LIMITED OFFICIAL USE 391 1 : The second one, too. 2 : Okay. 3 : All right. Now, we are 4 going to get into the actual incident. 5 MR. HAYES: Oh my God. Now, 6 (Indiscernible *03:34:06) getting ready to get 7 into. 8 : We don't have much more. 9 I promise. I mean, we are way passed the -- 10 MR. HAYES: Yeah. 11 : -- yeah. What is your 12 understanding of what occurred in Epstein's 13 cell on August 10th, 2019? 14 : I don't know. 15 : You don't know? 16 : I didn't go up there. 17 : Do you -. 18 : I never saw the cell. 19 : Do you believe if -. Do 20 you know if Epstein took his own life? 21 : That's what I've been told. 22 : Is that your 23 understanding of what happened? 24 : That was what was conveyed 25 to me. EFTA00059171

LIMITED OFFICIAL USE 302 1 : Do you have any 2 information, with regard to anyone else taking 3 Epstein's life? 4 : No. 5 : No. Have you heard that 6 Epstein's cell door was left opened on the 7 night of August 9th, 2019, and/or the morning 8 of August 10th, 2019? 9 : I didn't hear that. 10 : You have never heard 11 that? 12 : No. 13 : Have you heard that any 14 cellmate's in the SHU - any cells within the 15 SHU, any of their doors were left opened on the 16 night of August 9th, 2019 in the morning? 17 : I did not hear that. 18 : On August 9th. No? 19 : Hmm-mm. 20 : Do you know if anyone 21 harmed Epstein? 22 : No. I would have reported 23 it. 24 : All right. So, these are 25 the - let's see - this is the Bureau of Prisons EFTA00059172

LIMITED OFFICIAL USE 1 Health Services Clinical Encounter. 2 : Right. 3 : Did you get to review 4 this one at all? 5 : No. 6 : It talks about responding 7 to a body alarm at 6:35 for medical emergency. 8 : I think I might have saw the 9 memorandums, but I don't I don't recall 10 seeing this. 11 : All right. So, let me 12 just read this, for the record -- 13 : Mm-hmm. 14 : -- because it is a very 15 quick one. It says, "Responded to a body alarm 16 at 6:35 for a medical emergency on Nine South. 17 Upon arrival, inmate was received on the floor 18 of his cell, unresponsive, with CPR in progress 19 by correctional officers. The inmate was cold 20 with circumferential bruising around the neck 21 and posterior mottling. Pupils fixed and 22 dilated. No palpus (Phonetic Sp. *03:35:59) 23 pulses, call place for EMS, CPR continued. 24 ED placed. No shock advised. CPR 25 continued. Inmate transported to HSU treatment EFTA00059173

LIMITED OFFICIAL USE 1 room, with CPR in progress. 18G, heplock 2 (Phonetic Sp. *03:36:12)." No. I'm not going 3 to read the rest of this. It just talks about 4 continued CPR in progress. Are you aware, 5 after Epstein was found on August 10th, 2019, 6 at approximately 6:33 a.m., did he ever show 7 any signs of life? 8 : I never -. I wasn't up 9 there. 10 : Yeah. I just didn't know 11 if you had heard -- 12 : No. When I -- 13 : -- (Indiscernible 14 *03:36:34). 15 : -- when I got there, he was 16 already out. 17 : Because they said that, 18 you know, he was declared deceased at the 19 hospital. So, my question is, it sounds like, 20 from this person's report -- 21 MR. HAYES: Yeah. 22 : -- he was -- 23 MR. HAYES: Right. 24 : -- there was no signs of 25 life. EFTA00059174

LIMITED OFFICIAL USE 1 2 305 : And that's -- : And I was just wondering, 3 had you heard anything from staff? Was there 4 ever any signs of life, that you are aware of, 5 while after - from the point he was found, on. 6 : Well, the impression that : 7 was given was, he was alive when he left the 8 institution. 9 : So, you believed he was 10 actually alive? 11 : That's what was conveyed. 12 : It was conveyed to you 13 that -? 14 : I think he was still alive, 15 if I remember right. I think he was -. They 16 did the CPR. And then, they got him out. 17 : And who -. So, according 18 to this, again, this person arrived at 6:35 -- 19 : Mm-hmm. 20 : -- they're saying the 21 inmate was cold. You know, "Pupils fixed and 22 dilated. No palpus pulses." Meaning, I'm 23 assuming, that means no pulse. You know? 24 : So, you would probably have 25 to look at the response, the staff responding EFTA00059175

LIMITED OFFICIAL USE 306 1 memorandums on what -. 2 : So, up until this date, 3 did you think that he was alive when he had 4 left the institution? 5 : That's what I believed. 6 That was the impression I had. 7 MR. HAYES: Can I ask a question? Right. 8 If he was dead when they came, and somebody 9 found him, or even if he was close to death, 10 how long would it have been that he tried to 11 kill himself, and the time that they found him? 12 In other words, does that mean he tried to kill 13 himself 45 minutes before? Does that mean he 14 tried to kill himself 30 minutes before? You 15 understand the question I'm asking? 16 : Sure. I mean, that is 17 something that the medical examiner, you know, 18 makes that determination. 19 MR. HAYES: Because obviously, if he was, 20 had done whatever he did, during the time that 21 there was supposed to be a round, and somebody 22 fucked up, you know what I mean? If you are 23 there, with a towel around your throat, that's 24 a hint that you are not exactly in the best of 25 moods. EFTA00059176

LIMITED OFFICIAL USE 1 2 197 : Mm-hmm. : But the other thing is, you 3 know, I don't know, like you just said, the 4 medical examiner determines, you know, if he's 5 alive or -. 6 : Well, and that was going 7 to become my follow up. First of all, who - 8 this person. It says provider, Joseph Columbo, 9 RN. Is that someone who worked at -? 10 : He was one of the nurses 11 that worked. 12 MR. HAYES: Mm-hmm. 13 : All right. And is it 14 your understanding, by saying provider, this is 15 the person who wrote this report? 16 : Yeah. Typically, who has 17 the encounter fills it, writes it in the 18 system. 19 : Okay. So, up until me 20 reading these out, you actually were under the 21 assumption that he was alive? 22 : Yeah. 23 : When he left. 24 : I thought he was alive. 25 Yeah. That was my assumption. EFTA00059177

LIMITED OFFICIAL USE 308 1 : Okay. Does that have 2 anything to do with the fact that the medical 3 examiner is the only one who can declare him 4 dead? 5 : It does, too. 6 : All right. And also -- 7 : Yeah. 8 : I have heard that 9 inmates don't die at prisons. 10 : Well, I mean, people say 11 that, but again, in reality, we - no one in the 12 prison can declare an inmate dead. 13 : Right, right, right. 14 : Even if -. 15 : But is that what you mean 16 by that statement, though? Did you -. I mean, 17 had you heard that he showed signs from life? 18 : From what -- 19 : Because we have heard 20 this -- 21 : -- from -- 22 : -- type of thing -- 23 yeah, from what I 24 : -- before. 25 hear, they were still EFTA00059178

LIMITED OFFICIAL USE 309 1 performing life-saving measures on him, even 2 when, from - what do you call it? - EMS coming 3 in there. So, when you say to me that we are 4 performing life-saving measures, I'm assuming 5 that he is still alive. 6 : Right. Like, there is -- 7 : so -. 8 : -- always a chance you 9 could bring him back. 10 : That, you know -- 11 : Or you are hoping that 12 you are going to resuscitate him. But do you 13 know of any indication of -- 14 MR. HAYES: That he was successful -- 15 : -- signs of life? 16 MR. HAYES: -- yeah. 17 : I didn't. Again, I'm going 18 off of, assuming that he was still alive 19 because they were still working on him. 20 : Okay. 21 : So, and if somebody start, 22 now, I've been in situations where the 23 paramedics come in, and, you know, they work on 24 them, and they say, you know what? There is 25 nothing else we can do. He still hasn't been EFTA00059179

LIMITED OFFICIAL USE 310 1 declared dead. 2 : Sure. 3 : But they still -. 4 MR. HAYES: Right. 5 : But from what I gather, they 6 were still working on them. 7 MR. HAYES: When you say nobody dies in 8 prison, you are being facetious? 9 : It's just one of those 10 things that -- 11 MR. HAYES: Yeah. It doesn't -. 12 : -- it happens at the -- 13 MR. HAYES: Yeah. 14 : -- at the hospital. 15 MR. HAYES: Yeah. 16 : Mm-hmm. 17 : That's where they are 18 declared dead. 19 MR. HAYES: Yeah. 20 : Mm-hmm. 21 MR. HAYES: Right. Okay. 22 : And that's not, you know, 23 necessarily true. I mean, it's where you are 24 like, sometimes -- 25 MR. HAYES: It's sort of a joke. EFTA00059180

LIMITED OFFICIAL USE 1 : -- yeah. 2 MR. HAYES: To (Indiscernible *03:40:46). 3 : It's a joke. Because 4 sometimes, the bodies are still there, and -- 5 : Right. 6 and we know he is 7 deceased. But then, the doctor and the medical 8 examiner -- 9 MR. HAYES: Yeah. 10 : -- declares 11 MR. HAYES: At the hospital -- 12 : -- (Indiscernible 13 *03:40:57). 14 MR. HAYES: -- (Indiscernible *03:40:57) 15 : Right. 16 MR. HAYES: The guy's got a big 17 (Indiscernible *03:41:00), you know 18 : Uh-huh. 19 MR. HAYES: -- whatever they call them, 20 knives in his chest. 21 : Mm-hmm. 22 MR. HAYES: You know, you can tell he's 23 not coming back, but I mean, you know what I'm 24 saying, they don't say he's dead on the scene. 25 : Uh-huh. EFTA00059181

LIMITED OFFICIAL USE 312 1 : But just, I just want to 2 be clear, because with that statement, without 3 me getting a little more clarification, people 4 are going to read, wait a second, 5 said that he was still, he thought he was still 6 alive. Now, I want to make sure I'm clear. 7 Are you saying that there was a chance for them 8 to bring him back, or based upon the 9 conversation with someone - and my follow would 10 be that, who? - did you believe that he was 11 still alive? 12 : My assumption, from when I 13 was called, was they were working on him, and 14 he was - they were being taken to the hospital. 15 : Okay. 16 : That's -- 17 MR. HAYES: That was -- 18 : -- that's the term. 19 MR. HAYES: -- that -. Wait. You were 20 called at a certain time. 21 : Yeah. When the lieutenant 22 called. 23 MR. HAYES: Okay. Now, the lieutenant 24 says -. 25 : So, when you came back EFTA00059182

