101 1 certain. 2 MR. : Okay. So, back then, 3 they wouldn't have been at the end of the hall? 4 They were probably at the beginning of the 5 tier? 6 MR. : I know at one point in time, 7 they were, the clipboard was being rested on 8 that coax pipe. 9 MR. : Would this be underneath 10 L tier, or would that be where it would be? 11 MR. : No. It's always on the 12 inside of the range. 13 MR. : Always on the inside? 14 Okay. 15 MR. : Yeah. 16 MR. : So it would have been 17 after you opened the range door, but not at the 18 end of the hall at that time? 19 MR. : I know I, like I said, at 20 one point, they had it on the wall to the side, 21 but at one point in time, they were putting the 22 clipboard, they were just resting it on that 23 pipe. 24 MR. : Okay. 25 MR. : As long as it was downrange, EFTA00061161

102 1 it needed to be downrange. 2 MR. : So, even at that time, it 3 was supposed to be downrange? 4 MR. : They always have to be 5 downrange. 6 MR. : Okay. 7 MR. : Yes. 8 MR. : Per BOP policy? 9 MR. : Yes. 10 MR. : Okay. And this is just, 11 so, we had to review a lot of emails and I see, 12 this one, I think, was directed to you. It 13 says, "BOP official legal hold notice for 14 inmate's death." What was your, was your 15 understanding of that not to destroy any 16 documents? 17 MR. : Yes. 18 MR. : All right. Did you 19 destroy any documents? 20 MR. : No. Not at all. 21 MR. : So you still have all 22 your emails from then and everything? 23 MR. : I don't have anything. 24 Like, I know the AUSA had my memo. I don't 25 even have a copy of my memo. EFTA00061162

103 1 MR. : Okay. 2 MR. : And I don't, I didn't tear 3 up anything. 4 MR. : Perfect. 5 MR. : And I've been getting these 6 periodically from you guys. 7 MR. : Oh, you still do? Okay. 8 MR. : Yeah. 9 MR. : Do you still have, like, 10 all the emails from back then and everything? 11 MR. : No. I mean, anything that I 12 had, I either just closed out of, but the thing 13 is, I didn't, I don't even remember having any 14 direct emails. All the official emails, like, 15 I, like, sent them to my trash bin, like even 16 these, I mean, this was just telling me not to 17 destroy anything, and I didn't destroy 18 anything. 19 MR. : Okay. 20 MR. : So, I didn't save these. 21 MR. : Okay. But as far as, so, 22 did you understand, like, as far as if you 23 received an email pertaining to Epstein, were 24 you supposed to save that, or could have you 25 deleted that? EFTA00061163

104 1 MR. : What do you mean? In, like, 2 as far as from staff? 3 MR. : Yeah, like, for instance, 4 this is another one that, I think this is the 5 email that you would have received, regarding 6 Epstein being required to have a cellmate from 7 July 30, 2019? 8 MR. : Oh, yeah, yeah. No, these, 9 I would get them and delete them. 10 MR. : All right. So you would 11 delete those? 12 MR. : Yeah. And as long as I 13 knew, you know, that was it. 14 MR. : So, you didn't 15 understand, like, this to mean, like, not to 16 delete anything pertaining to Epstein? 17 MR. : No, but the thing is, at 18 least I never got anything like this, after it 19 happened. 20 MR. : Yeah, yeah, yeah. I'm 21 talking about, like, prior to, I think that 22 this is asking you to save anything that was 23 related to Epstein, correct? 24 MR. : Yeah, no. I get what that, 25 you know, that, I didn't think that that was EFTA00061164

105 1 what it meant. Like these. These were just 2 routine things. I thought it meant -- 3 MR. : Okay. Well, that came 4 from yours. So, you didn't, I was able to get 5 it, at least 6 MR. : Okay. 7 MR. : You may have deleted it, 8 but my point being is, like -- 9 MR. : Uh-huh. Well, I 10 misunderstood, maybe. I'm thinking destroying 11 means shredding. 12 MR. : But if you received an 13 email pertaining to Epstein, you thought you 14 could delete it? 15 MR. : Yeah. I guess so. 16 MR. : Right. Fair enough. 17 MR. : There's, like, stuff like 18 this, if it's sitting in my trash bin. I don't 19 always empty my trash. I mean, anybody in the 20 Bureau could pull those emails anyway. 21 MR. : Okay. Let me see how -- 22 MR. : Yeah, I thought it meant, 23 like, physically, like, destroying stuff. 24 Like, I wish I could even have a copy of my 25 memo, but AUSA has it. EFTA00061165

