201 1 : Yes. 2 : So that's why I thought 3 it was decided to put Epstein in that one. 4 : Right. Because it's right 5 off the -. 6 : So what I'm asking is, do 7 you know who made that decision? 8 : Probably between the 9 Captain, AW and the Warden. 10 : So at that point, he's in 11 220. Who is responsible for making sure that 12 he's coded at 220? 13 : Well, when he came - when 14 he comes up from suicide watch, it should have 15 been Control. 16 : So Control apparently put 17 him in, what you're saying, in 206? 18 : Correct. 19 : So after he's now in - 20 he's not in 206, he's in 220, who is 21 responsible for making that change? 22 : Well, whoever notices it or 23 when we conduct the bed book count which most 24 likely we didn't. It regularly should have 25 been me to key him, "Oh, okay, he's there," but EFTA00060573

202 1 I never saw that he was in the wrong cell. 2 : So that's what I guess, 3 so how would that - so I guess the question is, 4 how would it be noticed that he was in the 5 wrong cell? Is that something that's supposed 6 to be like reviewed or you're supposed to be 7 checking? How does that -- 8 : When you conduct a bed -. 9 : -- and I don't know, so 10 again 11 : Well, no, when you conduct 12 a bed book count, which now, it happens every 13 week, before, maybe once a month, or the next 14 time you notice would be, "Oh, 21 days to move 15 him," you would have came out that cell and he 16 was never in that cell. But you still see him, 17 you see who is there. 18 : Yeah, yeah. 19 : But you just don't verify 20 with the bed book count. 21 : Now, are you confident 22 that he was always in 220 though from the time 23 he returned from suicide watch? 24 : That I remember? Yes. 25 : All right. EFTA00060574

203 1 : The only time I remember he 2 was in another cell, was when he was in 3 cell, which that was right before 4 he went to suicide watch. 5 : Okay. From the time he 6 came back from suicide watch, he was always in 7 220. 8 : Yes. 9 : And this, 206, was that 10 just an administrative error? 11 : That most likely was. 12 : Okay. 13 : Because I know he was up 14 there. 15 : All right. 16 : So after , which 17 I wasn't even here when that happened, after he 18 was his bunkie, he was placed on suicide watch 19 and I think I came back and he was already up 20 there in the cell. 21 : All right. So the only 22 two cells that you know of is when he was with 23 and then when he returned from -. 24 : Yes. 25 : So from basically July, EFTA00060575

204 1 at least 30th, the 29th, to August 10th, 220 is 2 the cell he was always in? 3 : Yes. 4 : This 206 thing was an 5 administrative error. 6 : Correct. 7 : And it would have been 8 caught if there were weekly bed book counts 9 done. 10 : Yes. 11 : All right, and that's - 12 other than that bed book count, is there 13 another time that that would have been that 14 that could have been or should have been 15 caught? 16 : Maybe when, if you were 17 moving him, if you were moving his bunkie, but 18 there's no -. 19 : Okay, get a note to make 20 sure we ask for Reyes's cell assignment. And 21 he was always from 220 - I mean, from 7/29 to 22 8/10 - July 29th to August 10th, he was always 23 with Reyes? 24 : Yes. 25 : Okay. All right. Now EFTA00060576

205 1 we're going to talk about - do you mind just 2 initialing. Now would the Lieutenant have any 3 oversight over this as well? 4 : If he was there, yes. 5 : Is that something he 6 suppo- he's, you know, I think it was, we were 7 told that the Lieutenant comes in and audits 8 the books and things like that. Is this 9 something that he would have been auditing? 10 : I'm not sure if that's - 11 because I haven't worked like as a SHU 12 Lieutenant, but he does have to confirm the 13 rounds. Only way he would order that is 14 probably before the SHU meeting, which the SHU 15 meetings we usually had on Thursdays. 16 : Okay. Anything more you 17 want to ask on that? 18 : I don't know if you want him 19 to sign the SHU. 20 : We're still going to look 21 at that. So, this has been a great confusion 22 too that we're hoping you can help us. What 23 cameras are actually located in the SHU outside 24 of 10 South and G Tier? 25 : At this point in time. EFTA00060577

206 1 : So, not at this point in 2 time, in August of 2019. 3 : So in August we only had 4 : I'm sorry, man. Sorry. 5 : -- one camera at the end of 6 the range. So you walk in through the rear 7 door. 8 : Can you - again, I guess 9 this is too confusing. 10 : So -. 11 : Are you able to determine 12 - if we're saying that this is the second 13 floor, here is L Tier. There is Epstein's cell 14 -- 15 : So there was always -- 16 : -- officer's station. 17 : -- a camera right here. 18 : That points down this 19 range? 20 : Yeah. 21 : All right. So that 22 should have been at least where Epstein's cell 23 was located. 24 : Well, it wouldn't - it 25 would see both. EFTA00060578

207 1 : We have this camera 2 angle. Where is this camera? This is the 3 officer's station. 4 : That - this is outside of 5 10 South, which is the second floor and this is 6 the other office that I was in, the 7 Lieutenant's office on top. 8 : Okay. So the 9 Lieutenant's office is here. 10 : Yes. 11 : So, LT right there. 12 : Uh-huh. 13 : And then this floor 14 though is 10 South? 15 16 to 10 South. 17 : Yes. This is the entrance : 10 - I'm putting 10 South 18 on the door and pointing to the LT's door. Is 19 this the officer's station? 20 : Yes. 21 : I'm circling the 22 officer's station. Where would Epstein have 23 been located? 24 : It's up - you can't see it 25 through there. EFTA00060579

208 1 : This over here? 2 : Yeah. 3 : So I'm going to put E and 4 pointing to it. So that's where Epstein's cell 5 would have been. What is this over here? 6 : That's on J Tier. 7 : That would have been G 8 Tier? All right, so I'm going to put G 9 10 11 J, J. : J? Oh. : Yeah, J as in Jack. 12 : J up that way. All 13 right. So that's our point of reference. What 14 other cameras other than this should have there 15 been in the SHU? 16 : Well, there's another one 17 out here that focused on the whole MPA, which 18 the MPA is this general right here area. 19 : Okay. 20 : And then every range, when 21 you walk in, has a camera towards the end. 22 This is -- 23 24 25 : So every range -- : -- in August. : -- is supposed to have a EFTA00060580

209 1 2 3 4 camera? : have them there. Yes. They did. They still : So when you call it a 5 range, you're talking about -- 6 : All right, so 7 : -- each tier? 8 : Yes, each tier. So, I walk 9 into the tier, there's a camera at the end of 10 all of them. Now -. 11 : So, every one of them 12 should have had a camera. 13 : Yes. They did have 14 cameras, they are still there. 15 : That should have been 16 working. 17 : Correct. 18 : Ok so. 19 : They're still there, the 20 cameras. 21 : Are you able to tell, 22 what is this a picture of? 23 : That's the Sally port, the 24 visiting elevator. 25 : On the 9th floor? EFTA00060581

210 1 2 3 4 : Yep. : So when you say, "Visiting elevator," what does that mean? : So you walk in through the 5 first floor and only - if there's visitors, you 6 can come out through there. So -. 7 : You can visit the SHU? 8 : Yes. 9 : Like outsiders? 10 : Yes. Visit the SHU 11 inmates. 12 : I didn't know that. So 13 instead of bringing the SHU, the inmates 14 downstairs, the visitors actually -- 15 : Yep. 16 : -- come into the SHU? 17 : And they walk into the room 18 in here, they sit down with their visitors. 19 : So this is called the -. 20 : 9 Sally - 9 visiting Sally. 21 : 9 -- 22 : Visiting Sally. 23 : -- visiting - is Sally, 24 S-A-L-L-Y? 25 : Yes. EFTA00060582