LIMITED OFFICIAL USE 313 1 and found out, did you ever find out that he 2 wasn't showing signs of life, when you came in 3 and talked to people? 4 : No. Because I - first of 5 all, when it happened, I wasn't going around 6 questioning people about -- 7 : Okay. 8 : -- okay, what's going on 9 with this, because then, I knew that it was a 10 criminal case. But not criminal, but there was 11 going to be an investigation into it. And so, 12 I didn't want to give the appearance of 13 anything, that I was interfering with any 14 investigation. But when I did call, they said 15 they were working on him, and that, you know, 16 he was being transported to the outside 17 hospital. 18 : And who was it that 19 provided you with that information? 20 : The lieutenant. 21 22 MR. HAYES: So, you drew the inference 23 that that -- 24 : Uh-huh. 25 MR. HAYES: -- meant he was still alive? EFTA00059183

LIMITED OFFICIAL USE 314 1 : Right. I assumed that, you 2 know, they were still working on him, and he 3 was still alive. 4 : And after that 5 conversation, though, and speaking with other 6 people, you never gathered that, oh, he was, 7 they were working on him, attempting to bring 8 him back, but he was not alive? 9 : I didn't -. 10 : From -. 11 : The assumption, my 12 assumption, was that he was deceased at the 13 hospital. 14 : Okay. 15 : Yeah. So. 16 : All right. Do you want 17 to follow up on that at all, anymore? 18 : No. 19 : Mm-hmm. 20 : Okay. 21 : That kind of covers it. 22 MR. HAYES: Are we through now? 23 : No. 24 : No. 25 MR. HAYES: Oh, god. EFTA00059184

LIMITED OFFICIAL USE 315 1 : We only have, really, 2 very brief conversations left. All right. So, 3 this was an email sent from you, to 4 It just says, subject, "Names." 5 : Mm-hmm. 6 : It says 7 : Mm-hmm. 8 : Tova Noel, and 9 Davis. 10 : Mm-hmm. 11 : Who were -? Why were 12 those people listed? 13 : Because he wanted to know 14 who was working up there that night. 15 : Okay. 16 : Who was the staff working 17 there that night. 18 : So, why did you write 19 Davis versus, like, , or who else was 20 up there? Was Shack (Phonetic Sp. *03:43:25) 21 still there? 22 : No. 23 : At least Bonhomme and 24 Davis. Was Bonhomme left off for any reason? 25 Because I think Bonhomme worked -- EFTA00059185

LIMITED OFFICIAL USE 1 2 : I think this -- : -- until midnight, and 316 3 Davis only worked until 10:00. 4 : No. For - and I don't - 5 correct me if I'm wrong - I don't know if he 6 wanted to know who was on the midnight shift. 7 And then, I included who was on Ten South. I'm 8 not sure. 9 : I think Davis was 10 the OIC of the shift previous. And then, just 11 Tova, 12 : Tova would have -- 13 : -- and Tova were the ones 14 from -- 15 : -- been two up there. 16 : -- midnight afterwards. 17 : Yeah. 18 : And then -. 19 : I think that Ten South was 20 Robert Adams. 21 : Yeah. So, I don't know, 22 remember it. But I know it had to do with the 23 question about who was working. 24 : Okay. 25 : So, I don't know the EFTA00059186

LIMITED OFFICIAL USE 1 specifics and why it listed those three. 2 : And you don't know if, 3 like, because these were, who we considered the 4 subjects. 5 : No. I mean, these two would 6 have been obvious because they were working up 7 there on the midnight shift. But I don't know 8 why Davis got thrown in there. 9 : Okay. 10 : Mm-hmm. 11 : Mind just initial and 12 dating that? Okay. And this one is an email 13 from to you, dated Sunday, 14 August 11, 2019. And it says, subject, "A 15 memorandum, Epstein." 16 : Mm-hmm. 17 : And it says that this was 18 dated August 10th, 2019. 19 : Mm-hmm. 20 : It's from 21 It says, subject is, "Security expectations 22 involving inmate Epstein, Jeffrey." 23 : Mm-hmm. 24 : Are you familiar with 25 this? Did you ever see this, that he sent? 117 EFTA00059187

LIMITED OFFICIAL USE 318 1 : I did. 2 : Do you know what the 3 purpose of this was? 4 : Let me read it again. 5 "(Indiscernible *03:44:56), and while this 6 could be conducted, I did, I informed staff 7 (Indiscernible *03:44:59) be dealing with 8 inmate Epstein, and others were notified. 9 explained that lieutenants were to conduct 10 (Indiscernible *03:45:08), and at that point, 11 (Indiscernible *03:45:09). I explained I 12 could, and they would not (Indiscernible 13 *03:45:15)." Oh, no. I just was asking him 14 when the thing happened, what is the guidance 15 he provided? 16 : So, what did he provide 17 to, like, the SHU staff and the 18 Because -- 19 : Yeah. 20 : -- at least the last 21 little point on this first page -- 22 : Yeah. 23 : -- so, it says, "In 24 detailed conversations with the SHU 25 he was informed of my expectations regarding EFTA00059188

LIMITED OFFICIAL USE 319 1 the supervision of inmate Epstein, 2 specifically, he was reminded on several 3 occasions that inmate Epstein was to be housed 4 with a cellmate." 5 : Right. 6 : So, is this all, like, 7 the expectations surrounding 8 : The expectations. 9 : -- Epstein? 10 : Right. Mm-hmm. 11 : And when he says, "During 12 the week of July 31st, 2019, in order to 13 address management concerns with inmate 14 Epstein," do you know what he is talking about 15 there? With management concerns. 16 : The housing of them. And in 17 the Special Housing Unit. 18 : Okay. And do you know 19 if, according to this, it looks like he is 20 saying that he did perform informal training 21 sessions with staff. Do you know if he, in 22 fact, did that, or is it just based upon 23 : Just based upon -- 24 : -- what he wrote here? 25 : -- on what he sent out. EFTA00059189

LIMITED OFFICIAL USE 320 1 : Okay. So, there is no 2 other information, aside from what he's telling 3 you? 4 : Right. Yeah. He told me 5 that. 6 : So, this one is - I want 7 to get your take on this matter - so, this is 8 back to , who was relieved 9 at 5:30, but she stayed at the institution at 10 least until 9:30, and sent out that email, 11 detailing, you know, what day, and the 12 log, and the daily activity log. 13 So, sent her an email on 14 8/12/2019, stating, " , I am 15 reminding you to submit your supervisory 16 memorandum for the inmate Epstein incident that 17 occurred on 8/10/2019. 18 Please have it complete and ready for 19 submission on 8/13/2019." She responded with 20 no, addressing nothing, just saying, just 21 responded simply, "In your email, you state, 22 quote, `I am reminding you.' End quote. I 23 haven't spoken to you or anyone else regarding 24 the incident involving inmate Epstein or 25 anything else pertaining to August 10th, 2019. EFTA00059190

LIMITED OFFICIAL USE 321 1 So, how is it possible for you to be reminding 2 me? Second, I had been properly relieved, 3 prior to the incident involving inmate 4 Epstein." What is your take on that email? 5 : First of all, any major 6 incident that takes place in the institution, 7 we have to do what is called a report of 8 incident. 9 : Sure. 10 : He is well within the scope 11 of his employment, asking, okay, where is your, 12 where is -. And I don't know if he was asking 13 her the overall memorandum. Like, you are the 14 shift . You know, when this incident 15 took place. So, technically, you should have 16 been doing the packet. So, he is probably 17 contacting her for that. 18 : Well, she was relieved at 19 5:30 a.m., but she was still there, and the 20 incident happened at 6:30. And again, she was 21 there at least until 9:30. And she did respond 22 to the SHU afterwards, helping with the 23 feeding. Should have she written a memorandum? 24 : Yes. 25 : Yes? EFTA00059191

LIMITED OFFICIAL USE 322 1 : I mean, she said she 2 responded to the incident? 3 : She didn't respond to the 4 incident. She responded after the incident, to 5 help in the SHU with feeding and dealing with 6 the inmates. 7 : So, she -. Well -. 8 MR. HAYES: So, somebody told her that the 9 fucking guy hung himself, should she have 10 Right? 11 : Again, from what I gather, I 12 am under the impression, when the 13 relieved her, she was gone. Because, and, you 14 know, and I can't speculate on what was there. 15 So, if we -. 16 : She said she stuck 17 around, working on matters that she needed to 18 catch up on. 19 : Okay. So -- 20 : But it sounds like 21 manipulating those numbers on the counts and 22 stuff. 23 : Okay. 24 : Right? 25 : So, let me ask you this EFTA00059192

LIMITED OFFICIAL USE 323 1 question. I have, I have a medical emergency. 2 A suicide, right? That is an emergency 3 everyone in the institution has to respond to. 4 Why didn't you respond to it? 5 : So, you think that she 6 maybe came back after? 7 : It doesn't make sense to say 8 9 : Well, she never sent out 10 her required logs, though. 11 : Right. So, that, but -- 12 : So, you reviewed her 13 emails. And I would think that she would have 14 sent that out, if she had left, I would think 15 she would have sent that out before she left. 16 Right? As required. 17 : Right. So, did you leave 18 and come back? I mean, because if you are 19 saying that you were there, you would have been 20 one of the first responders up to the unit. 21 : Yeah, 22 : For the emergency. 23 : That's a really good 24 point. 25 : You know? EFTA00059193

LIMITED OFFICIAL USE 32 1 MR. HAYES: In other words -- 2 : I wish we had -- 3 MR. HAYES: -- they're saying it sounds 4 fishy. 5 : I wish we had thought 6 of that. 7 : I mean, so, and then, if you 8 9 : And if she didn't, why? 10 : -- and if you didn't 11 respond, why didn't you respond? 12 : If she Is it a claim 13 at all, I had been relieved, I wasn't 14 technically working? 15 : If you are in the building, 16 you have to respond. 17 : Is that right? 18 : It's an emergency. 19 : Okay. 20 : I mean, as a 21 : Okay. 22 : I would want to respond, 23 and say -- 24 : And so, the fact that she 25 states that she was there, and she was working EFTA00059194