106 1 MR. : Cause, like, for 2 instance, this says, "Please preserve all 3 electronic files; example, emails or 4 documents." 5 MR. : Right. I missed, I totally 6 misunderstood. 7 MR. : All right. So, you 8 misunderstood that? 9 MR. : Yeah. 10 MR. : Okay. 11 MR. : I wouldn't do it 12 maliciously. 13 MR. : Yeah, yeah, yeah. No, 14 and that's what I wanted to know -- 15 MR. : Uh-huh. 16 MR. : -- cause a lot of people 17 got this, so you're the first person I'm even 18 asking about this. 19 MR. : Uh-huh. 20 MR. : So I was just curious, 21 it's like, what is your understanding. So, did 22 you not know 23 MR. : Yeah. I thought it meant, 24 actually, like, physically, like, destroying 25 things, like, you know, in the shredder. EFTA00061166

107 1 MR. : Right. All right. So, 2 yeah. So you didn't actually read it, I'm 3 assuming, like, where it says emails? That's 4 the first thing it says. 5 MR. : I probably mis, no, like, I 6 remember the first one I received, I called the 7 staff attorney. I was, like, what does this 8 mean? And he was like, just that you're still, 9 it's still active. 10 MR. : Okay. Would you mind, 11 just, anything we talk to you, it's just 12 initialing and dating. 13 MR. : Yeah. No problem. 14 MR. : It's just to say what it 15 is what we looked at and talked about. 16 MR. : Uh-huh. 17 MR. : And you already 18 mentioned, you remember receiving this email 19 from Psychology -- 20 MR. : Yeah. 21 MR. : from 22 23 MR. : Yeah. Dr. 24 MR. : Yeah. 25 MR. : Yeah. EFTA00061167

108 1 MR. : Saying that he was 2 required to have a cellmate? 3 MR. : Have a cellmate. 4 MR. : So you do remember that? 5 Okay, great. 6 MR. : Uh-huh. 7 MR. : And you knew he was 8 required to have a cellmate? 9 MR. : Yes. 10 MR. : Do you mind just 11 initialing and dating that? 12 MR. : Sure. 13 MR. : Was that the same email that 14 you mentioned before? Cause you mentioned that 15 there was an email from Captain 16 MR. : I believe there was one, as 17 far as when he, anytime he would be put as a 18 lieutenant hold. This is the one I was talking 19 about, like, Psychology would send out that, 20 about having the cellmate. 21 MR. : Oh. 22 MR. : Thank you, sir. Now, as 23 far as this, you said no one told you. So, 24 this is a memo from, at the time, SOS 25 MR. : Uh-huh. EFTA00061168

109 1 MR. . It 2 says, "Past information from Special Housing 3 Unit." It says, "On Friday, August 9, 2019, at 4 approximately 1:50 p.m., I, SOS 5 passed on to oncoming staff member, Officer 6 and present shift staff, SOS and 7 Officer , that inmate was going WAB 8 and possibly may not return. Also that inmate 9 Epstein will be needing a cellmate upon arrival 10 from his attorney visit." Did you know 11 anything about that? 12 MR. : No. 13 MR. : Is this the first you're 14 seeing of this memo? 15 MR. : That's the first I'm seeing 16 of it. 17 MR. : All right. So, a couple 18 things. First, if passed on to these 19 people and those are the people that worked on 20 your shift? 21 MR. : Yeah. Yes. Right here. 22 No, wait. What does it say? No, 23 was day shift. was day shift. 24 is the only one. 25 MR. : Okay. So, oncoming staff EFTA00061169

110 1 2 members , and Officer , so let's see. When would have been working 3 on this, like, what -- 4 MR. : 2 to 10. 5 MR. : So, would have been 6 2 to 10. 7 MR. : Uh-huh. 8 MR. : And the present ones were 9 When would he have been working? 10 MR. : 8 to 4. 11 MR. : And 12 MR. : 8 to 4. 13 MR. : All right. So, I think 14 would have only been working as 15 MR. : Till 2:00. 16 MR. : 2:00. So, if he told, 17 before he left, 2:00, , and 18 19 MR. -: 20 MR. : Right. Should any of 21 those people have notified either you or 22 , that he was, that was gone and -- 23 MR. : Yes. 24 MR. : Yes? Okay. And nobody 25 did? EFTA00061170