211 1 : All right, the second one 2 we just went over. That's from 10 South 3 outside of. What is this? 4 : That's 10 South. 5 : This is 10 South? And 6 this again is 10 South? 7 : Yes. 8 : And again, 10 South. Is 9 there a reason why - did you want to identify - 10 11 : No, no, it's okay. 12 : I'm going to actually 13 take those -- 14 : Yeah. 15 : -- pictures out of this 16 and just look at those three. All right. So 17 the fact that we only have these three camera 18 angles and saying that these are the three that 19 are only working, do you know anything about 20 that? Do you know if all those other cameras 21 should have been working on each of the ranges? 22 : Well, they should have. 23 : All right. So, each 24 tier, to your knowledge on every single one, 25 including on L Tier where Epstein was located, EFTA00060583

212 1 should have had a camera that pointed down. 2 : They should have a working 3 camera. They still have the camera. It works. 4 At that time, I don't know if it did or didn't, 5 but the camera was on the wall. It's there on 6 the wall. 7 : On the wall of every 8 tier. 9 : Correct. 10 : Including Epstein's tier. 11 : Yes. 12 : Do you know anything 13 about those cameras not working on August 9th 14 or August 10th? 15 : No. 16 : Do you know anything 17 about Epstein's tier, that camera not working 18 on -. 19 : No. 20 : Who is responsible for 21 making sure that the cameras were working? 22 : I think the Com Department. 23 Com Tech. 24 : And do you remember in 25 August 2019 who was working in the Com EFTA00060584

213 1 Department? Anybody? Is there a Mr. 2 : I think , that's the 3 only one. The only Com Tech that we've had and 4 that we still have. 5 : And he's still here? 6 : Yes. 7 ? All right, so 8 would be the person to talk to about 9 this? 10 : Maybe tell you more or less 11 if what cameras worked or didn't work at that 12 time. 13 : Okay. But no one ever 14 talked to you? Is there any way that as the 15 OIC or anybody that worked in the SHU that you 16 would have known that the cameras were or were 17 not working? 18 : No. 19 : So who - is there anybody 20 that live monitors any of those cameras? 21 : That I know of? No. 22 : All right. So you don't 23 know anything else about the cameras? Is this 24 the first you're hearing that these cameras 25 were down? EFTA00060585

214 1 : I mean, I've heard it in 2 the news, but not from the building. 3 : Is that - does that raise 4 any suspicion for you the fact that these 5 cameras aren't - they don't have video of these 6 cameras? 7 : Not really. This building, 8 there's always something going wrong in the 9 building. So, it wouldn't surprise me or 10 didn't surprise me when they said the cameras 11 weren't working. 12 : All right. But, I mean, 13 that many? If we have how many tiers are in 14 you just do this top page. That many 15 : In six tiers. 16 : Six tiers and we don't 17 have any cameras for any of the six tiers then. 18 Is that to you like, "Wait, what?" Does -. 19 : Not really. 20 : No? 21 : No, not really. Like I 22 said, sometimes the lights go off in the tier 23 and we got to reset the breaker, so ever since 24 I started, there's always been a problem with 25 something not working in this building. So the EFTA00060586

215 1 camera doesn't surprise me, it's just another 2 thing that didn't work for the moment. 3 : So this is where like, 4 it's just like, what are your - what is your 5 opinion on the fact that we got no cameras 6 working on at least, you know, definitely on 7 Epstein's tier, he's in the wrong cell, you 8 know, we could always - you know, the counts 9 are basically, you know, potentially falsified, 10 the counts weren't done. Is there anything 11 that you're seeing here that you're like, 12 "Somebody is covering up for somebody," or, 13 "Somebody is like manipulating things or 14 deleting cameras or taking anything down?" Is 15 there a reason for you to believe any of that? 16 : Mm, not really. I said, 17 going on seven years now, a lot of stuff has 18 gone wrong in this building and I highly doubt 19 that stuff was on purpose. My -. 20 : What about even to just 21 cover up -- 22 : My belief -. 23 : -- from what they were 24 doing administratively? Is there anybody that 25 would have been able to, like, knock cameras EFTA00060587

216 1 out or knock them down or manipulate them? 2 : No, because -. 3 : Do Lieutenants have the 4 ability to do that? 5 : No, the Lieutenants don't 6 and leaves at like, I think, at 2:00 in 7 the afternoon. 8 : So like, for instance, if 9 an Ops Lieutenant, would that - would an Ops 10 Lieutenant be able to -- 11 : Go somewhere 12 : -- manipulate the 13 cameras -- 14 : -- and turn the syst-. 15 : -- or anything? 16 : No. 17 : No? 18 : No. 19 : Even from like the camera 20 room or anything like that? 21 : No, we don't have access to 22 the camera room. 23 : Okay. 24 : We could log in to the 25 camera system, but we can't turn on or turn off EFTA00060588

217 1 any camera. 2 : So who has the ability to 3 turn on and turn off cameras? 4 : That should be the Com 5 shop. 6 : All right, so just 7 8 : Yes. 9 : -- is the only person 10 that can do it? Okay. Do you know who BOP 11 employee is? 12 : He's a case manager here. 13 : Okay. Still here? 14 : Yes. 15 : All right. Are you aware 16 on August 9, 2019, when worked and what 17 his responsibilities were, like in - I don't 18 even know if he's on here, let me see. 19 : I didn't even think he was 20 here that day. 21 : He was. Yeah, okay. So, 22 if you can find him on there and tell me if you 23 can figure out what his role and 24 responsibilities were, looking at the daily 25 assignment roster. EFTA00060589

218 1 2 : Yes. 3 : He's Unit Team, he wouldn't 4 be on this roster. 5 : Well, if you look at the 6 bottom, you'll find his name at least. 7 : That's 8 : That's a different one? 9 : Correct. 10 : All right. So Unit Team, 11 does that mean he's non-custody? 12 : Yes. 13 : Okay. And what were his 14 roles and responsibilities, do you know? 15 : He's a Case Manager, pretty 16 much serving incident reports, referring them 17 to DHO, give out legal phone calls. 18 : Okay. 19 : Deal with some 20 : Legal phone calls 21 : -- kind of legal -- 22 : -- is one of things that 23 -. 24 : -- legal paperwork. 25 : Okay. So -- EFTA00060590

219 1 : Make copies. 2 did you have any 3 conversations with on August 9, 2019 4 regarding Epstein? 5 : No. 6 : Did you ever - did you 7 remember ever talking with about 8 Epstein? 9 : Huh-uh. 10 : Do you know anything 11 about allowing Epstein to make a 12 telephone call on the evening of August 9, 13 2019? 14 : No. 15 : Did you hear anything 16 about that after the fact? 17 : No, and that's new. 18 : So do you know anything 19 about Epstein being authorized a telephone call 20 from the SHU? 21 : No. 22 : You ever hear anything 23 about Epstein making a telephone call from 24 inside the shower area? 25 : No. EFTA00060591