LIMITED OFFICIAL USE 325 1 on her administrative responsibilities -- 2 : Right. 3 : -- so, is that a problem, 4 then, as ? What do you mean you are 5 working on the administrative? You should have 6 responded to that emergency. 7 : No. But - and I don't want 8 to speculate on when you are there - but I 9 just, there is just some questions 10 MR. HAYES: Wait, and I think 11 : -- they just don't -- 12 MR. HAYES: -- that is a yes or a no -- 13 : Right. 14 MR. HAYES: -- you know, question. 15 : Yeah. I mean, it's a 16 problem. If you are saying I am working on it, 17 okay. Now, at what point did you say, okay, I 18 need to, because once they had said, hey, I 19 have a suicide or something going on, which is 20 probably over, you know, a real medical 21 emergency, and you hear the transmission on the 22 radio, you are going to go up there. So then, 23 you say, oh, I went up there later, to help 24 with the feeding. Either way, you were in the 25 building. The captain is asking you, it EFTA00059195

LIMITED OFFICIAL USE 326 1 happened on your shift, you are responsible for 2 conducting the report of incident. 3 : So, that answer is yes, 4 she should have written a memorandum? 5 : She should have written one. 6 I don't understand why she didn't, you know? 7 : And is that at all 8 reading how she responded - is that 9 insubordination at all, to you? 10 : Listen. I will put it this 11 way. I can't speak on other supervisors or how 12 they tolerate, but if you had given me a 13 memorandum like this, we would be having a 14 conversation. You know? 15 : Is that, at the very 16 least, inappropriate -- 17 : I think -- 18 : I think it's 19 inappropriate. I mean, that's the way -- 20 : I mean, I read it. 21 thought it was inappropriate. 22 : -- yeah. 23 : I just didn't know how 24 : I would have gone to have a 25 conversation, like, you know, first, are you EFTA00059196

LIMITED OFFICIAL USE 327 1 all right? And then, secondly, what is this? 2 But yeah. 3 : Fair enough. 4 MR. HAYES: Okay, listen, one last 5 question. 6 : Sure. 7 MR. HAYES: Does that give the implication 8 that she is covering up for somebody, or she 9 just didn't do her job? 10 : I don't know. 11 : We don't know. That's 12 Had you heard anything about her covering up 13 for someone? Because -. 14 : I haven't heard anything, 15 but, you know -- 16 : Did you hear about 17 inmates saying that she was making statements 18 that she was going to cover for other people? 19 : Again, I don't want to make 20 any statements -- 21 : No, no, I'm asking you -- 22 : -- that are not factual. 23 MR. HAYES: (Indiscernible *03:51:56). 24 : -- did you ever hear -? 25 : No, I didn't hear anything. EFTA00059197

LIMITED OFFICIAL USE 328 1 MR. HAYES: I would hate to -- 2 : You never heard it. 3 : Right. 4 MR. HAYES: -- I would hate to give my own 5 client a hard time. 6 : Right. 7 MR. HAYES: But, but it sounds to me like 8 she's got three hours where she knows this guy 9 is dead. 10 : Right. 11 MR. HAYES: You know? And she don't say 12 much. I mean, you know, if I was him, I would 13 be drawing an inference, saying, what the fuck 14 is going on? Excuse my language, by the way. 15 I have a filthy mouth. 16 : No. I mean, I understand 17 what you are saying, but you know, I'm just, my 18 point of view is - and my concern - is 19 MR. HAYES: Yup. 20 : -- if you were there -- 21 MR. HAYES: Your concern is, you would 22 have asked, unlike myself, you would have asked 23 her a question first -- 24 : Right. 25 MR. HAYES: -- rather than jumping into, EFTA00059198

LIMITED OFFICIAL USE 329 1 which is -- 2 : Because I was -- 3 MR. HAYES: -- which is what I did. 4 : -- under the impression, 5 because when called me, he was 6 the , and he had relieved 7 her. 8 : Right. 9 : She had gone home already. 10 : Well, he had certainly 11 relieved her, but -- 12 : Yeah. 13 : -- according to her, she 14 hadn't gone home. 15 : Yeah. 16 : Do you mind just 17 initialing and dating that? 18 : Yeah. 19 : Maybe you asked this 20 question. And I just want to clarify. Being 21 that she started this shift 10:00 p.m. the 22 night before, right? 23 : Mm-hmm. 24 : Let's say this incident did 25 happen. We're not saying she did. We don't EFTA00059199

LIMITED OFFICIAL USE 330 1 know. If she went in and she altered the 2 logs, for the previous shift, did 3 she do something wrong? 4 : Well, and again, we are 5 knowing, though, that she started at 10:00 p.m. 6 So, that is still her shift. 7 : Yeah. But -- 8 : We've had this 9 conversation -- 10 : -- no, no, but -- 11 : -- before. 12 : -- let's just say, you know, 13 the fact that the inmate wasn't moved until 14 midnight, and then the clarification, and the 15 count, the count numbers being changed in 16 there. Now, so, the log count 17 numbers are accurate, except the count, the 18 actual count slips, were completely off. So, 19 somewhere along the way, someone altered those 20 numbers to -- 21 : Well -- 22 : -- correct it. 23 : -- the is 24 required to take a count on each shift. So -- 25 MR. HAYES: So, see, wait. EFTA00059200

LIMITED OFFICIAL USE 331 1 : -- you got the -- 2 MR. HAYES: -- the is supposed 3 to take in a count. Right? 4 : Right. Just to take one 5 count -- 6 MR. HAYES: He's supposed to -- 7 on shift. 8 : An institutional count. 9 : Institutional count. 10 MR. HAYES: Okay. 11 : Not a physical, in the 12 SHU count. 13 MR. HAYES: Okay. So, now -- 14 : But now, if you 15 (Indiscernible *03:53:53). 16 MR. HAYES: -- I got to shut up. 17 : Yeah. Go ahead. 18 MR. HAYES: He's supposed to take a count. 19 : Right. 20 MR. HAYES: Right? And he's supposed to 21 enter the count. 22 : Right. 23 MR. HAYES: Right? Okay. And there was a 24 count entered, right? And there is no question 25 that, at some point, the count was altered? EFTA00059201

LIMITED OFFICIAL USE 1 : The count was wrong. 2 : The count was wrong. 3 MR. HAYES: Okay. Okay. 4 : Well, no 332 5 MR. HAYES: Yeah. (Indiscernible 6 *03:54:14) -- 7 : -- what he's saying is it 8 was altered. 9 MR. HAYES: -- (Indiscernible *03:54:15). 10 : I'm talking about the numbers 11 12 : So, if you recall 13 on the paperwork. 14 : -- on August 9th, 2019, 15 the log says, at midnight, there 16 was 72 in the SHU. The count slip says 73. 17 : Mm-hmm. 18 : And the iog 19 for the next day at midnight says there was 73. 20 : Mm-hmm. 21 : So, what Agent is 22 asking is, well, that obviously goes to show 23 that she went back and changed those numbers to 24 72, because -- 25 MR. HAYES: But what is her motive -- EFTA00059202

LIMITED OFFICIAL USE 1 : -- that midnight -- 2 MR. HAYES: -- to do that? 3 : -- she says she was just 4 trying to make things accurate. 5 MR. HAYES: But what would be an ulterior 6 motive that would create the idea that she was 7 doing something wrong? 8 : It goes back to when you 9 asked -- 10 : Mm-hmm. 11 : -- is there something to 12 do with a cover up? 13 : So, if - and granted, 14 mistakes are made in the log - but you also 15 annotate that in the log. Like, you will put, 16 okay, late entry. Because typically, if you 17 say the log is done already, when you go back 18 and make changes, you make changes for this 19 reason alone. An investigator comes in, looks 20 at it, and says, well, wait a minute, it looks 21 like you've been playing, you went back and 22 just changed the numbers. So, you can put in 23 there, and you say, okay, late entry, explain 24 what your change was, and what the mistake was. 25 MR. HAYES: So, really, with this -- 13 EFTA00059203

LIMITED OFFICIAL USE 334 1 : You know? 2 MR. HAYES: -- to show a malicious intent 3 in her part, there's got to be something that 4 influences her to protect one of the people 5 that were - no question - were fucking around. 6 Right? The two guys that were fucking around 7 ended up getting pinched. Right? So, if one 8 of them is her friend, then she's got a 9 malicious motive to go try and cover for that 10 guy. Like, did $8,000 (Indiscernible 11 *03:55:58) police officer, he says, well, I 12 thought he drew a gun on me. 13 : Right. 14 MR. HAYES: And I shot him. 15 : Yeah. 16 MR. HAYES: Oh, okay. Nobody else saw 17 that. 18 : Yeah. 19 : But you are not aware of 20 her involvement at all, you said, or 21 : As far as what? 22 : -- covering up for them, 23 or involvement in Epstein's death? 24 : No. She wouldn't have had 25 that conversation with them. EFTA00059204

LIMITED OFFICIAL USE 335 1 : And you weren't - until 2 now, it sounds like - even aware that she was 3 at the institution after 5:30 a.m.? 4 : I was told she left. 5 : Okay. 6 : Yeah. 7 : And again, who told you 8 that? 9 : The 10 Because he called me and he says, hey, I 11 relieved -- 12 : So, 13 14 : Sorry. 15 : Yeah. 16 : Okay. And did you have - 17 before we move on to the next subject - do you 18 have any more on that? 19 : No. 20 : So now, we are going to 21 talk about the cameras. 22 : Mm-hmm. 23 : Were the SHU cameras 24 recording on August 9th and 10th of 2019? 25 : I didn't physically go check EFTA00059205

LIMITED OFFICIAL USE 1 to see if they were, were recording or not. 2 : Did you learn that they 3 were not recording? 4 : Yeah. We found out 5 afterwards, that they weren't recording. 6 MR. HAYES: Wait. Wait. We had this 7 conversation. 8 : Right. 9 MR. HAYES: The cameras don't work in a 10 lot of these institutions. Right? 11 MR. HAYES: Yeah. Yeah. 12 MR. HAYES: All right. And that's because 13 they didn't spend the fucking money to make 14 sure the cameras work. 15 : Well, it's -- 16 MR. HAYES: And I got to stop saying 17 "fuck." 18 : -- that's the issue, too, 19 funding, and, you know, so, since that 20 incident, I guess there was some audits done by 21 the agency, and they realized that it was kind 22 of a system (Indiscernible *03:57:15). 23 MR. HAYES: But you see, the issue is, 24 should you have checked why weren't the cameras 25 working? EFTA00059206

LIMITED OFFICIAL USE 337 1 : Well, that's my question 2 is, do you know why they were not working? 3 : I don't know the specific 4 language that was used, and what was wrong with 5 it, because I guess, after I left, they kind of 6 made a determination on what was why -. What 7 was the reason. I know we were going through 8 the process of auditing and fixing some 9 cameras. But those specific SHU cameras, I 10 wasn't aware of the extent. 11 : Okay. Let's just really 12 quickly review -- 13 : Mm-hmm. 14 : -- the SHU camera 15 documentation. Were you ever provided any 16 documents of a camera that actually was working 17 in the SHU? 18 : You mean, the day of the 19 Epstein thing? 20 : Right, right. At ar, 21 time. 22 : I don't recall. 23 : So, were you provided 24 with this? This is right outside of 25 : This was a -- EFTA00059207