111 1 MR. : I wasn't told. Like I said, 2 I found out the day after it happened. Well, 3 the day that it happened, when I came in. 4 MR. : Now, on the second note 5 of this, if knew that was WAB, 6 should have he ensured that he got a cellmate 7 prior to his departure, at 1:50 p.m.? So, if 8 left at 8:38 a.m., WAB, into R&D, he's 9 keyed out of the system. Should a new cellmate 10 have been assigned to Epstein, even prior to 11 leaving? 12 MR. : It would have been prudent 13 to do it as soon as possible. 14 MR. : Okay. So, should 15 have then notified any, you know, 16 , and it looks like , during his 17 shift, that, hey, we need to get Epstein a new 18 cellmate? 19 MR. : Anybody that was on that, 20 that is mentioned there, should have been, if 21 the knowledge got passed, it was never passed 22 to the lieutenants. 23 MR. : Okay. But, okay. And 24 then if the lieutenants knew, so, for instance, 25 and , if told them, hey, EFTA00061171

112 1 is gone, should have he notified them 2 that he was WAB gone? Or, so, if he believed 3 he was at court, WAB -- 4 MR. : Uh-huh. 5 MR. : -- and let's say, for 6 instance, is the Ops, so he's kind of 7 like the boss, right? 8 MR. : Uh-huh. 9 MR. : If knew, yep, I 10 know is gone. I know he is Epstein's 11 cellmate. Is there any reason, and especially 12 if he went WAB, is there any reason, any 13 argument for to be made that, well, I 14 didn't know if he was coming back or not? 15 MR. : If he wasn't notified that 16 he was WAB, it would, you wouldn't know. 17 MR. : Okay. So, if he wasn't, 18 if he didn't know he was WAB, it is an argument 19 to be made to say, well, he could have come 20 back, is that correct? 21 MR. : Yes. 22 MR. : Okay. So, he would have 23 had to have known that he was WAB? 24 MR. : If he didn't, he would have 25 had to have known he was WAB, if he knew he EFTA00061172

113 1 wasn't coming home, like, coming home, coming 2 back to the jail. 3 MR. : Okay. All right. If he 4 knew he was WAB, he should have acted and 5 gotten him a new cellmate. If he didn't know 6 he was WAB, then it was okay for him not to 7 issue him a new cellmate? 8 MR. : Yeah. If he didn't know he 9 wasn't coming back or if he was even gone, he 10 wouldn't know. That's why I said, if the white 11 shirts didn't get notified, we don't know 12 what's happening. 13 MR. : Yeah, yeah. But you had, 14 so, let me ask you separately. If says, 15 yep, I knew was, I knew was gone. 16 I knew was Epstein's cellmate. And he 17 didn't know he was WAB. Was it okay for him 18 not to have acted? 19 MR. : No. If he was told, it was 20 not okay. 21 MR. : But if he wasn't told 22 that he was WAB, he was just told he went to 23 court. 24 MR. : I mean, at that point in 25 time, I would have been a little worried that EFTA00061173

114 1 he was alone, but you're talking day watch, 2 there's constant movement. 3 MR. : Well, if Epstein's down 4 in attorney visits until 8 p.m. -- 5 MR. : Yeah. That's probably what 6 happened. 7 MR. : Yeah. 8 MR. : He's in attorney conference, 9 thinking by the time he goes back upstairs, 10 this guy is coming back from court. 11 MR. : Okay. 12 MR. : I'm assuming. 13 MR. : And what time did 14 work until, until that day? 15 MR. : I relieved him at just about 16 probably 2:00. 17 MR. : Okay. So, if he is 18 saying, I knew was gone, but I didn't 19 know he wasn't coming back, would that 20 translate to mean he didn't know he was WAB? 21 MR. : Yes. 22 MR. : Okay. So, if he didn't 23 know he was WAB, was it okay for not to 24 tell you that was gone? 25 MR. : If he didn't think that EFTA00061174

115 1 there was an issue, no. 2 MR. : Should have he told you 3 that there was gone, being that it was Epstein, 4 he was required to have a cellmate, and 5 was at court? 6 MR. : If he knew, then he should 7 have notified me. 8 MR. : So, regardless if he was 9 WAB or not, he should have notified you that 10 was at least at court? 11 MR. : At that point in time, so, 12 see, this is where it's hard to tell. Look, 13 when you're Operations Lieutenant, you're 14 moving, you're working the entire institution. 15 MR. : Yep. 16 MR. : You're filling overtime. As 17 you can see, filling that roster was a 18 nightmare. 19 MR. : Uh-huh. 20 MR. : All right? You're doing 21 this, you're doing that. You're doing a 22 million things. Right? You may not even know 23 that this guy even went to court. 24 MR. : But if he says he knew? 25 MR. : If he says he knew -- EFTA00061175

