 MR. QJ: That incident? No. 2 MR. a : No. Do you know what wo ios) 3 transpired? 4 MR. ae: They say he put something 5 around his neck. In his cell. And that was 6 it. 7 MR. a : Did you ever hear any 8 rumors that his cell mate may have tried to 9 harm him? 10 MR. a: Oh yeah. You’re talking 11 about um -. Yeah. I heard about that. Yeah. 2 MR. a : What did you hear about 3 that? 4 MR. a: That it was a ploy for him to 15 get (Indiscernible *00:22:43). Something like 16 that. 7 MR. QM: 411 right. So did you -? 8 Is your understanding that he actually did try 9 to harm himself? Or was it your understanding 20 that his cell mate tried to harm him? 21 MR. ae: You’ re talking about the 22 rumor? 23 MR. a : Yeah. What is your 24 understanding of -- 25 MR. ae: The rumor was the guy -- EFTA00111021

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LIMITED ies) w fos) ive) oO oo OFFICIAL USE MR. Ee : -- what actually -? MR. a: -- also had a high-profile case. MR. QJ: 9 And I think Epstein was up for a bail ing. So they made it look li he was doing that in order to get better. a: vo you rumor? I don’t know. Not after MR. Ee : All right. believe that he did actually try to harm himself on July 23rd? Um do you know a result of July 23rd if Epstein - if anythi happened with Epstein? Was he removed from as the EFTA00111022

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LIMITED OFFICIAL USE 1 MR. Ee : Okay. And what happens on suicide watch? Is that outside of the SHU? Wo wi ies) a Yeah. 4 MR. a : And then after you get 5 placed on suicide watch. Is that a temporary 6 thing and then you get moved over to psych observation? Not all the time. No. co Fs) 9 Psych makes that call. 10 Do you - are you aware if 11 Epstein was outside of the SHU and on suicide 2 watch or psych observation for approximately 3 one week? 4 MR. a: I know he was definitely on 15 there. Because I remember seeing him. 16 MR Ee : You saw him there? co Fs) a 3 k 7) rt iy wv rt o 0) Qo i] =] 7] @ ke Oo oc 9 were doing rounds? 20 there? 21 MR. ae: I had to - because I’m the 22 one who does the showers. 23 MR. a : Okay. 24 MR. a : For suicide inmates. On 25 psych watch if you’re down there. So he was EFTA00111023

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LIMITED OFFICIAL USE wo C 1 down there one day - probably a couple days. 2 But I know I took him to the shower one time. ies) Yeah. interaction with him. 7 MR. a : While he was in suicide w oO a Suicide watch. Yeah. t i=) Fa Okay. And I just thought 11 - I thought you were only on suicide like 24 hours. And then after that it was nN ive) called psych observation. Is 4 understanding? 5 MR. It’s up to psych. t oO a Okay. But is it in the same - Lee) 5 J 5 4 fu rt 0) wu ie] a he 0 J ie] fw i bh wo in the same location. Correct? No =) id Yeah but people who are on 21 suicide watch longer than 24 Okay. No ion) id al wu > So your understanding the 25 whole time EFTA00111024

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LIMITED ies) w oO ive) oO co OFFICIAL USE Ww ~] MR. a: I don’t remember. MR. ae: The whole time he was there. MR. a : Um do you know when he was removed from suicide watch? MR. a : Do you know why he was removed from suicide watch? MR. a: He would be moved because MR. a : Okay. And when someone on suicide watch, what does it entail? MR. a: You have a suicide smock. Suicide mattres if] b And a suicide blanket. And you allow approved it, t MR. a : Okay. And what’s the difference? What is the difference between y supposed to have. ch observation? What does that entail? MR. ae: You got the clothe MR. ae : All right. So when re on suicide watch, you don’t have if) MR. QJ: 9 Naked. EFTA00111025

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LIMITED ies) w oO wo i=) N ive) oO co No Nm No ion) OFFICIAL USE wo o MR. Ee : You’re naked the whole time? And you know if Epstein was naked that whole time? cloth MR. a : He didn’t have clothes when he was on suicide watch? MR. a: You can’t have clothes on suicide watch. it sound right that he would i] ” doe removed about a week later around July 30th. Does that sound like a date -- MR. a: I don’t know. MR. a : -- or you’re not sure? MR. QJ: 9 wm-hn. MR. ae : Okay. Did you ever receive any instructions from anyone with regard to Epstein being assigned after he came back from suicide watch? MR. a : All right. I’m going to EFTA00111026

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LIMITED OFFICIAL USE 39 1 show you an email. And then you can tell me if 2 you remember receiving it. An email froma ies) Do you know who that is? w 2 wy by an b HK b Q Ss ct H ct mn rr oO 6 Suicide Watch / ych Observation Update. And 7 that’s also what the subject is. And it’s from 8 July 30, 2019 It ys, “Inmate Epstein” and 9 it gives his reg number. “Is being taken off 10 ion and needs to be housed 11 with an appropriate cellmate.” Do you recall 2 receiving -? 3 MR. a: Yeah. It’s a generic. We 4 always get those. c uw bd K ie] i= Q oO rt those? 7 MR. ae : There’s names on the 8 back. It shows that you were one of them and 9 that you read it. Do you see your name? Yeah. 20 It would be under J. So. It’s all 21 alphabetical. 22 MR. a: It’s under what? 23 MR. a : It would be your first -. 24 MR. a : Oh, okay. Yeah. 25 MR. a : So does that ring a bell? EFTA00111027

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LIMITED OFFICIAL USE ~] wo 10 11 Do you remember getting that? MR. QJ: 39 Yeah. MR. a : Okay. Cool. And then do you recall -? So you are aware that he needed a cellmate then. Correct? You already said that you knew he needed one because he was a regular inmate. Right? MR. a: Yeah. But I don’t know what ct a p. i] } if) at 12:30 the 30th right? MR. a : Yeah 7:30 - so yeah. MR. QJ: 90h it was 7:30 July 30th? MR. a : Correct. MR. QJ: 9 Okay. MR. a : Placed back in the SHU and required a cellmate. MR. a: Okay. MR. a : And just before we forget. Do you mind just initialing and dating a each one of these documents just so that they or) rt don’t start piling up? And as well a hat email. Thank you, 0] ir. Now do you remember having any conversations with anyone else like verbal. Like | or anybody regarding the need for him to have a cellmate? 40 EFTA00111028

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LIMITED ies) w oO wo i=) N ive) oO co wo No Nm No ion) OFFICIAL USE 41 MR. a : Because, I’m assuming, he was the most high-profile if not one of the most high-profile inmates at the time. 7) o wu 7 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. 5 K © wu J MR. ae : You got a follow-up that you wanted to ask something? MR. ae: We’ll finish up on this. it’s going back one. MR. a : No-no. Please. Go MR. QJ: = So you mentioned that you had interacted with Epstein when he was on suicide watch. You took him for his showers. Yeah. 5 How was the interactions with him? EFTA00111029

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LIMITED OFFICIAL USE 42 10 11 12 18 19 20 21 22 MR. a: You know, cuff up, take him 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. a: I don’t know exactly what day it was. But you know it was around there. MR. QJ: «Got it. MR. a : 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 EFTA00111030

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LIMITED OFFICIAL USE 43 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 inmate comes off of watch, they send it out. 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. QM: 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. a : 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 EFTA00111031

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LIMITED OFFICIAL USE 44 w ~] wo 10 11 a cellmate for a year. You understand what I’m saying? So as far as the notice we get, but do everyone know that? I’m not sure about that. MR. a : But you knew. MR. QJ: 9 veah. MR. a : How did you know though? MR. a: I got the email. MR. a : Okay. So, your knowledge is from the email, but earlier, you said that anybody in the SHU, anyway, needs to a cell mate? MR. a: Yeah. MR. a : All right. So, he had basically two requirements to him. One, there was the email that he received; also, the fact that he was in the SHU, and he didn't have any of those special requirements, like, he was going to harm someone else, or something like that, that he should have had a cellmate? MR. EJ: $9 Right. MR. a : All right. And do you know if you ever communicated that to anybody, when you visited the SHU in July or August of 2019? MR. a: Hmm. I'm not sure. EFTA00111032

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LIMITED OFFICIAL USE 45 w ~] wo 10 11 MR. Ee : Like, the people that 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. a: Bring up? Yeah. If I - yeah - but if he had a - one - if he had a cellmate, though. MR. QJ: 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. a : And is that something - when you would visit the SHU - is that something you would ask? How many single cells do you have? MR. a: Yeah. MR. a : Is that a like one of the check-the-box things? Does everybody that visits the SHU -- EFTA00111033

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LIMITED OFFICIAL USE 46 1 MR. a: I can't speak for everybody. 2 But I know, even as OIC, we said, hey, you know Ww ct + oO fine, we have single cells. Maneuver to 4 condense it for space. Stuff like that. w co wo i=) 2 MR. ae: If I seen someone withor hey, wh ive) 4 housed 5 MR. t oO a 7 MR. ae : But when you would visit the SHU, was that something you would address, co 9 saying how many single cells do we got? 20 MR. QJ: 9 t'm not the SHU lieutenant. 24 MR. a : I'm talking about -- lieutenant -- EFTA00111034

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LIMITED OFFICIAL USE 47 1 MR. Ee : -- when you do your 2 rounds. 3 MR. ae : -- you do the rounds, you 4 only say it if you know that -a 5 new come in. Okay, you got space for him. No. 6 Right now, we’ve got to put him in a single 7 cell, or something like that. 8 MR. a : Okay. And were you ever 9 10 2 MR. QJ: «1 don’t think so. I was never SHU lieutenant. ive) 15 remember ever having any conversations with 16 anyone in the SHU -- at the MCC about Lee) 5 | 1 9 Epstein and his cellmate requirement? 20 MR. BJ: No. 21 MR. QJ: No? All right. So, 22 referring to the duty assignment roster, who 23 were the MCC’s supervisor on duty, with 24 responsibility for overseeing the SHU on August 9, , when you were working? EFTA00111035

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LIMITED ies) w oO wo i=) N ive) oO co wo No Nm No ion) OFFICIAL USE 48 MR. QJ: ot would be me and yy. MR. a : So, the two of you would MR. a : Okay. And then, would it be the same thing for the shift after you? lieutenant and MR. a : And is that because, when the SHU lieutenant is not there, activities’ lieutenant and ops lieutenant always have Vell, I told you we have to make SHU. Yeah. But that would be the lieutenants - they would be the lieutenants that would have oversight over the Pretty much. Okay. On August 9th, Fh what communications did you have with any o the other lieutenants with regard to Epstein EFTA00111036

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LIMITED OFFICIAL USE 4 wo 1 being housed with the MCC, or the MCC SHU? Can 2 you recall? ies) i 4 MR. a : And again, thinking back, 5 this is like one of the biggest things that’s 6 ever happened when y were there, this dies. Can you remember any conversations you 8 had the day before, with anyone, with regards wo to Epstein? 10 MR. a: I just know that he used to 11 come legal all the time. 2 mR. (RR: Yeah. ive) Fs) Attorney conference, pretty 4 much the whole day. that’s about it. 7 MR. ae : And about what time would he be moved to attorney conference? 9 MR. a : Early. Like, probably 8:00 F oO Fs ty 5 Q co 20 in the morning. 21 MR. ae : And who would be the 22 person that would move him there? 23 MR. a: The SHU staff. Get him out ho No w Fa) EFTA00111037

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LIMITED OFFICIAL USE 50 1 MR. QJ: 9 He was in SHU. 2 MR. a : And what would the - as 3 the activities’ lieutenant, did you visit him 4 at all in attorney conference, or check on him? 5 Is that part of your round process oO a Ph It’s not part of the rounds, but if you see him in there, if you standing by co the elevators or something like that, yeah. wo 7) fe) 2 wu K< - you don’t 11 have to check. No. 2 MR. a : All right. Did anyone 3 ever provide you with special instructions, 4 with regards to Epstein? 15 MR a: Special instructio 16 MR Ee : Yeah. 7 MR. a: Like? Something - no. B MR. SR: 30? 9 MR a : With special instructions? 20 Like -? 21 MR. ae : Like, conversations with 22 Epstein, hey, make sure you do this Just 23 Epstein, make sure this is going - you know? 24 guess specific instructions. Maybe “special” 25 isn't the right word -- EFTA00111038

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LIMITED ies) w oO wo i=) N ive) oO co wo No Nm No ion) OFFICIAL USE MR. a : -- but did anyone ever specifically say, you know, this is Epstein, we've got to make sure we’re doing this? MR. QJ: 9oymm-mm. No. Not that I MR. a : No? Did any lieutenants ever talk to you about Epstein’s requirement to ° have a cellmate? Like I said, we’ve got the email. by the way, (Indiscernible *00:36:07), and didn't he have a cellmate up until then? I think he had cellmate since he got on the fw suicide watch. So, I don't think there was a lapse in it. MR. ae : So, what about up until MR. a: Right. Yeah. The cellmate, MR. a : -- so, what is your wo rary EFTA00111039

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LIMITED OFFICIAL USE 52 w ~] ive) understanding of what happened -- MR. a: What happened? MR. a : -- 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. Ee : So, we’ll get into that. I’1ll ask 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’1ll 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. BJ: No. MR. a : 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 EFTA00111040

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LIMITED OFFICIAL USE 53 w ~] to oversee them as the lieutenant, or anything like that? MR. a: You could take a count, but usually, you're doing patrol, you’re not doing the count with the officers. wR. (I: 9 8ich presence in the SHU, the only time that the rr - So, in physically 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 9, 2019? MR. a: I'm not sure. I can't recall. MR. Ee : 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. QJ: 9 Yeah, I know. MR. a : 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. EFTA00111041

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LIMITED Oo w ot) oO oo OFFICIAL USE 54 MR. Ee : Well, that’s what I mean, MR. ae : Mm-hmm. you know, tt lieutenant, know, on ifically, like MR. Ee : All right. And it’ll be, lie a a. Michael Thomas, Tova Noel, a. EFTA00111042

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LIMITED OFFICIAL USE 1 MR. Ee : Okay. So, you didn't wo wi 2 speak to any of those people about Epstein 3 being required to have a cellmate since his 4 cellmate was gone w a You’ re talking about that 8 MR. a: Or you’re just saying -- the day that -- 10 MR. a: -- I can't remember. 11 MR. Ee : -- okay. All right. The wo i _ o 2 people that are in the SHU, are they 3 responsible for conducting counts and round 4 during their shift? 16 MR. Ee : As far as the shift that 7 you worked, on day watch, what is 8 understanding of how many rounds and counts 9 they should have done? 20 MR. QJ: 9 There’s no counts on day 21 watch. 22 MR. ae : Okay. What about the 23 rounds? 24 MR. a : The rounds, every - you’re 25 doing a certain shift, we go about. So, you do EFTA00111043

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LIMITED ies) w co ive) oO co OFFICIAL USE 56 one , say, like, 8:00 to 8:30, you do one. 8:30 MR. a : So, every 30 minutes? 30 minutes. Not to exceed 40 minutes. They’re regular rounds. MR. a : Okay. And you’re supposed to do one of those rounds with them, rounds with them. No. MR. ae: Do our round in SHU. MR. Ee : And can you recall if you t be abnormal if you didn't? MR. ae: I can't recall. MR. ae : You can't recall if it would be abnormal if you didn't? MR. a : If I didn't do the round? EFTA00111044

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LIMITED OFFICIAL USE w ~] ive) J uw MR. a: Would it be abnormal? I mean, I'm not the SHU lieutenant. That’s what I'm saying. MR. QJ: 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. ae : But there’s no SHU lieutenant. MR. QJ: Right. So, but I don’t recall if I did a round or not. No. MR. a : 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. a: Yeah. MR. a : -- but would you normally have done it, if there’s no SHU lieutenant? MR. QJ: 9 yeah. EFTA00111045

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LIMITED OFFICIAL USE 58 1 MR. Ee : Yeah? So, knowing 2 yourself, you probably would -. ae : If there’s no SHU lieutenant, ies) a w a wu 7 MR. a : When did you become aware 8 removed from the M 9 9, 2019 11 MR. QJ: what is -. 12 MR. ae: The only thing I heard is, I ioe) know, I woke up, they’re saying, I saw the 15 MR. a : What is your 16 as the activities’ lieutenant that day, with 17 18 no involvement. 19 , the activities -- 20 MR. QJ: 39 (indiscernible *00:41:32). 21 -- lieutenant is not 22 23 24 Is the ops lieutenant 955 25 EFTA00111046

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LIMITED ioe) w io ioe) its) MR. a: Not really, no. MR. a : So, who is involved? Who MR. QJ: 9 Roo. . Ee: Okay. And do you remember who was working in R&D that day, in and Discharge. that morning? MR. a : -- sheet? How does do you find out who was in R&D for work? How On that morning. iB 4 j fw t u 4 3 3 Oo rt o i im 0) @ wu > What would don't know. You’re not sure? o wu rt A s not our department. aI } Ut [! MR. did they come OFFICIAL USE 59 EFTA00111047

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LIMITED OFFICIAL USE oO’ oO 1 and retrieve those individuals from the SHU, or 2 does the SHU staff bring them to R&D? 3 MR a: It depends. If it’s busy, 4 you say, hey, I need help, they go up and help 5 you out. If not, the SHU crew, all right, take 6 them down 7 MR. a : So, if it were at a non- 8 busy traditional way, who would have been the 9 people on that roster? 10 MR. a: The SHU crew. 11 MR. Ee : And who on that day? 12 MR. a: You mean, for the court 3 movements? 4 MR. ae : Yeah. Like, what time? 15 First of all, I guess I should say. Ll? saying - so, 8 Brooklyn, or wherever, 9 So, e oO, 21 the other? And does not - 22 8:00 a.m., who would have 23 MR. a: The day 24 MR. : And 25 that day? It depends - that’s what I'm it depends on if they’re going to you start early at 6:00. that would morning watch or day watch. it would be one or let’s say if it was it been? watch crew. who was on day watch EFTA00111048

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LIMITED ho ho ho No i) ioe) w io its) Wa OFFICIAL USE 61 remember speaking about MR. a : All right. And who was Who was the officer-in-charge, out of MR. ae: According to this, it was document to show you a memo that was written by | All right. I'm going a. that inmate Reyes was going WAB, and possibly may not return. Also, that inmate ing a cellmate upon arrival EFTA00111049

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LIMITED OFFICIAL USE ies) w ~] wo 10 11 ive) from his attorney visit.” So, does that refresh your memory? Did you have any conversations with | MR. GR: No. MR. a : Who would have made | aware that Reyes was going WAB? MR. a : He could see it on the ight before. MR. a : So, if that’s not on the night before, if on the night before, there’ roster. They send a sheet up i] no WAB - and is at 1:50 p.m. that this notification was made note - if there’s no WAB -. Well first of all what’s WAB stand for? MR. a: With All Belongings. MR. a : And if WAB is not next to Reyes’ name on the night before, the August 8th roster, how would have he become aware at around 1:50? Would normally the court call R&D, and R&D pass that information along? MR. QJ: 9D could have called him. MR. QJ: so, would R&D call SHU directly, or would they typically call the ops or activities’ lieutenant? MR. QJ: 9 they call the sHu. MR. QM: they do call sHU EFTA00111050

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LIMITED OFFICIAL USE 63 1 directly? They wouldn’t call you guys, and you 2 would have to the pass information on? mR. QR: No. ies) f it your 5 belief, then, that if it’s that, in fact, what 6 happened, if Reyes went to court, and then he 7 became WAB? Just tell me, what is your 8 understanding -- 9 MR. a : I'm not sure how that one. 10 MR. PF -- of how that would 11 work? 2 MR. ae: I'm not sure about that. 3 MR. a : Yeah. I'm not saying, 4 specifically, how he got it. What would be the 15 typical way that would work? If an inmate -- 16 MR. ae: If an inmate -. 7 MR. ae : -- goes to work -- 8 MR. QJ: «9 Mm-hon. 9 MR. Ee : -- and then is released. 20 MR. J: 9 m-hon.. 21 MR. ae : How does that proces os) 22 work? Once that inmate is released, what 23 happens from that point, for the court, how do 24 they make the notifications known to the MCC, 25 all the way down to where that inmate was EFTA00111051

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LIMITED ies) w co wo ive) co OFFICIAL USE 64 housed? Specifically, this one in the SHU. MR. a: R&D. Hey, that guy’s not coming back. And then, would say, now WAB, would that be the words would use, or would they say, he’s not coming back? MR. QJ: cit something that’s on the roster. to the roster, or is WAB also if he was called and told? I don’t know. I’ve seen it before on the roster. Like, hey, this is the court list. It says WAB. if there is no WAB -- circumstance, I'm not sure. EFTA00111052

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LIMITED ies) w co ive) oO co OFFICIAL USE 65 MR. a : No? And you seem pretty confident with that. Not like I can't recall. You did not have any conve What about with a: yersations with | | about coming back? ft, I can't recall that, Did you know that Reyes cour So then, therefore, did you not know that he was not coming back? MR. QJ: =No, I didn't know. No. ay. And you don’t actually did a round in ti! to see that he wasn’t there? MR. QR: No. So, can you recall any that day about Reye EFTA00111053

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LIMITED ies) w co wo ive) co OFFICIAL USE 66 MR. a: I don't think I had no conversations about Reyes. MR. a : That’s what I'm asking. can't recall any conversations that day about Reyes? MR. a : And you don’t think you We're going to continue with this. MR. ae: I’ve got -- All right. clarification. o know like I said, the court MR. a : Hmm-mm. I guess R&D. EFTA00111054