LIMITED OFFICIAL USE 1 2 : -- Ten South. : -- that says camera angle 338 3 out of Ten South. 4 : Right. Were you ever 5 provided with that, as far as -- 6 : It looks -- 7 : I think from -- 8 : -- it looks familiar, but 9 don't -- 10 : -- from 11 he might have. 12 : Okay. But you don't 13 remember specifically? 14 : Yeah. I don't specific. 15 : Okay. And then, just 16 while we are here, I guess, what are these 17 doors right to the right of this picture? 18 : This, this door goes into 19 Ten South. 20 : Okay. 21 : And then, this one, I think 22 is a utility room door. I'm not sure. 23 : Okay. So, the door that 24 says "46" goes into Ten South? 25 : That looks like the Ten EFTA00059208

LIMITED OFFICIAL USE 339 1 South door. Oh, wait, wait. Yeah. The phone 2 is -. Yeah. That is Ten South. It looks like 3 Ten South. 4 : And what are we looking 5 at down here? 6 : So, this is the, right here 7 is the officer's station area. 8 : And do you - based upon 9 that - do you know what tier that would be 10 right there? 11 : Oh, man. You got 12 (Indiscernible *03:59:02) stopped. Let me see. 13 Is that G and H tier, I think, if I remember. 14 : And what would be right 15 to the right of the officer's station? 16 : Oh. Wait. G. H. I. J. 17 A. I don't remember if that was I and J. That 18 19 : Would this be L tier up 20 here? 21 : Yeah. L and M tier. That's 22 what -. 23 : So, right up, right to 24 the right of the officer's station, looking at 25 this picture EFTA00059209

LIMITED OFFICIAL USE 1 2 : Right. : -- would be L. And is 3 that where Epstein was housed? 4 : I believe he was on the L 5 tier. 6 : Okay. Do you mind just 7 initialing and dating that? 8 : Mm-hmm. 9 : So, here is a map that we 10 were previously provided. Does this look like, 11 then -? So, this is where we were that this 12 camera angle is focusing down here on the 13 officer's station. This is L tier. 14 : Mm-hmm. 15 : On the second level. 16 : Mm-hmm. 17 : And this is where Epstein 18 would have been housed. 19 : Mm-hmm. 20 : Does that look right? 21 : That looks right. 22 : Okay. Is this L tier 23 here? 24 : That's L tier. 25 : Does this look like what EFTA00059210

LIMITED OFFICIAL USE 341 1 would have been Epstein's door? I know you 2 can't really see because of the police 3 crossings -- 4 : Yeah. 5 -- on it. 6 : I noticed it. The crime 7 scene tape. 8 : Okay. Do you have any 9 reason to believe that that wouldn't be 10 Epstein's door? 11 : What do you mean? 12 : As far as, I know we 13 can't see the number 14 : Yeah. I don't know the 15 number, but I'm taking your word for it, that 16 that is. 17 : Okay. Now, if you see, 18 this is L tier range. And at the very end, you 19 see this camera. 20 : Mm-hmm. 21 : Should that camera have 22 been recording? 23 : Yes. 24 : Okay. And is that a 25 camera that I'm actually looking at right EFTA00059211

LIMITED OFFICIAL USE 1 there? 2 : That is a camera. 3 MR. HAYES: Was that camera recording? 4 : Sir, do you know if the 5 camera was recording? 6 : I didn't see. After I left, 7 I guess they said there were camera issues, but 8 I don't know what, I wasn't provided 9 information on what specific cameras were 10 working or not. 11 : So, they didn't tell you 12 if they were working or not? 13 : Well, remember, I was 14 removed. 15 : I just didn't know if you 16 found out on the 10th or 11th. 17 : No. I was removed on the, 18 you know, they said there were some camera 19 issues, and then, what they were doing, they 20 had the FBI came in, and took hard drives, and 21 I guess they were working to see what was 22 working and what wasn't working? 23 : Can you initial and date 24 that? 25 : I'm not going to get into EFTA00059212

LIMITED OFFICIAL USE 343 1 this since he wasn't aware that they weren't 2 recording. 3 : Mm-hmm. 4 MR. HAYES: Boy, I'm impressed by your 5 thoroughness, I'll tell you that much. 6 : That's why they put me on 7 it. I'm -- 8 : Yeah. 9 MR. HAYES: You're very thorough? 10 : -- yes. 11 MR. HAYES: You know, if you, if you are a 12 good trial lawyer, you know, allegedly a good 13 trial lawyer, a lot of times, you are not 14 supposed to be thorough. You are supposed to 15 put an idea in the jury's head, right? Where 16 you can see they're invulnerable, stay on that 17 fucking idea, because if you are going to be 18 thorough, you have to bring out something that 19 you don't want to bring out. You know, so you 20 to speak to the things, but you know you got 21 them. 22 : Yeah. 23 : So, this is an email that 24 was received. Who's 25 : He's the facilities manager. EFTA00059213

LIMITED OFFICIAL USE 344 1 : Okay. So, is this what I 2 wanted to show you? Hold on. Now, did you 3 print out the one that I sent you this morning? 4 : Is that -. That should be 5 the last thing on the -. 6 : Okay. I'm not going to 7 get into those. So, you weren't aware that the 8 cameras were not - or you are not aware if the 9 cameras were or were not recording -- 10 : We had camera -- 11 : -- in the SHU? 12 : -- no. We had camera issues 13 throughout the institution. 14 : Okay. 15 : So, I don't know which 16 specific one, because we had Mr. workin: 17 on a project, to get some money for it. 18 : Okay. 19 : But when it came to that 20 specific night, I didn't know if they were 21 working or not. 22 : Were you ever told that, 23 either on August 8th or August 9th, that the 24 cameras were not recording in the SHU? 25 : I heard - yes - I was told EFTA00059214

LIMITED OFFICIAL USE 345 1 that there were some issues with the cameras 2 : On either the 8th or the 3 9th, prior to Epstein? 4 : -- no. I'm talking about 5 afterwards -- 6 : Yeah, yeah, no -- 7 : -- when it happened. 8 : I'm saying -. So -- 9 : Yeah. 10 : -- August 10th is the day 11 he is found. 12 : Right. 13 : On August 9th or August 14 8th, even, leading up to Epstein being found, 15 were you ever informed that cameras were not 16 recording? 17 : No. I wasn't told about 18 cameras. 19 : All right. So, based on 20 our investigation, we learned that MCC, III 21 22 : Mm-hmm. 23 : -- and that II 24 : Mm-hmm. 25 : -- became aware on August EFTA00059215

LIMITED OFFICIAL USE 346 1 8th, 2019, that at least some of the MCC 2 cameras were not recording. They contacted 3 comtech , and may have also 4 notified . Did you ever 5 hear anything about that? 6 : I knew prior that there was 7 some cameras in the institution that needed to 8 be fixed, but not specifically the SHU, no. 9 : Okay. 10 : Yeah. 11 : And would have that been 12 based upon what they found? The II and 13 14 : No. Because we had had some 15 issues with cameras, and we were trying to seek 16 funding. So, and we were trying to see, okay, 17 what was working and what to get fixed. But 18 specifically, in SHU, no. 19 : All right. So, only 20 because, you said that you were trying to get 21 funding. Did you know that there were already 22 cameras at the institution, and that's what 23 they were able to replace when the FBI took the 24 cameras on the 10th, they were able to 25 immediately replace them with the cameras that EFTA00059216

LIMITED OFFICIAL USE 1 were onsite? 2 : So, cameras all -. 3 Institutions always have, like, backup cameras 4 to fix what is there. But I was talking about 5 funding to replace the whole system. 6 : So, this was from fiscal 7 year 2018 -- 8 : Right. 9 : -- back in September. 10 : Mm-hmm. 11 : This is a memorandum for you, from a 13 14 : Right. 15 : And these are all the 16 different documents that go with it, regarding 17 a new camera system that was purchased. 18 : Right. 19 : It was, it looks like 20 there was $800,000. 21 : Mm-hmm. 22 : For this total. These 23 are all the documents that - here you go - this 24 is an approval of your September 11th, 2018 25 request. So, this is a memorandum for -- EFTA00059217

LIMITED OFFICIAL USE 1 : Right. 2 from, it 3 looks like a (Phonetic Sp. 4 *04:05:31). 5 : Mm-hmm. : The 348 7 8 : Mm-hmm. 9 : It says, request to 10 exceed the spending limit of $50,000 on a work 11 request number 8158, replace camera system at 12 MCC New York. This work request is to replace 13 the current degraded camera system. The total 14 cost of this work is not to exceed $800,000." 15 : Mm-hmm. 16 : Then, at the bottom, it 17 says, "If you have any questions, please call 18 me or have your staff contact," and how do you 19 say that name? Do you know? 20 (Phonetic Sp. *04:05:57)? 21 -• 22 (Phonetic Sp. *04:06:00). 24 25 : Mm-hmm. EFTA00059218

LIMITED OFFICIAL USE 349 1 : And it says, "At the 2 phone number." And then, here are the, you 3 know, the work orders for that. So, we have 4 spoken with SigNet, who was the camera provider 5 6 : Mm-hmm. 7 : -- they said that on or 8 around October or November of 2018, they were 9 delivered. 10 : Mm-hmm. 11 : And then, talking with 12 the (Indiscernible 13 *04:06:22) -- 14 : Mm-hmm. 15 he said 16 that they started working on the infrastructure 17 of the camera project on or around March 2019. 18 : Mm-hmm. 19 : To get everything ready 20 for the new camera system that was onsite to be 21 installed, and said that -. 22 : They had to run wires. But 23 the old system was there. So, they had to run 24 wires. And they had to get a contract done. 25 : Uh-huh. EFTA00059219

LIMITED OFFICIAL USE 350 1 : In order, because you needed 2 the comtechs, and I forget the wording that 3 they used, is to run the cables, to get the new 4 camera system in. So. 5 : And do you know how long 6 that typically takes to run the new wires and 7 all that? 8 : You would have to have the 9 staff (Indiscernible *04:06:58). We didn't 10 have the staffing. 11 : So, were there two people 12 TDY'd, though, in order to do that? 13 : They started TDY'ing people 14 in, to come in. 15 MR. HAYES: Wait a minute. Can the staff 16 run the new wires, or you have to get an 17 electrician to run the wires? 18 : No. We have staff that are 19 qualified to do it, but then, some of them were 20 new and really didn't know how to do it. So 21 MR. HAYES: Okay. 22 you know, it was -. 23 : So, according to 24 it says, "The camera system was 25 scheduled to start March 17th, 2019, and it EFTA00059220