116 1 MR. : He says he knew he went 2 to court. He just didn't know that he wasn't 3 coming back. 4 MR. : That's different. If he 5 knew, if he said he knew, then something should 6 have happened. 7 MR. : So, if he knew he went to 8 court, even if he says, I didn't know if he 9 wasn't coming back or not, he should have at 10 least notified you, though, hey, heads-up, 11 is at court? 12 MR. : Uh-huh. Yeah. Or it was 13 just, or at least tell the OIC, like, listen, 14 if Epstein comes back up and this guy is not 15 back from court yet, make sure Epstein has a 16 bunkie. 17 MR. : Okay. 18 MR. : You know, something should 19 have been put in place. 20 MR. : So, should have at 21 least, should have notified either, should have 22 notified, it sounds like, both you, as well as, 23 in this case, who was the OIC at the time? 24 MR. : Day watch OIC? 25 MR. : So, EFTA00061176

117 1 MR. : SHU-1 is OIC. 2 MR. : Okay. So, but even 3 though , so was the OIC, 4 though, I think, for, like, the whole, is it 5 always SHU-1? Cause I thought was 6 just the OIC, like, in the SHU, I thought it 7 worked that, like, was -- 8 MR. : Whoever is assigned as SHU-1 9 is the OIC. That's the OIC position. 10 MR. : All right. Cause my 11 understanding was that at this period of time, 12 was known as the OIC of the SHU. 13 MR. : If he, unless he is 14 assigned, if he is assigned to SHU-1 -- 15 MR. : Just SHU-1? 16 MR. : -- for the quarter, then 17 you're the OIC. 18 MR. : Okay. So, in this case, 19 though, . So, should have notified 20 21 MR. : If he knew. 22 MR. : If he knew that, if he 23 knew that he was at court, but again, wasn't 24 sure he wasn't coming back, what should have he 25 told EFTA00061177

118 1 MR. : That make sure that if 2 Epstein, when Epstein comes back from legal 3 visit, he gets a bunkie. 4 MR. : Okay. And never 5 informed you? 6 MR. : No. 7 MR. : Okay. And should have he 8 informed you? 9 MR. : If he knew -- 10 MR. : If he knew that he was in 11 court? 12 MR. : -- that he wasn't going to 13 get a bunkie, I should have been told. 14 MR. 15 asking, 16 MR. 17 MR. sorry, : Great. But what I'm I think we're confusing here -- : If he knew that he was -- -- even if he didn't know 18 that he was, so, if his argument is -- 19 MR. : Just the fact that he was 20 out. 21 MR. : Right. 22 MR. : If he knew, yes, I should 23 have been told. 24 MR. : So, if he knew he was at 25 court, he should have let you know? EFTA00061178

119 1 MR. : If he knew that, if he knew 2 that he was going to not have a bunkie, I 3 should have been, I should have known, being 4 that I was coming on. 5 MR. : So, this is where I'm 6 trying, just try to focus on my words. 7 MR. : I'm sorry. 8 MR. : Right now, I'm asking, if 9 was at court, but didn't know that 10 he wasn't coming back. He just knew that 11 was at court, should have he told you? 12 MR. : Yes. 13 MR. : Okay. So, regardless if 14 he was coming back or not, he should have 15 notified you? 16 MR. : Well, see, that's the thing. 17 We don't always, we don't know who went to 18 court until we do that roster of the movement. 19 MR. : But if we talk to 20 and he says, yep, I know was at court. 21 MR. : Uh-huh. 22 MR. : I just didn't know if he 23 was coming back or not. 24 MR. : Yeah. 25 MR. : Should have he relayed EFTA00061179

120 1 that information to you? 2 MR. : Yes. Especially because of 3 the profile found. 4 MR. : Okay. So, he should have 5 relayed that information? 6 MR. : Yeah. 7 MR. : Okay. I just wanted to 8 get to that. Do you mind just initialing and 9 date that? 10 MR. : Uh-huh. 11 MR. : And he did not, correct? 12 MR. : No. 13 MR. : Thank you, sir. Do you 14 remember, while we're at it, do you remember in 15 this case being that shift says it 16 ends at 2. Well, , she's on an overtime 17 shift. So, she doesn't actually start until 4. 18 MR. : Uh-huh. 19 MR. : Is it okay, do you know 20 if would have had to have stayed from 2 21 to 4 until he was 22 MR. : Not necessarily. As long as 23 there's a lieutenant on the desk. 24 MR. : Okay. So, the fact that 25 if you're, you know, either you or is EFTA00061180