220 1 : Do you know about inmates 2 in general ever making telephone calls from 3 that shower? 4 : They're not supposed to. 5 : They're not supposed to? 6 : No. 7 : Is there a jack there 8 though? 9 : There's no jack close to 10 the shower. Usually for a phone call, we plug 11 in the phone to the jack and give them the 12 phone through the slot. They make their phone 13 call, 15 minutes are up, you take the phone 14 back. 15 : So Epstein placed a 16 telephone call from the shower, they plugged in 17 the thing, gave Epstein the telephone and then 18 closed the shower doors I guess and allowed him 19 to speak in there. Has that ever happened 20 before? 21 : The only place that I think 22 that would reach would be G Tier. Because 23 they're inside the tiers, the jacks weren't 24 working. 25 : And am I saying that EFTA00060592

221 1 correctly? 2 : Yeah, I think the shower was 3 in the G Tier. I think one 4 : It was a shower in the G 5 Tier 6 : Yeah. 7 : -- not in the L Tier, so 8 he placed a telephone call from a shower, not 9 necessarily the L Tier shower. So he placed a 10 telephone call from the shower, a shower and it 11 was plugged into a non-recorded line. 12 : Well, those are the legal 13 phone calls because we can't listen to the - or 14 the attorney phone calls aren't supposed to be 15 on a recorded line, from my understanding. 16 : All right. So is that 17 something that you would allow inmates to do? 18 : Personally, I put them 19 downstairs. 20 : When you say, 21 "Downstairs," where is that? 22 : In the recreation area, the 23 law library. 24 : So outside of the SHU? 25 : Correct. No, it's actually EFTA00060593

222 1 inside the SHU -- 2 3 : Okay. : -- but it's like a cage 4 that where the computers were and plug in the 5 phone in the tier and make it reach all the way 6 downstairs. 7 : Is it abnormal -- 8 : Not the shower. 9 : -- that they allowed 10 Epstein to place a call from the shower, 11 whichever shower it was, it sounds like G Tier 12 and use a legal line? 13 : Not really, unless there's 14 no - couldn't put him on the library or you 15 couldn't put him in the rec cage then. 16 : What if you told the officer 17 that he wanted to call his mother? 18 : You got social calls for 19 that and those calls, they would be recorded. 20 : And what would be a 21 reason why that it would be on a legal line to 22 call his, quote, unquote, mother? 23 24 25 : There shouldn't be. : There shouldn't be? : There shouldn't be. Use EFTA00060594

223 1 your minutes. 2 : So you hadn't heard 3 anything about this? 4 : No. 5 : This is the first you're 6 hearing of it? 7 8 9 abnormal that : Yes. : Okay. Would it be would have set this up 10 for him to be able to call his mother from the 11 shower then and plug it in the legal line? 12 : Unless he told him he was 13 calling his attorney, but even with that, 14 you've got to verify the attorney, "This is - 15 is this attorney such and such?" "Yes, okay, 16 I'm going to put your client on the phone." 17 That's how it should have been. 18 : And even at that, is 19 someone supposed to monitor that telephone 20 call? 21 : Well, he can't sit there 22 and listen to it, but once your time is up 23 then, "All right, give me the phone back." 24 : Okay. So no one is 25 actually supposed to sit there and actually EFTA00060595

224 1 monitor the call even though it's not recorded? 2 : Correct. 3 : They are not? 4 : They are not because of, 5 it's a legal call. 6 : Okay. And it's only a 7 legal call that's not supposed to be monitored? 8 : Correct. 9 : As far as a call to his 10 mother or anybody other than a legal call, it 11 should have been recorded? 12 : Yes. On a recorded line, 13 yes. 14 : And does everybody in the 15 SHU know that? 16 : Yes. 17 : Should known 18 that? 19 : Definitely. 20 : Okay. And when inmates 21 place calls from the SHU, how is that - how do 22 you keep track of that, if at all? 23 : Well, we have - on SENTRY, 24 we have the TRUFONE, so we just print that or 25 in SHU we should - 1 don't know if they're EFTA00060596

225 1 still doing it, they had a log book so you 2 request for the phone, I give it to you, I fill 3 it - I put your name down that you had a phone 4 call. 5 : So I guess that's what - 6 is it tr- Epstein didn't actually have one of 7 those like keypad things. 8 : PAC and PIN. 9 : Oh, he didn't have one? 10 : So if he didn't have one, 11 how would he place a call? 12 : He can't. 13 : So the only way he could 14 place a call is from an actual 15 : Unit Team, yes. 16 : So if the - if, in those 17 cases, are the calls supposed to be monitored? 18 : Yes. 19 : So in this case, if 20 Epstein placed a call and was told, like - my 21 understanding is got the approval to 22 allow him to place a call but left him in the 23 shower area, left the unit, and no one 24 monitored the call. Is that a problem? 25 : Yes. So -- EFTA00060597

226 1 : Who -. 2 : -- if it's -. 3 : Who should have been 4 responsible for monitoring that call? 5 : He should have. 6 • • 7 : Yes. He should just not 8 stand there and listen to his conversation, but 9 he should have verified -- 10 : Even if it's not a legal 11 call. 12 : Well, if he said -. 13 : So he doesn't have one of 14 these PAC and PINs, or whatever it's called and 15 they said he -. 16 : Then it's not going to be a 17 social call, then it's going to be a legal 18 call. 19 : No, no, no. What I'm 20 saying is, he doesn't have the ability to make 21 a social call, but he's provided the approval, 22 "Yes, allow him to make this call, but monitor 23 it," stood there? 24 : He should have stood by 25 there. EFTA00060598

227 1 : And is the one 2 who should have done that? 3 : Yes. Because he's the one 4 who put him on the phone. 5 : All right. And he 6 shouldn't have passed that responsibility off 7 to someone in the SHU? 8 : Correct. 9 : Okay. 10 : So if, for instance, the 11 Warden says, "Give Mr. Smith a phone call, a 12 five minute phone call but make sure you stand 13 there and monitor it," then, "Here's the phone, 14 it's going to be on a non-recorded line," but I 15 am going to stand there and listen to your 16 conversation because it's not a legal phone 17 call -- 18 : Right. 19 : -- it's just kind of like a 20 courtesy phone call, you're given the 21 opportunity to call your family. "Okay, you're 22 phone call is done? Thank you." Hang up the 23 phone and walk away. 24 : And how are those calls 25 allowed, did you say? EFTA00060599

228 1 : Should be a book. 2 : In a written book? 3 : A log book. Yes. 4 : Okay. Not in anything in 5 like a TRUSCOPE or anything 6 : No. 7 : -- like that? SENTRY? 8 : You could put it on 9 TRUSCOPE, just to kind of - in case something 10 like this happens, cover yourself. 11 : Okay. 12 : Let's say an order like that 13 did come down. Are they allowed to call any 14 person they wanted or does it have to be a 15 specific number off a list? 16 : It has to be a legal phone 17 call only. 18 : No, no, no. If -. 19 : Only to your attorneys. 20 : If he doesn't have the 21 ability to make a social call and they say 22 that, "Yes, allow him to have this social 23 call," would he even have a list if he never 24 : No. No, he could just call 25 whoever he wants to on the phone. EFTA00060600

229 1 : Okay. 2 : But I guess though, I 3 want to make sure you're understanding that 4 question. When you're given the ability to 5 make phone calls, they vet people and you have 6 a list of people that you're allowed to call, 7 correct? 8 : Right. 9 : Like the monitored calls. 10 If you're never given that - what's it called? 11 PAC and -. 12 : PIN and PAC. 13 : PIN and PAC, if you're 14 never given a PIN and PAC, do we even have a 15 list of people that you -. 16 : No. 17 : So he wouldn't actually 18 have a list. 19 : Correct. 20 : If you want to follow up 21 on that -- 22 : No, no, no. 23 : -- that's fine. But do 24 you know if he had a list or not? 25 : There was a - I think that EFTA00060601