LIMITED OFFICIAL USE 1 started on schedule. When I arrived TDY 2 February 2019, we only had one communication 3 technician -- 4 : Mm-hmm. 5 : -- therefore, after 6 talking to the regional office, they started a 7 project to assist in funding and labor. So, we 8 were able to start the week of March 17th, 2019 9 for the camera system, and all other 10 infrastructure throughout the institution. 11 MR. HAYES: St. Patrick's Day. 12 : Mm-hmm. 13 : Below is the email sent 14 to all the institution from Bond 15 (Phonetic Sp. *04:07:49), the northeast 16 regional -- 17 : Right. 18 : -- facilities 19 administrator." But point being, it looks like 20 that project had started. Correct? 21 : It has started, but -- 22 : And I only say that 23 because I wanted to make sure you weren't 24 confused, because you were saying we were 25 looking for funding. EFTA00059221

LIMITED OFFICIAL USE 352 1 : No. No. I misspoke. What 2 I'm saying is, I meant that the project 3 started, but the cameras hadn't been replaced. 4 Because they were still running wires for the, 5 to get the new system started. 6 : Okay. 7 : So, that unit still had the 8 old cameras. 9 : Right. But then, the 10 camera system was actually onsite, and they 11 were working on it? 12 : Well, yeah, but they weren't 13 - you didn't have enough staff to install, to, 14 you know, to rewire the whole place, because we 15 had, we wanted to put one, some on the ranges 16 that never had cameras. 17 : Mm-hmm. 18 : So, it was a tedious 19 project. 20 : I see. 21 : That required us to TDY 22 staff from other institutions. And then, you 23 know -. 24 : Yeah. And were you kept 25 apprise of where they were on that? On the EFTA00059222

LIMITED OFFICIAL USE 1 camera project. 2 : I would acquire about it, 3 like, where we were with it. But we were to 4 the point where we were bringing people in from 5 other institutions. To get it done. 6 : Okay. And do you know 7 when the camera system was scheduled to 8 actually be installed, or was it ever 9 scheduled? 10 : From - and if I remember 11 right - it was a matter of before you even 12 installed it, you had to run the wiring for it. 13 : Right. And that's what - 14 15 : (Indiscernible *04:09:13). 16 : I think was -- 17 : Right. 18 : -- what they were saying 19 in March of 2019. 20 : But that had -- 21 : That 22 been completed. Because 23 you had to TDY people there. And to get it 24 done. 25 : And they never provided EFTA00059223

LIMITED OFFICIAL USE 354 1 you with an update as far as, like, when it 2 would actually be completed? 3 : It was still ongoing. 4 : Okay. 5 : Now -- 6 MR. HAYES: (Indiscernible *04:09:27). 7 : -- but after I left, they 8 got people in there and completed it. 9 : Yeah. Yeah. Because I 10 think, I think that whole week, they were able 11 to complete the whole thing. Correct? 12 : I don't know when. 13 : You don't know? 14 : You know, because they had 15 people come in from different institutions. 16 : Now, is that, did they 17 ever, did the facilities manager, Captain 18 Whomever, ever explain to you how bad the 19 system was, and that it kept on shutting down, 20 and stopping, you know, cameras weren't 21 recording? 22 : I mean, we would have 23 incidents where, you know, something would 24 happen, and we tried to go back and find the 25 tape, and we couldn't. So, and it would break EFTA00059224

LIMITED OFFICIAL USE 355 1 down, they would fix it. So, I mean, we did 2 have issues like that before. But it was the 3 age of the cameras. The -- 4 : Yeah. 5 : -- you know, we had 6 infrastructure issues. So. 7 : Because, yeah, the 8 comtech claims that, you know, like, he had 9 been, I mean, he's a very soft-spoken person, 10 but like, basically, screaming at the top of 11 his lungs as much as a very soft-spoken person 12 can, we need to fix these things, this is a 13 continual problem. 14 : So, here is what it is. We 15 don't have money readily available at an 16 institution to fix it. That money comes from 17 what we call buildings and funds. 18 : Mm-hmm. 19 : Which is funded by Congress. 20 So, you would have to talk to somebody in the 21 region about what the regional budget is, but 22 other institutions have issues going on. 23 : But being that -- 24 : Yeah. 25 : -- we have all these EFTA00059225

LIMITED OFFICIAL USE 356 1 cameras already onsite, and they had already 2 done the wiring for, you know, at least six 3 months prior to this -- 4 : Well, not all the wiring -- 5 : -- they -. 6 : -- was done. 7 MR. HAYES: Yeah. He just, he didn't say 8 the wiring was done. 9 : Yeah. 10 : No, no, no. I'm just 11 saying, like, is that, I'm just trying to get a 12 feel for what was the plan here, and who was 13 responsible. 14 : Well, the plan was to get 15 the manpower to get it installed, but at the 16 time, we only had one person. Which was 17 18 : Mm-hmm. 19 : So, one person can't 20 : Well, and the TDY staff. 21 : -- right, but even the TDY 22 staff came, they did help. You know, but then, 23 we also had other TDY staff that were coming in 24 for, because of our staffing issues. 25 : Mm-hmm. EFTA00059226

LIMITED OFFICIAL USE 1 2 : But -. : Well, that's what 3 told us. That the TDY staff that was assigned 4 for him sometimes were getting put on the 5 custody posts. Do you know if that is accurate 6 or not? 7 : We might have had to do it a 8 time or two because we wanted to staff. 9 : Okay. 10 : Yeah. Yeah. 11 : And whose responsibility 12 were the cameras? To make sure that those 13 things were going to be operational and working 14 properly. 15 : Well, it's not a matter of 16 who was responsible. It's, like, working on 17 getting it installed. 18 : Okay. 19 : So, there was no deadline as 20 far as, you know, okay, when they had to be up. 21 You know, they just had to be installed. 22 : Okay. Because we were 23 told the cameras are the captain's baby. Is 24 that accurate? 25 : No. No. It's not. EFTA00059227

LIMITED OFFICIAL USE 358 1 MR. HAYES: Yeah. That -- 2 : It's not. 3 MR. HAYES: -- that can't be true. 4 Captains don't know how to install it. 5 : Yeah. He doesn't -- 6 MR. HAYES: (Indiscernible *04:12:11). 7 : No, no, no. Not to 8 install them. But to make sure that they are 9 operational, and get the right people to 10 actually get it done. 11 : Well, I -- 12 MR. HAYES: That can't be right, either. 13 : -- well, I -- 14 MR. HAYES: Because how the fuck would you 15 know what -- 16 : -- right. I -- 17 : Well, because -- 18 MR. HAYES: -- who the right people is. 19 : -- because what we were 20 told is that this was constantly happening, 21 whereas the cameras would stop working. And 22 then, nothing would be recorded. 23 : So -. 24 : The only way you find out 25 that that is happening is to physically check EFTA00059228

LIMITED OFFICIAL USE 359 1 the DVR recording to see if there has a light 2 on it, or if you try to attempt to rewind, and 3 you are unable to. 4 : Mm-hmm. 5 : Because everything is 6 still live monitored feed, showing, so you 7 can't tell just by looking at the cameras. 8 It's only when you try to rewind them, that you 9 can say, oh my gosh, they are not recording. 10 : Right. But that, it wasn't 11 just as simple as that. I mean, there were 12 technical aspects of it that you had to check 13 to see if the cameras are working or not. 14 : Oh. Absolutely. 15 : Right. And the captain 16 basically looking to see if, okay, is the 17 screen up? And then, is it recording? But 18 there was some instances where the hard drives 19 weren't working, and you don't know that until 20 you get deep into it, into the system. So, I 21 wouldn't, you know -- 22 : That's -- 23 : -- put that -. 24 : -- that's what he just 25 stated. EFTA00059229

LIMITED OFFICIAL USE 1 2 360 : Yeah. : Like, the fact that the only 3 way we would know if the hard drives were not 4 working is by going in 5 : Right. 6 : -- to check the video. And 7 the video, there is no videos that they can 8 pull back. 9 : Right. 10 : That's when they know the 11 hard drives stopped recording. 12 : Stopped recording. And 13 then, and look at them. But then, this is, you 14 know, there was other technical aspects of it 15 that, you know -- 16 MR. HAYES: I can't imagine that 17 : -- yeah -- 18 MR. HAYES: -- the captain would know. 19 sure as hell wouldn't. 20 right. 21 : So, I guess, knowing, 22 though, that this was, like, a reoccurring 23 problem, and the fact that, well, what we 24 didn't say is, it seems, it appears that the 25 cameras actually stopped recording all the back EFTA00059230

LIMITED OFFICIAL USE 35! 1 in July, and for half of the institution. 2 : Mm-hmm. 3 : Who should have made sure 4 that that camera system was replaced, and that 5 we had an operational camera system in there? 6 : Well, the centralized area, 7 and I don't know where the break down was. So, 8 if it's a centralized area, then it would be, 9 you know, within our facility department has 10 access to -- 11 : Well, the camera -- 12 : -- the comm -- 13 : -- you are asking where 14 the cameras are? 15 : -- no, the comm room. 16 : Yeah. The comm room. 17 Where these recorders were, were all in the SIS 18 secured area. 19 : Right. The actual cameras. 20 But where - if you go out - where -? And I 21 don't know the word, what's the word? Where 22 your centralized main area is for the whole 23 system. Yeah. That SIS areas has the cameras. 24 But that's fine. 25 : Not the control room. EFTA00059231

LIMITED OFFICIAL USE 362 1 But it's back around where, it's a locked door 2 within the SIS locked room, where the actual 3 DVR recording and rack is, and everything. 4 : Right. 5 : Yeah, yeah, yeah. That's 6 7 : But -- 8 : -- is that what you are 9 talking about? 10 : -- that, but there is also 11 another, should be another area in the 12 institution, just for the communications. 13 Where everything comes into. So, I don't know 14 if it was back there or whatever, but our 15 facilities department, you know, their 16 communication guys check that, too, if there is 17 something intricate with it. 18 : Now, so, was either III 19 , or , how do you pronounce his 20 name? 21 -: 22 : Was , or 23 , were either of them expressing the need 24 to you at all, to, hey, we need to get these 25 things fixed? EFTA00059232