121 1 there, could have ended at 2? 2 MR. : Yes. 3 MR. : And there could be a gap 4 from 2 to 4 with -- 5 MR. : Yeah. That was actually 6 common. 7 MR. : Okay. 8 MR. : You know. Especially when 9 we didn't have a regular lieutenant scheduled 10 for the 2 to 10 activities. 11 MR. : Okay. So, would you 12 always get, as a lieutenant, especially as Ops 13 and Activities, would you get the prisoner 14 production lists? 15 MR. : Yes. From R&D. 16 MR. : And then was that 17 something that you were supposed to review? 18 MR. : It's basically, if we needed 19 it. 20 MR. : Okay. 21 MR. : Yeah. 22 MR. : So, for instance, this 23 one. It shows that it was dated Thursday, 24 August 8, 2019, prisoner production for August 25 9, 2019. EFTA00061181

122 1 MR. : Uh-huh. 2 MR. : It's from, it says -- 3 MR. -: 4 MR. 5 MR. : Yeah, he used to work here. 6 Now he works for the U.S. Marshals. 7 MR. : Okay. 8 MR. : Yeah. 9 MR. : And then this is the 10 attachment to it. 11 MR. : Uh-huh. 12 MR. : So, it says the second 13 list down was . Are you able to 14 tell from this at all what it was that was 15 going on with that day? 16 MR. : Sorry. That would probably 17 be the time that he had to go down to court. 18 MR. : Okay. 19 MR. : Down to R&D. 20 MR. : Does this transfer within 21 mean anything? 22 MR. : I'm not familiar. It 23 doesn't say that on our stuff. 24 MR. : But this would have been 25 what you got, right? This is the email that EFTA00061182

123 1 2 3 4 was sent to the lieutenants? MR. : Yeah. MR. : I pulled this from your emails. 5 MR. : No, I got it. 6 MR. : So, I'm just, I'm 7 curious, is this something that, like -- 8 MR. : Transfer within doesn't, it 9 don't jump out at me, cause I'm used to seeing, 10 like, pre-remove, pre-hold. 11 MR. : Okay. So, there's the 12 PP38 that you were talking about. 13 MR. : Okay. 14 MR. : It shows from 8/9/2019. 15 MR. : Uh-huh. 16 MR. : So that's the daily log. 17 MR. : Yeah. 18 MR. : On the third page, it 19 says, " , pre-remove, 8:38." 20 MR. : Yes. 21 MR. : If he was just going -- 22 MR. : That's the time that he was 23 keyed out of the institution. 24 MR. : So, if he was just going 25 to court, would have he been listed to pre- EFTA00061183

124 1 remove? 2 MR. : No. It would, I believe it 3 would say SDNY or EDNY, or whatever, whatever 4 court he was going to. 5 MR. : So, if it was listed as 6 pre-remove 7 MR. : Uh-huh. 8 MR. : -- does that assume that 9 he's not coming back? 10 MR. : Yes. 11 MR. : Okay. So, at 8:38 -- 12 MR. : Now, that has changed 13 before. Like, they've been pre-removed and 14 then come back -- 15 MR. : Okay. 16 MR. : -- because something got 17 cancelled. 18 MR. : All right. So, is this 19 something that you got, like, as the Ops and 20 the Activities Lieutenant, are you supposed to 21 be kind of aware of this stuff? 22 MR. : Well, we would get sent 23 this, mainly, I hate to say this, there would 24 be sometimes issues with the officers in the 25 morning, getting the inmates out to court. EFTA00061184

125 1 MR. : Okay. 2 MR. : And they wouldn't have the 3 actual court list, so if they had to call us 4 and be, like, hey, Lou, you know, R&D is 5 calling for this guy and I would just bring 6 this up, and be like, yeah, he's on the list. 7 But we wouldn't study this. We would just, we 8 were included in the Marshals loop, because we 9 would be the supervisors. 10 MR. : Now, if he was actually 11 being transferred to another institution -- 12 MR. : Uh-huh. 13 MR. : -- would he be also 14 listed on the court list? 15 MR. : No, he would be on the moves 16 for the day. 17 MR. : All right. So, here is 18 an email from also the U.S. Marshals Service, 19 from a Choo, C-H-O-O -- 20 MR. : Okay. 21 MR. : -- subject, "Transfer of 22 Prisoners from NYM to GEO." 23 MR. : GEO. GEO. 24 MR. : What's GEO? 25 MR. : It's the private jail. EFTA00061185