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LIMITED OFFICIAL USE 67 10 11 12 13 14 16 18 19 20 21 22 23 24 R&D over there, right? MR. BJ: No. 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. QJ: ut - 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 EFTA00111055

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LIMITED OFFICIAL USE 68 1 MR. Ee : -- so, you’ve never seen 2 it on email. It’s just a list that’ 107) ie] K oO Pp. Q o Q WwW i¢2) ) sy rs) \ R&D comes and g 4 MR. ae: No. They send it up. So, Internal comes and wi aw 7 MR. ae: Internal. Yeah. MR. a : So, on this date, would you know who would have been Internal? Who co a wo i=) SHU? I see who’s Internal, but I'm 2 not - I don't know if they would have provided 3 it We’ve got two Internals. 4 MR. ae : And who are the two 5 Internals? 16 MR. ae: | (Phonetic Sp. 7 *00:48:29) and [g.- 21 the two that typically - you’re not saying that co 22 they did - but they’re typically the people 23 that would have provided the court list? 24 Yeah. Internal. That’s what 25 It could have been a EFTA00111056

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LIMITED OFFICIAL USE o io 1 sanitation. 2 MR. a : Now, isn't the list typically provided the day before, or is it ies) Ph 4 just created the day before? et i) I don't know. I can't -. wi aw yided the day before? 7 MR. a : Yeah. 8 MR. a: It was provided the same day. 10 MR. a: You get about - you 11 morning watch the day of. oO a 2 MR. fF : Iwas always - I was 3 under the understanding that the night before, 4 on August 8th, they would create the list for 5 the morning, on the 9th. Do you know -- t fea) m3 Ke o w x 7 MR. ae : -- was that a correct 8 understanding? 9 MR. a : I'm not sure. All I know is, 20 if you’re an officer, day of. 22 MR. a: Because an 23 officer, I used to get 24 MR. QM: «411 right. And you've 25 worked in EFTA00111057

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LIMITED OFFICIAL USE 10 1 MR. MR. ies) it would come in that 5 6 Around what it arriv co io 12 MR. a : So, it would come in at morning watch. 14 MR. a: Yeah. Morning watch. there ioe) w ay. And 16 people in Internal working at that time, around co 22 MR. ae : So, those morning watch would probably 24 have provided EFTA00111058

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LIMITED ies) w co io ioe) co OFFICIAL USE 71 MR. Ee : And do you know, is that re? The court list oO document maintained anywh document? know who - MR. a: I don't know. I mean, t not my department. MR. MR. MR. ae : -- do you know who, in ugust, would have been that pers MR. a : In August, no. out for a while. EFTA00111059

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OFFICIAL ies) w USE also had a would be? I know No. But supervisor. that’s I don't know who 1t is. And And do you that supervisor. know who that they had a their position, but would be, like, ies) fu a lieutenant? oO a No. Who would -? Lieutenant is custody. R&D 2 is non-custody. ive) a) Explain to me what R&D Receiving and F oO oO p- w Q > wu 4K Q oO yeah, yeah, yeah. Lee) 5 So, they deal with the inmate 9 movement, the inmate courts, the transfers, the surrenders. self MR. And you’re saying that 22 they’ re not called lieutenants or anything. 23 What are their titles? 24 MR. a : Correctional systems officer EFTA00111060

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LIMITED OFFICIAL USE 73 1 officers. And, like, a supervisor, would they 2 still be, like -? ies) a Supervisor correctional 4 systems officer 5 MR a : And would that be, like, 6 a nine or an 11 type of -- 7 MR. a : Something like that. 8 MR. a : -- position? All right. 9 But they’re just outside of, you said custody, 10 underneath -. What is the system that they’re 11 underneath? 2 MR. ae: It’s the non-custody and custoay. ive) 15 MR a: And they have correctional 16 officer, a correctional worker, as opposed to custody is a correctional officer. 8 MR. a : Okay. And who would be - is] 9 . Does the captain also have oversight over 20 them? 21 MR. GJ: No. 22 MR. ae : Who has oversight over 23 them? Non-custody. 24 MR. MJ: =the cmc. They have a 25 supervisor. EFTA00111061

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LIMITED ioe) io ioe) oO oo wo OFFICIAL USE 74 MR. QJ: 9 what does the CMC mean? MR. a: Correctional Management MR. a : And you don’t remember at that tim who that we ay. And you rsations at all. So, you ions with | abou MR. a: No. Not that I remember. MR. a : No? But he would have nd of interaction with her at all on August 93th? EFTA00111062

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LIMITED ies) w oO wo i=) N ive) oO co No Nm No ion) OFFICIAL USE MR. GJ: No. can't remember if you No? So, obviously, you had any conve I don’t remember WAB? No? So, at this point in time, obvi point in time. Now, you know about Reyes being remo 5 Ll LJ. c w rt we Es oO = oa o and never came back. information about who wasn’t coming back? MR. QR: No. you don’t know? So, did you ever receive time, saying -- -- that Reyes was going sly, ying you didn't know anything at that after the fact, what do ed from the went to court, Do you know any was informed that he So, even after the th ia Qa rt EFTA00111063

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LIMITED ies) w co ive) oO co OFFICIAL USE I mean, was it at hey, somebody droppe don’t recall him goi sonally - didn And I don’t think a i] i ct ion r K ) fu a all you know anything -. d the ball there? m thing. i) nM] o know he didn't ng - I was ‘t know he was going WAB. lot of ot people did, Did anyone ever MR. GJ: No. MR. MR. August 11th, you and say, coming back? MR. And fon) EFTA00111064

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LIMITED OFFICIAL USE 77 1 interviewed for this matter before? 2 MR. QJ: No. ies) a No? Did you have w Oo Kh fu o K 3) 5 o ih o Q wu a Q Pp 5 Q ct oa p rt) 3 iit) ct rt oO in] a fw mh ct o KK te ue} a) ct oO Bb 5 wu fa bh ie) Cc o on Les] 5 is) ue] 13] ct o Bb =) being found, and wo sa] 12] ct a fu bp. o a ry a oO e be a FT rt oO 10 MR. GJ: No. 11 MR. Ee : No? You never talked to 2 anybody in the institution about that? ive) Fs) About him not having a 4 cellmate, or are you talking about him being t wi Hh i3) Cc 3 ion No. About him not h t oO as bi | Lee) 5 I mean, not ina -. I mean, 9 we sent a, hey, what happened, or, like, what 20 happened to his cellmate? Oh, he got released. 21 Okay. It was - he said it like that, but 22 nothing -. No. Not like that. 23 MR. a : Was it any conversation 24 of, like, hey, they put a new 25 cellmate with him? EFTA00111065

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LIMITED ioe) w io ioe) its) OFFICIAL USE 78 at around 7] 4 o wu t n 5 iat + 4 3 saying. a+r That’s the time. That’s I'm looking at MR. QJ: should have h communicated with either or || about that? i) MR. hm Q s) 5 t * o oO = mh on Oo t= rt * fo ie) = how he communicated with. EFTA00111066

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~) wo LIMITED OFFICIAL USE 1 didn't say nothing to the lieutenant, I could 2 see why. I mean, you’re telling me, I'm the 3 orc And okay, I got the notification. MR. a: So, if he didn't pass nothing w Oo on, it’s -. 7 MR. a : Is it abnormal that he 8 didn't pass it on, though? Should have he 9 passed it to you? Because -. 10 MR. a: It’s not. It’s not -. I 11 mean — 2 MR. a : Could have he placed 3 another inmate with someone like Epstein? 4 MR. a: I'm not sure because then, 15 again, it says possibly. WABs get cancelled. 16 They get cancelled 8 MR. a : That’s why the 1:50, we don’t 9 know until after, like, hey, who is this guy 20 coming back? R&D is open at 8:00, 9:00. 21 MR. ae : So, about what time would 22 they normally make that notification that, okay 23 -? 24 MR. QJ: 9 After 4:00. EFTA00111067

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LIMITED OFFICIAL USE 80 2 MR. a : And is it some - when you 3 say after 4:00 - is it usually between 4:00 and 4 5:00? wi md a io Hh ct oO K ney o Any time after =) i a : So, anywhere from 4:00 to 8 5:00, 4:00 to 6:00, 4:00 to 8:00. What -? 9 MR. a : After the count. 10 MR. a : So, after the 4:00 p.m. 11 count. 2 MR. a : After the 4:00 p.m. count. 3 MR. a : And why is it after the 4 count? 15 MR. a: Because that’s when the guys 16 come back, after the count. We do the 4:00 7 count. And then, you get an (Indiscernible 8 *00:56:31) base count training is like this. 9 You get 20 guys came back from court, this WAB 20 got cancelled. 21 MR. ae : So, as far as the 4:00 22 count, or is it at that point, do people start 23 saying, where are these guys, and start making 24 calls, are they coming back or not? 25 MR. QJ: «at 4:00? No. EFTA00111068

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LIMITED OFFICIAL USE 1 MR. Ee : No? So, when 81 the next 2 time that they would be listed on that count? ies) MR. ae : The 9:00 count. 4 MR. a : The 10:00 count? MR. a: Oh, the 10:00 count. w 6 MR. a : Do you want Yeah. some 7 more questions on that line? I'm ji trying to 8 -. Because I thought it was at - I felt people 9 have told at 4:00, that’s when they start 10 making calls to say, is this guy coming back or 11 not. That’s not your understanding? 2 MR. a : Why would you make a call at 3 4:00? w 16 coming back. 7 MR. a: Well, the count, 4 MR. ae : Because you’ve got to know if they’re coming back to the unit or not 8 over. So, you’re in the unit or not. So, at 9 4:00, we do the count. After the count, that’s 20 when the guys come in from court. 21 MR. QR: okay. 22 MR. a: That’s when we get the guys 23 coming back to SHU and going back to their 24 units. 25 MR. a : And would you be - would EFTA00111069

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LIMITED OFFICIAL USE B82 10 11 12 13 14 16 18 19 20 21 22 23 24 anybody be notified, prior to 4:00, that people were, or were not, coming back? 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 Reyes was not coming back? MR. a: Yeah. MR. a : All right. So, if Reyes doesn’t come back after 4:00 p.m., who, on that daily assignment roster, would be responsible for making notifications, or determining that Epstein needed a cellmate? MR. QJ: 31 mean, the notification is here. We already have the notification. MR. Ee : Yeah. I know you’re pointing to the email that says 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 Reyes - it’s known that Reyes is now not coming back. MR. a : Mm-hmm. MR. a : Not - possibly not coming back, but he’s not coming back. Who would be responsible for placing - for making EFTA00111070

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LIMITED OFFICIAL USE 83 w ~] ive) notifications that, hey, Reyes is out, Epstein does not have a cellmate, we need to start making some notifications? MR. a : I mean, I don't know. There’s no notifications. That’s if he doesn't have a cellmate, we give him a cellmate. MR. a : Yeah. So, what I'm saying is -. MR. a: But the lieutenant is not saying, hey, by the way, you know? If they catch it, they’1l say it, but if they don’t -. MR. a : And I'm not saying it’s - MR. a : -- a lieutenant’s responsibility. What I'm asking is, whose responsibility is it? MR. a: To say, hey, this guy, get him a cellmate, or make a notification? MR. QJ: Yes.) Like, who would be the first one to know that Reyes is no longer there? Would it be the SHU? MR. QJ: §9=o1’d say Rep. MR. : So, R&D would be there. What is R&D’s responsibility, at that point? EFTA00111071

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LIMITED OFFICIAL USE 84 1 MR. a: Oh, hey, we’ve got all the Ww ' rt n is) c i] ' 4 rt Q o “t J 1 =] 4H a o =] ct a o KK @ 5 ie) ct a 2) 3 p- Q But would R&D be wi aw 6 responsibl 13) it] for saying, hey, uel 7 coming back, or would they say, hey, ops 8 lieutenant, Rey isn't coming back. Who would 9 10 I'm not sure. In the past, I 1 would 2 MR. QM: spu directly? calling SHU directly. ive) oO co 9 MR. a : That’s the only three listed. Okay. And if they 24 weren’t notified, at what point would they kn 25 Reyes isn't coming back? EFTA00111072

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LIMITED OFFICIAL USE 85 wi ~] 10 11 12 13 14 16 17 18 19 20 21 22 23 24 MR. a: I’ll say about 8:00. MR. a : And how would they be 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 (Indiscernible *01:00:27) 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. Ee : 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 EFTA00111073

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LIMITED OFFICIAL USE oo fen) 1 think, set by 8:00. 2 MR. a : I'm sorry. What did you say about 8:00? 4 MR. ae: By 8:00, is when I say, hey, is anyone else coming u ies) w n 'o ae) 5 Q ct 7 bP o t OT ct Ss o ioe a o oO 6 count. Like, I want to get everything straight 7 in the computer. 8 MR Po : Okay. 9 MR. QJ: 91/11 say by 8:00. 10 MR. a : And on that date, when 11 those three people were working, would 2 typically be responsible for doing something 3 like that? Is it, like, SHU one, SHU two, two 4 three, or is it just anybody, any one of them, 15 or how does that work? To do what? 7 MR. ae : To say, like, hey, we’ve t oO a 8 got to make sure our base count is correct. 9 MR a : I mean, it could be any one 20 of them 23 MR. a : But it’s not like 24 someone’s job? It’s just someone should take 25 that role. EFTA00111074

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LIMITED OFFICIAL USE oo ~~] 1 MR. a: I mean, but they’ve got to 2 have the base count right, for the 10:00 count. 3 MR. a : So, one of those people 4 should have got the base count right, but it’s 5 not one specific person’s duty? Or is it 6 something that they’re supposed to collaborate 7 on all together? 8 MR. a: I mean, it depends. It 9 depends. If you’re working, hey, such and such 10 (Indiscernible *01:02:01). If you’re number 11 two, you know, you go to the board, you could 2 change it yourself. You know, the OIc. All 3 right, you know, making sure everything is in 4 order. 15 MR. QM: «Ss Was there an OIC on that 16 night? 7 MR. QJ: 9 Yes. 8 MR. SR: «who? 20 MR. QE: so, EJ wes the o1c? 21 MR. QJ: 9s ves. 22 MR. ae : So, technically, he’s 23 probably the one who should have been 24 responsible to catch the fact that their base 25 count changed, and he wasn’t coming back? EFTA00111075

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LIMITED OFFICIAL USE 88 w ~] ive) MR. a: I'm not sure about that. Because he was non-custody. I'm not sure. MR. a : Okay. MR. a : Because, you see, he’ custody. Mine was bon-custody. He’s just up fa non- there for overtime. So, I'm not sure. MR. a : Okay. Now, as far the lieutenants’ job. So, at that point in time, it was fs that was the ops, and | hat was the activities. What is their role in ensuring that Reyes is, one, back; and two, Epstein is placed with a new cellmate? MR. QJ: 9 Yeah. MR. ae : Do they have any role? Or is it all on the SHU? MR. a: I mean, it’s - they don’t have a role. You know, it’s -. MR. a : What about when they’re conducting their rounds, as part of their responsibility to say, to check that kind of inmates are o < ics mt rt stuff, or is it just to se rt s wu rt there, and that the inmates are there, are okay? MR. a: Pretty much. You’ve got to do a round. EFTA00111076

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LIMITED OFFICIAL USE 89 10 11 12 13 14 16 18 19 20 21 22 23 24 MR. a : Does that round entail verifying that Epstein has a cellmate and Reyes 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. a: Yes, with staff and accountability. For the most part. You know? Inmates banging, hey, all right, I’11 be up, doing my round. I/’11 deal with this when I get up there. MR. Ee : 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. a : 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. EFTA00111077

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LIMITED OFFICIAL USE 90 1 MR. QJ: No? All right. So, as 2 far as a round conducted by a lieutenant, would 3 they know - would they be able to figure out 4 that Reyes was removed? 5 MR. a: Depending on what time the 6 round was. 7 MR. a : And can you give me more 8 explanation? What time would that change? 9 MR. a : If I do an early round, and 10 Epstein’s in a cell by his self, okay, I still 11 have time, still doing court movements, and it 2 raise no suspicion or no alarm. 3 MR. a : Okay. So, about what 4 time would there be a suspicion or alarm that 15 be raised? 16 MR. ae: I told you. At about 8:00. 7 MR. QJ: «8: 00? 8 mR. QJ: 9 Yeah. 9 MR. Ee : Because Reyes hasn’t been 22 MR. ae : Okay. Were you ever 23 provided any instructions on what actions 24 should be taken if Reyes was removed as 25 Epstein’s cellmate? EFTA00111078

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LIMITED ies) w oO wo i=) N ive) oO co No N N ion) OFFICIAL USE 91 MR. GJ: No. MR. a : What actions should have been taken once Reyes was removed? MR. GJ: 9 ann. i Said, we o a c 3 jas w b b ct a o Bb a] 3 wu rt Oo n if he were to move, look for him a new bunkie. MR. a : And is that something - should have they notified - when they say look for a new bunkie, I'm assuming you’re talking about the people in the SHU? MR. a: Yeah. A new cellmate. Yeah. MR. a : So, I think you said i. a. and Noel? MR. a : Could have they placed him with a new cellmate, or would have they had you make notification to the ops and/or activities’ lieutenant? MR. a : You know, they don’t need to make notification. MR. ae : What about as an inmate as Epstein? MR. a: No, he didn't make notification. MR. a : So, you don’t think that or) omeone EFTA00111079

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LIMITED OFFICIAL USE 92 w ~] wo 10 11 they would have. Do you know if Epstein’s cellmates were vetted by the captain and above? 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. QR: 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. ae : 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. Ee : Okay. Should have they? MR. QJ: «i'm not sure. Like you said, the whole vetted thing, yeah. I'm not sure. MR. ae : So, if they knew that Reyes was vetted, and was placed with him, at that point, should have they done anything else? Such as called the lieutenant to say, EFTA00111080

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LIMITED OFFICIAL USE ite] ios) 1 hey, he’s not back, we need to get him a new 2 cellmate. Can I place someone with him, or 3 should have they just taken action on their 4 own? I don't know. 6 MR. a : If you were - I know you wi aw 7 were day watch - but if you were evening watch, 8 would of you expected them to notify you? Oo Oo BO ad on i) a} y So, in this case, should 11 V hey notified a. or should have they 2 or either of them? 3 I'm not sure. Should have -. no Od That was Should have the person t oO a notified them by telephone, or when one of co those lieutenants did their rounds? wo Fs Ss ie) c wn ri] B ie] n a (2) Cc an o rt om oO ket ion wu 0 21 MR. ae: If they would have? Both. Call, email, whatever. Yeah, No Nm 0) B ct om 0) a] Oo ini No ion) id Now, someone like -. So, 24 | was the activities’ lieutenant that EFTA00111081

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LIMITED OFFICIAL USE 94 A if 2 MR. a : Since she was not a 3 lieutenant, she was an SIS, do you feel that 4 she had the knowledge and capabilities to be 5 able to do that job, at that time? 6 MR. ae: What job are you talking 7 about? ivities’ lieutenant. foe) 5 fed is] ct eah. I think she wa its] m3 K @ wu if) i=) training, right? 11 MR. MJ: swell, 1 -. 2 MR. ae: I think she was training. ive) 4 rt n that temporary post, right? 15 MR. QJ: §9=veah, but that still wouldn’t 16 be on her, though. 7 MR. ae : If she’s the one who did a round in the SHU for her shift. co 9 MR. a : Yeah. 20 MR. QJ: «sts that something that 21 she should have checked on? Hey, where’s Reyes? 22 There’s nobody in -. Because not only - I 23 mean, everyone knows what cellmate Epstein is 24 in. So, even if Epstein’s not in there, and 25 he’s still down at attorney conference, nobody EFTA00111082

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LIMITED OFFICIAL USE 95 10 11 12 13 14 16 17 18 19 20 21 22 23 24 is in there. So, shouldn’t that have been something that you’d say, hey, where is this 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. a: Yes. 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 his? Is he coming back? MR. QJ: «Well, that’s R&D. R&D notifies us if they’re coming back or not. MR. ae : 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 -- EFTA00111083

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LIMITED ioe) w io ioe) its) OFFICIAL USE wo o the SHU? “Mandatory rounds m on Eps number MR. MR. a : All right. nothing you ever saw in any of your time All right. If that up - sorry. EFTA00111084

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LIMITED OFFICIAL USE 97 w ~] wo 10 11 MR. Ee : No, no, no. MR. a: -- I have a funny joke, 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 thi 7] guy - where is his bunkie? MR. ae : 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. ae : It says specifically -- MR. a: Than when it’s not -- MR. a : -- rounds on -? MR. a: -- yea, but normal, it’s not EFTA00111085

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LIMITED OFFICIAL USE 98 1 going to think just because - it’s not going to 2 mix this with this. 3 MR. a : So, even though they’re 4 looking in on Epstein, seeing that he’s not - 5 he’s by himself, that won't alert them to the 6 fact -? 7 MR. QJ: 9No. Not that sign. No. MR. SR: No? a : No. 10 MR. a : You don’t think so? “Mandatory rounds. 2 MR. a : Do you know of any other signs that were in the SHU, saying that he was co a oO a ” ive) 4 required to h 5 MR. a: Hmm. I can't recall. What about the hot list? t oO a 8 hot list is inmates who 9 or or 20 And 22 Yeah 23 Do you remember seeing 24 the hot list that was in the SHU? EFTA00111086