LIMITED OFFICIAL USE 363 1 : I mean, the request had been 2 sent up. 3 : Yeah, yeah. No. 4 : So, yeah. 5 : And these were all 6 onsite. 7 : Right. So, yeah. I mean, 8 we were going through -- 9 : And again -- 10 : -- the process of getting 11 the system up and running. 12 : But there was no set 13 schedule for when it was actually going to be 14 completed? 15 : No. Because we had to TDY 16 people. Sometimes we got them in, sometimes we 17 couldn't get them. And then, towards the end, 18 you know, boil down to money, with getting 19 people in to come fix them. 20 : And when people are TDY, 21 do you - when you say boil down to money - does 22 that come out of -- 23 : It comes out of our -- 24 : -- MCC's pocket? 25 : -- it comes out of our EFTA00059233

LIMITED OFFICIAL USE 364 1 budget. It comes out of budget. It comes out 2 of the region sometimes gives it. Plus, on top 3 of that, we were for TDY to come to our 4 correctional post, because we were so short. 5 : All right. So, what 6 would you say is the main reason, then, that 7 the cameras were onsite, but not installed? 8 Lack of manpower and funding? 9 : Well, manpower to get it in. 10 And then, it kind of boiled down to funding. 11 You know, to keep TDY people, to get it done. 12 MR. HAYES: But do you have money, you can 13 really keep the TDY people. You don't have 14 money -- 15 : Yeah. 16 MR. HAYES: -- you can't keep them. You 17 know? 18 : But again, there is no, 19 there was no actual set schedule of it will be 20 operational by the end of this calendar year -- 21 : No. 22 : -- or anything like that? 23 : No. 24 : That wasn't discussed? 25 : That wasn't discussed. We EFTA00059234

LIMITED OFFICIAL USE 365 1 were trying, you know, doing the best we can 2 with the hand we were dealt. 3 : Okay. And Monday morning 4 quarterbacking that. Should it have been 5 discussed, or planned ahead, that these cameras 6 be installed? 7 : Would -? I don't understand 8 the question. 9 : Well, being that there 10 is, it seems that there was potentially around 11 two weeks of no cameras, and in the SHU, no 12 cameras. Aside from that one outside of Ten 13 South. 14 : Right. 15 : That were recording. 16 : But that wasn't known -- 17 : But it was, according to 18 the, you know, according to the facilities, as 19 well as the comtech, they said it was very well 20 known that this continually happened, and that 21 the comtech guy continually had to rebuild hard 22 drives because they kept on crapping out and 23 not recording. 24 : I mean, it is an antiquated 25 system. EFTA00059235

LIMITED OFFICIAL USE 1 2 366 : Right, right, right. : So, when you go down, yeah, 3 obviously, you go fix it. But nobody knew 4 until after the fact that you, you know, that 5 you had a system that was out for two weeks. 6 You know, I mean, you go to any other, any 7 institution, the cameras go down. 8 : Sure, sure. 9 : And when the system breaks, 10 somebody discovers it, and they fix it. But as 11 far as getting the new system up, we were 12 working on it. 13 : Okay. You want to follow 14 up with any of that? 15 : You mentioned no one knew. 16 But the problem was, according to the comtech, 17 the system failed, the motherboard had to be 18 replaced on the 29th -- 19 : Mm-hmm. 20 : -- they had a failure. 21 : Right. 22 : And then, of course, no one 23 checked it until the 8th. 24 : Mm-hmm. 25 : August 8th. When the II and EFTA00059236

LIMITED OFFICIAL USE 367 1 the went in and they tried to 2 3 : Right. 4 : -- review video. Now, being 5 that they identified the system wasn't working 6 that day -- 7 : Mm-hmm. 8 : -- how soon should it have 9 been fixed? 10 : What do you mean? When they 11 -? 12 : On the 8th. 13 : Right. 14 : This is two days before the, 15 that, that Epstein was found. If they 16 identified on the 8th that, hey, listen, the 17 camera is not working. It's technically not 18 recording. How much of a priority is it to 19 make sure that those cameras are up and running 20 immediately? 21 : It's a priority. So, what 22 happens is, and we have run into this before, 23 the parts. Sometimes the parts weren't readily 24 available. So, you have to go somewhere and 25 call for the parts, and depending on where it EFTA00059237

LIMITED OFFICIAL USE 368 1 is at, it could be in California, or whatever. 2 So, you got to see how long it takes to get 3 that part. 4 MR. HAYES: Yeah. 5 : Over to repair. 6 MR. HAYES: And the key part for my 7 heating system -- 8 : Yeah. 9 MR. HAYES: -- is in fucking Belarus. 10 : Right. 11 : My understanding is they, it 12 was the hard drive that they needed. Right? 13 And the hard drive was sitting with the 14 computer services. 15 : Yeah. On the 8th. The.) 16 weren't able to get it. 17 : I don't know. 18 : Yeah. 19 : And on the 9th, they got 20 it. But then, he claims that he wasn't able to 21 gain access to the room because it was an SIS 22 shop, and he needed to go until later in the 23 day, and they were gone. 24 : I mean 25 : And on the 10th -. EFTA00059238

LIMITED OFFICIAL USE 369 1 we have an emergency keys 2 to get into any area of the institution. So, 3 if he is saying he couldn't get in to the SIS 4 office -- 5 : Mm-hmm. 6 : -- you got the captain, you 7 know, we got the techs that work in there. 8 We've got their glass is behind - what we call 9 in control center - behind a box. You know, we 10 can get that box open. 11 : So, he said that the only 12 way to be able to get into it is if he broke 13 the glass -- 14 : He can break the glass. 15 : mm-hmm. It's okay 16 that he would have done that? And then, should 17 have he? 18 : Yeah. If you couldn't 19 reach, you could just -. Well, he should have 20 gone to the captain or somebody and said, hey, 21 captain, I need to get into your SIS office. 22 : Do you think it's at all 23 acceptable, if knew on August 8th that these 24 cameras were down, and he didn't actually start 25 working on it, or at least, I guess he was EFTA00059239

LIMITED OFFICIAL USE 370 1 working on getting the parts, but then got the 2 parts again on the, some time on the 9th, 3 claims he didn't work on it because he couldn't 4 get into it, into the SIS office. So, he was 5 going to work on it on the 10th, on that 6 Saturday. 7 : So, the question -- 8 : -- and what is your -? 9 : -- the question I would pose 10 to you is, did he notify anybody that he 11 couldn't get in there? Did he make any attempt 12 to contact the captain, or anybody to say, hey, 13 I need to get into that office to get a part to 14 do it, because if he had told the captain that, 15 the captain would have got that office open for 16 him. 17 : Yeah. I agree with you. 18 It's a he says that the MCC was a different 19 So, at any other BOP institution, in the 20 country, that would have happened with, his 21 experience taught him that, at the MCC, 22 basically it could wait until tomorrow. 23 MR. HAYES: They wait until tomorrow. 24 : So, so that's his opinion. 25 But again, I'm going to pose a question. Who EFTA00059240

LIMITED OFFICIAL USE 371 1 did he bring up the issue to? Because my thing 2 is, if you know it's an emergency, and it's a 3 situation to say this is the MCC, is a cop-out. 4 : And is it, would that be 5 classified as an emergency? 6 : If the cameras are down, 7 yeah. 8 : That is an emergency. So 9 10 : Let's get them back. 11 : -- he should have 12 absolutely gotten into that room -- 13 : He should have gotten -- 14 one way or another? 15 in there, and he knows he 16 could have gotten into the room, because you 17 can, we can break - if he said that stuff was 18 sitting in there, whatever room he said it in 19 there, guess what? You can break glass. You 20 can break glass after hours, if you need to, 21 and it's an emergency to get in, into an area. 22 : So, his claim is that, he 23 has rebuilt these things so many times. And 24 every knew that these cameras needed to be 25 reinstalled, and he had been saying that they EFTA00059241

LIMITED OFFICIAL USE 372 1 needed to be reinstalled. And now he's being 2 looked at as the fall guy. 3 MR. HAYES: You know, it sounds like he 4 could, you know -. 5 : I don't -. This is not an 6 issue of being the fall guy. 7 : Right. 8 : So, let's take every issue 9 we just talked about. We talked about the 10 camera project that we were working on. 11 : Mm-hmm. 12 : We were getting the people 13 in there to working. So now, let's talk about 14 the specific issue that you were talking about. 15 He did not notify anybody to get into that 16 room, to get to that part. That part was to 17 fix the current system. It had nothing to do 18 with the new system coming in. This is, he is 19 saying that this was a part that we needed to 20 fix, get put in, to deal with the current 21 system. 22 : Now, what about the fact 23 that is saying both she and 24 the II knew that the cameras were down on 25 August 8th. They told to fix them. And EFTA00059242

LIMITED OFFICIAL USE 373 1 they also notified so that 2 she not only notified the captain, but wrote a 3 memo and provided it to him about the cameras 4 being down on the 8th. 5 : Right. 6 : So, at that point, what 7 are the responsibility of the captain and the 8 II? 9 : So, what the captain does is 10 he notifies facilities where works for, 11 and says, hey, the cameras are broken, you need 12 to fix them. 13 : So, should the captain 14 have, on the 9th, ensured that those things 15 were fixed? 16 : Well, I don't know what 17 conversation he had with facilities to say we 18 are getting, you know, was it being fixed or 19 not. 20 MR. HAYES: Well, do you know 21 (Indiscernible *04:23:25). If he knows to tell 22 somebody on the 9th, is it possible to fix it 23 on the 9th? 24 : Well, the 9th is a 25 Friday. So, the 8th is when we are told that EFTA00059243

LIMITED OFFICIAL USE 374 1 he was told, informed, learned. 2 : Right. 3 : So, we have all Friday on 4 the 9th to make sure it's done. 5 : Right. 6 : On the 10th, 7 unfortunately, is when -- 8 : But -- 9 : -- we know the severity 10 of the issue. 11 : -- but that's my point. You 12 knew that, okay, you were made aware that the 13 cameras needed to be fixed. Okay. So, your 14 answers, what you are saying is, I couldn't get 15 into a certain area, so -- 16 : Well, that's what 17 is saying. Yeah. 18 : -- but that, okay, but -- 19 : But my question is, 20 should the II or the captain have followed up 21 with that, to make sure that it was actually 22 being done. 23 : And to them, I don't, you 24 know, I don't want to make the assumption 25 because I don't know. There could have been EFTA00059244