126 1 MR. : In New York? 2 MR. : Yes. I believe it's in New 3 York. I'm not sure. 4 MR. : Okay. And this one is 5 also dated Thursday, August 8, 2019. It says, 6 "The following prisoners are to be 7 transferred." Here it says, " ." 8 And his reg number. "Please schedule a 9 transfer for Friday, 8/9/2019." Do you know 10 why he would be listed on this email, on August 11 8th, as well as a prisoner production on August 12 8th? Is there any -- 13 MR. : No. No. That's whatever 14 the Marshals were doing. 15 MR. : Have you ever seen 16 something like that before? 17 MR. : What, moving an inmate? 18 MR. : Well, so, on this, it 19 says he's going to court, right? 20 MR. : Uh-huh. 21 MR. : But on this one, it says 22 he's being transferred. 23 MR. : Quite honestly, it's, I know 24 I've seen, like I said, like on the 38, I'm 25 just going, I'm sorry, I'm going BOP-wise. EFTA00061186

127 1 MR. : And then the 38 -- 2 MR. : On the 38, see, like, GCT 3 release, full-time release, FT release, or like 4 you see here, the pre-remove status and stuff 5 like that. 6 MR. : Yeah, so that's kind of 7 where we're trying to, we're trying to put 8 these pieces together. Why would he be on an 9 email here, saying that prisoner schedule 10 report, listing him as court. Here, saying 11 he's being transferred, excuse me, to the GEO. 12 MR. : GEO. 13 MR. : And then on the 38, 14 showing he's pre-removed. 15 MR. : Yeah. I guess, I'm 16 assuming, I could be wrong, this is just the 17 way our computer, the way our system puts it 18 in. Like, this right here, the FT release, 19 that means this guy maxed out. He's not going 20 to, like, a halfway house or anything like 21 that. Where is it? Pre-remove means he's 22 being transferred. 23 MR. : Pre-remove means he's 24 being transferred? 25 MR. : Transferred. EFTA00061187

128 1 MR. : And do you know if this 2 thing next to him would be that transfer within 3 thing? Would that be -- 4 MR. : I don't know. Honestly, I 5 have, I can't answer that. 6 MR. : Okay. Giovanne Bousy. 7 (Phonetic Sp. *01:29:42). Where's that guy? 8 Yeah, so, Bousy officer says transfer -- 9 MR. : Pre-remove. 10 MR. : -- and he's pre-remove. 11 But these other guys don't seem to say transfer 12 within. So, is this something like, if this is 13 being sent to the lieutenant, should you be 14 able to look at this and say, like, transfer 15 within, that means he's out of here? 16 MR. : Honestly, I can't answer 17 that. 18 MR. : Okay. 19 MR. : I have never looked, I have 20 honestly never looked at that part. 21 MR. : Okay. 22 MR. : I have never looked at it. 23 MR. : So, when you receive 24 this, do you, as the Ops Lieutenant, Activities 25 Lieutenant, look at these things, these EFTA00061188

129 1 prisoner production lists? 2 MR. : I would glance at it, and I 3 would see what it is, but I would normally, I'm 4 not going to lie. I would put it off to the 5 side, because I would only really use that if 6 there was a problem with the officers getting 7 the inmates to court. 8 MR. : Okay. 9 MR. : And then, you know, R&D 10 calling the lieutenants over, saying, hey, I'm 11 trying to get this dude down from 7 North, and 12 they're not sending him, and then I would look. 13 MR. : All right. 14 MR. : I didn't look at it every 15 day. 16 MR. : So, the fact that these 17 are being sent to the MCC -- 18 MR. : Uh-huh. 19 MR. : -- saying he's transfer 20 within here, and he's here being, you know, 21 this one is, the prison production list, and 22 this one is being the transfer order for these 23 two people. 24 MR. : Uh-huh. 25 MR. : And then obviously at EFTA00061189

130 1 8:38, he is listed as pre-remove. So, we're 2 being notified that is leaving the 3 institution. With these notifications from the 4 U.S. Marshals Service, who should have acted? 5 Who should have known, isn't coming back? 6 MR. : I mean, whoever saw it 7 first. 8 MR. : Who, is there somebody, 9 like, that's responsible for, like, saying, 10 like, all right? 11 MR. : Everybody in this address 12 box gets it from the Marshals. It goes out at 13 the same time. 14 MR. : Sure. 15 MR. : And that's what I mean, 16 there's a lot of people there. 17 MR. : Yeah. And that's the thing. 18 MR. : There's a lot of people 19 here, and there's less people on this one. 20 MR. : Uh-huh. 21 MR. : This one, it looks like 22 it's, does this look, can you indicate from the 23 transfer email, can you tell at that time who 24 those people would have been? 25 MR. : Okay. Everybody here is the EFTA00061190