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LIMITED OFFICIAL USE 99 1 MR. Ee : Is that as part, as a 2 lieutenant, would they check out the hot list 3 when they would go down there? 4 MR. ae: No. We would just - no - we would just check to see if it’s updated. listed on the hot list. w oO a What does that, then, i=) working in the SHU? He needs a cellmate. MR. a : And do all of them know, if Epstein’s on the hot list, those people need No Fs ive) 5 MR. a: I'm not sure if all of them t oO tam 5S o = Lee) 5 wo a hed a = like the hot list is even m 21 the sign I just shov 22 purposes? 23 MR a: sign? Where the sign 24 come from? 25 MR. a : If this sign was in the EFTA00111087

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LIMITED OFFICIAL USE 100 WwW N Od K ie] Cc | w ' fu b = is] o BR 2 bh bh ~ Hh I'm not saying - 4 I can't say if - yeah - I can't tell you -- w co this was in the SHU. 1 MR. a: That’s what I'm 2 This, I don’t think this was up there. your question? i) sayin Q You don’t think that was ive) Fs) t o Fs w oO Q w is " oO | 7 MR. a: I mean, not in no tier or nothing like that. co hot list is up there, 23 MR. a : But what about, like, up 24 on, like, the desk area? Would you be around EFTA00111088

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LIMITED OFFICIAL USE 101 w ~] wo 10 11 ive) MR. a: Hmm. I mean, if I had to. MR. a : But you didn't notice MR. a : But not normally. MR. a : -- in the desk area? vR. BJ: No. MR. a : All right. Where would the hot list be located? MR. a: So, behind the desk wall we have, that we keep it up there. MR. Ee : All right. And they’re supposed to be checking that, and making sure , like, a is) those people are, one) checked on, and two) ° urpose? MR. a: The hot list is just any - it’s pretty much any inmate that comes from the have cellmates? Is that the “ 'd housing unit. They come from the housing unit. This guy psych alert, hey, make sure this guy s the initial check. gets a bunkie. That That’s what the hot list is for. MR. a : And are they supposed to check that list every day, to make those same - MR. a: I mean, you don’t - no, you get up there, it’s, hey, on the suicide watch, EFTA00111089

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LIMITED OFFICIAL USE 102 1 is he on the hot list? So, it’s not common to 2 check it every day. No. 3 MR. a : All right. So, it’s not 4 common to check it every day? w a a Cc ue] QQ fu ct oO jon 7 MR. a : Only when it’s updated, 8 you check it. 9 MR. a : Yeah, if the guy is still on 10 it. 11 MR. Ee : But wouldn’t - again, the 2 fact that the MCC is a jail, not a prison - 3 wouldn’t it be pretty regular that people are 4 being moved in and out? 15 MR. QJ: §9=Not on the hot list. t oO a No, but the people that 7 they’re bunked with. If they’re required to 8 have a cellmate -- 9 MR. QJ: 9 vm-hon. 20 MR. QJ: | -— wouldn’t it be pretty 21 regular that they would have to - their 22 cellmates might be leaving? Because if it’s a 23 jail, not a prison EFTA00111090

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LIMITED OFFICIAL USE 103 1 saying. So, how are they always ensuring that 2 those people that are required to have 3 cellmates have cellmates? 4 MR. ae: That’s when you say, hey, I 5 got a single cell up there. 6 MR. a : And at what point is that 7 reviewed? 8 MR. a: The single cells? 9 MR. a : Yeah. Is that supposed 10 to be a daily occurrence? 11 MR. QJ: 9 Yeah. 2 MR. a : And is that - what time 3 is that? The 8:00 time that you’re talking 4 about? 15 MR. a: No. Usually, that’s in the 16 morning. So, like, if I come in, hey, you 7 know, I'm going to - who’s in the single cell? 8 You know? 9 MR. Ee : Well, what about -. 20 MR. QJ: «At night, it’s just not -. 21 At night, it’s -. 22 MR. ae : Even when people are left 23 during the day, and then come back from court? 24 Some people come back, some people don’t. 25 MR. QJ: 9 Yeah. EFTA00111091

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LIMITED OFFICIAL USE 104 1 MR. Ee : Wouldn't that be another 2 time that they do it, or they don’t do it at 3 that time? OH wu 4 MR. ae: I mean, I mean, like I id, 5 after that cut off time, that’s when you start 6 saying, okay, we’ve got a single cell, of such 7 and such. Then again, remember, MCC get 8 inmates throughout the night. wo F 11 MR. Ee : Placed in the Ww N Od ee oO wu x Okay. And you didn't 4 work that night. Do you know of any people 5 that were placed in the SHU that night, on 16 August 9th? 7 MR. a: No. Not according to this, 8 no. 9 MR. Ee : And did you conduct any 20 counts or rounds in the SHU on August 9th? 21 MR. ae: I can't recall. 22 MR. ae : And what is the purpose? 23 Why do COs conduct counts and rounds in the 24 SHU? No w bd To make sure they’re alive. EFTA00111092

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105 H th) I rt wu b n 0 rt ie) 3 7 i o ifs) c = 0) 4 MR. a : And are cells and counts - are counts and ocumented? o a s i uel MR. a : -- how are tt 10 documented? 11 MR. a: 30-minute log in in TruSc tg K fe) o u o paar be io F Ww K fe} c 3 o u 15 MR. a : And what is the TruS Rounds. 17 MR. ae : That’s rounds, as well? You put rounds in there, too, t o Fs F co rs 19 but all the counts. No Ww wu a D + a Oo H oO bh bh 1] bh bh rt ct bh D & t bh ie] A =) ia rt wu kK 0) bh } b bh i) EFTA00111093

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LIMITED ies) w co io ioe) co OFFICIAL USE MR. MR. MR. MR. Not before th kn MR. MR. conduct 106 to Internal. come to Internal does It depends. is incident. ow how now Should they to nds? MR a : And how should they know? MR a: Training. MR a : And do y think everyone enough t count and a round? raining to know how to do a EFTA00111094

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LIMITED OFFICIAL USE 107 1 MR. QJ: 9 Yeah. 2 MR. a : Did you ever hear of 3 people, like, filling out count slips, or round 4 sheets? Either before, or at the very start of 5 their shift, for their entire shift, or at the 6 end of the shift for their entire shift? 7 MR. a : Not before this incident. 8 MR. a : Did you hear about that this incident? wo wu Fh ot i] K 11 MR. Ee : What did you hear about 2 that? 3 MR a: That they didn't count. I 4 mean, it was filling out slips. It wasn’t 15 counted. Wasn’t making rounds. 16 MR. Ee : And who was it that you 7 heard that wasn’t conducting counts and rounds? 8 MR. a : Thomas and Noel. 9 MR. Ee : Anybody else in there? 20 MR. BJ: No. 21 MR. ae : Did you hear anything 22 about counts and rounds not being conducted 23 prior to midnight on August 10th? So, any time 24 on August 9th, did you hear about any of those 25 counts and rounds not being conducted? EFTA00111095

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LIMITED OFFICIAL Ww re) cr w the 4:00 p.m. USE 10 On the watch then? Any time on August 9th. wu 8 conducted? wo Le i ioe) know of. No. MR. MR. days? MR. MR. the 4:00 You Yeah, the midnight Right. So, what I'm Have I heard that -- (Indiscernible acn'’t —-- wasnt done? MR. Right. count. EFTA00111096

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LIMITED OFFICIAL USE 109 1 MR. GJ: No. 2 MR. a : Now, do lieutenants sign the counts or the rounds? ies) 4 MR. ae: The rounds. Not the counts. the or) w a So, what i £ 6 lieutenants’ responsibility for signing the 7 round sheets? 8 MR. a: Making sure they’re in 9 compliance with the policy. 10 MR. QJ: 811 right. And do they 11 have to - is there any way for them to verify 2 if, like, the rounds were actually done? ive) Fs) Hmm. No. Unless you’re 4 doing a - checking a video. c uw a You just - is what you do oO if) ust to make sure that the - it’s actually ws. 7 filled out? Lee) 5 Correctly. oO a3 Correctly filled out? All 20 right. I'm going to - I apologize for this, 21 it’s gotten a little longer - so, I'm going to 22 show you. What is this that I'm showing you? round sheet. No No > Ww OD H o t U ed oa fu bt right. And what i 3) 25 the round sheet from? EFTA00111097

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LIMITED Ww wo Ww oO oo OFFICIAL USE 110 Sth. Did you have ctivities’ lieutenant g to do with signing would of And fw I Which officer? m not sure. i [!] You can't tell by looking EFTA00111098

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LIMITED ies) w co ive) oO co OFFICIAL USE 111 what time would of y indicat round i MR. MR. a : All right. And around MMMM: 9 Some time on my shift. ME: 11 right. e that you would have, then, conducted a d ie] i) wo rt + w rt n the SHU? a : I'm not sure. a : Would of you signed that ae: Honestly, I'm not sure. a : How else would of you a : I'm not sure. I can't recall you ever signed one of these round EFTA00111099

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LIMITED OFFICIAL USE 112 w ~] ive) the lieutenant would sign the sheet in the SHU? Because aren't they maintained in the SHU? MR. a: Typically, that’s what would happen. MR. a : So, typically, you would have signed this in the SHU. Correct? MR. QJ: 9 Yeah. MR. a : And would of you signed this after the last one was filled out? I'm assuming they wouldn’t fill one out after you signed it, would they? MR. a: I'm not sure. MR. a : So, this one says 2:05, 2:07. Wouldn't that typically mean that you would have been there at least 2:00? MR. a: I'm not sure. MR. ae : But by looking at this document, does that indicate to you, that if you signed it, you would have signed it? Do you ever sign -. Are these continued to be filled out after the - sorry - after the lieutenant signs it? MR. QJ: 9 yeah. MR. a : So, even for day watch right here? EFTA00111100

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LIMITED OFFICIAL USE 113 gyn it at 3 any point during this, and then, they continue 4 to fill it out? wi aw 6 MR. a : All right. And that’s what I'm asking. How does that work? I don't o a 3 Oo = fe) Mt 3 wu if ran p 3 W ts) a H 3 oO w o it’s eight hours. 10 MR. a : So, at any point, from 1 8:00 a.m. until basically p.m., you could 2 have signed that? Ww es) K oO 3) 5 genuine questions. 16 I'm just asking -- 7 MR. a: No. I understand. But it seem like that, is what I'm saying. 9 MR. Ee : And then, I'm not -- 20 MR. a: That’s what I'm say co Q is) i] 7] ing, like 22 MR. ae : -- I promise you, I'm asking, like, this isn't, like, an “I No ion) us. z mn rt uv A 24 gotcha” moment. There’s no -- 25 MR. J: 9 vm-hon. EFTA00111101

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LIMITED OFFICIAL USE 114 w ~] ive) MR. Ee : -- I gotcha moments in this. This is just asking for your, like, your 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. QJ: 411 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. BJ: 9 Yeah. MR. a : -- 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. EFTA00111102

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LIMITED OFFICIAL USE 115 1 MR. QJ: i got -. 2 MR. a: Or nothing. That’s what I'm saying. I'm not sure. 4 MR. a : But what I'm asking, I ies) 5 guess, is just - and I don’t even know what 6 there would be to incriminate h - but, 7 like, what I'm asking is, like, how does this 8 process work? If you give this person a round 9 sheet, are these round sheets signed in the 10 SHU? 11 MR. a: Typically. 2 MR. QM: typically. All right. 3 And are you aware of them ever not being signed 4 in the SHU? t wi a I'm not sure. Not that I oO know of, no. 7 MR. QM: 11 right. 8 more likely than not, you signed this document 9 in the SHU, at some point, between 8:00 and 20 2:00 p.m.? 23 probably did a round in there? 24 mR. QR: 9 Yeah. 25 MR. QJ: 411 right. And if it was EFTA00111103

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LIMITED OFFICIAL USE 116 wi ~] 10 11 12 13 14 16 17 18 19 20 21 22 23 24 between 8:00 and 2:00 p.m., both Reyes and Epstein were not in their cell at that time, then, correct? 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, Reyes 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. a: He left. And that’s what happened. MR. a : Right. And you, when you were there, there was no conversations that you EFTA00111104

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LIMITED OFFICIAL USE 117 1 had with anyone? 2 MR. a: No conspiracy. WN fe) H ct i] 5 fe rt Ww | | 4 MR. a : No, no, no, and we’re not wi wu i] — b- a] Q i} i} 6 MR. ae: -- nothing like that. 7 MR. a : -- for a conspiracy. 8 It’s just, we need to know who, what 9 conversations happened, where, where did the -- 10 MR. a: I didn't know nothing about 11 it until after I saw it in the ne 2 MR. a : And this is also me 3 showing you this now is more letting you know, 4 like, okay, that looks like you probably were 5 there. Does that help spark recollection? 16 MR. ae: I had no conversation with 7 neither one of them that day. Not that I 8 recall. 9 MR. Ee : None of them that day? 21 MR. ae : All right. Can you tell, 22 does this look like an RCS to you? 23 MR. a: I don't know who -- 4 MR. a : Why don’t you have a look ho No w wu ct ct a Pp H EFTA00111105

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LIMITED OFFICIAL USE 118 1 MR. a: -- whose signature that is. 2 MR. a : All right. So, on day 3 watch, there was a a. | sCS@S | | a. As well as a . Does that look 5 like any of those people to you? 6 MR. ae: Hmm. I'm not sure. 7 MR. a : Okay. All right. So, 8 you do not recall. And as we go, you mind 9 just initialing or whatever? ay. You got 10 those, too, if you don’t mind initialing this, 11 and this, and this Now, although it is 2 voluntary, I guess, we do have to just make 3 sure we know, it also has to be the answers are 4 truthful, you’re under oath. So, that also - 5 so, lack of candor can also be constituted by 16 not providing full information or, like, hiding 7 information. 8 MR. a : No. If I remember, it’ll - 9 and I don’t hide nothing - but if I remember, 20 then will say it 22 MR. a: But when you come with these No Fs) wn is) b- ct 103) KW ust -- No w bd i} i} saying it looks like, hey, EFTA00111106

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LIMITED OFFICIAL USE 119 2 MR. a : -- and again -- h, and if I'm, like -. 4 MR. a : -- our purpose, you would Ww 5 | | le 0 wu 5 have been interviewed a lot earlier, if there 6 was, like, you know -- 7 MR. QJ: 9 veah, but still -- 8 MR. a : -- we're -. a : -- I know, I know being that wo F 10 day, I know it was a big profile case. Hey, 11 let’s get such and such, tt fill this, and N ct oa 5 | | ive) Fs) Yeah, yeah. 4 MR. a: -- and I'm, like, come on. 5 MR. a : And we just need to know, 16 like, as, you know, we’ve got make sure that, 7 like, hey, what you do remember, you can tell 8 us Again, it’s voluntary, but, like -- 20 MR. QJ: -- all right. So, these, 21 I'm going to give you these count slips from 22 August 9th up until midnight of August 10th. 23 And is it your understanding that ZA on the 24 count slip, that stands for the SHU? EFTA00111107

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LIMITED ies) w co wo ive) co OFFICIAL USE 120 MR. Ee : All right. Can you just kind of look through those? I'm going to move this aside for you, so the papers don’t get kind of mixed up. Actually, I'm just going to give them back to you, [- *01:26:40). iscernible a) Oo , 1 look for what? a c ion rt > fw rt Oo 5 @ MR. = fu rt fu =I H hb 5 I f Bb w b I 3 wW Hh Oo rf | re) do what? MR. : So, when we initial these ct eg jae 3 n ~ H Ct i) , f oT a4 t O Fs) | c oO Pal w te we showed you. It’s not to say you’re certifying anything, or that y It’s any document we place in you, this is what we do for ev We ask them to initial and date this -- MR. That I’ve seen thi 7) Fs) Ke 1) n Oo a wu he 3) -- no, that today you’ve EFTA00111108

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LIMITED OFFICIAL USE 121 1 seen this, not that you’ve seen it before 2 today. It’s just that, today, while we’re 3 talking to you, this is in fact the document 4 that we were talking about. w a Okay. oO a It’s not certi 7 accuracy. It’s not saying you saw it before 8 today. It’s simply to say that’s the document 9 we’re discussing right now. 10 MR. a: And I'm looking for tt 11 MR. Ee : Thank you, sir. 2 MR. ae: -- or -? So, look at the ZAs, o ive) Fs) 4 starting. So, you’re - what is this one that I 15 gave you? Is that the - 16 MR. QJ: 9So, this is the 9th at 5:02. oo 5 wu 3 ia b Q a rt wo i wn is) 2) x fu ke n is) H Q it) o 3 Cc 20 the 5:00 a.m. count on the 9th. Can you just 21 take a look at the numbers? You can look at 22 the - is that - what’s this first page called? 23 Is that the El? No ry 5 Yeah. No w 5 ty an bh Rk bh .Q o ct t oO bh ie) ° bal fu rt EFTA00111109

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LIMITED ~] wo 10 11 OFFICIAL USE 122 the El. And then, look at the count slip for ZA. So, when you’re looking at El, just make note of what is the number that says on the El, 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 -. MR. a : You said the El and the what? MR. a : The El and the count slip for ZA. MR. a : The count slip: in the i wu i om MR. ae : should be either the last or the second to last page. And I just -- MR. ae: Where it’s 5:00 in the morning? MR. a : -- that’s 5:00 in the morning on the 9th. So, what do those numbers show? MR. QJ: «stn za? MR. QJ: Yeah. MR. QJ: =So, 77. MR. a : Does it say both of them, ~] ~) EFTA00111110

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LIMITED OFFICIAL USE 123 1 MR. a: On the El, yeah. 2 MR. a : All right. Cool. Now, 3 you can just initial and date that, and move it 4 aside. Again, these aren't I gotcha moments. 5 These just help us explain some stuff. All 6 right So, this El, well, can you tell me what 7 it says for the ZA on this one? And this is, 8 what, the 5:00 p.m. count? What is this? wo id K oO wu J o Ss 3 f Be 5 Oo oO ue] 3 he mean. No a H rt if] o Cc Q 12) Cc t=] rt But yeah. ive) ~ uw So, that ZA is J Fl 75. And the last one was wi =) =) t oO Fs) o w > J a — K k And what does that say? 8 MR 5 9 MR All right. 75. Cool. 20 Can you just initial that and put that on the 21 side? And you’1ll understand the question after 22 you look at these. And again, it’s not an I 23 gotcha. It’s to help us explain something. 24 All right. 25 MR. ae: What y’all trying to explain, EFTA00111111

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LIMITED ~] wo 10 11 OFFICIAL USE 124 though? MR. a : The count changes, and I'm going to ask you how you can - if there’s a way for you to be able to figure out how this count changed. All right. Can you look at the El on here, and compare it to the count slip back there? What is the -? MR. a: And it’s the 10:00 count, MR. a : 10:00 p.m. count on MR. a : 73? On both? And is there a count - does the count slip say something weird on that one? MR. ae: No, I'm just looking at the MR. a : Does it say, like, 73 MR. QJ: 90h, yeah. It does. MR. ae : ave you ever seen a plus one on any before, or could you understand a a] eason why someone will put plus one? MR. a : Plus one. No. I don’t know about a plus one. EFTA00111112

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LIMITED OFFICIAL USE 125 1 MR. QJ: 11 right. Now, thi: 7) h- n 2 the one that I really want you to look at. 3 Look at this El. This is now August 10th at 4 midnight. Check out what it for ZA on the 5 El. What number does that say? oO a N 7 MR. a : All right. And check out Les] ct i oO Qa Oo o 5 rt n ran a "Ss wo F What does the count 10 MR. a: It says 73. 11 MR. Ee : So, 73, but the top one, 2 that was clear, sf] Bb be ue] +] wu he ive) Fs) 4 MR. ae : And I’1ll give you one 15 more, just so it’s not a magic trick, look at 16 this page first, for the August 10th, and I A have the rest of them, too, if you want to see 8 them, but 3:00 a.m. on August 10th, and then, 9 the last page where it says the count slip. 20 What does it say on the El on the next one? 22 MR. ae : And on the El. And then, 23 what does the count slip say? 24 mR. QR: 972. 25 MR. a : So, in looking at all EFTA00111113

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LIMITED OFFICIAL USE 126 uw ~] 10 11 12 18 19 20 21 22 this, does that tell you - as a lieutenant and someone who worked in the SHU - does that tell 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. a : (Indiscernible *01:33:00). MR. QJ: | -- and this is not -- MR. a: It’s the 9:00 count. MR. Ee : -- we have no reason to believe you were involved in this. So, I want 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 vm-hon. EFTA00111114

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LIMITED OFFICIAL USE 127 10 11 12 13 14 16 18 19 20 21 22 23 24 MR. a : -- and the control lieutenant, who was working that night, figured 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. GJ: = Mm-hon. MR. QJ: -- 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 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. a : So, he would have been listed on -. Epstein would have been back at least by 8:00 p.m., right? MR. a: Yeah. MR. a : So, that would have -- MR. a: So, he should have been on this count. MR. a: -- he should have been on EFTA00111115