230 1 someone has mentioned that there was a list, 2 but I'm not aware, I haven't seen a list, so I 3 just wondered if he would know. 4 : But if he doesn't have 5 the PIN and PAC, no list would have ever 6 : Just nothing would -- 7 : -- been generated, right? 8 : -- exist. 9 : Right. 10 : Unless his list of 11 attorneys, that would be the only list he 12 should have. 13 : Okay. 14 : When inmates are brought into 15 the MCC, are they asked for a list of people 16 that they would like to call or keep as a 17 contact, anything like that? 18 : So you're asked for an 19 emergency contact, and that's it. When you see 20 Unit Team, you give Unit Team a list of family 21 members or whoever you want to call, they put 22 it into the system. 23 : Okay. 24 : If it's attorneys, they 25 also have a list of attorneys that you can call EFTA00060602

231 1 and you only make that phone call with Unit 2 Team there present. 3 : If he did give that name to 4 the Unit Team, where would they put it? 5 : That would be Unit Team. I 6 don't know where they have 7 : Or it's not like in -. 8 : No, it's not in SENTRY 9 : Okay. 10 : -- like that. 11 : And to you, though, is 12 that extremely abnormal? Have you ever heard 13 of something like that before? Somebody being 14 provided a phone call? 15 : It's happened before. 16 : Not having one of these 17 PAC and PINs and then walking away and letting 18 them just speak? 19 : Well, it's happened where 20 they've given inmates a phone call or transfer 21 a phone call when they don't have a PIN and 22 PAC, but most of the time it's a five minutes 23 call whoever you're going to call, just like if 24 the Chaplain receives a death notification in 25 the family, he brings you up, he gives you that EFTA00060603

232 1 five minute phone call, but he's sitting there 2 next to you listening to your phone call. Once 3 your phone call is done, "Okay, go back to your 4 cell." 5 : But as far as, if this in 6 fact happened where gave him a call, 7 leaves the tier, after 15 minutes calls 8 somebody in the SHU and says, "Hey, let Epstein 9 know his telephone call is done and get the 10 phone back." Is that -- 11 : It's -. 12 : -- pretty problematic or 13 is it just -. 14 : It shouldn't happen, but 15 it's happened. 16 : Okay. 17 : It's happened. 18 : Do you think it's because 19 it was Epstein, he was a guy - "I want to give 20 him his privacy because he's got this --" you 21 know, "--he's -- 22 : Mm. 23 : -- he's got this air 24 around him, he's a big deal," or why do you 25 think would have done that? EFTA00060604

233 1 : Probably a million things 2 on his head to do. 3 : Okay. How severe do you 4 believe that that would be though or if at all? 5 : Should not have did that 6 because of what happened. 7 : Right. 8 : But if it didn't happen, 9 then it would be another regular inmate. 10 : Okay. Anything more on 11 that? How - we're getting - we're almost 12 there, I promise. How was Epstein's 13 interactions with other inmates? 14 : Well, he only spoke to two, 15 which was and 16 : Never really any other 17 dealings? 18 : Everybody was always trying 19 to talk to him. 20 : But he wouldn't talk 21 back? 22 : Just regular conversation, 23 nothing crazy. 24 : Well, how, I guess, how 25 were his interactions, I guess, with his cell EFTA00060605

234 1 2 3 4 mates then, with : and Well, he always got along : He did? 5 : -- that I understood. They 6 were both always talking. They never had issue 7 with each other. 8 : What about with 9 : None either. 10 : Okay. So both seemed to 11 get along fine? 12 : Yes. 13 : Okay. When was the last 14 time you interacted with or saw Epstein? 15 : That should have been, 16 what, August 9th. 17 : So August 9th, the day 18 you left work - last - what was his state of 19 mind at that time? 20 : He seemed calm. 21 : Yeah? Anything -- 22 : He actually -- 23 : -- any -. 24 : -- joked around because he 25 asked for a new jumper and I told him, "No." EFTA00060606

235 1 And he said, "Why not?" I was like, "It's a 2 jail, this is what you got to do. Nobody else 3 gets a jumper, it's not Versace," you know. 4 He's, "Ha, ha, ha, ha," he laughed and that's 5 it. I brought him downstairs to attorney 6 visit. 7 : Okay. Nothing abnormal 8 though or out of the ordinary? 9 : No. 10 : Okay. 11 : He was very polite. 12 : Was he complaining about 13 anything? 14 : No. 15 : Aside from the jumper? 16 : Not really. 17 : Did he talk about any 18 other inmates or anything? 19 : No, he just, like normal. 20 : Express that he was in 21 fear or anything like that? 22 : No. He was just, you know, 23 always worried about his attorney visit. 24 : Were any threats made to 25 Epstein that you're aware of? EFTA00060607

236 1 2 3 was in prison? 4 : No. : Do you know why Epstein : Because of - what is it, 5 the child molestation and a bunch of other 6 stuff according to the news. 7 : And did you have any 8 specific feelings with regard to why he was in 9 prison? 10 : Not really, to me, just an 11 inmate. 12 : And would you have pretty 13 frequent conversations with Epstein? 14 : Mornings, I mean, "What's 15 up? You all right?" "Yeah, I'm good." 16 "Okay." 17 : Anything of substance 18 other than just, "Hello?" 19 : No. 20 : No? And you said you 21 didn't work on August 10th, correct? 22 23 24 25 Monday was. : Correct. : When was your next shift? : Monday, whatever date the EFTA00060608

237 1 : And did you speak with 2 BOP employees at that time about Epstein's 3 death? 4 : Everybody was talking a 5 lot, like, "Oh, shit, you hear what happened?" 6 "Yeah." That's like regular - nothing into 7 details. 8 : What was your 9 understanding of how he died? 10 : According to what I heard 11 and they said it was a suicide. 12 : Suicide? And do you know 13 anything about anyone else taking Epstein's 14 life? 15 : No. 16 : Do you know anything 17 about others assisting with taking Epstein's 18 life? 19 : Definitely, no. 20 : Do you believe that 21 Epstein took his own life? 22 : Yes. 23 : Did Epstein act alone in 24 taking his own life? 25 : Yes. EFTA00060609

238 1 : What would have prevented 2 Epstein's death? 3 : If he was still on suicide 4 watch. 5 : So you believe he should 6 have still been on suicide watch? 7 : If he was still on suicide 8 watch, he would have had 24/7 supervision. 9 : On that note, do you 10 think he was appropriately placed in SHU or 11 should have he been on like 10 South or G Tier? 12 : Well, if he was on 10 13 South, he would have been alone. If he was on 14 G Tier, he still would have been alone. 15 : And you think it was very 16 important because of Psychology that he was 17 with someone else? 18 : Correct. 19 : Okay. 20 : I feel, if he already tried 21 once, what's the chances he's going to not try 22 again. 23 : And do you believe he 24 should have still been on suicide watch? 25 : Yes. EFTA00060610

239 1 : You do? 2 : I think it was, what, two 3 weeks maybe or one week and then he came into 4 population -- 5 : Well, how -. 6 : -- or he came to Special 7 Housing. 8 : How often are inmates 9 typically on suicide watch or psych 10 observation? 11 : Well, if you actually 12 committed or did the noose and all that stuff, 13 then at least two weeks. 14 : So at least two weeks -- 15 : At least two weeks. 16 17 18 : -- he should have been? : Yes. : And what is your belief, 19 why did they release him early from suicide 20 watch or psychological -? 21 : Because he was Epstein. 22 : So you think it was 23 because he requested it? 24 : Yes. Well, this is my - 25 he's, according to everybody, very important, EFTA00060611