131 1 R&D staff. 2 MR. : Okay. So, R&D gets the 3 actual transfer notice. 4 MR. : Uh-huh. 5 MR. : On this prisoner 6 production list, it looks like, you know, 7 saying that he's leaving and it 8 says a transfer within. 9 MR. : Uh-huh. 10 MR. : As does the other person 11 on this email. 12 MR. : Yeah. 13 MR. : This Giovanne 14 MR. : Bousy. 15 MR. : Bousy also says 16 transfer within. 17 MR. : Uh-huh. 18 MR. : None of the other guys 19 seem to say transfer within. They all say, 20 like, status hearing, sentencing, change of 21 plea. All that kind of stuff. 22 MR. : Uh-huh. 23 MR. : So, being that we got 24 this going to R&D, then we got this going to, 25 also, custody, saying that, you know, he is EFTA00061191

132 1 being transferred within, is it the captain 2 that should have known it? Is it, who is the 3 one that should have said, like, yes, we know 4 he's leaving this institution. This is 5 Epstein's cellmate. Who should have been able 6 to take action on this? 7 MR. : I can't, I can't, I don't 8 know. 9 MR. : You don't know? 10 MR. : I don't know. I don't know 11 who would have been the main person responsible 12 for it. I mean, I guess everybody, I guess 13 it's for everybody's eyes, but it wasn't 14 something that routinely got utilized. 15 MR. : Is this something that 16 would have been, if this is a transfer within, 17 this transfer notice, is this something that 18 the SHU staff would have been notified of? 19 Saying -- 20 MR. : No. SHU, I don't believe 21 SHU 22 MR. : Cause they're not on 23 this. 24 MR. : -- the COs were tagged on 25 it. EFTA00061192

133 1 MR. : But I'm saying, like, as 2 far as, here's the, you know, whatever -- 3 MR. : Well, the inmates, whatever 4 comes on that, whatever R&D gets from the 5 Marshals Service, they put out their own court 6 list to the staff. 7 MR. : Huh. 8 MR. : The officers get regular 9 court lists generated. So those names of those 10 inmates would get put on the court, the call 11 out list. 12 MR. : Okay. 13 MR. : And for the court list, and 14 that court list gets handed out in the morning. 15 MR. : Okay. So, as far as 16 this, it looks like we know he's being 17 transferred, and now that we're seeing that 18 these two guys that were being transferred are 19 both listed on this prisoner schedule report as 20 transfer within -- 21 MR. : Uh-huh. 22 MR. : -- what should R&D have 23 done? Should have they, are the people that 24 are listed on that court list, are they also 25 the people that are being transferred to other EFTA00061193

134 1 institutions? 2 MR. : No. Everybody on the court 3 list, it would say exactly what they are. If 4 they're on the court list, it would say, you 5 know, court. It would say, or, it would say, 6 you know, WAS. 7 MR. : Okay. 8 MR. : So, and then they send that 9 out to the housing units, including SHU. 10 MR. : So, again, if, you know, 11 going back to that memo, knows, it 12 says, would it say WAB or court? Or both? 13 MR. : I believe it just says, if 14 it's WAB, it would say, it would say, I think 15 it says FT remove, or I'm not 100% sure. I 16 haven't seen one in so long. 17 MR. : Okay. All right. So 18 you're not exactly sure what it said, but -- 19 MR. : No. 20 MR. : -- it's all the same 21 document of the people they need to bring down 22 that morning? 23 MR. : Yeah, but it's, all of this 24 is not on that. 25 MR. : Right. EFTA00061194

135 1 MR. : It would just say the 2 inmate's name and that he's got to be in, it 3 says a.m. court and p.m. court, from the last 4 time I saw the actual court list. A.M. court, 5 meaning he's got to be down there at 6:30 in 6 the morning, once R&D opens. 7 MR. : Okay. 8 MR. : P.M. court would be 9 afternoon. 10 MR. : All right. 11 MR. : And SHU gets that legal, 12 that court list, just like every other housing 13 unit. 14 MR. : But again, if 15 for instance, knows that he's the one who walks 16 him down to R&D, he walks down. He knows 17 he's WAB. Again, you're saying, you know he's 18 WAB. He ain't coming back unless something 19 gets cancelled. 20 MR. : Uh-huh. 21 MR. : Like a transport gets 22 cancelled. 23 MR. : Basically. 24 MR. : All right. So, it sounds 25 like is the one who actually should EFTA00061195