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LIMITED OFFICIAL USE 128 2 MR. a: So, he threw it, yeah. And can you see where on ies) a 4 the - let’s talk about, I guess, what’s the one w before? The 5:00 p.m.? The 4:00 p.m.? 6 MR. ae: Yeah, he would have been at ~] attorney conference. Yeah. 8 MR. a : And it would have showed 9 him at attorney conference on one of these, 10 correct? On the El? 11 MR. a: Yeah. At 3:00, at attorney 2 conference. Well, from SHU. 3 MR a : And then, does it show 4 that he’s already in SHU in this one? Is there 15 any way an attorney conference at the 10:00 16 p.m. count? 7 MR. a: No. But see, what I was 8 telling you before about the numbers, see how I 9 had 76? 20 MR. SE: «up. 21 MR. QJ: «And this is at the 4:00 22 count. And then, it went down to 73? 23 MR. QM: Richt. 24 MR. a : So, you don’t know until 25 after the count, about the whole cellmate EFTA00111116

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LIMITED OFFICIAL USE 129 w ~] wo 10 11 coming back. MR. a : Right. But then, the weird part about it is going from 73 to 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: 9 Yeah. MR. a : Down to 73. That’s three people, and one person vanishes. MR. QJ: 9 vm-hon. 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. EFTA00111117

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LIMITED OFFICIAL USE 130 2 MR. a: So, I wasn’t here. I wasn’t Ww ct .) oO K o Hh fe) BK ct .) o ie] 1?) Ps =] rt wi aw _) o 7 this isn’t an I gotcha moment. We’re co trying to help -- a : No, no, but you know it feels oO a 1 MR. Ee : Yeah, yeah, yeah -- 2 . HM: Ss (indiscernible *01:36:12). a : -- and I get that because got special agents talking to ive) a) you -- 16 MR. Ee : -- it’s just all about 7 trying to piece the puzzle together. So, we 8 need help with people like yourself, to be able 9 to say, what the hell happened? You know what I 21 MR. ae: Yeah. Well, there’s also 22 three here. From (Indiscernible *01:36:28). I 23 mean, I think I'm -- 24 MR. a : And we’ve had other -- 25 MR. ae: -- and we hadn’t keyed them EFTA00111118

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LIMITED OFFICIAL USE 131 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 out, that’s what it is. MR. a : And you just -. 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 I 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 p.m. 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 EFTA00111119

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LIMITED ies) w oO wo i=) N ive) oO co wo No Nm No ion) OFFICIAL USE 132 what’s going on. They got R&D, (Indiscernible *01:37:57) cell plus one. And by looking at that able to tell who that Not by looking at that Not by the name. I mean, there’s no outcome. Don’t have the out count. Don’t have the out count? s that what you’re saying? MR. ae : And what time is that for? have the out count. MR. a : No, what time are you looking at? MR. a: This one is for the 10:00. MR. ae : So, the 10:00 p.m. doesn't even have an out count on it? Well, I can't - you don’t I mean, it don’t add up because - yeah, something is not right - because R&D is not on here. Unless they moved. EFTA00111120

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LIMITED ies) w co wo ive) co OFFICIAL USE 133 I mean, some time, they say a ghost count, but MR. a : And what does a ghost MR. BJ: 9 -- so, like, the guys medical, they say, 7, I didn't have time to a) key him in, but I'm verifying that he’s down here with me, and put him on my count MR. Ee : Now, this name, to me, looks like fF (Phonetic Sp. *01:39:27). Do you know any -- person there, wou EFTA00111121

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LIMITED OFFICIAL USE 134 w ~] wo 10 11 - would they be able to see like a dry cell, 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’s why the plus one is throwing me off. MR. Ee : 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 that’s like a ghost. A ghost count. MR. a : All right. Does this -- MR. a: But it mess up the base count, though. MR. a : -- but seeing, especially looking at the 72 -- its] EFTA00111122

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LIMITED OFFICIAL USE 1 MR. a: Yeah, I don't kno 2 happened. 3 MR. a : -- and does t 4 tell you anything about any of thes 6 _. a: 5 MR. Hmm. Like, we’ve h 7 people, you know, in higher positio 8 to me, it tells me that the counts 9 done. Does that tell you that? 10 MR. QJ: Yeah, but at 10:0 11 mean, yeah. I don't know, man. Ye 2 I couldn’t tell you, man. 3 MR. QJ: 411 right. s 4 MR. QE: == I don't understand that. 15 know. Okay. So, is couldn’t tell y 1 wo wi w how that e counts? rt ad other ns saying, weren’t 0? Pfft, I ah. I mean, don't it just a 7 baffling type of deal? Because it’s baffling -- 8 mR. QJ: 9 Yeah. 9 MR. Ee : -- to us, and then, we’re 20 just hoping that people can kind of help us - 21 especially people that were there -. 22 MR. a: I don’t know. See, that’s 23 why I don’t understand that. I don’t see how 24 they get 73 at the 10:00 count, and then they 25 lose one after the 10:00 count. EFTA00111123

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LIMITED OFFICIAL USE 1 ~] wo 10 11 lo oO MR. Ee : And that’s the same 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. Ee : So if he like went to SHU MR. a: He never went to SHU. MR. ae : -- and then back? MR. a: They keyed him in the SHU. 4 ey o y put him on this count. But he didn't make rt 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. QM: 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, EFTA00111124

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LIMITED OFFICIAL USE 1 Wo —] 1 seeing they could say, hey, well, I'm not putting him on our count, put him down there. MR. a : So, that would be like 4 the ghost count you’re talking about? ies) Oo wi BOB —_ 2 w ct Cc Z ct wu tt b ~ hy i os wu @ ~ H if) oO w 1 bh a Oo Cc 5 rt 7 MR a : That’s just saying someone 8 put him in there but took him out 9 MR. QJ: 411 xight. But if he’s 10 not physically there, he’s not actually allowed 11 to be on the count. Is he? 2 MR. ae: Exactly. No. That's - 3 and this is, I don’t - you see, this says RA? 4 That’s R&D. 15 MR. a : And does it say anybody’s 16 in R&D over on this one? 7 MR. a: Well, there’s no out count, 8 and that’s what I'm saying. There’s no out 9 count with that one. 21 MR ae: RA and R&D are separate. 22 MR. ae : -- is one. 23 MR. a: You need an out count for 24 this. You don’t need an out count for that. 25 This is a unit. EFTA00111125

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LIMITED OFFICIAL Ww =} w 6 RAI, io ioe) its) was ho i) b ho for USE MR. MR. MR. and MR. MR. MR. MR. MR. - (Indiscernible MR. MR. MR. -, right? HS: «So, at midnight, there is ct he midnight, but at the 10:00 p.m., you know -- Ps) b iQ I an two hour the ts) earlier, Oo Ki 4K ni] ) rt I'm this dude ct Oo Ps) fo Okay. = o wu tle how isa ct ct a oO io 1) slip? = tr oO ini 2 ie] R oo & = 7 rt i] > tw in O a y | \ thing. That it the 4 5) wu t 7) isn't the count slip 2:21). At the top. That’s ae: Well, they R&D. ld have me EFTA00111126

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LIMITED OFFICIAL USE 139 10 11 12 13 14 16 18 19 20 21 22 23 24 up. They should have had the RA count slip for that one. MR. a: What’s the difference between RA and R&D? MR. a: RA is a real unit. So, when the guys come back from court, they’re in RA status. R&D is when they keyed out. MR. a: To go to leave? MR. a: To go to court. But if they come back, they came back in their unit. If they don’t come back, they release them from R&D. But RA is technically a unit. MR. a : And it doesn't count as a - it doesn't show up as R&D? MR. a: No. (Indiscernible *01:43:57). MR. ae : Where would that one slip - that says R&D in there - where would that show up here? MR. QJ: §9That would be right here. But they don’t have nobody in R&D. MR. a : So, there’s - and so, is that even weirder, the fact that, at the 10:00 p.m. count, there’s a count slip for R&D, and there’s nobody for R&D on this? EFTA00111127

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LIMITED OFFICIAL USE 140 1 MR. a: That’s why I think they put 2 him, and they keyed him in SHU. They keyed him 3 in SHU, the inmate, and then put him down in 4 R&D. And then, changed it after the count. Or 5 they could have changed it right after this 6 count cleared, and set it up for the next 7 count, say the inmates, the inmate is in - this 8 is the 10 Ks] a K M fu a ct S wu ct is) Ss @ bh +] ct J oO 11 MR. a: Yeah. And you have the N 3 P- oo. o Pp. .Q a ct Oo 5 @ ive) id K i) 03) 4 MR. ae : That’s the midnight one f foal wD 4 o wu rr n ct y o ive) oO °o Lee) 5 See, (Indiscernible 9 *01:44:44) right here. 20 MR. QJ: 0h, «I think I took it. 21 MR. ae: So, who 22 put him, and they keyed him into RA and R&D. 23 MR. QM: this is the midnight. ver was in SHU, they 24 MR. a : Yeah. So that’s what 25 happened. EFTA00111128

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LIMITED OFFICIAL USE 141 ~] wo 10 11 MR. a: Does R&D have like a dry cell or dry room? wu MR. ae : No, they got cells. You see, they got RA right here. Yeah, that’s what happened. I think the guy came from SHU and went to RA. That’s MR. a : And can you think of why a person would go from SHU to RA, at that late one. at night? MR. a: Body scan. Probably pulled something. And they kept him down there, put him through the x-ray. MR. a : And is there any way - by looking at these - you can see how -. Is there - you said the 4:00 p.m.? MR. ae: Yeah. That’s the 4:00 p.m. MR. ae : Is the person in R&D at 4:00 p.m.? Are you able to tell by this? MR. a : Let me see. You know the inmate that was down there or no? MR. ae : I think Fernandez. Is that right? MR. a: Was he a west side dude? MR. a : Do you anything about him? EFTA00111129

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LIMITED OFFICIAL USE 142 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. a: No, I don't. 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. es : So, at the 4:00 p.m., was he anything to do with Fernandez on that, or anything to do with somebody in -? MR. a : Well, the 4:00 p.m. 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. QJ: | Bot it’s also said that at the 10:00 p.m., 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 -- EFTA00111130

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LIMITED OFFICIAL USE 143 2 MR. a: -- that’s what it looked The guy came from 9-South, he went in ies) i b- a o 4 the RA. He stayed there throughout the night. inmate was -- 6 MR. a : Yeah, yeah. 7 MR. ae: -- right there. 8 MR. a : And we have reason to the case. That there is a Oo @ 0 K rt a m oO oO o bh bh o o ct = wu cr t a wu rr # it) 10 guy that was in, you know, he did stay there at 11 the night, and he had somebody on him, and 2 that’s one of the reasons why we want to talk 3 in R&D to be able to 4 there? 5 16 And by looking at that, 7 would that be that individual we just talked co about? 21 MR. ae : Who did the count slip? 22 MR. a: It’s based on the count slip wo 23 (Indiscernible *01:48:18). 24 MR. a : Yeah. 25 MR. a : Um all right. Does this EFTA00111131

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LIMITED OFFICIAL USE 144 w ~] wo 10 11 tell you anything else? Just before we move on. MR. a: I mean just -. I don’t know. Yeah. I don’t know. I don’t understand it. That’s the only thing I think they probably took him down for that then. MR. QM: «ts there - which, from looking at these, what basic like counts seem bad to you? Does this 10:00 p.m. one seem like a bad count to you? The way that it - what you just looked at? When there’s nothing on the El and there’s a count slip? MR. QJ: oun. MR. a: If you were working that night and you got a count like that, is that a good count or bad count? MR. a: I would have said bad count. MR. a : And who - can you tell by looking at this - who was the one who took this count? MR. ae : a: And was there any lieutenants involved with this? MR. a: I mean there could have been. I’m not sure. EFTA00111132

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LIMITED OFFICIAL USE 145 1 MR. Ee : But by looking at it like 2 I think like probably the midnight one there a was an actual ops lieutenant. Are you able to ies) 4 tell that by looking at the - I think the ops w t Bb oO i= ct oO s fu o ct Bb ty the one who caught it at 6 midnight? Are you able to tell that that -? 7 MR. ae: Oh this one here? MR. a : Yeah. Are you able to - co a 9 by looking at these, are you able to tell when 10 the lieutenant actually took the count? she took the 2 count - | took the count at midnight. WwW Fs) to ra be iad pe Q ey ba He 5 a H rt it] 7 fe) = n f foal wD 4 t wu rt 1) w rt f rt 7 MR. ae : And on this one does it show any lieutenant was involved? 9 MR. ER: No. 20 MR. Ee : So it would just been fos) n 23 MR. QM: 4.11 right. 24 MR. a : What about the 4:00 p.m.? it show the lieutenant’s name on the 4:00 EFTA00111133

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LIMITED OFFICIAL USE 146 Do you have any idea what ies) a No. 6 MR. a : But this does seem like a wi aw co a MR. a: El seems good. But um -. Even though that no one oO AJ i=) Ww 5 w 0 a wu c m © ct ea 0 3 you say one that t oO a wv Or =] ct ct a fu ct us. Cc ct 7 was printed? Oh. Because the numbers are 8 printed on that? 20 MR. Ee : I see what you’re saying. 21 So ¢ wu fter 9:33 possibly, something changed? 22 MR. a: So that could be two things. 23 Either the Marshals was trying to get one in 24 befor oO the count and they thought they had 25 enough time to process him upstairs. And then EFTA00111134

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LIMITED OFFICIAL USE 147 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 when they call in the count, it’s wrong. Like 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 p.m. 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 p.m. seems wrong, but the count slips seems right. EFTA00111135

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LIMITED OFFICIAL USE 148 10 11 12 13 14 16 18 19 20 21 22 23 24 At least for R&D. I - we have reason to believe the count slip for ZA is also wrong for Well time been MR. a : Yeah-yeah-yeah. MR. a : -- 10:00 p.m. because -. it depends, I guess, like you said, what the individual was moved to R&D. We’ve 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 p.m. count. Does that sound right to you? mean know talk able MR. a : That’s what I’m saying. I something could have happened. And you taken this guy downstairs. MR. Ee : And that’s why we need to to people. So by looking at this, are you to like figure out who we can talk to? To see if something happened at 10:00 p.m. to change this count and make this -? have MR. a: Did you see the log already? MR. a : The lieutenant’s log? MR. a: Yeah. MR. a : Do we have it? Yeah. I it. EFTA00111136

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LIMITED OFFICIAL USE 149 10 11 12 13 14 16 18 19 20 21 22 23 24 MR. a: Anything with log? 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. QJ: 9 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. a : 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 EFTA00111137

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LIMITED OFFICIAL USE 150 1 know this person was moved to dry cell? 2 MR. QJ: ==. 3 MR. a : Oh. And also if you’ve 4 got that, are you able to tell by looking at 5 that when you worked until? No? 6 MR. ae: No. I wouldn’t have done a 7 log that day from activiti 8 MR. a : Yeah. I just didn’t know wo }- Kh it like mentioned when people - you know ops 10 tarted or stopped 11 No. It doesn’t 7 when he - 2 Inmate Fernandez on dry cell. 3 It doesn’t say when he went there. 4 MR. a: There’s no time associated 15 with the movement on there? 16 MR. Ee : Should have there been? 7 MR. a: I mean that’s good to put in 8 there yeah. 9 MR. Ee : So you said you wouldn’t 20 have been associated with the lieutenant’s log. 21 Who does the lieutenant’s log? 22 MR. a: Ops should take care of it. 23 MR. a : Ops would so on your 24 shift it would have been a: 25 MR. ae: Yeah. But Fernandez is EFTA00111138

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LIMITED OFFICIAL USE 1 already on dry cell on da 2 MR. QM: nd 3 confused And that’s why 4 believe - because it seem 5 put on day watch. 6 MR. QJ: «at 3:15 7 MR. a : Doe 8 placed on there? 9 MR. QJ: 9 Yeah. 11 the 2 also both bad. He wasn’t 3 that make sense to you 4 MR. QJ: «=I think 15 wasn’t in the SHU, but he 16 keyed in SHU. 7 MR. J: Se 8 SHU, but he wasn’t there? 9 MR. QJ: = Yeah. Rig 21 they would still show it. 22 people in control would k 23 actually did their count 24 72 people in here not 73. 25 un. SE: I mean.. y watch it 0] ays. that’s where we get we have reason to s like Fernandez was s it that indicates to us an :00 p.m. count were in the SHU. Does he was -. he was was was still keyed in the ht. So for the Els, The only way the now it is if SHU and said we only got Right? EFTA00111139

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LIMITED OFFICIAL USE 152 w ~] wo 10 11 MR. Ee : Because people working in the SHU. They know hey, we only count bodies that are present. MR. MJ: «0h hold on. This is the 9th. Okay. So he went to -. Transfer to special housing - dry cell at 4:00. MR. QJ: 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: 9 Well this just looks like the log is the same. MR. a : We also have reason to believe that people manipulated the log after the fact. MR. a: Yeah. That’s what I’m saying. Some things are (Indiscernible *01:57:13). MR. a : Do you know anything about that? While I mentioned that? EFTA00111140

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LIMITED OFFICIAL USE 153 1 MR. a: No. I see SHU corrections; Fernandez; dry cell; RA; Saturday. Yeah. So I I think that Ww 3 wu =] rt J w un w saw something in there io ioe) its) 25 MR. a : Or was it that EFTA00111141

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LIMITED OFFICIAL USE 154 10 11 12 13 14 16 17 18 19 20 21 22 23 24 potentially | was late, and you relieved 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: Mm. MR. a : Or is she not supposed to write that? Or not supposed to be in there? MR. QJ: 9So who wrote that? MR. a: Uh I don’t know. It could be - that’s the thing. It could be a - it’s like a from the day’s 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 EFTA00111142

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LIMITED OFFICIAL USE 155 2 before you were ops is what you’re saying? 3 MR. ae : Yeah. I think I was ops that 4 whole quarter though. I think so yeah. you were - that whole wi Fa] wn ie) 6 quarter you were ops? Why were you -? 7 MR. | : Overtime. 8 MR. a : So overtime was a wo en pb Hh hh o 8 oO a rt Q c ct bed F Qo F w 5 11 MR. Ee : So you were the ops 2 lieutenant up until that day? You were 3 activities’ lieutenant that day though? 4 MR. a: Yeah. I think so. 5 MR. a : So being that you were like w wo t fea) is} ue] ii) . o iad o het Oo c fu be wo potentially acting Lee) 5 =} 9 MR. Ee : Like as in like since that were your normal duties would have you 21 also took - taken that on? Like hey, I know wu 22 I’m activities, but I’1l do the ops role? And 23 this is, again, just to try to help recollect - 24 - 25 MR. ae: I don’t know. EFTA00111143

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LIMITED OFFICIAL USE 15 w ~] MR. Ee : -- what you were doing. MR. a: I think I was ops that quarter though. MR. QJ: 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. a: Yeah. The dry cell stuff. 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. BJ: 9 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. QJ: 9 yeah. MR. a: You’ re going to - do you key it in, or do you call in to somebody and tell I EFTA00111144

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LIMITED OFFICIAL USE 15 w ~] wo 10 11 them to key it in? Who keys it in? J MR. a: You can do it if you want to. You can do it by yourself. MR. a : And let’s say you move it. Is someone supposed to be notified hey, listen this person is moved? Or you - the SHU CO’s can move the inmates by themselves? MR. a: Someone from a different unit? MR. a: Yeah. Like control or R&D? MR. a: No you tell - you can call control. MR. a: Is it policy that control must be notified? MR. a: I don’t know if it’s policy, but I mean, they taking a count it’s good to know. Hey, this is what’s going on - got to move this guy down to dry cell. MR. a: And let’s say - sorry. Go ahead. MR. a : I was going to say I guess - are you asking like who is responsible for doing the keying? Yeah who -? MR. MJ: «tt could be cna. MR. QM: what’s cna? EFTA00111145

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LIMITED ies) w oO wo i=) N ive) oO co wo No Nm No ion) OFFICIAL USE 1 uw o MR. a: Control number two. MR. a : Okay. But control would be responsible for him. It’s not ops or SHU that would have been responsible for (Indiscernible *02:01:28). It’s control rt a fu rt was -- MR. a : -- responsible for -? MR. a : -- make that change though. MR. QJ: | sgu could? MR. a: I mean if they say hey, I need this guy in dry cell. You know. Okay. You notify them. You know hey, move him. MR. ae : Okay. I guess though is like under the regular practice - I understand that other - some people have the ability to do it. But who MR. a: Should have moved keyed the MR. a : Yeah-yeah-yeah. to R&D? EFTA00111146

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LIMITED OFFICIAL USE 1 ~] wo 10 11 uw \o MR. QJ: | Yeah. MR. QJ: 9oUh cna, control. MR. a : Control should have? MR. QJ: «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 ct n wu t change needed to be made? MR. a: Mm. I mean Sue 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. MJ: «othe sHU. They just (Indiscernible *02:02:37) down there. MR. QJ: So the suv. MR. a: They’1l call control. Yeah. MR. ae : 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 EFTA00111147

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LIMITED w ~] ive) OFFICIAL USE 1 oO’ oO made this movement. He needs to be rekeyed. MR. QJ: 39 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 here. MR. Ee : So should have a lieutenant been involved in that? MR. a: Not necessarily. MR. ae : 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. ae : I guess but if anybody can do it and no one is told to do it, I gue 7) rt) - I would assume - that it would quite frequently not be done because everyone would EFTA00111148

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LIMITED OFFICIAL USE 161 w ~] 10 11 12 18 19 20 be like “well he could have done it - he should 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, “well that person could have done it - that person could have done it.” MR. a: Yeah. MR. a : So is there anybody that’s supposed to do it? MR. QJ: §9To notify? MR. a : Yeah. To make the notifications so that the numbers can be changed on the El? MR. a: Yeah. I would say the SHU un ct fw hh Hh MR. QJ: suv staff. MR. a: They kind of say hey, this guy is not up there. check to see where he’s at. MR. QJ: 411 xight. MR. a: Maybe key him to R&D. EFTA00111149