240 1 so. 2 : Right. And with all that 3 we talked about and like, you know, again, 4 speaking about the cameras, the, you know, 5 logs, the count, shifts, you know, all this 6 kind of stuff, do you believe there's any 7 suspicious activity at play with regards to 8 Epstein's death? 9 : I think, maybe when he came 10 to maybe a round or a count sheet, yes, could 11 have been stuff messed up, but any foul play 12 with staff, I don't think so. 13 : What about even with like 14 Psychology placing him into the SHU a little 15 early? I know you said it's because he was 16 Epstein, but do you think that it had anything 17 to do with people hoping he killed himself? 18 : I don't think so. 19 : No? 20 : I don't think so. I think 21 this building is always under the radar with 22 everything so instead of attracting attention, 23 "Let's get him out of -" - because if not, his 24 lawyer is going to eat MCC alive, that's what a 25 lot of, I feel. This building is worried about EFTA00060612

241 1 being on the paper. 2 : Okay. 3 : And what happens? They 4 were on the paper. 5 : Right. Now -. 6 : If I'm not mistaken, 7 another institution the same day, two inmates 8 also committed suicide. 9 : Oh wow, right.. Now what 10 about, did anyone ever approach you, either 11 inside or outside the institution about Epstein 12 while he was here? 13 : No. 14 : With regard to harming 15 him or assisting him? 16 : No. 17 : No? Okay. What are some 18 of the systematic problems inside the MCC and 19 specifically the SHU that allowed for Epstein 20 to die? 21 : The shortage of staff. 22 Staff constantly working doubles with little 23 sleep in between. I think that's - we don't 24 have enough equipment, like, you know, we don't 25 have enough tools to make this SHU specifically EFTA00060613

242 1 succeed. 2 : What about if you're told 3 that people weren't doing counts and rounds, do 4 you think that played into it as well? 5 : Yes. 6 : Do you think if rounds 7 were actually conducted, he would at least be 8 alive on August 10th? 9 : It takes three minutes for 10 a person to - when that's something look the 11 line. If he wanted to commit suicide, he would 12 have whether the staff would conduct the rounds 13 or not. 14 15 cellmate with him? 16 : Depending who the cell mate 17 is and how the cell mate sleeps, because 18 also had medical problems. I think it would 19 have been more of a chance for him to be alive 20 if he had a cellmate. Not that -- 21 22 23 have tried. 24 : What about if he had a : So on that note -. : -- he definitely would not : Right. So on that note, 25 who out of all the people here, who do you EFTA00060614

243 1 believe holds the most responsibility for 2 reassigning Epstein with a cellmate? 3 : I think everybody played a 4 little bit of part. 5 : And can - and this will 6 be the last question, tell me what people 7 what part people played in like how that could 8 have been rectified as far as getting him a new 9 cellmate? 10 : Um -. 11 : Where it should have 12 begun, where should it have ended? 13 : So it started with his 14 bunkie leaving. So, yes, I told my relief he 15 needs a bunkie. Maybe R&D should have called, 16 say, "Hey, this is Epstein's -" - the whole 17 building knew who Epstein's bunkie was. R&D 18 should -. 19 : So is it acceptable for 20 anybody to say, "I had no idea who Reyes was 21 and I didn't know that Reyes was Epstein's 22 bunkie?" 23 : No. 24 : Did everybody in the 25 building at the time know? EFTA00060615

244 1 : Everybody in the building. 2 : And how did they know 3 that? 4 : Just word. 5 : Word of mouth? 6 : Everybody talks and it's 7 not that many of us in this building, so. 8 : Okay. And I apologize 9 for interrupting, I just wanted to ask this. 10 11 12 : That's known. : Sorry. : So, R&D, "Hey, we're losing 13 this guy, Reyes is leaving." The Lieutenant, 14 "Hey, Psychology, Reyes is leaving." 15 Everybody, and since it was a Friday -. 16 : So who should have 17 notified the Lieutenants? 18 : I think maybe I should have 19 said, "Hey, sir, Reyes is leaving." 20 : And do you - 21 "We got to get him a 22 bunkie." Instead of, "Hey, sir, you know, 23 Reyes is leaving today, Epstein needs a 24 bunkie," and just me leaving. 25 : And do you believe that EFTA00060616

245 1 you did tell a Lieutenant? 2 : Oh, I definitely, without a 3 doubt, strongly believe I told more than one 4 person that Reyes was leaving. 5 : I know you have the memo 6 saying that you specifically told as well 7 as and were present, but as far 8 as Lieutenants, do you have that belief that 9 you, without saying I can actually put myself 10 there, do you believe that you told a 11 Lieutenant? 12 : Yes. I think I spoke to 13 and 14 : And what do you believe 15 you told them? 16 is leaving, Epstein 17 is going to need a bunkie." 18 : All right. So if they 19 say, "We knew Reyes left, but we didn't know 20 that he wasn't coming back," do you that that's 21 true? 22 : Yes. Because, like I 23 explained before, there's a lot of WABs that go 24 downstairs and within one hour, two hours, 25 sometimes right before the 10 o'clock count, EFTA00060617

246 1 they end up coming back. Or they say they're 2 going to court, they'll spend two, three hours 3 in R&D and come back. So it's not always 4 because it says WAB on the paper, a hundred 5 percent guarantee that they're not going to 6 come back. Whether they take all their stuff 7 or not. 8 : So you think it's 9 extremely likely you told, not only , but 10 also ? Should they have made the 11 notification to either the Captain or to the 12 relief? 13 : Maybe they did. I'm sure 14 they did because of -- 15 : Well, if I can tell you - 16 - 17 -- who Lieutenant -. 18 -- nobody notified the 19 Captain. Should have they notified the 20 Captain? 21 : Yeah. 22 : If it's claimed that they 23 didn't tell their relief, should have they 24 notified their relief? 25 : Yes. EFTA00060618

247 1 : All right. 2 : So something everybody, 3 especially being Epstein, you pass it down. 4 : Okay. Now let's say this 5 is a unique situation. Let's say , he's 6 working from 6:00 to 2:00. 7 : Correct. He leaves the 8 same time I leave. 9 • his relief, she's 10 on a regular time shift until 4:00 so she can't 11 start the Activities Lieutenant until 4:00. 12 : Correct. 13 : What would happen with 14 those two hours in between? He leaves at 2:00, 15 she starts at 4:00. Was he supposed to stay 16 until 4:00 -- 17 : No. 18 : -- until he's relieved or 19 can he leave at 2:00 and then just the 20 Activities Lieutenant goes unfilled for two 21 hours? 22 : He could leave at 2:00 23 because you have Operations Lieutenant until 4 24 o'clock. 25 : Okay. So because - well, EFTA00060619

248 1 I thought both Activities and - I thought 2 they both stopped at 2:00. 3 : No, one is 6:00 to 2:00, 4 another was 8:00 to 4:00. 5 : Okay. So at that time 6 when someone is doing the - 7 : Somebody has to be in that 8 position until the next Lieutenant comes in and 9 takes over, and -. 10 : But , at that time, 11 they're allowing the Ops Lieutenants to leave 12 two hours earlier than their shift due to 13 traffic. So the Ops Lieutenant actually is 14 leaving at 2:00 as well -- 15 : No. 16 : -- and then he's being 17 replaced by who is, although the 18 assignment says 4:00, he actually comes in at 19 2:00. 20 : So, if -. 21 : Because is there, 22 can and both leave? 23 : Yes, because is 24 still in the building. 25 : Although doesn't EFTA00060620