LIMITED OFFICIAL USE 375 1 some follow up. I don't want to speak on it, 2 but you know, if he had told him something on 3 the 8th, you know, I don't know the 4 conversations that were taking place between 5 them. Like, where is that, and what is he 6 saying? Right now, I'm responding to what he 7 is saying, and it makes no sense. 8 : Yeah. No. I would just 9 think that, you know, being a captain or a II 10 would be -- 11 : Right. 12 : -- whoa. The cameras are 13 down in the institution? 14 : Right. 15 : Well, let's make sure 16 that those things are back up -- 17 : So, and -- 18 : -- so they would at least 19 check back in on the 9th, and say -- 20 : -- and then -- 21 : -- where are we at on 22 this thing? 23 : -- but then, I don't know, 24 you know, what that conversation was. I don't 25 know if, on the 9th, even came to work. EFTA00059245

LIMITED OFFICIAL USE 376 1 : Right. 2 : I don't know. He could have 3 said -- 4 : Well, we do -- 5 : -- oh, well, I'm not going 6 7 : -- we know. But yeah. 8 : -- huh? 9 : And we know. 10 : Right. 11 : Yeah. 12 : So, I don't know. I don't 13 want to speculate on that part. 14 : Yeah, yeah, no. That's 15 what we are trying to tell you. Is, like 16 : Right. 17 : -- we know he was there. 18 : Right. 19 : On the 8th, he couldn't 20 get the parts. On the 9th, he got the parts. 21 But then, he said, he tried to get into the SIS 22 office. He was told by the - it wasn't an SIS 23 tech, because there were only two people there. 24 It was somebody that -- 25 : Monitored. EFTA00059246

LIMITED OFFICIAL USE /-- 1 : -- monitored the 2 telephones. I think he's now retired. Tay? 3 : Tay. Yeah. 4 : Was there. And he said, 5 I'm getting ready to leave, and he can't come 6 in here without me. And then, he said, I 7 didn't have access to the room after that. So, 8 my plan was to come in on the 10th, the 9 Saturday, because I was coming in anyway. And 10 that's what I was going to work on. 11 : He's the com shop. He can 12 go anywhere, where there are computers. 13 : So, that is not an 14 acceptable answer that he provided? 15 : I don't understand that 16 answer. 17 : Okay. 18 : It's because that room is 19 not in where the SIS shop is. That's the phone 20 monitor room. That's the camera room. 21 : And the key for the camera 22 room is how, I think it's only the SIS 23 , and the SIA that has the keys for 24 it. 25 : That's what the SIS EFTA00059247

LIMITED OFFICIAL USE 378 1 office said -- 2 : So, the -- 3 : -- they said that -. 4 : -- the phone monitor is, 5 he's in the SIS, but he draws keys to get into 6 that room. So, that room is all -. And you 7 can draw keys to get into that room. 8 : Yeah. 9 : When you saw draw keys, what 10 do you mean? 11 : Well, you get them from 12 control center. 13 : Okay. 14 : Yeah. 15 : You know? 16 : Well, we were told by 17 , the only way he could have 18 gotten them is to break the glass, which he 19 could have done. But -. 20 : You could have broken the 21 glass. And that time of time it was 8:00. The 22 captain is there. The security officer who 23 controls all the keys in the institution is 24 there. 25 : Right. EFTA00059248

LIMITED OFFICIAL USE 1 : You can go to them and say, 2 hey, I need -- 3 MR. HAYES: The key. 4 : Now -- 5 : I need the key. 6 : -- now, did either the 7 captain or the II inform you of this issue? 8 : No. I don't -- 9 : So, you didn't know -- 10 I don't 11 : -- anything about this? 12 : -- recall anything about 13 that issue. 14 : Should have they? 15 : So, if -- 16 : If it was a Thursday, 17 they found out, and it was all -. You weren't 18 there for that. 19 : I weren't there on Friday. 20 : Okay. 21 : I wasn't there on Friday. 22 : You weren't even -- 23 : Yeah. 24 : -- there on Friday. 25 : So, you know -. 379 EFTA00059249

LIMITED OFFICIAL USE 380 1 : And who - I'm sorry - can 2 you remind me, who was acting in your stead on 3 Friday? 4 : I believe it was 5 , I think. 6 : Okay. 7 : So. 8 : Now -- 9 : Okay. 10 : Yeah. 11 : So, you weren't even 12 there. 13 : Yeah. 14 : Our understanding is, I think 15 was in the institution, too, 16 about 8:00 p.m. 17 : Mm-hmm. 18 : On the 9th. 19 : On the 9th. 20 : Right. 21 : So -- 22 : On Friday. 23 : could have been to 24 any time during that period? 25 : He could have seen him. I EFTA00059250

LIMITED OFFICIAL USE 381 1 mean, just, you can't -. If it's an emergency 2 to get something for, I don't understand. That 3 is not -. 4 : No. That's great to 5 know. 6 : Yeah. 7 : About this. So, you say 8 that's not acceptable. 9 : No. You can, you can get in 10 there. So, I don't know -. 11 MR. HAYES: Well, one of the things is, is 12 in prison, you need a camera. Yeah. 13 : Right. Especially in the 14 SHU. 15 MR. HAYES: Right. Especially in the SHU. 16 : Now, who was responsible 17 to have the new camera system installed? 18 : What do you mean as far as 19 responsible? 20 : Like, who had overall 21 oversight on that? 22 : The facilities manager. 23 24 -: . Yeah. So, he - 25 EFTA00059251

LIMITED OFFICIAL USE 382 1 : All right. 2 -- gets the people in there, 3 but we're allocating things. But again, I want 4 to say, that was, you know, with manpower. 5 : Okay. Now, you've pretty 6 much answered this, and you can say it's the 7 same answer, but I just want to read you the 8 question. What are your thoughts on the fact 9 that the new camera system was there since 10 October 2018, but it wasn't installed after the 11 Epstein incident that occurred on August 10th, 12 2019? 13 : It's the manpower. 14 : Manpower. 15 : Yeah. You know, getting 16 people, qualified people in there to do it. 17 mean, one person couldn't do that. It was, and 18 we were putting in new cameras in new areas. 19 So, he needed more people. One person couldn't 20 do it. 21 : Okay. Do you mind just 22 initialing? And don't have to go through this, 23 just the top is fine. Anything more on the 24 camera issue? 25 MR. HAYES: Oh, Christ. You got more EFTA00059252

LIMITED OFFICIAL USE 1 issues? 2 : No. I think the -. We 3 have one more issue, and then just a couple of 4 questions based upon the BOP's findings. It 5 does say that there's leaks information. Where 6 are those emails? 7 : It was in -. Did we mix that 8 up? 9 : Here it is. So, here is 10 two emails that were sent both from 11 One to you, and one to (Phonetic 12 Sp. *04:29:13). : Yeah. He was the 14 at the time. 15 16 : Yeah. 17 : Okay. So, the first one 18 was on August 10th, 2019, at 6:14 p.m. to you. 19 And the subject is, "Urgent request. Potential 20 leak in hospital regarding Epstein's death." 21 : Mm-hmm. 22 : It looks like -- 23 MR. HAYES: You mean -- 24 : -- where is the -- 25 MR. HAYES: -- media leak? EFTA00059253

LIMITED OFFICIAL USE 384 1 : -- yeah. It says, 2 "Please ensure this information is given to the 3 OIG FBI. Thanks." 4 : Mm-hmm. 5 : And then, this next one, 6 like you said, is from to the director. 7 Subject, "Prison guards skip mandatory checks 8 before Epstein's death." This, the body says, 9 "Couldn't see the entire article on my phone, 10 but I wouldn't be surprised there are staff 11 that are paid contacts for local media outlets. 12 This has also been discussed at the department 13 level, all the way to the White House. And who 14 knows who may have overheard those 15 discussions." 16 : Mm-hmm. 17 : Do you know anything 18 about leaks in the media from the MCC? 19 : So, what happened was, when 20 came to see me, the issue we had was - 21 and I told him about it - was there was a 22 article in the Post that took a picture of our 23 staff, and our staff rode with Epstein on it. 24 So, I told about it, and I guess they 25 said one of the paramedics had leaked the EFTA00059254

LIMITED OFFICIAL USE 385 1 information. 2 : Like, took a picture of 3 them, like -- 4 : Took a picture -- 5 : -- posing with him? 6 : -- took a picture of them 7 coming in the room, when they got to the 8 emergency room. Took a picture of Epstein 9 being rolled in. And our - what do you call 10 it? - and our staff. So, I talked to 11 about that, and then, I had also told him that, 12 you know, there might be some staff, you know, 13 because, and I didn't know where it was coming 14 from, because the information was just coming 15 out, you know, so quickly, and it was, like, 16 where is this, you know, coming from? So, I 17 called and made him aware, you know, told him 18 about it when he came on Sunday. But the main 19 one was because of the picture in the Post. 20 : Now, who is it that you 21 suspect would have been leaking information to 22 him? 23 : I couldn't, I couldn't even 24 tell. But I just was, you know, with this 25 whole thing. You know, stuff would leak, had EFTA00059255

LIMITED OFFICIAL USE 1 2 3 4 5 been leaked out to the media, and you are, like, where is this coming from? Do you have any suspicions, though? : I can't speculate. I mean - 6 7 MR. HAYES: That's my boy. I mean, I 8 don't know nothing. 9 : (Indiscernible *04:31:48). 10 : You're talking like an 11 attorney. 12 : No, I mean -- 13 MR. HAYES: But like that, I don't know 14 nothing, but what I do know, I don't know. 15 : I mean, I can't speculate. 16 I mean, the half of it was towards me. I mean, 17 so -. 18 : Did you leak the 19 information, you mean? 20 : No. I said it was towards 21 me. 22 : Oh, you mean the 23 information -- 24 : Like, the negative press -- 25 : -- and the negative to EFTA00059256

LIMITED OFFICIAL USE 387 1 you? 2 : -- yeah. It reverted back 3 to me. 4 : Uh-huh. 5 : So, I mean, that's, you 6 know, and it was just, it was fast and furious. 7 : So, like, negative things 8 to people, you believe someone in the BOP was 9 leaking negative information about you? 10 : I don't -. I mean, I, you 11 know -- 12 : Can you give me, like, an 13 example of what was leaked about you? 14 : Well, I mean, you know, 15 stuff that happened, you know -- 16 MR. HAYES: Listen, the -- 17 and I'm not saying 18 MR. HAYES: -- (Indiscernible *04:32:26) 19 investigation was going on. 20 : -- specifically -- 21 MR. HAYES: I mean, you know -- 22 : -- specifically -- 23 MR. HAYES: -- whose fault is it? 24 right. Towards me. But 25 it was just automatically the blame was, you EFTA00059257