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LIMITED OFFICIAL USE w ~] wo 10 11 MR. Ee : Sorry I didn’t mean -. MR. a: No-no. That’s exactly what I was thinking or trying to get to. You said the 3) 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. Okay. This was -. a: a: MR. MR. oO MR. 9:30. But let’s see the 4:00 p.m. 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? EFTA00111150

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LIMITED OFFICIAL USE 1 w ~] is) Ww MR. QJ: = Nah. 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 p.m. Are you able to tell? MR. QJ: yeah. It looks like -. Okay. So let’s start with this. This is the 9th, right? MR. QJ: 9 Yes. 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. ae : 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 H.... 411 righ 9th Friday he goes in at 3:15 in dry cell. And rr - So at 9:00 on August 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. EFTAQ0111151

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LIMITED OFFICIAL USE 164 10 11 12 13 14 16 18 19 20 21 22 23 24 MR. a: Yeah. MR. a : 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. GJ: 9 Mm-ho. MR. a : Now we’re trying to determine were the counts ever conducted in the SHU? MR. GJ: vn. MR. a : It doesn’t appear to us that they would have been. Because they would have caught that at 4:00 p.m. and the 10:00 p.m. They would have said this is the number of people we physically have present. MR. a: Yeah but I don’t see -. MR. Ee : 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. EFTA00111152

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LIMITED OFFICIAL USE 1 w ~] wo 10 11 is) w MR. QJ: «9 vr-hn. MR. a : 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 veah. MR. Ee : And that is also one of the things that we believe happened. Is that fu at least on one of the instances, they did do round, but they didn’t do an actual count. MR. QJ: Yeah. Because honestly, I don’t see it on this end. A 4:00 and a 10:00. MR. ae : You don’t see what? MR. a: The missing of 4:00 and MR. a: Yeah. The fact that they EFTA00111153

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LIMITED OFFICIAL USE 166 Ww a] H Ph ct 7 o be) iat Oo w a ct i wu an a ke 4 counting. Correct? o w BO Lad @ wu J a 5 Q rt > fw rt ifs) y we believe - and it sounds like you agree - they didn’t 8 actually do the 4:00, the 10: or the wo midnight count. i=) No. I mean I’m thinking t and the 10 MR . a : Even though the numbers N Fs Ww wu H o = K 12) =] a 4 MR. a: Yeah. They probably just went off the numbers. ae: SO you think -- 7 MR. QJ: «what -- they conducted the round? t oO Fs Lee) 5 1 1 wo a3 They conducted a round 23 miss the number if they’re actually counting 24 numbers both at 4:00 - or all not just both. 25 At 4:00, at 10:00, and at midnight, all of the EFTA00111154

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LIMITED OFFICIAL USE 1 ~] wo 10 11 oa ~] count slips are wrong. 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. J: 9 nle 4 one. Then they could do it. But 73 plus one if] if] Bb ct = wu i) ~) Ww 3 } 45 c n seems to indicate they’re using the number that’s provided -- MR. QJ: 9 on the £1. MR. a : -- 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. Ee : 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. GR: No. MR. a : Okay. There’s no way for EFTA00111155

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LIMITED OFFICIAL USE 168 10 11 12 13 14 16 17 18 19 20 21 22 23 24 like anyone else other than the people in the 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. QJ: 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 to - Thomas and Noel? MR. a : 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 EFTA00111156

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LIMITED OFFICIAL USE 169 1 know? 2 MR. a: I mean they wasn’t counting. ies) a Yeah-yeah-yeah. I know. 4 But I mean just letting you know like, oh yeah, 5 first we want to know about the cellmate. Hey, 6 know thing about this? Did you - it 7 looks like -. From the way 8 reads, we assumed that eith told © a @ le a @ it) = "I w Make sure he gets a 10 cellmate. Because that’s one of the reasons 11 why we want to talk -. MR. ae: Based on that memo? Yeah. because like the N Fs) ive) Fs) ying, I knew. I knew he was going WAB. And I told him. Mm-hm. 7 MR. ae : Hey, make sure he gets a t oO a 8 cellmate So the assumption that we were going 9 off of is that either you and/or iz -- 20 MR. J: 9 wm-hn. 21 wR. GR: -- spoke to (J anc 22 said he’s going WAB. Make sure he gets a 23 cellmate. 24 ve. ER: «on. EFTA00111157

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LIMITED OFFICIAL USE 170 w ~] wo 10 11 you’ re ing is you don’t -. You didn’t even is] know, and you never had that conversation. MR. a: With Reyes 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. Ee : 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. ae : So R&D wouldn’t call control. And control wouldn’t call him? R&D would call directly to the SHU? MR. QJ: 9 That’s how we used to do it. MR. a : Okay. That’s how it would always be? So when you were in the SHU - 2 MR. a: They call up -. MR. QJ: &D would call you EFTA00111158

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LIMITED OFFICIAL USE 1 uw ~] 10 11 12 18 19 20 21 22 directly? MR. a: But again that’s evening watch. Again that’s on evening watch. MR. QJ: Right. MR. a: That guy’s not coming back. MR. a : But at 1:50 that’s early. 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. QJ: 9 wm-hn. MR. ae : 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. a: Mm-hm. MR. a : And again we were told typically the way it works - and it sounds like you’ re correcting us - R&D typically calls ~) BR EFTA00111159

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LIMITED ies) w co ioe) co OFFICIAL USE 172 control. Control calls ops. Ops calls SHU. s that not correct? MR. ae : What. When an inmate doesn’t come back? MR. a : No? It doesn’t work that way? So R&D you’re saying typically just wo go straight to up. That’s a s not coming back. Control knov MR. ae: Control knows. They could call control too. But usually they call in you know MR. Ee : I don’t know. MR. ae : That’s just what we were told. MR. a: Hey, this guy’s not coming MR. a : And then again, we’re EFTA00111160

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LIMITED w ~] wo 10 11 OFFICIAL USE 1 ~) a only as good as who the people we talk to. MR. QJ: «= m-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. a : Right-right-right-right. MR. a: Blame someone. Who dropped the ball? Who did this and that? MR. a : Totally get it. MR. a: I mean two years later, now it’s still like okay, let’s go down and see. MR. a : And the reason why and I’m sure you saw on the papers what happened recently. MR. QJ: 9 veah. MR. ae : 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 EFTA00111161

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LIMITED OFFICIAL USE 174 1 after a whole shift. You know. 2 MR. a : It’s not necessarily go 3 after the whole shift. But we’ve got to figure 4 out what went wrong at the MCC. And what needs 5 to be fixed. you know what I’m saying? I mean -. 7 MR. a : But I get -. Trust me -. Just to deal - they have oO a co Fs) its] n =] m7 a ra on oO if 3 ju 4 Like they do. i=) a Yeah-yeah-yeah. Totally. 11 MR. a: He just happened to be a 2 high-profile one. 3 MR. a : Right. And because it’s 4 so high-profile, and the fact that there were - 15 t oO a The other things with the -- 7 yeah-yeah-yeah 8 MR. a : All these other things 9 are going on now. It looks like there was some 20 false you know slips that were created. 21 MR. ae: Yeah. 22 MR. ae : They weren’t doing 23 counts. You know we’re getting these signs 24 saying that -- 25 MR. ae: Yeah but that stuff is -- EFTA00111162

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LIMITED ies) w co wo ive) co OFFICIAL USE 175 MR. Ee : -- hey, you’re supposed to check on him every -. MR. ae : -- not the normal though. MR. a : Right-right-right-right. MR. QJ: 9 That’s not the normal. yeah. And re right. It’s because it’s a high-profile H MR. a: I was there used to do that stuff and all that. That’s i] ] oO rt “] MR. GJ: | what’s MR. a: Missed counts and all this MR. a : It’s definitely abnormal. MR. Ee : When you were in the - were you ever - did you ever experience people not doing counts? MR. a : People always did counts u were there? EFTA00111163

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LIMITED OFFICIAL USE 176 w ~] wo 10 11 ~) oO MR. Ee : And that’s -. MR. QJ: 39 Yeah. MR. a : You know and that’s what people - that’s what the conspiracy theorists come in and all that 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. QM: ean. MR. a: You know? They lose - inmates go out WAB all the time. New inmates come in. MR. QJ: Yeah. MR. QJ: So this is a revolving door. MR. a : All 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. EFTA00111164

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LIMITED OFFICIAL USE 1 w ~] ~) ~J] MR. Ee : What is the purpose of a supervisor actually signing this round sheet? MR. a: Making sure the officer is filing 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. QJ: «Right. MR. Ee : 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. a : 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 EFTA00111165

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LIMITED OFFICIAL USE 178 1 day. And it was such a big event that’s been 2 in the news now for two years. ies) mR. QR: «9 vm-hn. 4 MR. a : Just try and really place 5 yourself. What was your role on that day? 6 MR. ae: Yeah. Like I said I just 7 know I worked. And that was it. 8 MR. a : All right. And as far as 9 you know, were rounds being conducted in the 10 SHU at that time? 11 MR. a: Yeah. It’s day watch. 2 You’ve got to make rounds. 3 MR. a : On day watch you’ve got 4 to 15 MR. a: There’s no way you can avoid 16 a round on day watch. 7 MR. ae : What about for - and I’m 8 not talking about just your shift - I’m saying 9 the SHU in general. Are you aware that rounds 20 weren’t being conducted on evening watch or 21 morning watch? 22 MR. a: Weren’ t? 23 MR. a : Yeah. Were not. 24 MR. a : Evening watch you’ve got to 25 make rounds too. I worked SHU for years. EFTA00111166

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LIMITED OFFICIAL USE 179 10 11 12 13 14 16 18 19 20 21 22 23 24 MR. a : Yeah-yeah. 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. EJ: No. MR. ae : 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 EFTA00111167

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LIMITED ies) w co ioe) co OFFICIAL lieu USE t 0) na conv time nt. a : Yeah-yeah. Did you have ersations with the SHU lieutenant? At to him con\ going these rounds and that MR. MR. Ee : Prior -? No. What I’m bout is up until August 10th. a : Mm-hm. you know looked at or he’s got a cellmate or ing like that? a : Man, I don’t recall that. re) EFTA00111168

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LIMITED OFFICIAL USE 181 ~] wo 10 11 MR. a: Yeah. But we all you know. It’s hey, you got the email. MR. a : Right. The email saying he needs a cellmate. MR. a: 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 thin acceptable for any lieutenant to say that they — = cr > 7) didn’t know that Epstein needed a cellmate? MR. a: Some people say they didn’t know the cellmate left. MR. ae : 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: 411 right. So she’s in - like an acting lieutenant. She’s the person -. MR. a: I don’t think she was acting MR. a : Well I just mean that she EFTA00111169

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LIMITED w ~] ive) OFFICIAL USE activities’ lieutenant. MR. : a : Sorry. and she was Yeah-yeah. MR. activities’ lieutenant training or she’s typically an though. Should have she known on the hotlist and Epstein you Should she hav suicide watch. was required to have a cellmat ue. a Should he have known? aware though. you’re - first Uh-uh. No. No? Wha MR. I mean that’ If I’m not awar MR. I though I thoug Well, no. you’re a certain classi odd number and they can’t would be he’s so have But then MR. on the hotlist. Everybody knows that 182 She was the was either SIS at time U by Epstein being know coming off e known that he e? Just by -? s only if you’re e, the guy left. t you said if ht you said that in you’ re supposed to have a cellmate fication. metimes it be an one. the second thing Everybody knows EFTA00111170

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LIMITED OFFICIAL USE 183 1 if you’re on the hotlist you’re supposed to 2 have a cellmate. Right? ies) 4 MR. QJ: nd then the third thing 5 would be that there’s an actual email that was 6 sent out and that said he’s supposed to have a 7 cellmate. 8 MR. QJ: 9 Right. Ks] ~ a n is) that’s where -. With 10 that all in mind -. And I’m not -- 11 MR. a: About the notifications -. 2 MR. a : -- pointing to one person 3 out in particular. What I’m just asking is 4 these people that were working. So you’re not 15 like throwing somebody under the bus. 16 MR. QJ: 9 on well. 7 MR. ae : I’m just asking like as 8 far as these people. Should || have known 9 that there should have been -? And I’m not 20 saying that he knew. These people may very 21 well have not have known that | -. I’m 22 jus i) t asking like -. 23 MR. a: Yeah but I’m thinking. 24 MR. a : In general with their 25 positions. EFTA00111171

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LIMITED ies) w co ioe) co OFFICIAL USE 18: MR. QJ: In general. well 3 ver got the email. 0) probably n known? MR. ae: I think all should know. MR. a : What about -? MR. a : But then again, we all - if inmate’s leaving, follow-up. And MR. off of EFTA00111172

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LIMITED ies) w co ioe) co OFFICIAL USE 18 MR. Ee : And then the next replaced should she known that he needed a cellmate? MR. QJ: 391 could see her not knowing. he es) o =) a Bb wn rt im rt ion @ ie] m7] c a i) ) wasn’t a MR. a: Not a lieutenant. ay. What about He’s not a lieutenant. Yeah. Or knew. Like I email. MR. ae : And then what about sounds like there Two: he came off of suicide watch. Should have Three: an email was sent out to Should have a cellmate. So is there any -? wi EFTA00111173

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LIMITED OFFICIAL USE 186 10 11 12 13 14 16 18 19 20 21 22 23 24 happens all the time though. Like the guy 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. a: But 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. ae : 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 EFTA00111174

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LIMITED OFFICIAL USE 187 3 a guy goes to court and he leaves, you know and 4 you’re doing your daily operations. There’s so 5 much going on. Epstein ain’t the - I know he’s oO high-profile out to the outside. 7 MR. a : But I mean he’s still on the hotlist. co wo a3 K oO wu J 10 MR. a : So he’s on the hotlist 11 still. So doesn’t that indicate he needs a 2 cellmate? If he’s still on the hotlist. ive) Fs) Yeah. But he had one. t wi a Right. And that’s why 16 I’m ying. By - we’re knocking you and we’re 7 knocking || out of this thing because you’re 8 saying 8:00 So let’s now look at 8:00 on. 9 Let’s say - even for this instance let’s even 20 say BR and BJ they didn’t know. Now 21 let’s look at ae Certainly by 22 midnight you should have known. Right? 23 MR. a: Yeah. But not a lieutenant 24 though. EFTA00111175

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LIMITED OFFICIAL USE 188 1 MR. a: Like if the information isn’t 2 told to me -. 3 MR. a : But if they’re coming in 4 -. You said that they needed to do a around. 5 Right? Don’t these - for this case | or 6 | needed to do a round in the SHU. ~] Correct? Mm-hm. oo Fs) 9 MR a : Check on all the inmates. 10 MR. a: Check inmates, feeding, or 11 officers - making sure they doing the rounds or 2 got to go to SHU. 3 MR. : GS. ves she 4 required to check on all the inmates and do a 15 round? 16 MR. ae: When she was probably doing a 7 round. Yeah. 8 MR. a : All right. So as far as 9 her that point, now we’ve only got -. You 20 know we’re now -. You know let’s say that 21 she’s the one that corrected you know the count 22 slip. She caught that. She goes. She visited 23 - She’s supposed to go to the SHU. She’s 24 supposed to actually visit all the tiers and do 25 a round? EFTA00111176

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LIMITED OFFICIAL USE 189 10 11 12 13 14 16 17 18 19 20 21 22 23 24 MR. a: I mean our policy is really 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 -. EFTAQ0111177

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LIMITED OFFICIAL USE 190 1 MR. Ee : By policy I’m saying. 2 MR. a: By policy you’ve got to make Ww wu a] ie) c 3 on 4 MR. a : And that round is 5 classified as like a round like the COs who are 6 in the SHU do a round? 7 MR. a : I’ve got to double check on 8 that 9 MR. QR: Okay. 10 MR. a: To tell you the truth. 11 MR. Ee : And that’s what’s unsure? 2 MR. QJ: 9 Yeah. 3 MR. a : You’re unclear? Okay. 4 And that’s where I’m still trying. Because 15 we've also had less people - but some people 16 have also said no, a round for a lieutenant and 7 a round for a CO is different. A round for a 8 lieutenant is visiting the SHU and checking in 9 with the officers. We’ve had more people say 20 no-no-no-no-no. You need to go into the SHU. 21 You need to check in with the officers, but you 22 also need to walk the tier. 23 MR. QJ: 9 Right. 24 MR. a : And I’m trying to get 25 that like -. EFTA00111178

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LIMITED co wo co OFFICIAL USE 191 MR. a: It depends on the lieutenant. MR. a : And then their interpretation? MR. QJ: But sthere’s no -? MR. ae: Like I said that’s why I that part. =] really don’t - I’1l have to check o MR. a : Okay. And what policy would that be in? Where it would spell that MR. a: That would be in inmat discipline which is SHU. And it also would i) probably be in psychology. for if the lieutenant needs to do it? MR. ae: I know it’s about 30 and everything. MR. a : But it would also be like oO Oo MR. a: But for lieutenants -. MR. ae : It would also be 1 MR. GJ: well 1 EFTA00111179

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ies) w ~] oo wo i=) ive) w he H rom 3) 5 cr S wu 0 rt 'S sychology. Isn’t it in there? MR. a : I don’t know. I was going to look. be. Psychology is definitely the 30-minute Yeah. Let me see. It might rounds. I know. gotcha.” MR. SE: a might have it with like lieutenants -. The -. Again these aren’t “I These are just genuine questions. Yeah. But psychology you think Well they definitely with the 30 minutes. policy clearly states that rounds need to be Yeah. I mean the conducted. I just haven’t seen anything that said lieutenants need to do it. And that’s where - I mean you can look through them if you want. vn. MR. ae : If you can -. MR. : may not be in this, but it’s definitely in Nah. I think it’s in there. It there. Speaking of lieutenants, we don’t need EFTA00111180

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LIMITED OFFICIAL USE 193 1 to make you look in this. We’1ll look it up. 2 MR. a: This is post order We’1l dig into that. 7) ies) a wi aw But you think it’s 6 probably in the SH 7 MR. ae: Yeah. It’s a round, but to 8 say specific on and all that. I 9 don’t know if it all th 10 MR. QJ: «811 right. It just 1 you need to conduct a round. And then Ww 5 . 0 fw J Me 0 ue] 5 MR. a: But then again, if you don’t get the information, I can see it being missed. oO Les] Fs) w © e) ny ce ty] ru) B- Hh fs) fe) fe) 5 1) rt i) ra be u =| oO 21 know Reyes left, I know Epstein is by himself. 22 But I didn’t 23 MR. QJ: 9 Mm-hn. 24 MR. a : Does that make sense to ow he needed a cellmate. EFTA00111181

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LIMITED OFFICIAL USE 194 10 11 12 13 14 16 18 19 20 21 22 23 24 MR. a: I mean. Unless she didn’t get 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. QJ: 9 Yeah. MR. a : So her saying I didn’t know. Is that to you like, of course you knew. You’re 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? Saying that I didn’t know if those three things EFTA00111182

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LIMITED OFFICIAL USE 195 10 11 12 13 14 16 17 18 19 20 21 22 23 24 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. a : 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. a : -- 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 inmate is on the hotlist. Initially. EFTA00111183

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LIMITED OFFICIAL USE 196 w ~] 10 11 12 18 19 20 MR. Ee : 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. QJ: =o. mean I’m not psychology. MR. a : 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. QJ: 1 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 walk to you about Epstein needing a cellmate? EFTA00111184

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LIMITED ies) w co ive) oO co OFFICIAL USE MR. QJ: 9 Not that he in fact did continue to un i oO c a A a fu o ct 0 pa QA oe Hi un w 5 captain or another lieuten And one Anyb a Anyone. MR. ie) hould h something sending out an e I don’t a) continued 197 I recall. Who should have? If need a cellmate, who ychology. Not the ant? It was who in of them. oc Hey, it’ mail. un an i) you think that like once a week or mail? Or how often? wasn’t even ike how soon should think a weekly or you EFTA00111185

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LIMITED OFFICIAL USE 1 1 MR. Ee : That was maybe ten days. 2 MR. a: Because I don’t know. I fe] oo 3 don’t know. I know they (Indiscernible 4 *02:30:39) to us so I don’t know their policy. 5 Because I know they supposed to follow-up. And 6 then there’s steps to it. I don’t know. I’m 7 not familiar with that policy 8 MR. a : Okay. But you think it 9 was psychology’s - they’re the ones that should 10 have made sure like there’s people -- 11 MR. QJ: 9wWell they -. 2 MR. QJ: «ss -- in the Suu and the -. MR. a: They sent out the email to ive) c a7] w 16 MR. ae: They notified us. 7 MR. ae : But you’re saying like 8 that could be like a day or two. It doesn’t 9 mean that two weeks from there it matters. 20 MR. QJ: 9 Yeah, I mean. That happens 21 two weeks after that? Yeah. The guy goes to 22 court. He leaves. There’s a time and 23 opportunity. And I don’t think it’s nobody’s 24 fault. 25 MR. a : You think it’s just -? EFTA00111186