249 1 take on Activities shift until 4:00? 2 3 yes. 4 : Until 4 o'clock, correct, : So there can be just one 5 Ops Lieutenant from 2:00 to 4:00? 6 7 8 : Yes. : Okay. : Just like now, there's only 9 one Ops Lieutenant from 6:00 to 10:00 -- 10 : Okay. 11 : -- by themselves. 12 : So, and , if 13 they both knew, they didn't notify the Captain 14 or their relief, what should have happened 15 next? Should -- 16 : If they did not -. 17 : -- at the 4 o'clock 18 count, is that when - so you're saying you kind 19 of could take a little bit of responsibility 20 but you also believe that you not only notified 21 your relief, but you also passed it up the 22 chain, correct? 23 : Correct. 24 : So now it gets passed up 25 the chain and nothing happens. When should - EFTA00060621

250 1 what should have happened next with regard to 2 the cellmate? When should have the next time 3 this thing have been brought back up? The 4:00 4 5 : Whenever - whoever was - 6 the first person that found out that was 7 not coming back, that person should have passed 8 it down to everybody again. 9 : And that would have been, 10 you believe somebody like or one of 11 those? 12 : It could have been 13 It could have been R&D that the first person 14 pretty much, like, "Oh, you know, Reyes is not 15 coming back." "Okay." Let's say R&D found out 16 first, then they should have called the Captain 17 or even they should have just notified the 18 Lieutenant. If Reyes found out -. 19 : So R&D would actually go 20 straight to the Captain? 21 : Or most likely the 22 Lieutenant first, then, "Okay, I did my part, 23 that's pretty much - I did my part, I told the 24 Lieutenant," that's, the rest is on - it's on 25 them because I did my part in notifying EFTA00060622

251 1 somebody. 2 : Now, if we're told that 3 R&D usually just goes direct to the SHU, does 4 that sound right to you or do they usually go 5 first to like the Ops or Activity and then 6 somebody else 7 : Like inform? 8 : Yeah, so if they know, 9 "Hey, Reyes isn't - we now know he didn't come 10 back, he was released." R&D is the first 11 person to get that word. What is their typical 12 procedure? Do they contact both the SHU and 13 the Lieutenant or do they contact one or the 14 other? 15 : Depending who is working. 16 Sometimes they'll tell both of them, sometimes 17 they'll call SHU, sometimes they'll just call 18 the Lieutenant, the Lieutenant calls SHU and 19 says, "Hey, this guy is not coming back." Or 20 if they call SHU, then SHU would fix it on the 21 computer or SHU would call Control, say, "Can 22 you take off the count?" 23 : And would the person that 24 got contacted in R&D, you said everybody knew, 25 would the person in R&D know that was EFTA00060623

252 1 Epstein's cellmate? 2 : I would assume they did. 3 : And are they on this 4 form? 5 : Are they, no. 6 : How would we find out who 7 was working at approximately 4:00 - what does 8 their shift go from? You said 2:00 to 10:00? 9 : Yes. Think -. 10 : How would we find out 11 : There was one that -. 12 : -- who was - do we know 13 who was working -- 14 15 16 17 18 : It's -. : -- 2:00 to 10:00? : They're 6:00 to 2:00 -- : Not for R&D. : -- 2:00 to 10:00 and 12:00 19 to 8:00, R&D. 6:00 to 2:00, 12:00 to 8:00 and 20 2:00 to 10:00, that's R&D's schedule. 21 : So the 2:00 to 10:00 22 would be the people that would have found out, 23 I'm assuming. 24 : Yes. 25 : How do we find out at EFTA00060624

253 1 this point who was working in R&D from 2:00 to 2 10:00? 3 : You would have to get with 4 an R&D supervisor. 5 : Who is an R&D supervisor 6 that we can get with right now? 7 : Is that 8 -: doesn't know. We 9 reached out already. 10 : Oh. 11 : She said she doesn't know 12 but wouldn't they keep track of like who worked 13 14 : Rosencrance already did and 15 she didn't seem to know. Is there like a 16 schedule? Do they keep it somewhere? 17 : That - because, this is our 18 schedule and that goes back for years, so. 19 : That's why I would think 20 that also R&D would have something similar. 21 : But with them -- 22 : So let's get with -- 23 : -- they're not 24 , let's ask 25 her -- EFTA00060625

254 1 : Okay. 2 : -- about that. 3 : They're not on our - 4 they're not on a roster. The only time they 5 would be on a roster if it's - if they're doing 6 overtime with us. 7 : Uh-huh. 8 : So we could say they do 9 night off, then we would put them on our roster 10 for night off. 11 : Okay. So it sounds like 12 you have very limited liability because you do 13 believe, in fact, you not only - and you're 14 confident you passed it to 15 : I'm very. 16 : Under oath, like, "Yes, I 17 did," or is it like, "I believe I did?" 18 : No, like, very, very, very 19 confident. 20 : Like you can actually 21 recall passing that information? 22 : Yes. The same thing with 23 being there too. 24 : So you specifically 25 recall, like almost like you can see, you can EFTA00060626

255 1 remember -- 2 : See -- 3 : I said this. 4 : I'm in SHU, is 5 walking in, we're there, "Make sure this guy 6 gets a bunkie." "All right, G." 7 : You said, "Make sure 8 Epstein," or, "This guy?" What did you say? 9 : Well, Epstein 10 : Okay. And is the 11 one that said, "All right, G?" 12 : Uh-huh. 13 : All right. And you 14 believe, although you can't recall with such 15 clarity, that you passed it to the Lieutenants. 16 : Correct. 17 : Okay. 18 : If or or any one 19 of them turns around and says that, "Hey 20 listen, you never told them," would they be 21 lying? 22 : Most like, I don't think 23 they would tell you that, but -. 24 : No, no, but I'm asking, I 25 said, you know, I have to cover both sides. EFTA00060627

256 1 : Yeah. 2 : Would they be lying if they - 3 . 4 : They - I strongly believe 5 they wouldn't tell you that -- 6 : Okay. 7 : Because, again, it's a 8 little bit of people, we're always - it was 9 only us throughout the whole time. So I 10 strongly, strongly believe that I spoke to - 11 , I even forgot was there, but, 12 and , yes. 13 : On the same note, if we ask 14 the same thing towards or 15 16 : I didn't speak to -. 17 I don't even remember seeing him that day. 18 : But 19 : But and 20 , yes. 21 : They would say that you spoke 22 to them about it? 23 : Yeah. 24 : Okay. 25 : Although, if they claim, EFTA00060628

257 1 "Yeah, we know he went but we didn't know that 2 he was not coming back," that also holds 3 weight? 4 : I was actually - because, 5 again, not everybody has WAB. 6 : Sure. 7 : Doesn't -. 8 : So could have you - could 9 have a new cellmate been assigned to Epstein 10 prior to 4:00 p.m.? 11 : Only if it was confirmed 12 that Reyes is not coming back. 13 : But a new cellmate can 14 not be - so, a new cellmate cannot be assigned 15 to Epstein until it's confirmed that Reyes 16 isn't coming back? 17 : I mean, you could assign 18 them even with Reyes being there. 19 : I know, but I'm just 20 saying, like in this case, that's his cellmate. 21 : That's his cell. He's -. 22 : So you -. 23 : He's keyed into that cell. 24 : Right. 25 : So until we know for a EFTA00060629