LIMITED OFFICIAL USE 388 1 know, put on me. 2 : Mm-hmm. 3 : And then, you know, the 4 other part of it was, I don't know if it came 5 from the department. I don't know if it came 6 from the institution. 7 : Okay. 8 : Because all that information 9 was going, you know -- 10 : But did anybody -- 11 up on different levels. 12 : -- did anyone tell you 13 that they believed that a certain person was 14 leaking information? 15 : No. I didn't hear if it was 16 a certain person. I didn't, you know? 17 : Okay. And did you leak 18 any information to the media? 19 : Absolutely not. 20 : Okay. Do you mind just 21 initialing and dating that? Do you believe, 22 though, somebody in the BOP was leaking 23 information? 24 : And I'm not -- 25 : And I don't mean that EFTA00059258

LIMITED OFFICIAL USE 389 1 personally. I just mean 2 : -- no. But -- 3 : -- you know, you could 4 always get -- 5 : - I don't -- 6 : -- the second one under 7 there. 8 : -- it could have been up to 9 the department, because the information was 10 going up to them. I mean -- 11 : But I just mean, like, 12 based upon what information was being leaked, 13 do you believe that someone in the BOP - not 14 necessarily the MCC, I just mean BOP - was 15 leaking the information? 16 : I will put it this way. The 17 Department of Justice might -- 18 : Yeah. 19 because all the 20 information -- 21 : Because it could be -- 22 : -- was -. Yeah. 23 : OIG. FBI. 24 : Initial. 25 : Anybody. EFTA00059259

LIMITED OFFICIAL USE 390 1 : It could have been anybody. 2 So, I don't want to -- 3 : Gotcha. 4 : -- kind of put it S : Sure. 6 : -- on one person. 7 : All right. The last 8 actual topic, before we ask a couple about the, 9 a couple about the findings. Epstein's will. 10 : Mm-hmm. 11 : Do you know anything 12 about Epstein changing his will just prior to 13 his death? 14 : Mo. 15 : Had you ever heard that? 16 : After the fact. 17 : Right. And when you say 18 after the fact, how did you learn about it 19 after the fact? 20 : I don't know. Reading it. 21 Or hearing it on the news. 22 : Did you ever hear about 23 it in an official capacity? 24 : No. 25 : All right. Do you know EFTA00059260

LIMITED OFFICIAL USE 391 1 if it's true? 2 : Don't know. 3 : Okay. 4 MR. HAYES: He left this all to his 5 brother. Right? 6 : I -- 7 MR. HAYES: Is that true? 8 : I can't comment on 9 that kind of stuff. But what actions should 10 have been taken, or you don't know if it was. 11 If it was learned that Epstein's will had been 12 changed just prior to his death, do you believe 13 any specific actions should have been taken? 14 : I don't know anything. 15 mean, I can't comment on that. 16 : Okay. So, that's the 17 last of the topics. Now, we have - 18 (Indiscernible *04:34:38) refer to it - I don't 19 think we have to refer to anything other than 20 the - where is that? 21 : The after action? 22 : Yeah. Do you have it? 23 And I don't know what we actually need to cite 24 (Indiscernible *04:34:53) initial them. This 25 is the after action report. Is that -? That EFTA00059261

LIMITED OFFICIAL USE 392 1 the BOP created in response. So, just a few 2 quick questions on it. It says, "On August 3 1st, 2019, at 8:30 a.m., psychology documented 4 they were notified by correctional systems of a 5 form received from the United States Marshal 6 Service, the previous day, stating inmate 7 Epstein had reported suicidal tendencies." 8 : Mm-hmm. 9 : Do you know anything 10 about that, and what transpired? 11 : Wait. Read that again. 12 : So, "On August." So, 13 just to refresh your memory of a time, 14 timeline. On July 30th, he comes off of 15 psychological -- 16 : Psychological observation. 17 : -- observation. 18 : Right. 19 : And goes to the SHU. 20 "Two days later" - so, there's July 31st and 21 August 1st - "8:30 a.m., psychology documented 22 they were notified by correctional systems of a 23 form received from the United States Marshal 24 Service, the previous day." So, I guess on 25 July 30th. EFTA00059262

LIMITED OFFICIAL USE 1 2 Mm-hmm. : The 31st, I mean. 393 3 "Stating inmate Epstein had reported suicidal 4 tendencies." This was the BOP's finding. Do 5 you know anything about that? 6 : I don't know anything about 7 that. And that's before, when he first came in 8 the system, or -? 9 : No. That was after he 10 came off of psychological observation. So, 11 after his actual first attempt at suicide. 12 : Right. 13 : Or potential harm from 14 Tartaglione. 15 : No. I didn't. 16 : You don't know anything 17 about that? 18 : Nuh-uh. 19 : Okay. And do you know 20 anything about the suicidal tendencies that he 21 was showing? 22 : No. 23 : No. All right. And 24 then, on the same date, August 1st, 2019, 25 again, this is after the Tartaglione incident. EFTA00059263

LIMITED OFFICIAL USE 1 2 394 : Mm-hmm. And after coming off of 3 psychological observation. "1:00 p.m. 4 Psychology conducts a suicide risk assessment 5 noting watch is not indicated, with a 6 recommendation for follow up in one week. The 7 delay in conducting this assessment is not 8 justified in the report." Did you learn 9 anything about that? 10 : No. I don't. 11 : Yeah, yeah. 12 : I -- 13 : And again -- 14 : -- it's psychological. 15 : -- this is just some of 16 the -- 17 MR. HAYES: Yeah. 18 : -- the negative findings. 19 : Okay. 20 : We just want to know your 21 take on it. I don't expect you to know any, 22 all of this, or anything. 23 : Right. 24 : It's just asking because 25 there's some negative findings. Okay. The EFTA00059264

LIMITED OFFICIAL USE 395 1 next one. It says, "Significant -- 2 MR. HAYES: Don't bring this guy in on 3 another case. All right? If the next time 4 this comes up, and he says, I'm going to bring 5 this guy, don't fucking do it. 6 : It says, "Significant 7 discrepancies exist within Sentry, regarding 8 admission/release status, ARS." 9 : Right. 10 : Sentry does not reflect 11 inmate Epstein being escorted from the 12 institution by the U.S. Marshal Service on July 13 31st, 2019. Although a signed prisoner remand 14 form is on file, documenting -- 15 : Mm-hmm. 16 : having received him 17 from the U.S. Marshal Service. Additional 18 review revealed inmate Epstein departed the 19 institution for a total of four court 20 appearances, and only one of these occasions 21 was an ARS change made within Sentry. It 22 appears there is a culture of foregoing this 23 vital function, due to the likelihood of the 24 inmate returning from court. This lapse in 25 procedure is a severe inmate accountability EFTA00059265

LIMITED OFFICIAL USE 396 1 deficiency." 2 : Well, that statement is 3 incorrect. I know the regional office looked 4 into it and said that a pre-trial institution 5 can outcount an inmate to go into court. So, 6 he doesn't have to be keyed out on the ARS. 7 : Okay. 8 : So, the way they were doing 9 it, they looked at it after the fact, and said 10 there was nothing wrong with that. 11 : So, they did re-review 12 this matter, and -- 13 : Yes. 14 : -- said that there was -- 15 : They were fine 16 : -- they were doing it 17 with it. 18 : Okay. 19 : Yeah. Because they kept 20 thinking, when they were looking out, same 21 thing like you said, he was going out to court, 22 but they can outcount him in that area. 23 : All right. And what are 24 they talking about, like, pre-removing him or 25 something like that, when he goes to court? EFTA00059266

LIMITED OFFICIAL USE 1 2 No. Going to court. : Yeah, yeah. 397 3 : And if anyone is going to 4 court, because you have so much court movement 5 that you can outcount them. And then, when the 6 Marshals say, hey, he's not going out, then you 7 release him out of -- 8 : So, this is -- 9 : Okay. 10 -- this means, on the El, he 11 would be listed on the outcount? 12 : As court. 13 : As court. 14 : Yeah. 15 : Okay. 16 : And that's what they were 17 actually doing? 18 : That's what they were doing. 19 : Okay. 20 : They had him on the El. 21 : So -- 22 : Yeah. 23 : -- so, this is no longer 24 25 : That's not -- EFTA00059267

LIMITED OFFICIAL USE 398 1 : -- an issue. 2 : -- an issue. 3 : All right. The next one, 4 it says, "No notations concerning a requirement 5 for a cellmate were entered into the SHU 6 program, and subsequently available for SHU 7 officers to reference." Who would have been 8 responsible for noting that in the SHU program? 9 : So -. 10 : First of all, what is the 11 SHU program? 12 : The SHU program is -- 13 : Is that the 292? 14 with the 292s. So, 1 15 don't know, from what I understand, and was 16 told after the fact, that they couldn't find 17 the information on Epstein in the SHU program. 18 So, I don't know how you came to that 19 conclusion. 20 MR. HAYES: By the way, let the record 21 indicate that he is not sweating under his 22 armpits. A good sign. 23 : We didn't. BOP came to 24 these conclusions. 25 : Right. So, I don't know EFTA00059268

LIMITED OFFICIAL USE 399 1 where that conclusion came from because from 2 what I gather, they couldn't get - they 3 couldn't find the -. Because usually -- 4 : Well, they found the 5 292s, but they were just very limited. 6 : Right. The 292s usually had 7 to have everything indicated on it. So 8 : And on that note, we were 9 told the 292, his file, was extremely small, 10 and it should have been larger. Had you heard 11 anything about people removing documents from 12 files? 13 : From what I understand, and 14 was told, that there was no file. They 15 couldn't -. They had every other inmate's 16 file, but not his. 17 : They couldn't even find 18 it. You didn't think they could find his file 19 at all? 20 : No. That's what was told to 21 me. 22 : And who told you that? 23 : I think I heard that after 24 the fact. I don't know if the regional 25 director told me after they came in and did the EFTA00059269

LIMITED OFFICIAL USE 400 1 check, that they couldn't find it. So, I don't 2 know. 3 MR. HAYES: That's after they found out 4 the Hilary Clinton -- 5 : Yeah. 6 MR. HAYES: -- came down and had them 7 (Indiscernible *04:40:44) a certain 8 (Indiscernible *04:40:45). 9 : Right. 10 : But back to the original 11 question, whether it was there or not. 12 : Right. 13 : If it, the cellmate 14 requirement was not entered in the SHU program, 15 who should have made sure that it was? 16 : On the, in the 292? And I 17 don't know who was doing it. It should have 18 been the lieutenant, to ensuring that it's all 19 in there. 20 : So, the SHU lieutenant? 21 : When they - yeah - when they 22 deny it, or the OIC. So, if the captain 23 conveyed the information to him, that should 24 have been put on the 292. 25 : So, either EFTA00059270