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LIMITED OFFICIAL USE 199 1 MR. a: I just don’t think it’s WwW a Hh wu c a rt Okay. And do you recall 4 this sign - or any sign - hanging up saying 5 that he needed a cellmate, or he needed to be 6 30-minute rounds on him? 7 MR. ae: I definitely don’t recall 8 that. Signs about you saying him needed rounds © 2) HK i} 10 MR. a : That’s the rounds. 11 MR. a: No the one that - MR. a : And then you don’t -. N Ww 5 ys 5 0 rr a 0 KR Oo 5 0 b i] t fea) a 4 o oO i) & Q 5 v 7 MR. ae : So we've been told that 8 there was a sign s Epstein was 9 required to have a cellmate in the 20 desk area. 21 MR. ae: Could have been. I don’t 22 know. I don’t be in the desk area. 23 MR. a : So you don’t - you’re not aware? But you know that there was a hotlist ho wi at least. No 77) EFTA00111187

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LIMITED OFFICIAL USE 200 w ~] wo 10 11 ive) MR. a: No. The hotlist is there. It’s been there since I was working there. The hotlist is back there. And that’s about it. MR. a : And do you know if Epstein was on the hotlist? MR. a: No. I’m not sure. MR. a : You’re not sure. MR. a: Do you have the hotlist? MR. a : Not with us. No. I don’t think. Do we have it? No. You said you didn’t even as the ops lieutenant you don’t recall specific conversations with anybody that worked in the SHU on August 9th or 10th? No? MR. a: Specific conversation, no. It was a regular day. MR. Ee : Yeah-yeah-yeah. I mean up - leading from basically July 30th to August io th. MR. QJ: «0h. = About the -? MR. QJ: | Sbout the need for checking on Epstein or a cellmate o KR anything to do with Epstein? MR. a: No. All I know is when he tried it the first time, he went to suicide watch. Came off. And they put him with the EFTA00111188

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LIMITED OFFICIAL USE 201 w ~] wo 10 11 other guy. No-no. They put him with someone else. I don’t know. MR. a : So initially he is with - is it Tartaglione? MR. a: Tartaglione he was named. Yeah. MR. QJ: | nd then he went to suicide watch. MR. QJ: 9 uh-huh. MR. a : Came back on Jul 30th like that. So from July 30th to August 9th. i] As ops lieutenant or otherwise, did you have any conversations with anybody working on the SHU - in the SHU - on August 9th or August 10th about Epstein? MR. QJ: 9 Yeah. MR. ae : And what were those conversations entail? MR. a: Uh you know just hey, leave him with - just gotta make sure they got down here early. You’ve got legal visits. Uh I know he was asking for a phone call. This is like basic you know regular stuff. MR. a : What about with regard to making sure they’re doing rounds or that he has EFTA00111189

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LIMITED OFFICIAL USE 202 1 a cellmate? Did you have any conversations 2 from the time you got that email on? After you 3 got that email, did you call down to the SHU 4 and say hey, or visit the SHU, and say hey make 5 sure he’s got a -? oO Fi he a w 5 rt iad oO ie) t b And I wouldn’t do it if I’m co Fs) wo =] 18) ct rt 7 o ! 11 MR. a: You know? 2 MR. a : Did you take any action 3 after receiving that email? Did you talk to 4 anybody about it? t wi a Hi can’t recall. t oO a That email was -. Why 7 was that email sent out to all the lieutenants? 8 MR. a : I told you. They send it out 9 every time someone comes off suicide watch. 20 MR. QJ: | Right. So what is the 21 purpose of that? 22 MR. a: For the doing they job. 23 MR. a : So by you getting it and 24 doing your job as like an ops lieutenant. Or 25 an activities’ lieutenant. What does that - is EFTA00111190

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LIMITED OFFICIAL USE 203 10 11 12 13 14 16 18 19 20 21 22 23 24 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. QJ: Right. MR. a : Lieutenants (Indiscernible *02:35:05). MR. a : SO that’s what I’m saying. Well it’s not an all-staff email. EFTA00111191

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LIMITED OFFICIAL USE 204 a correctional 7) 2 MR. QJ: =No. it’ services and correctional system: 4 MR. a : Oh you can tell me. Here Ww n a bp. te] 5 ct 5 I’1ll show you. I thought it was primarily 6 lieutenants. I mean I think a couple SHU staff 7 might be on there. But it’s the three pages 8 behind it. 9 MR. a : Okay. So suicide watch psych 10 observation update. So you got legal in here, 11 food service, case managers, lieutenants, unit 2 team -. Ww 5 w is) oO he reviewing that are 4 you able to tell like is there a target 15 audience that they’re -- t oO a 7 MR. ae : -- sending it out to? is to make everybody Lee) 5 ite] ) = w K oO 20 MR. QJ: | Because it’s not an all- 21 staff email though is it? 22 MR. EJ: No. 23 MR. a : So who are they sending EFTA00111192

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LIMITED OFFICIAL USE 205 1 MR. Ee : Like how do they come up 2 with that group of people to send it to? 3 MR. ae : It’s the same way we do the 4 logs. We send it to eh same group every night. 5 MR. a : What group is that? 6 MR. ae: Then Executive staff, then 7 lieutenants, then psychology, then a 8 assistant, it’s a-. wo = a So is it all correctional 10 staff though 11 MR. a: Correctional staff yeah. 2 It’s not all correctional officers though. 3 MR. a : So is everybody but the 4 officers? 15 MR. a: You got some officers on here 16 too. 7 MR. ae : But you’re not sure how 8 they make that decision? 9 MR. a : No. Yeah. You got medical, 20 lieutenants, food service, R&D, legal, duty 21 officer, yeah. I mean I think they would 22 probably do this it’s for your information. 23 Like FYI. 24 MR. a : But you know -. I 25 understand where the FYI. EFTA00111193

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LIMITED ies) w oO wo i=) N ive) oO co wo No Nm No ion) OFFICIAL USE N o C i) mR. QM: 9 Yeah. MR. a : You’re not clear on why that a target audience? specific people? Okay. But as far as you receiving it. MR. a: Yeah, I can’t recall if I spoke to him about it up internal or not. 5 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. Ee : Yeah-yeah-yeah. MR. QJ: 9 So they y, BE this coming in. Make sure. Okay. Make sure it) 7h oO you know. I’m saying directly to the staff I’m supervising. it) a ct rt wv oO Oo aI if] EFTA00111194

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LIMITED OFFICIAL USE 207 1 lieutenant’s job to make sure the SHU 2 lieutenant does it? 3 ve. J: on. 4 MR. : Is there any oversight 5 there? Does the ops lieutenant kind of have 6 oversight over the SHU lieutenant? 7 MR. a : I mean sometimes the SHU lieutenant has rank on an ops lieutenant. co wo a Oh. It depends on if 2 MR. QJ: 411 right. it’s not 3 based upon the position that you’re holding? 4 Like the ops lieutenant doesn’t - like that 15 position doesn’t -. 16 MR. ae: I mean we don’t sup lieutenants. No lieutenant supervises oO rvi ta e 8 lieutenants. 20 MR. QJ: 9 That’s - we have a 21 supervisor. 22 MR. ae : No-no-no. And again, 23 these are questions just for us to try to 24 understand how the operation works here. 25 MR. QJ: 9 Yeah. EFTA00111195

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LIMITED OFFICIAL USE 208 1 MR. Ee : And it again, not placing 2 blame on you whatsoever. It’s just trying to 3 figure out how is it supposed to work? If 4 they’re saying it’s you, are you supposed to do 5 something with that information? 6 MR. ae: I mean but the thing is they 7 follow-up into that time. 8 MR. a : What do you mean? 9 MR. a : He had a bunkie up until that 10 time. 11 MR. Ee : Right. So they put it 2 out He had a bunkie. ive) Fs) Right. 4 MR. ae : And then he didn’t. And 15 that’s what we’re trying to figure out. 16 MR. ae: And then (Indiscernible 7 *02:38:39). 8 MR. a : Who - where was the 9 communication breakdown? Who should have at 20 that time taken action to make sure he had a 21 bunkie? 22 MR. QJ: 9 Yeah. 23 MR. a : And that’s the whole 24 thing we’re looking into. Who should have made 25 sure Epstein -? Once Reyes was removed and EFTA00111196

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LIMITED OFFICIAL USE 209 removed. Who wu a 1 people were notified that he w 2 should have taken action? WwW 5 M< om fw 7 4 MR. a : And who in your opinion w 6 MR. ae: I don’t know man that’s a tough one. Yeah. 8 MR. a : But like even position wise. Not to name names. What position should wo i=) have taken action? 11 MR. a: Mm. I’m not sure. I’m not sure with that on N 0) i a iu) KR i) Ww es) Cc ~ fw he 4 MR. a: I just - that just -. The guy left and I mean, you know. t oO a Now I’m just handing you back this lieutenant log. Lee) 5 Mm-hm. 9 MR. Ee : You know a few pages 20 back. But um did you - were you involved with 21 that lieutenant’s log? Did you ma! 22 entries on that lieutenant log on August 93th? 23 MR. a: I’m not sure. 4 MR. a : Yeah. Are you able to looking at it? Like is that something ho No w ct oO bh bh Co ten EFTA00111197

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LIMITED ies) w co wo ive) oO co OFFICIAL USE you can can make tell an ent or anything like that after an entry de? Does it show who made what entry? MR. leaving MR. MR. What does it say? Reyes to pre-remove. Pre-trial remove. ae : Does that mean that he’s and he’s not coming back? Yeah. Yeah. What time does it say Yeah. that mean tn 0 a WwW oo uo re] o n that mean EFTA00111198

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LIMITED OFFICIAL USE 211 w ~] wo 10 11 that they knew at 8:38 that he wasn’t coming back? MR. a: Not necessarily. MR. QJ: 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. :00 a So he was taken off the count from 7:00 to he was taken off the count. MR. a : Are people that go to court always taken off the count? MR. GJ: om. No. MR. a : So by looking at that, that tells you that he was already WAB? MR. QJ: 9m. I mean if they go to Brooklyn, sometimes they take them off for a different court. But this one here, I would say yeah, taken off the count. And again I’m not sure. I see pre-remove proof. Pre-remove. MR. a: But by saying pre-remove, EFTA00111199

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LIMITED ies) w co ioe) co OFFICIAL USE 21 does th is at approximately 8:30 , did we wu rt 3 a) i] oa r rt ‘s more likely that he’s -- HE’s taken off the coun C rt -- not coming back? Uh. Yeah. oO And who would have that 5 H 3 5 is) rt it] c 5 o | 0 ie) 12] is * a 12] = B Kh I’m not sure. And there’s no way to a: ow. as the BOP - did we already know hey, this p MR. robably not coming ba Um. I’m not sure. coming back? 8:00. No-no-no. What would show? If he was coming back? You said that’s it’s pre- EFTA00111200

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LIMITED OFFICIAL USE N a Ww Yeah. N Fs If he was coming back, what ies) would it show? Would it say pre-remove or 4 would it say something else? wi aw that’s the thing is -. I 7 MR. a : Like not that he was 8 coming back. Like if he’s just going to court, 9 don’t know if he’s coming back or not. s not WAB. Would ive) am 5 MR. a : So it would only say that thought he wasn’t coming back? 7 MR. a: Mm. Yeah. Probably. a : All right. looks like from looking at that. 21 MR. ae : At - by 8:38, we knew he 22 was probably not coming back? oO Lee) 5 24 MR. QJ: 411 cight. And with that any action - or should EFTA00111201

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LIMITED OFFICIAL USE 214 10 11 12 18 19 20 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. a: I’m not sure. You know. The thing is this is when it was -. See our log is not -. I could go in and see what time someone left and input it. MR. SR: r-n. MR. a: That’s what we do. At the end of the shift. MR. a : So at 4:00 p.m. this could have been updated is what you’re saying? Not at 8:30? MR. a: Uh probably like 3:00 around there. Yeah. It’s not the only one. MR. ae : Yeah. I’m not saying specifically, I’m just saying like later in the day. MR. QJ: §9=o.t’s not an ongoing thing. MR. a : It could have been -. So -. But does that -. But do you wouldn’t put 8:38 - this is when that happened - if at 8:38 you dint’ know that. Would you? MR. QJ: «Well if I don’t check it, I EFTA00111202

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LIMITED ies) w oO wo i=) N ive) oO co wo No Nm No ion) OFFICIAL USE 21 wouldn’t know it. MR. a : Right. I’m not saying MR. ae: No I mean anybody. If I go on the computer and it has a time. And it say these are the people that left. That’s what I’m going off of. MR. a : If I don’t check it at 8:38 or - I won’t know. MR. Ee : So when I say “you” though I’m talking about BOP. So what I’m saying is like the person who entered that. was known MR. a: It was known to BOP. MR. QR: Right. MR. a : Yeah. And who likely would have entered that? Like who has access wi EFTA00111203

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LIMITED ies) w oO wo i=) N ive) oO co wo No Nm No ion) OFFICIAL USE to enter else? Sele vi it’s - y then con didn’t e reviewin this isn of figur Or to wn = Zz O that? Control and lieutenant would have been either you, a. or Correct? ae: Mm. I’m not sure. a : But I’m just saying like ou’re the only two lieutenants on. And trol. Right? a : And this is all just - I ven realize this until we’re now ain, I’mn Q g it. So thi if isn’t a - I promise you ‘t like a setup. This is just trying e out. a: I’m not sure. Because what t if I say hey, I didn’t do the log. you forgot the log. You h ae : What do you mean? WM: «sf you get an emergency. a : Yeah-yeah. a : Hey listen, believe me -- a : Yeah-yeah. EFTA00111204

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LIMITED ies) w co ive) oO co OFFICIAL USE 217 MR. a: I ain’t touch the log. All right. Whatever. I got you. Right-right. So you re just saying i control? don’t know who did it. All right. mean like I know like I’m pretty sure | ew he was going but he didn’t know he wasn’t coming back. Is that correct? with this is if I relieve you nothing. Hey, you know, look got You know what I’m saying. EFTA00111205

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LIMITED ies) w co wo ive) co OFFICIAL USE Hh b- b b m 2 ie] Gc ct o K rt) fe) =| mo ie) 3 0) MR. maintain that con MR. MR. point in what = wu un 0] ‘) 5 Nm e br fee) w rt fos) lo co iow would they know? They got a computer. What would tt at i) a: ed for a long period of time? the movement. And would that be 5 Bp un stantly refreshed? time would we be able It refreshed midnight. And then did mm: : it could come you don’t \ would say EFTA00111206

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LIMITED OFFICIAL USE 219 1 MR. QJ: 391 don’t know who did this. 2 Was it day watch or what? ies) a And there’s no way to 4 tell by looking at it? 5 MR. QJ: No. oO a Is there in Sentry any 7 way to tell who entered it? co Fs) We don’t do the Sentry. We 9 just take the information off of Sentry. 10 MR. QJ: 0h.) Well who would have 11 put it in Sentry? R&D could have Ww 5 5 9° w z 4 put it in Sentry and then whomever - either one 15 of the lieutenants or control would h 16 it in? 7 MR. QJ: 9 yeah. 9 MR. a : Or yeah somebody. 20 MR. QM: «411 right. So with this Lee) 5 21 information at 8:38, would it have been - if at 22 8:38 we knew that -? And when I say “we” - BOP 23 or whomever - R&D. control - knew that he was 24 going and likely not coming back. Who should 25 have starting making those notifications that EFTA00111207

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LIMITED OFFICIAL USE 220 w ~] 10 11 12 18 19 20 Epstein was without a cellmate? Is that SHU staff? Is it lieutenants? MR. a: He said they known at this time? MR. a : 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. Reyes is saying I’m out. I’m not coming back. MR. QJ: 9 wm-hn. 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. QJ: | bike who should have -? MR. a: I don’t even know who the MR. NM: Right. MR. a: So for one, a regular staff wouldn’t even know who bunkie is. EFTA00111208

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LIMITED OFFICIAL USE 221 uw ~] 10 11 12 18 19 20 21 22 MR. Ee : And that’s where my question. Should SHU have started saying like this is - hey ops and activities’ lieutenant. This Reyes 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- removed to such-and-such. MR. a : Okay. So is that why WN. =m. 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 he knows who to tell. MR. Ee : 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 could see that happening because like you said, this happens all the time. EFTA00111209

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LIMITED OFFICIAL USE 222 ies) w ~] wo 10 11 ive) MR. Ee : All right. Because again it says that inmate Reyes was going WAB and may not return. Also that inmate Epstein will be needing a cellmate upon arrival from his attorney visit. So looks like they knew - SHU. Should | have told you activities’ lieutenant - or | - ops lieutenant? MR. a : I mean. MR. a : I’m not saying that he did or that you know. You already said you dint’. MR. a: I’m not even saying that he should have. MR. ae : Okay. MR. a : If he was notified, and he said it could be. Again I told you 8:00. That’s (Indiscernible *02:49:44) guys come in all the time from court. MR. ae : Yeah-yeah. But I’m just saying with the fact that Epstein - everybody knows he needs a cellmate. Should have they notified up the chain of command at this point? EFTA00111210

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LIMITED OFFICIAL USE 223 10 11 12 13 14 16 18 19 20 21 22 23 24 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. QR: 9 vm-hn. MR. a : Should these guys have started making some notifications? MR. a: Mm. 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. Ee : Okay. So you were the activities’ lieutenant and || was the activities’ lieutenant when that thing says 8:38. Do you believe -- MR. QJ: «de 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 time that these notifications should have been made to you? Would have you - do you believe EFTA00111211

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LIMITED ies) w co io ioe) co OFFICIAL USE can. So pre-removal all the time. to make If he did it on I could staff on? this that see co him notifications -. way -. appropriate EFTA00111212

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LIMITED ies) w oO wo i=) N ive) oO co No Nm No ion) OFFICIAL USE 22 , a. Right as he’s gone, He’s going to - like if he doesn’t that’s Epstein 03) come back, definitely he’s going to need a cellmate. MR. ae: He said that to who you Well this is what the and Officer | - that inmate Reyes was going WAB and p sibly may not return. Also that inmate Epstein will be needing a cellmate upon arrival from his attorney visit.” was on day watch? Okay. sounds like what he says is that he told a. present. And these guys were also So in my expert option, at EFTA00111213

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LIMITED OFFICIAL USE 226 uw ~] 10 11 12 18 19 20 21 22 that time, he did the right thing. MR. QJ: 11 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 thought you said we need to know to change him out or we start - yeah. MR. a : And even keeping in mind that both Tartaglione, or however you pronounce his name. MR. QJ: 9 Well after that I don’t think he was bunked with him after that. MR. a : Him and -. No-no-no. What I’m saying is both of his previous inmates - Epstein I’m saying - Reyes and Tartaglione - they were both vetted from the highest of levels. Even with that knowledge, you think that they should have still waited. MR. a: I mean I don’t under -. MR. a: They were vetted by the EFTA00111214

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LIMITED OFFICIAL USE 227 1 captain, the warden, and the regional director. 2 3 some 5 6 do 7 Or 8 oO a Ae) ct = in 30? Um. 10 MR. a : Well I mean 1 MR. a: I mean I don’t ive) oO fee) Fs) oO I’m talking about 20 MR. Ee : Yeah-yeah-yeah. But what 21 I’m saying like it appears that in looking 22 that, it appears that they knew he was WAB 25 MR. a : So I’m saying between EFTA00111215

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LIMITED OFFICIAL USE 228 10 11 12 13 14 16 18 19 20 21 22 23 24 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. a : Yeah. MR. a: I’m giving you the heads up. MR. ae : 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 - no inmate - just a regular inmate shouldn’t be placed with this guy. He needs to be vetted. EFTA00111216

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LIMITED OFFICIAL USE 229 w ~] 10 11 12 18 19 20 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 Reyes? 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. SR: | e-n. MR. QJ: 9 t could be in the Eastern District - whatever. If you do come back, they put you back on. MR. a : But only if you come back. Otherwise, they won’t name you again. MR. a: So this isn’t definite. EFTA00111217

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LIMITED OFFICIAL USE 230 1 MR. Ee : It’s indefinite? Ww id ed an bt KR b Q 5 ct 5 definite. That means he’s possibly - he could 6 come back. Just because it says pre-removed, 7 he’1ll come back. 8 MR. a : But what I’m saying is 9 the fact that he didn’t come back. Should have 10 there been another note saying he is now 11 definitely off of our books. 2 MR. ae: No. You just don’t see it on 3 the - you just don’t see it c wi a ri] Q tan ° =] bh ct ct a im] ct ws G on t 3 oO wu is] wn a oO — 4K oO Mh it) KR oF ri] a * i} t oO Fs) ‘< w x 7 MR. ae : Hey, refer back to that 8 thing where it said that he was possibly not 9 coming back 20 MR. BJ: 9 Yep. 21 MR. ae : There should not be any 22 more notes saying like he’s gone. 23 MR. a: No. Only think because if 24 I’m evening watch, the only think I’m checking 25 for is the pre-removed to the institution. So EFTA00111218

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LIMITED OFFICIAL USE 231 1 these three, hey did they come back today or 2 are they off the count? So there wouldn’t be 3 no follow up. 4 MR. a : SO there’s no additional -? There should have -. There’s not ~ w her fw rt no 6 line item that shouldn’t be in there sayin g Reyes wasn’t one of the individuals that J rt on wu rt 8 came back. 9 MR. a : No because - because no. 10 MR. a : So there’s a pre-removed 11 but there’s no line for removed. 2 MR. a : No. Pre-removed means off the 3 count. He’s out the building. Now if he comes 4 back -- 15 MR. a : -- and you -? 16 MR. ae: -- you just put him back in. 7 MR. ae : Okay. So that’s the only 8 notification that should be made - should have 9 been made on the lieutenant’s log? 20 MR. QJ: Yeah. This one here? 21 MR. ae : Yeah. 22 MR. a: Yeah. 23 MR. a : All right. And do you 24 mind just putting it like you did that last 5 one. Just a little star next to is. EFTA00111219