258 1 2 3 fact, "You know what? is not coming back, we're going to key him out," then, "Shit, let's get him -" - now we have from let's say 4 we found out left the building at 1 5 o'clock in the afternoon, we have until 8 6 7 o'clock to get him a bunkie because he's in attorney visit. 8 : And was it confirmed that 9 10 wasn't coming back while you were on duty? 11 : No. 12 13 he was not -- : So no one ever told you 14 : No. 15 : -- coming back. 16 : All I saw was that WAB and 17 I assumed he's not. 18 : You assumed, but, yeah, 19 but you didn't - but you be- 20 : But I didn't know for sure. 21 22 you should -. : -- but you didn't believe 23 : Get him a bunkie because, 24 25 "Hey, there's still a chance this guy could come back." EFTA00060630

259 1 : Okay. 2 : If I would have known for a 3 fact, we wouldn't even be here I think. 4 : And is that the reason 5 why you told ? Did you also say, "Hey, if 6 Reyes doesn't come back, get him a bunkie," or 7 did you just say, "Hey, Reyes isn't coming 8 back, get him a bunkie?" 9 : No, I know I didn't tell 10 him he is not coming back because I didn't 11 know. 12 : Right. 13 : So -. 14 : So what do you think you 15 actually said? 16 "Hey, you know, if Reyes 17 doesn't come back, he needs a bunkie." 18 : Okay. 19 : Which he already knows 20 Epstein needs a bunkie. 21 : And you said that? You 22 believe you said the same thing to both 23 and 24 : Yeah. 25 : And that would have been EFTA00060631

260 1 probably, believing, doing his rounds at 2 about 11:30? Would have that been when you 3 told him or do you believe you would have 4 called? 5 : No, probably when he's 6 doing his rounds. 7 : Doing his rounds? And 8 you said you actually do remember speaking with 9 that day? 10 _• I remember him being 11 there and just told him, I always talk to him. 12 : Would it be like talking 13 to him in the SHU? 14 : Yeah. 15 : So both and 16 would have visited -. 17 : One at a time. 18 : But they both would do 19 it? 20 : They both would have walked 21 over, yes. 22 : And are they both 23 actually required to do it or just one? 24 : No, they're both required 25 to do the rounds. EFTA00060632

261 1 2 3 : Oh, they are? : Yeah. : All right. I thought it 4 was one or the other. So looking at that 5 sheet, was also on it? Would he had to 6 have logged in like something, when he did a 7 round in the SHU? Can you get me that 8 Lieutenant's log? So both the Activities and 9 the Ops Lieutenant are both required to do a 10 round in the SHU. 11 : Correct. At least once per 12 shift. 13 : And that was also the 14 case in August of 2019? 15 : Yes. But like on the round 16 sheets, if one signed it, the other is not 17 going to sign over it. 18 19 20 21 : (Indiscernible *03:15:35). : There it is. : It's right here, sorry. : So is on this at 22 all? You can ask, but I don't remember him 23 there. 24 : No, he's actually not. 25 : So -- EFTA00060633

262 1 : Unless -. 2 : -- should have there been 3 a -. 4 : Unless because did 5 it. He didn't do it. Just like on -. 6 : Because we were told if 7 the Ops Lieutenant is too busy, he just tells 8 Activities Lieutenant to go do it. But you 9 believe 10 : I mean - I mean -- 11 : -- they actually both -. 12 : -- physically and you 13 actually, both Activities and Operations have 14 to walk and do the rounds. 15 : And you actually - not 16 together though. 17 : Not together. 18 : Separately. 19 : That's - and one or the 20 other fills it in on TRUSCOPE. 21 : Okay. So is it 22 surprising you to see that doesn't even 23 have anything logged on this day? 24 : No, not really. 25 : No? And does this EFTA00060634

263 1 suggest - when they sign this, does it show 2 where it was signed from? 3 : No. 4 : No? Just they can change 5 like this -. 6 : Well, wherever you logged 7 it from, that, I don't even know how it shows 8 up somewhere else. 9 : Okay. Because aren't 10 they supposed to actually log it from the 11 actual unit themselves? 12 : Well, now, if as long as 13 you do it one, you could log in from 14 downstairs, let's say the Lieutenant's office 15 and logged in a unit. 16 : But are you supposed - 17 like if someone visits the SHU, aren't they 18 supposed to actually log the round from the 19 SHU? 20 : Yes, log it in the computer 21 and log it in. 22 : Yeah, yeah, yeah, that's 23 what I was - okay. Did I get - so we said the 24 cellmate - so you said, told at least and 25 you remember that specifically. You believe EFTA00060635

264 1 that the other two, and them, they should 2 have - once it was actually verified that he 3 wasn't coming back, that's when it really 4 should have been done though. 5 : Correct. 6 : But we just don't know 7 exactly when it was verified or how it was 8 verified. 9 : Correct. 10 : And you believe R&D - how 11 does R&D receive that verification? 12 : I think through the 13 Marshals. 14 : So the Marshals tell them 15 and then they're supposed to make the proper 16 notifications? Are they supposed to go, you 17 said it depends on who is in R&D but they're 18 supposed to notify the appropriate housing 19 unit? 20 : No, they can just call the 21 housing unit, "Hey, this guy is not coming 22 back," or call Control. 23 : And let Control know. 24 : Correct. 25 : All right. And do we EFTA00060636

265 1 know who at - let me see that August 9th one - 2 who in Control - would Control always be in the 3 loop with that? 4 : Not really because there's 5 times that R&D would call SHU and if there's 6 somebody in SHU that has enough knowledge to 7 just key him back in, they'll key them back in, 8 or R&D would key them back in. So now, you 9 don't need to speak to R&D, I mean, you don't 10 need to speak to Control because the inmate is 11 walking back up to SHU and R&D already keyed 12 him back into the building. 13 : All right. And then, 14 what is the - what about like when Noel and 15 Thomas are working on their morning shift, 16 should they have recognized that Reyes wasn't 17 there? 18 : Definitely by that time 19 they - by 10 o'clock, it's way after, they 20 should have known that he's not coming back. 21 : But I just mean the start 22 of a new shift now. Now midnight starts a new 23 shift, we're now on morning watch. Should they 24 have recognized, "Hey, Epstein is by himself." 25 : Yes. EFTA00060637

266 1 : And when and how? 2 : Yes. 3 : No, when should have they 4 noticed and how? 5 : Right on their first round 6 on morning watch. 7 : So, during a round they 8 should have 9 : You have to do a count at 10 midnight, so, at that time you should have saw 11 he was by himself. That's a little light 12 should have went off in your head saying -. 13 : So immediately, right 14 away, midnight, Epstein is by himself. If the 15 count was done, they would have known, "We've 16 got to make this notification?" 17 : Yes. 18 : And would have they known 19 that that notification needed to be made? 20 : Yes. 21 : And do you believe that 22 both Thomas and Noel knew that Epstein was 23 required to have a cellmate? 24 : They should have known, 25 yes. EFTA00060638

267 1 : And how should have they 2 known? 3 : Due to the little paper I 4 had there and -. 5 : Well, the paper said, "Do 6 rounds," right? 7 : And supposedly somebody 8 else had another paper there saying that he 9 needed a bunkie, but -. 10 : Now, so this - so you 11 know of a different paper that was 12 : No, from what you told me 13 earlier. 14 : No, that was somebody 15 saying that you created another paper saying 16 that he -. 17 : Oh, that I don't remember. 18 : So you don't remember 19 ever creating a paper saying he needed a 20 bunkie. 21 : Maybe I did, but I don't 22 remember doing it. 23 : Okay. 24 : I remember this just 25 because it has the God phrase and it was kind EFTA00060639

268 1 of funny to us. 2 3 : Yeah, yeah, yeah. : But we all know that if an 4 inmate comes from suicide watch, he has to have 5 a bunkie. 6 : And everybody knows that. 7 : Everybody knows that. 8 : All right. Any other 9 questions? 10 : Just a couple follow ups. Do 11 you know why was in the SHU? 12 : If - I think he got into 13 a fight or somebody hit him while he was in 11 14 South. 15 : So he -. 16 : On that time. 17 : So he was put in there for 18 his own protection or did he -- 19 : Yes. 20 : -- assault somebody end up in 21 that? 22 : So, I think he had a fight 23 or somebody assaulted him and they both ended 24 up in SHU. 25 : What about Reyes? EFTA00060640

269 1 , I think it was 2 because of smoking, I think. No. 3 : Contraband? 4 : Yeah, contraband. Nothing 5 that I can remember. 6 : You got something else? 7 : The only other question I 8 would say is, outside of the SHU, now we got 9 and we got and then we also have 10 later on. If they were actually 11 conducting rounds as they should have, would 12 have they at that time known Epstein was by 13 himself and needed a cellmate? Should have 14 they known if they're conducting rounds after 15 4:00 p.m.? 16 : Yes. 17 : So all of them have some 18 liability then too to know, "Hey, this guy - 19 where is Epstein's cellmate?" 20 : Well, maybe at 4 o'clock, 21 depending what time they did the rounds, no, 22 because Epstein was always downstairs in his 23 attorney visit until 8 o'clock at night. 24 : But if no one is actually 25 in Epstein's cell, wouldn't they notice that? EFTA00060641

270 1 : They would notice that it 2 was empty, but, "Hey, where's Epstein?" "Oh, 3 he's in -" - because you - people don't ask for 4 Reyes usually. : Right. 6 : "Where's Epstein?" "He's 7 in his legal visit." "Oh, okay." And the 8 Lieutenant, the Lieutenant's office is like ten 9 steps away from the attorney conference so you 10 would know that Epstein is still there and you 11 got to approve the out count. 12 : All right. And when you 13 were there, do you recall that the Activities 14 and the Ops Lieutenant were actually conducting 15 rounds in the SHU? 16 : I know for a fact 17 and then he always just 18 walked around to see what was going on. 19 : Who would? 20 21 : So he wouldn't actually 22 do the -. 23 : No, he would walk around 24 just to see what was going on because he -- 25 : What -. EFTA00060642

271 1 : -- was the SHU Lieutenant 2 before too. 3 : What about 4 • , he's always 5 walking, but I didn't see him that day. 6 : What about 7 8 : I know for a fact she 9 always does her rounds. 10 : So if she says that she 11 wasn't required to walk the tier, she just 12 needed to check in, do you think that - what 13 would you say to that? 14 : Maybe she knows something I 15 don't know. Because, I mean, I'm a new 16 Lieutenant, I still - I walk around every 17 range, every tier. 18 : But when you were the SHU 19 OIC, you recall all these Lieutenants coming in 20 and actually walking the tiers? 21 : Yes, because that round 22 sheet, on the bottom of it, it says, 23 "Operations Lieutenant." 24 : And, yeah. 25 : If you look at it. EFTA00060643

272 1 : Yes. And that actually 2 is for conducting rounds of the tiers, not just 3 doing rounds with your -. 4 : In the Special Housing 5 Unit, correct. 6 : Yeah, yeah, yeah. I 7 guess what I'm saying is, some people are 8 saying, "No, it's, I'm doing a round with my 9 staff. I'm not doing a round on inmates, it's 10 the staff's members doing the rounds on 11 inmates, I'm doing a round with my staff." 12 13 14 : But, again, that bottom -- : That bottom. : -- little square says, 15 "Operations Lieutenant," which even if you 16 don't know anything about it, if you read it, 17 it says, "Operations Lieutenant." 18 : Doing a round of the 19 actual inmates? 20 : Or does it also mean that 21 they're certifying that those other rounds by 22 the COs were conducted? 23 : It could be that, but 24 regardless, you got to sign it and go down the 25 range. EFTA00060644

273 1 : Yeah, that's where I 2 wasn't sure if this was signed to make sure 3 that you guys were doing your job. 4 : I understand as to make 5 sure you did your round. 6 : Okay. Now, let's do 7 that. 8 : That the Lieutenant. 9 : Lieutenant. 10 : Lieutenant. 11 : Yes. 12 : Okay. 13 : Okay. I'm sure we could 14 sit here and just pick your brain all day long, 15 but we've been here a long time, so, are we 16 missing anything? 17 : No. That's it. I hope, 18 you know, everybody takes this as a learning 19 experience, you're fucking up, stop fucking up. 20 Excuse my language. 21 : Now, do you think one 22 person fucked up more than another in this? 23 : No, I mean, I think it was 24 going to happen if you wanted it to happen, 25 regardless whether rounds were done, whether he EFTA00060645

274 1 had a cellmate, maybe less likely that he would 2 have with a cellmate, but also, a cellmate 3 could go to the law library, you know. Thirty 4 minutes is a long time, 40 minutes is a long 5 time, so. 6 : Yeah, so, but you do 7 believe it's the cellmate thing that would have 8 actually helped keep him alive. 9 : I think it would have 10 helped a little bit. 11 : Right. 12 : If he wanted to do it, he 13 was going to do it. 14 : Uh-huh. And you think 15 everybody from the point that you left on plays 16 a large responsibility in the fact that he 17 wasn't assigned a new cellmate, especially 18 since you specifically told people, "Make sure 19 he gets a bunkie if Reyes doesn't come back." 20 : I mean, I don't blame 21 anybody. I think everybody should maybe passed 22 the information a little more. Maybe it got 23 lost in miscommunication. 24 : All right. 25 : No, that's it. EFTA00060646

275 1 : But you don't believe 2 that the people that you told will actually 3 admit that they were told it? 4 : Correct. 5 : Right. And you are 6 swearing, again, under oath, under penalty of 7 perjury of law that you did tell them that? 8 : I'm very, very confident 9 that I told more than one person. 10 : And who are you confident 11 that you told? 12 : I told was 13 there. Lieutenant saw Reyes leaving, 14 but even Reyes we weren't sure -. 15 : So actually saw 16 Reyes leaving? 17 : He was downstairs, I think, 18 -- 19 : Okay. 20 -- and saw. But, again, I 21 don't blame anybody and it's just unfortunate 22 everybody got to go through this. 23 : Yeah. Okay. You good? 24 : I'm good. 25 : Anything else you want to EFTA00060647

276 1 add for us? 2 : That's it. 3 : Thank you, sir. 4 : Thank you for -- 5 : I can't thank you enough. 6 : -- taking three hours of my 7 day. What time is it now? 8 : You got a nice cozy seat, 9 you know, we gave you the most comfortable one 10 we had. 11 : Turn up the heat. 12 : 4:39. 13 : All right. It's 4:40 14 p.m. on Wednesday, July 14, 2021. This is 15 Senior Special Agent and I'm 16 turning off the recorder. 17 18 19 20 21 22 23 24 25 EFTA00060648

277 CERTIFICATE I hereby certify that the foregoing pages represent an accurate transcript of the electronic sound recording of the proceedings before the Department of Justice, Office of the Inspector General in the matter of: Interview of , Transcriber EFTA00060649

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