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LIMITED OFFICIAL USE 2 1 MR. a: I’ve just got a question real Wo ies) id Ke i) & please do. wi ial b- Q a ct 6 MR. QJ: 9 w-ho. 7 MR. ae: This outcount that you see fos) g i) kK a 0] a] o Oo a ry o R N 10 MR. a: For ZA sorry. 2 MR. ae: ZA. See that one? Is that th ive) t for o = is) c 07) Mh is) K H 03) a] oO 4 MR. a: Outcount. 5 MR. a: Who normally gets marked off? t’s outcount? t fea) 2) ] rt om oO 113 ra ct J wu co 21 MR. ae: You never usually see an 22 outcount for thi one though. I don’t know 24 MR. a : Say that again. 25 MR. ae: I’m not sure what EFTA00111220

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LIMITED OFFICIAL USE 233 w ~] ive) MR. a: You don’t know what account? MR. a : Uh. It could have been some type of -. MR. a: I was just trying to figure out if they were still counting him as hey, if] there’s a possibility of him coming back. They’ve left him as outcount. And eventually, after evening they removed him from outcount. MR. a: No. So the outcount - oh I know what you’re saying now. You’re traying to Say you mean who is the one that they have at attorney conference. MR. a: See attorney conference we know. That’s -. MR. a: Yeah. That’s the same thing. MR. a: That’s the same thing? MR. a: Yeah. All the numbers is € repeats for the outcounts. MR. a : So you hear what he’s saying? MR. a: Yeah. Okay. MR. a : Ten, one, two. That equals 13. One, one. Three plus one plus l WwW EFTA00111221

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LIMITED OFFICIAL USE 234 w ~] plus two equals 19. MR. a: Got it. So at this point, Reyes is completely off the count. MR. a : Yeah. 4:00. Yeah. He was off at this time. MR. QJ: «okay. MR. QJ: «But the thing is he could come back. MR. QM: «Got it. MR. a: That’s why I’m saying that -. I know you’re saying that 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. a: I 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. a : Okay. And he didn’t notify you? MR. QJ: «No. Not that I recall. EFTA00111222

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LIMITED OFFICIAL USE 2 Ww wi 2 we’re going to move on from that You can give 3 that back or you can hold onto it. Whatever 4 you want to do. Do you know about any cameras 5 in the MCC SHU that were not working on August fon) oO ct > Oo Kh bh o ct a v co working? MR. a : Yeah-yeah-yeah. 10 MR. GJ: No. 11 MR. Ee : Have you - did you ever - wo 2 were you made aware of that after August 9th? 3 Any cameras were not working? 4 MR. a: I heard something about when 15 they was like checking videos and stuff. 16 MR. Ee : What did you hear about 7 it? 8 MR. a : That some of them was showing 9 grainy 20 MR. QJ: | And who would have been 21 responsible for making sure the cameras were 22 working? 23 MR. a: Mm. The facilities. 24 MR. a : Who from facilities 25 should we speak wit EFTA00111223

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LIMITED oO io ioe) oO oo wo OFFICIAL USE N lo o MR. a: I’m not sure. MR. a : Who worked in facilities? MR. Manager is. Facilit MR. QM: «Do you know who that back in Aug MR. BJ: 919. MR. : dé é t. person MR com tech. MR. would be MR. ae : All right. Were you that prior to th weren’t working? EFTA00111224

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LIMITED ioe) w io ioe) its) OFFICIAL USE N lo ae : I know him. you know what his been that role communication with MR. MR. housed within the MR. about something but upervisor of a unit a : What unit team at the not sure. Did you have any stein with a: Like what? Ee : Just with him being a: I probably talked to him don’t recall nothing EFTA00111225

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LIMITED ies) w co ive) oO co OFFICIAL USE 2 wo MR. a: No communication like that. MR. a : Did you ever provide him with any nstructions with wu Not that I recall. MR. QJ: = No?) «What about -? Did you ever communicate with fs regard =>d in the § rounds being cond MR. QJ: 9 Not that I recall. MR. a : Are you aware that | allowed Epstein tor call on the a teleph rening of Augi MR. QJ: «wm. sf think I heard something about that. I don’t know was it | though. MR. SR: 30? MR. a : I just heard something. I call though. know anything about Fd involved with that do you MR. a : All right. What is co EFTA00111226

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LIMITED OFFICIAL USE 2 w ~] ive) Ww 9 understanding of the phone call that took place on August 9th with Epstein’s telephone call? MR. a: It was a regular phone call. MR. a : Did you hear that it was made in the shower area? vR. BJ: No. MR. a : Have you ever heard of telephone calls being made in the shower area? MR. a: In the shower area? Yeah. MR. a : And what’s the purpose of that? MR. a: The cord can’t reach. And I’ll say we got him (Indiscernible *03:02:16) hey I’m going to give you a phone right now while I’m -0 while you’re right there. I don’t have to pull you out and it’s like a time consuming method. MR. a : 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. ae : Okay. So would there be any reason to provide someone with a legal line that’s not recorded? MR. GR: No. EFTA00111227

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LIMITED OFFICIAL USE 240 2 MR. a: Would there a be a reason? a : Yeah. ies) i w 3) if they provided shower area for a w ored line? co a MR. a: You mean an unmor wo i=) ive) 3 MR. a: Yeah. Unless you didn’t know 4 which one it is. 5 MR. a : And if they did know that 16 they gave him a legal line, that was an 7 unmonitored line, should someone have monitored 8 that call? 9 MR. a : You can’t though. You said 20 it was unmonitored. 21 MR. SJ: vo 22 and listen to the call. Oh you mean like - I mean the time. I think they could 25 you know they let =m call their legal EFTA00111228

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LIMITED OFFICIAL USE 241 1 attorneys. And yeah, they do that. 2 MR. QM: Okay. And if they didn’t do that. 4 MR. ae: I don’t know if it’s a violation. HE: Bight. 7 MR. ae: But it’s 8 MR. a : Yeah. So let’s say if ies) w Oo a n 9 the captain even authorized it. Yeah, give him 10 his phone call. Just make sure you monitor it 11 and log it. MR. ae: No. a : They didn’t monitor it. it. Would that be a problem? 5 MR. a: The captain telling me. N Fs) ive) a) oO 7 MR. ae : All right. Did you ever that practice taking place in the past? a : Unmonitored calls? 20 MR. QJ: Yeah. Or like letting 21 somebody in the SHU have a phone call on an Les] a uy ow K is) Fh wo 5 22 unmonitored line, walking away, letting that 23 person talk? 24 MR. a : No. Now from an officer’s standpoint? EFTA00111229

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LIMITED OFFICIAL USE 242 1 MR. QJ: | Yeah. 3 MR. a : You never seen that 4 before? Or heard about it? 5 MR. a: Officers. No. 6 MR. a : Okay. What is the policy 7 for inmates making a calls from the SHU? 8 MR. a: Mm. I do know they could get 9 - they got to come - there’s a (Indiscernible 10 *03:04:12) in SHU that everyone has a line. A 11 compassionate phone line. And they get with 2 the chaplain they can make a phone call. Like 3 say that they might you only get one call every 4 30 days. So chaplain say hey, give this guy a 15 call. They come up. They bring him. They let 16 him use the compassionate phone. 7 MR. ae : And when you say -. 8 MR. a : And that’s about it. 9 MR. Ee : What’s a compassionate 20 phone? 21 MR. ae: Yeah. It’s like something 22 they have a death in the family or something 23 like that 24 MR. a : But is that a monitored 25 call? EFTA00111230

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LIMITED OFFICIAL USE 243 think so. But I mean It’s monitored 2 3 yeah It’s monitored. 4 So anybody in the staff 5 It’s either a monitored line or staff is with 6 them Is that correct J Ps) Hi fh b- ct i) 3 12) 3 Pp ct 12] a] i) a b- =] ct 7 0) Mn is G oO id K oO wu J i=) a a : So when I say monitored, 11 I mean it’s either a recorded line -. MR. ae: Or you right there. -- or you’re right there. N Fs ive) Fs) 5 ne 16 yr 7 a non-recorded line? 8 MR. a : Mm. I mean probably like an 9 emergency or something. 20 22 23 24 would actually have the 25 ability to do either a recorded line or a non- EFTA00111231

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LIMITED OFFICIAL USE 244 1 recorded line? Ww a a! a oO H @ Kh bh Q a t 3 0) x ct t Oo Yeah. 6 MR. a : Yeah. Okay. What about 7 - what’s the MCC poli w a H ct fs wu Ww. w 0 nv conducting searches co 3 in the SHU? Cell searches. oO a You have to search the cell. 10 MR. a : Do you know about tt em Ww 5 ? 0 wu a 4 MR. a: Like what? 5 MR. a : Like for instance here’s on August f foal c 0) bh bh n oO wu iad O a nal iad 3) 3 7 9th. It’s one 12:36 p.m. during the day by a . It’s 9 the only cell search that was conducted on onducted H rt = fu o) ie] co wu rt 21 MR. QJ: on. 22 MR. ae : Is that weird for you? 23 That you would see only one cell search 24 conducted on a day? 25 MR. QJ: 9 Meh. EFTA00111232

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LIMITED OFFICIAL USE 245 Ww ee K o wu J 4 MR. a : How many are th 5 6 7 And is it at least five 8 wo Ww 15 MR. a : Is that including the 16 morning watch? 17 MR. GR: 9 No. 18 MR. a : So day watch and -? MR. a: Do area 20 watch. its) on morning ae : So your understanding is 22 that on day watch and on night watch it’s d to be five per shift? 25 MR. a : And are you aware if th EFTA00111233

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LIMITED OFFICIAL USE 246 1 weren’t doing that? 2 MR. SJ: «vn. ies) a 07) Or is this what you were 4 saying before? An abnormal day? I mean I don’t know. I w a oO wasn’t aware that they wasn’t doing it. No. 7 MR. a : Okay. Um and is there 8 any responsibility 2 of the ops or activities’ 9 lieutenant overseeing to make sure that these 10 cell searches are being conducted? Ww N Od K wu oa . H om oO ta] 0] i 0] 4 MR. ae : And what is that t oO a MR. ae: I mean pretty much we check every 30 days. They’ve got to be done. t 0 K A fos) ie] o bt bt n = Oo ie] Oo n o o to eb searched every 30 days. So 20 MR. QJ: Every cell in there is 21 supposed to be searched every 30 da 22 MR. a: The whole unit yeah. 23 MR. a : Okay. And that’s where the ops lieutenant and activities’ lieutenant ho No w EFTA00111234

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LIMITED OFFICIAL USE 247 1 MR. a: Any lieutenant. 2 MR. a : Any lieutenant. It’s everybody’s ies) a wi ig wn is) bet Q Cc oO un 77) = o wu rt H 3 lieutenant in there. As the activities’ 8 lieutenant or the ops lieutenant on any of the 9 watches. Should have they been like making i=) were doing their job? 11 MR. a: Mm. I’m not sure. 2 MR. a : You’re not sure? 3 MR. QJ: 9 Yeah. 4 MR. a: Because I mean that’s in 5 TruScope. It’s like you’re not checking at that time -- 7 MR. ae : Yeah-yeah-yeah. You know. t a WJ K c w Qa is] ue] oO Lee) 5 -- anyway} 9 MR. Ee : And during your rounds -- 21 the cells - the cameras probably show the cells 22 being checked. I’m quite sure. They just 23 didn’t log them. No id ed an bt KR b Q 5 ct U fe kK is) =] ct a Pp Ss tan No w ct S ou t ct y o he kK @ wu a ct c fu bh bh het w M fu i is] a P- Ss Q ct a oO 3 EFTA00111235

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LIMITED ies) w oO wo i=) N ive) oO co wo No Nm No ion) OFFICIAL USE N o MR. a: They got to. MR. a : And not locking it? MR. ae : You got to hey, get out. You’ re doing a feed and cuff up, showers, you come out and yeah. So they not locked. MR. a : But would it be surprising to you to hear that there was a lot of extra linens and clothing and all that kind of stuff in the SHU? MR. a: That’s not surprising. MR. Ee : So if they’re doing cell searches, wouldn’t they take that stuff out and tai keep them with the -? MR. a: I suppose so. Yeah. MR. QJ: 4.11 right. But you believe that they were actually conducting the MR. a : I’m quite sure. More than conducted. 12) 3 oO = wu ia ie] MR. ae : SO you think it was just - this is all they logged but they probably did more? MR. ae: Yes. EFTA00111236

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LIMITED OFFICIAL USE 249 ioe) w io ioe) No e ° wo i) b ho y- All right. Do you authorized to MR. ae: Pillows? MR. a : Pills. Like medication. MR. a : Should have he been allowed medication in his cell? MR. a: I mean MR. a : Is there ever a problem with like OD-ing or anything like that? MR. a: I mean if it’s - depending on the medication, medical MR. a : All right. And so EFTA00111237

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LIMITED ies) w oO wo i=) N ive) oO co wo No Nm No ion) OFFICIAL USE 250 and that’s not abnormal for them to have their A own pill bottles and things like that in the MR. a : What can an inmate have in their cell in the MR. BJ: -s towel, depending on what season too. Blankets, 1irt, boxes, washcloth, a blankets and two sheets? MR. ae: Depending on the weather. MR. a : Okay. MR. a: And how much is available. MR. a : What about in August? How many blankets and sheets could have they MR. a : How many they could have? MR. Ee : Or are they allowed to have? them -. It depends. It they say hey, let them keep it, two and two, let them keep it. MR. : I say hey, you need to - you > tf + 2 EFTA00111238

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LIMITED ies) w co ive) oO co OFFICIAL USE 251 know. They go down to one. MR. a : Would it be ever authorized to have more than two of each? MR. ae: How many? Like an extra blanket or something? or four blankets. MR. a: I don’t know about four, but an extra blanket I heard tt! rtime MR. Ee : What about in August? MR. ae: An extra blanket? MR. a : Or extra linens. pending on the cells. MR. a : Yeah. What about extra MR. a: I mean it wouldn’t be MR. a : They do that? EFTA00111239

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LIMITED OFFICIAL USE 252 1 MR. a: Yeah. They fish. 2 MR. a : All right. And would be caught on the cell search if they were Ww ct + fy rt 4 being conducted though? 5 MR. QJ: 9 Not all the time. a : And how would they miss co a3 EFTA00111240

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LIMITED OFFICIAL USE 2 ow ios) 2 MR. a : All right. Do you know 3 if Epstein was given any special privileges to 4 have extra clothing or extra linens? No. fon) w a a No? Do you know if he had extra clothing or extra linens? No. wo co OD Who was making sure that i=) Epstein had the correct amount of clothing and 11 linens? 2 MR. QJ: «Not sure. Would it be like the SHU ive) Fs) 4 staff or the lieutenant or all of the above? 15 The SHU lieutenant? t oO a ae: I’m not sure. 7 MR. ae : Working in the SHU 8 though, or previously, you don’t know who would 3 -? 20 MR. QJ: §9=who is mentoring it? I mean. 21 MR. ae : Like who would be - who’s 22 responsible? Not let - sounds like - 23 like no one was monitoring it but who was 24 actually responsible to make sure him and these 25 guys aren’t supposed to have that many - that EFTA00111241

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LIMITED ies) w oO wo i=) N ive) oO co wo No Nm No ion) OFFICIAL USE 254 much clothing or linen. MR. SE: we used to do linen, you give me three, I give I’m not sure. Because when That’s how we used to monitor it. like a one-for-one exchange. MR. ae: Yeah. responsible to keep an eye on his things you three. if) ed to be or) suppo So I don’t know who’s I uh -. a) Typically who provides inmates with eir linens? taff. Do lieutenants ever do No. Not really. 5 mM So it would be the staff that’s responsible then huh? MR. a : Yeah. That’s why I say (Indiscernible *03:12:15) responsibility I guess Okay. Does the SHU lieutenant ever do it? I mean, it could. I could if I want to. MR. : Yeah. But typically it EFTA00111242

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LIMITED OFFICIAL USE 2 w ~] wo 10 11 uw w would be the SHU staff? MR. QJ: 39 Yeah. 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. a : 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. a : Where 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 was general population. MR. a : All right. So people EFTA00111243

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LIMITED ies) w co wo ive) oO co OFFICIAL USE 256 that tell us that he was in the SHU the entire First got through, he And for how long was he in general population? MR. ae: Say about a day or two. And are you the one that actually moved him into the SHU? MR. QJ: 9 Who did that? I don’t know. All right. But an officer reported it to you? And then you -? MR. ae: Yeah. I know he was in general population. MR. ae : And what did you do with the information when that was told? MR. Ee : You said an officer said MR. a : I wanted to know I what’s going on. I said alright, we going to EFTA00111244

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LIMITED OFFICIAL USE 2 w x) 1 look into this. And then they moved him. 2 MR. a : Okay. 4 MR. a : But I guess my question ies) 5 was did you report that information to someone? 6 And then it was - a person? 7 MR. a : I don’t remember. I know I 8 passed it on. I said hey, this guy, I think 9 he’s high profile. 10 MR. QJ: okay. 11 MR. a: Look into it I think by the 2 captain or someone got together and they moved 3 him. Put him in place in the SHU. 4 MR. ae : Okay. And when was the last time you interacted with Epstein? 16 MR. ae: I can’t recall. 7 MR. ae : Did you have any w 8 interactions with him on August 9th? 9 MR. a : I could have. I don’t know. 20 He’s right there on the floor. So I could 21 have. 22 MR. ae : But you don’t know. So 23 again, dude dies the next day. You can’t 24 remember if the day before you talked with this 25 guy when it’s like the biggest case ever? EFTA00111245

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LIMITED OFFICIAL USE 2 1 MR. a: yeah. 2 MR. a : You don’t remember? uw o 3 MR. ae : Uh-huh. ‘Cause I brung him 4 up to SHU a few times. But I don’t know if I 5 did that day. 6 MR. a : I’m just saying that kind 7 of sparks a little suspicion if -- 8 MR. a: I know what you’re saying. 9 MR. QJ: -- it's like - if it’s 10 like you can’t even remember the last - if you 11 talked to him on that day - the day before. 2 MR. ae: I mean it’s a big case. I 3 get that. But I mean, you know, I have a job 4 like you know? 15 MR. a : Yeah-yeah. I mean, I’m 16 just saying that that’s going to create a 7 little -. 8 MR. a : Yeah but I cannot remember if 9 I spoke to that dude that day. 20 MR. QJ: | Dos you remember when was 21 the last time you saw him? 22 MR. a: No. I’m probably assuming 23 that day. If he was in attorney conference. 24 MR. a : Um. And is that because 25 you would have visited attorney conference? EFTA00111246

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LIMITED OFFICIAL USE 259 1 MR. a: Yeah. The elevator is right 2 there. I’m on the third floor here. Attorney 3 conference is there. If I wait right here in 4 the elevator, I see him. He’s in the same room 5 every day. 6 MR. a : But you can’t remember if 7 you actually spoke with him on that day? 8 MR. GJ: No. 9 MR. a : Would you typically speak 10 with him when he was in attorney conference? 11 MR. a: The only time I used to speak 2 to him is if they say hey, you can bring this. 3 Hey, you going to SHU? Can you take him up? 4 All right. Come on. 15 MR. QM: 4.11 right. 16 MR. ae: Can I ask a question on that? 7 MR. ae : Yes. Please do. 8 MR. a : Just in case, I mean I know 9 you said you don’t remember, but that’s his 20 last day. That’s the last time you saw him. 21 Do you remember who he was with that day? 22 MR. a: His lawyers. 23 MR. a: Do you remember 24 ve. ER: «on. 25 MR. ae: Was he upset? Was he demeanor? EFTA00111247

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LIMITED OFFICIAL USE 2 w ~] wo 10 11 oO’ oO yelling? Did he complain about anything? MR. a: He used to sleep a lot. That’s all I know. Sometimes you see him in there, he’s just laying on the table. His lawyer is right there. MR. QJ: 9 while he’s with his attorneys? MR. a: He was there -. He used to be there from 8 from in the morning time all the way to day watch and evening watch. MR. Ee : Around what time would he show up there? MR. a: Early. He’d be the first one MR. a : And what time would that be? MR. QJ: 98:00, 8:30. MR. a : And then what time would he typically go back to the SHU? MR. QJ: 9 Before - or attorney conference over at 8:00. So about 8:00. MR. ae : So basically 8:00 a.m. to 8:00 p.m.? And who were the people that would take him to attorney conference and then take him back to the SHU? EFTA00111248

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LIMITED OFFICIAL USE 261 1 MR. a: I told you. Like I said, 2 I’ve done it sometimes. ies) a Yeah. 4 MR. ae: But typically, hey get the &D's uw es) guy ready in SHU. Bring him down. If 6 out there, y we got to move him. You know. 7 I’1l take him down. Oo oo OD Ey | a 5 s going that way. 10 MR. a : Did you take him either 1 there to attorney conference or back to the SHU 5) 3 don’t think so. I can’t Ww 5 he 4 recall 5 16 at Lee) 5 And what time do you 9 believe that you left MCC on August 9th? Sometime between 2:00 and But you weren’t back? So 25 he was in attorney conference all that time. EFTA00111249

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LIMITED OFFICIAL USE 262 1 So the l fu st time you possibly could have 2 interacted with him would have been around 8:00 Correct? 4 MR. ae: I mean interacting like Ww wu =} w ct fw bh bp. 5 QQ ct J pe 3 6 MR. a : Speaking with him. 7 MR. ae: Yeah. But I don’t think I - 8 I can’t recall if I spoke -. I don’t think I ts) n ue] 2) tal o + 12] a t 5 wo i=] ct | | 10 MR. a : Yeah-yeah-yeah. 11 MR. a: -- I’m not sure if I did or I Nm en Pp: oF a rt ive) Fs) les Okay. ut -. u 4 MR. a: The last time would have been 5 I mean -. Yeah. If I stepped into attorr oO conference and said something. But -. I don’t recall that. Lee) 5 wo a But you don’t recall what 20 his demeanor was? Or state of mind? 22 MR. ae : Yeah. Um you just hing where he was worried No WwW 3 ‘) = rt p. oO =] o a ct ia o ie) o o rt EFTA00111250

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LIMITED OFFICIAL USE 2 w ~] is) Ww 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. a : 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. Ee : 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. MR. a : So he didn’t want to be on suicide watch? EFTA00111251

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LIMITED OFFICIAL USE 264 2 MR. a : Is that what you’re Ww n wu 3 Q 4 MR. ae: No. He didn’t want to. So he wanted to go back wi aw 6 to the SHU? 7 MR. ae: Well he wanted to go -. oO id 0 18) you know if he wanted he want to be ir wu MR. ae: I don’t know. Did he ever tell that to N Fs ive) Fs) Do you ever -? Do you t oO a 7 believe that he was in the correct place in the 8 SHU? Or do you believe he should have been on 9 like 10 South or G Tier? 20 MR. a: I mean he can’t be in G Tier. 21 Can’t be in 10 South. He got to have a Bunkie, 22 right? 23 MR. a : Well. I guess. It 24 depends on -. Do you know what the reas 25 he would need a Bunkie? EFTA00111252

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LIMITED ies) w oO wo i=) N ive) oO co wo No N N ion) OFFICIAL USE are or 10 MR. in 10 What’s their -? Tier? Like have them gets - just MR. the - 0 South, South is on the cameras some cameras a: His su suicide attempt so they hav BM: om. I ho Wh who goes -- a. a. ae: there, r Single Single Ye in like 10 feah b e wu in Do been in a ce No. some of icide attempt. you ever put people s or hotlist in G Tier e extra eyes them? on don’t think. No one tlist. I don’t recall. at about G Tier? hat’s the deal with G cells. in there? cells. But ah-yeah-yeah. they one of 13] ight? very South bi | J =i rt | ut uh 9 South those. Psych you believe Epstein ll with a camera in it? yeah, if you have to the cameras is single EFTA00111253

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LIMITED OFFICIAL USE 2 w ~] wo 10 11 ) fon 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. a : 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. QJ: = How? MR. QJ: On the cameras I don’t know. MR. EJ: No. MR. a : SO they’re not actually being monitored? MR. a : They can’t watch. No one can EFTA00111254

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LIMITED ies) w oO wo i=) N ive) oO co wo No Nm No ion) OFFICIAL USE 267 watch time. No. Okay. So you think that it would have been just as risky or if not more y with him being in G Tier or 10 South? Okay. Fair enough. Do you know why Epstein was in prison? Why? And did you have any MR. QR: No. How often would you MR. a : Uh whenever I needed to. All right. Any kind of conversation that had any substance to it? substantive conversation? Anything that was like more than just like below? not work at all on August Nah. and you said you did anehH- 20th? EFTA00111255

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LIMITED ies) w co ive) oO co OFFICIAL USE MR. Saturday? MR. early as 2:¢ wa —: : a: by the y gone Aug is) t is] on us I th Mm. Saturday. MR. MR. He ae: a: Sunday. I Satu thi I me died on Saturday, Yeah. sn’t there. And then were you n - from the h? ink so yeah. And you may p.m. you just When wa next you That happened on wh: found on a right? Yeah-yeah-yeah. rday. I don’t know if I nk came in Sunday. Okay. And did you at k with anybody about an I knew about it. EFTA00111256

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LIMITED OFFICIAL USE N a wo talking about it. 2 MR. a : Yeah-yeah-yeah. So what WwW i] & 5 c a] c a o o K it ct =] Qo Pp o Q fu oO oO c rt oy Oo = a o jon p. oO on MR. a : Do you know anything life? w 6 about anyone else taking hi n 8 MR. a : No? Do you know anything 9 about anyone assisting with taking his life? 10 MR. QJ: =Nah. 1 MR. Ee : No. Do you believe that 2 Epstein took his own life? a: Yes. 4 MR. ae : Do you believe that acted alone in taking his own life? ae: Yes. 7 MR. ae : All right. Then there’s only three more questions here. They’re more ive) a) t oO a co 9 open-ended. What do you believe would have 20 prevented Epstein from dying? 21 MR. QJ: «9 Nothing. 22 MR. ae : Nothing? Do you think 23 that if he was - wanted to take his life he 24 would have done it? 25 MR. ae: If it was a regular inmate, I EFTA00111257

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LIMITED OFFICIAL USE 2 w ~] wo 10 11 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. He man, you’re right. MR. QJ: 9 Yeah. MR. ae : 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. QJ: | nd 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 not. If I have the notice he had up until that time and left for one day. Then this happens. ~) oO EFTA00111258

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LIMITED OFFICIAL USE 271 10 11 12 13 14 16 17 18 19 20 21 22 23 24 I can’t blame lieutenant, staff, notifications. You know. Remember there’s like 900 inmates in there. 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 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. MR. a: Because -. EFTA00111259

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LIMITED OFFICIAL USE 10 11 12 13 14 16 18 19 20 21 22 23 24 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. QJ: «t's a judgment call. MR. a : And I’m not talking about at 8:00 a.m. I’m saying like what you just said -- MR. a: I want to say we can’t (Indiscernible *03:24:48) notice. MR. QJ: | -— 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 got to make sure he’s got a cellmate. MR. a: Yeah. Yeah but what if I 272 EFTA00111260

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LIMITED ies) w co ioe) co OFFICIAL USE guys one right. I MR. talking i time got -. T not now talking a Remember these gi don’t even - vening watch wasn’t even sure it was I know | -- a : Well no, I’m not talking t was overtime. nk worked -. Yeah-yeah-yeah. I’m But if I’m the OIC. I think JJ and nx even wasn’t no more. He Noe ova So we're alking about morning watch. re saying EFTA00111261

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LIMITED OFFICIAL USE 274 1 MR. QJ: 9 Yeah. 2 MR. a : So that’s evening watch. 3 So we’re looking at -. Where are we looking 4 at 5 MR. QJ: So if I know - if I’m 6 notified by 8:00. And I call the captain. hey, this guy don’t -. What’s my next move co then? Throw him in there with wo a Yeah, so 2 MR. a : So yeah, I guess-. can see them saying Ww Fs) H 3 oO i a ' 4 - whoever said that. Because they say hey, 15 kick it up 7 MR. a: You know. Kick it up. Kick 8 the blame up top. Now if I’m on, what do you 9 want me to do? Throw the guy in there with 20 anybody? Just because he have to have a 21 cellmate? 22 MR. ae : Well some people have 23 said that at the very least they would have put 24 him on like a dry cell type of a situation 25 where you've got a staff member on him until he EFTA00111262

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LIMITED OFFICIAL USE 27 w ~] wo 10 11 ive) ~) wi can get placed with a cellmate. MR. a: Yeah. But that’s a questionable move too. MR. : on. MR. a: You want me to take him and put him on - you know? MR. a : So you believe - so I guess. What is your belief then? 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. a : But don’t -? MR. a: Uh yeah. MR. a : -- do you believe though as a correctional officer it’s the it) responsibility to ensure that we ensure that they don’t die in our custody? MR. a: Well that’s what the rounds 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 count. i) Not necessarily the cellmate but the rounds and the counts. MR. a : Well in SHU, you required to EFTA00111263

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LIMITED ies) w oO wo i=) N ive) oO co wo No N N ion) OFFICIAL USE N J C do it. MR. QM: Richt. MR. ae : You have to do it. It’s for e MR. a : And if they’re not doing the rounds - the 30-minute rounds - that’s MR. a: That’s a bad situation. MR. Ee : So you blame it on the rounds way more than you would blame it on the a 4 S ou rt to a rr j D The cellmate, he MR. a: You know I mean that happened. It’s the same thing. I understand they sent out the notification. There’s no time for any more than that. MR. ae : Yeah-yeah-yeah. MR. a: Is an inmate goes hey, you know, by the way, tt was on - you sent this out a month ago. He’s not suicidal no more. He said it. It’s like you know. EFTA00111264

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LIMITED OFFICIAL USE 277 1 MR. Ee : Well in this case I think 2 it was like 9 days. But yeah. 3 MR. ae : Yeah. But there’s still no 4 timeframe. Some guys say they suicidal just to 5 get out of SHU and play the game. Go back in. 6 MR. QJ: | Right. 7 MR. a : But it’s never saying hey 8 this guy is not. There’s no memo saying he 9 does need a cellmate. 10 MR. a : Would you agree though 11 that it’s both? The fact that the was require 2 to have a cellmate and they weren’t conducting 3 rounds? 15 MR a : And that’s where - when I 16 talk about the problems 7 MR. a: The thing is, that happened, 8 but it’s - that can happen. Hey oh. His 9 Bunkie left. I didn’t put a cellmate. That 20 can happen. No N 5 Right. No N 5 You know. That can happen No ry 5 Right. No w bd You get inmates that was EFTA00111265

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LIMITED OFFICIAL USE 1 crying on level two. Hey, got to have a 2 cellmate. You moved him? Yeah. Oh you ain’t 3 check? Oh you know. 4 MR. QJ: Yeah. «So I think what I 5 understand you saying is that the primary issue 6 is not doing rounds. Secondary and a much 7 lesser issue was that they didn’t fill up his 8 cellmate. Is that correct? 9 MR. QJ: 9 Yeah. Okay. 11 other problems or violations 2 the MCC that we should be made 3 MR. ER: or. 4 MR ae : We’re ta 15 mcc. Violations? 16 MR. SE: Anything And are there any occurring inside aware of? lking about the that we should 8 have known about that you think needs to be 9 fixed. 20 MR. QJ: 9 You got mandated. I know 21 that. You’re working. 22 MR. ae : So there’s - is what 23 you’re saying then that they’re severely They was. I don’t know how EFTA00111266

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LIMITED OFFICIAL USE 27 wo 1 it is now. Buy they was. 2 MR. a : And again when did you WwW t i) w 0) rt a @ 4K i) w 5 vu © a m 3 om 0 RR ° Fh N Oo bar wo Hed ct oO that point they were still extremely over -? 7 MR. a : Extremely. 8 MR. a : What about - was there 9 anything that was being fixed ever since when 10 Epstein died and August of 2019. Did you see 11 anything being fixed by that point? 2 MR. ae: Uh. They did change the log. 3 I know that. 4 MR. ae : What does that mean? They started putting inmates t wi a 16 that go to court. Just in case. We started 7 doing them and started attaching the PP38 to 8 the log. 9 MR Ee : So they would almost be 20 part of the outcount? 21 MR. ae: No. You could see. You 22 could see all the movement. 23 MR. a : Okay. 24 MR. a : You know. You could see all 25 the movement. They started single cell memos. EFTA00111267

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LIMITED OFFICIAL USE 280 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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. QJ: 3 mean that’s -. Yeah. That’s been a problem for a while. It wasn’t like that when I first got there though. MR. ae : 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. MR. a : Yeah. MR. a: It’s not easy. I’11 tell you that. EFTA00111268

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LIMITED ies) w oO wo i=) N ive) oO co wo No Nm No ion) Ee : What it makes it so ae : You’ve got some unruly ae: You got a lot of unruly You doing some long hours. a : Are they doing long hours though because it’s understaffed? i] I mean. So it sounds to me, I mean an outsider’s perspective. Is that they need a lot more They need that s there a way for us to y get employees but get good employees? What would be a solution there? to recruit. HM: «=f smean you a : I mean it takes some people You know. Say hey, you can make this EFTA00111269

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LIMITED OFFICIAL USE 10 11 12 13 14 16 18 19 20 21 22 23 24 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. a : 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 (Indiscernible *03:32:28) problem there. 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. MR. a: Yeah. But I think they have um credits. I think they change it for 282 EFTA00111270

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LIMITED OFFICIAL USE 2 oo ios) 2 MR. a : Yeah. Some people have 3 said some college. 4 5 That we’ve talked to that 6 they 7 I think - 8 MR. a : I don’t think I’ve talked 9 to anybody that said they didn’t have any 10 college. But I mean I think it was like a 11 couple credits. You know. 2 MR. ae: Yeah. But I mean some people 3 without college, it’s one opportunity to say 4 hey, you can make $60,000 your first year. I 15 just need you to show up and work. 7 MR. a: Follow the rules. You know. 8 And the credit check I think was getting a lot 9 of people. 20 MR. QJ: «sts that right? 21 MR. ae: Yeah. Credit checks. I 22 think that’s what weeds out a lot of people. 23 MR. a : Now do you believe though 24 - on that note - if we’re not doing credit 25 checks, we’re letting that slide. Wouldn’t EFTA00111271

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LIMITED OFFICIAL USE 284 ~] wo 10 11 that breed a potential problem with introduction of contraband and being paid you know for brining things in? MR. ae: Bribery and stuff? MR. a : Yeah. Because that’s big problem in the BOP. MR. a : Yeah. But I think that’ I mean you’ve got some people in there I mean. A w is] I That don’t work. That don’t. no. you could be. I seen people get arrested with good credit. MR. QR: | Right. MR. a: Six figures - making six MR. ae : Okay. MR. a : I’m not saying take everyone But you know. MR. QJ: Yeah. MR. ae: It’s like if you renting to somebody and you a landlord. And you say alright, I know you ain’t got the top score, but I see you pay your bills on time. You had a little student loan debt here or whatever. EFTA00111272

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LIMITED OFFICIAL USE 285 1 I’ll give you a shot. 2 MR. QM: Yeah. 3 MR. ae : You know. 4 MR. a : What have you got? 5 MR. a: You mentioned that you saw 6 Epstein in the conference room. 7 MR. a : Attorney conference. Yeah. 8 MR. a: And sometimes he was 9 sleeping. 10 MR. a: It looked like he was 11 sleeping. ie would lay down on the table like 2 that. 3 MR. a: Is that normal for inmates to 4 be sleep in the conference room? 15 MR. a: To sleep? No. that’s not 16 normal. Most guys trying to get out. Saying 7 hey, you need to do this and do that. 8 MR. a : Did anyone ever tell him to 9 wake up or address it? 20 MR. QJ: 91 don’t think so. 21 MR. ae: The reason I ask is like was 22 that a privilege that was allowed to Epstein? 23 To do that? 24 MR. a : No. It wasn’t a privilege. 25 I think the being that he was there from early EFTA00111273

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LIMITED OFFICIAL USE 286 w ~] in the morning to whatever time. The lawyers probably like alright, let’s look over this. And he probably laying, and I’1l wait until y'all finished. And then alright, let’s go But he also gets to buy out the vending machine too. At first. MR. a: The vending machine? MR. a: Yeah. He used to get all his snacks. MR. a : Yeah. Because you weren’t allowed to give him food in there right? MR. a: In the SHU? You got food. MR. QJ: Not in suv. MR. a: In attorney -. MR. a : Attorney conference. I was told that he basically had to get his own food from the vending machines. mR. QJ: 9 Yeah. MR. Ee : Was he allowed -? Would people feed him - the BOP food - when he was in attorney conference? Would they bring him a tray? MR. a: Mm. No. I don’t think so. I don’t even think he even at that. I’m not sure. I don’t even know if he even ate the BOP EFTA00111274

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LIMITED OFFICIAL USE 287 ~] wo 10 11 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 ary in SHU. MR. a : No. I’m talking about because 8:00 a.m. to 8:00 p.m. he was always commis i) with attorney conference. MR. a: Yeah. So he used to get drinks and chips - snack food. MR. Ee : 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. J: ae. mR. QJ: 9 Yeah. MR. Ee : 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? MR. a: Uh. I mean yeah . but that wouldn’t be -. That wouldn’t be kind of common. That’s what any legal visit that we 4 EFTA00111275

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LIMITED OFFICIAL USE 288 1 used to do. 2 MR. a : Yeah-yeah-yeah. I’m just 3 saying if he’s 7 days a week not eating - only 4 eating a bag of chips or something from 8:00 5 a.m. to 8:00 p.m., that seems like he’d get a 6 little more hungry than that. 7 MR. a : Yeah. I don’t kr . I don’t know - I don’t recall him getting a tray in co wo there though. 10 MR. a : Yeah-yeah-yeah. No. 11 MR. a: Yeah. I don’t kr 2 MR. a : I don’t know if he was or 3 not That’s why I was asking 4 MR. a: Yeah. But if he comes back 15 from there and they said hey that’s my tray 16 from earlier and if he was in legal visit, we 7 would give it to him. 8 MR. QJ: Right 9 MR. a : I mean that’s common 20 practice 21 MR. ae: Let’s say - once Reyes left 22 that morning. EFTA00111276

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LIMITED OFFICIAL USE 289 1 MR. a: Once he left that morning, I 2 know there’s like a sheet that keeps track of 3 all the inmates in the SHU. Right? They have 4 like a bed count sheet. 5 MR. a: Bed book count. 6 MR. a: Bed book count. Would that ~] book need to be updated? 8 MR. a: That he left? Yeah. 9 MR. a: Whose responsibility would 10 that have been? 11 MR. a: Uh. I don’t know officers. 12 MR. a: So officers should have 13 updated it. Now let’s say they went in 4:00 14 p-m. count. And then 9:00 p.m. count - god 15 forbid there was something off with the count. 16 They would have to pull out eh bed book and 17 verify it. Right? 18 MR. a: If you get two bad counts. 19 MR. a: Two bad counts. 20 MR. BJ: 9 Yeah. 21 MR. a: But if no one updated the 22 book, would that be an issue? 23 MR. a: Well if you get two bad 24 counts, you’ve got to a bed book. And then 25 you’1l find discrepancy. But then again, you EFTA00111277

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LIMITED OFFICIAL USE 230 1 know who usually updates the bed book count? 2 MR. a: The lieutenant? 3 MR. a: Morning watch. Because I’m 4 now - this is the new day - 12:01. 5 MR. a: Okay. 6 MR. a: This person’s not here. Now 7 I know for a fact that this is what I’m 8 starting my day with - for the whole day. 9 MR. a: I was going to show one - the 10 same document. You mentioned that when you 11 were working the SHU around 2:00 a.m. you would 12 have got the court document. Right? The 13 attorney would have brought it up. Or someone 14 would have brought up the document. 15 MR. a: Yeah. It comes up on morning 16 watch. 17 MR. a: If - I mean and we don’t know 18 for sure if that was the same happening. Who 19 would have got that notification at 2:00 a.m. 20 on August 9th? 21 MR. a: About the paperwork? 22 MR. a : About the court documents. 23 MR. QJ: 9oUh probably internal. 24 MR. a: No who in the SHU. Who was 25 in the SHU at that point? Who would have EFTA00111278

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LIMITED OFFICIAL USE 291 1 gotten notified? Hey, listen Reyes is meeting 2 me in the morning. Ww a ca a wu =] jon 4 s 13) =| fw v w 2 wy K oO wu J 6 MR. ae: And let’s say the morning ~] came around. The shift changes and -. Who 8 would have notified um - they got the document? 9 They - Reyes is leaving. 10 MR. QJ: 9 wm-hn. 11 MR. a: Who would have notified 2 control or kept track of the fact that Reyes is 3 walking out of there? 4 MR. a: And again I told you, see if 15 you don’t - it’s not a thought. It’s not 16 coming on my radar until -. 7 MR. a: No. I’m not saying that. 8 But who in the SHU would have been responsible? 9 MR. a : Someone in the SHU like I 20 said evening watch around 8:00. If they’re 21 saying hey, R&D they weren’t back? Make sure 22 our count is right. But um. Yeah. 23 MR. a: That’s it. I just had to 24 clarify that. Thank you. 25 MR. a : But just because Thomas EFTA00111279

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LIMITED ies) w co io ioe) co OFFICIAL USE 292 w ] ion .Q Oo f rt a wp rt a] ion 0) rt P- rt Q a) i) wo 3 ct 3 @ wp 5 that at that time, right? Wouldn’t it shift to get -? Who would have ready to do at 8:30? MR. ae: Well depending on what time. I mean they could do it at MR. a : They being? MR. MR. QM: all right. have been the guys that probably getting to court? I K i) wu 5) At least giving them notice. MR. = Oo = wu if) Oo 5 fo i= Hh a ct ct Oo Q 0) ct vs o fo i) it) cal ) H Hh J o bh 0] Hh ct w 8 Oo P= } . 8) MR. 5) Monge. MR. c= i) rt if) EFTA00111280

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LIMITED w Oo co wo i=) OFFICIAL USE 293 MR. QJ: Okay. «At 6:00 a.m.? MR. a: Yep. I see - wait. So I see he notified his relief is what he’s saying. || was his relief at 2:00. memo. Right? Yeah. According to that I mean yeah. It’s one MR. a : That’s all I got. Okay. Cool. Anything you got (Indiscernible *03:40:03). We had a really long interview here. So I apologize for recorder. EFTA00111281

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LIMITED OFFICIAL USE 294 1 CERTIFICATE that the Oo w Transcriber t fu H QO a es) K wu t t o 5 oO oo EFTA00111282