136 1 have, at the very least, notified his 2 superiors, hey, we need to get him a new 3 cellmate. Is it okay that he has wrote this 4 memo, saying, I passed it on. You know, I knew 5 at 8:38 he was WAB, but I passed it on to the 2 6 p.m. people, make sure he gets a cellmate? 7 MR. : I don't, like, can you, I'm 8 sorry. 9 MR. : So, I'm just trying to 10 figure out who messed up here. Cause 11 obviously, Epstein's required to have a 12 cellmate. 13 MR. : Uh-huh. 14 MR. : We saw from that email. 15 We know is being transferred. We know 16 he's gone. 17 MR. : Uh-huh. 18 MR. : So, we know the day 19 before it happens, there's emails that go out. 20 We know at 8:38, R&D listed him as pre-remove. 21 He's gone from this institution. However, 22 Epstein never gets a new cellmate. 23 MR. : Uh-huh. 24 MR. : Somebody doesn't take 25 action. So, what I'm trying to figure out is, EFTA00061196

137 1 who should have taken action? 2 MR. : I mean, I don't, I can't 3 make that decision. I don't know. 4 MR. : As the Ops Lieutenant at 5 the time, you can't figure that -- 6 MR. : I mean, as an Ops 7 Lieutenant, I should have been told by 8 somebody. 9 MR. : Right. 10 MR. : I should have known about 11 it. 12 MR. : Uh-huh. All right. And 13 so, when is passing, would 14 have known, though, if he were WAB? 15 MR. : I should have been notified, 16 truth be told, the way, I was brought up in 17 this agency, I should have been notified by the 18 OIC. 19 MR. : Right. So, but you 20 weren't on the schedule? Like, in the daytime? 21 MR. : In the daytime, no. 22 MR. : So that's where, I'm not 23 even focusing on you. 24 MR. : No, I get it. I get it. 25 MR. : I'm focusing on the EFTA00061197

138 1 daytime thing. 2 MR. : I get it. 3 MR. : What should have 4 happened? knows, WAB? 5 MR. : The OIC should have notified 6 day watch Operations. 7 MR. : Okay. So, should 8 have known, he should have been, he should have 9 known, yes, he is WAB and he needs a new 10 cellmate. 11 MR. : Uh-huh. 12 MR. : Then what should have he 13 done? 14 MR. : Made sure that he got a 15 cellmate. 16 MR. : Should have he notified 17 the captain? Or should have he just gotten him 18 the cellmate? 19 MR. : He should have got on the, 20 told the SHU OIC, hey, get, he needs a bunkie, 21 ASAP. 22 MR. : Okay. So, it basically 23 falls onto the Ops Lieutenant to have, he 24 needed to have taken that action? 25 MR. : To make sure that, ensure EFTA00061198

139 1 the OIC. 2 MR. : All right. And do you 3 remember, I know you said you didn't know he 4 transferred, but should his, you know, should 5 you have known by these documentations, from 6 this prisoner report? 7 MR. : If I had read that, well, 8 this, I don't, I have never seen this before. 9 MR. : Right. This one. 10 MR. : But that? 11 MR. : From looking at it? 12 MR. : I would just, from looking 13 at it -- 14 MR. : Would you even know? 15 MR. I don't remember, recall 16 the transfer within. I would always only look 17 at the names. And know that they have to be 18 generated for a court list. 19 MR. : Okay. So you just know 20 these people are going to court? You don't 21 even know that the transfer was (Indiscernible 22 *01:37:52) the transfer? 23 MR. : I don't always know, off the 24 top of my head, like, this guy is going here, 25 this guy is going there. I just know they have EFTA00061199

140 1 to be presented so there's no problems, like, I 2 said, I would only really refer to that if R&D 3 contacted me and said, hey, LT, this guy, I'm 4 waiting an hour so far for this guy. Can you 5 get on the office? And I'd look, okay, yeah. 6 Hey, Jones, inmate Schmukatelli (Phonetic Sp. 7 *01:38:11) from 7 North, you know, you got to 8 get him to court. 9 MR. : Okay. 10 MR. : He's on the court list. 11 MR. : All right. So, and as 12 the court list, does the Op, like, would 13 have had that court list, saying, if it said 14 WAB, would have he had that, , the Ops 15 Lieutenant, have the court list? 16 MR. : Yes and no. Sometimes, the 17 internal would drop a copy of the court list 18 off to the lieutenant's office. Mainly, the 19 main people that need it was internal, and the 20 housing units. 21 MR. : Okay. 22 MR. : And SHU. 23 MR. : All right. So, the Ops 24 Lieutenant isn't actually provided a copy of 25 the court list? EFTA00061200

141 1 MR. : It's not required. 2 MR. : All right. Okay. Do you 3 mind just initialing and dating these? 4 (Indiscernible *01:38:54). 5 MR. : While you do that, the 6 transfer email, the one that you signed, who 7 was that from? 8 MR. : It's from 9 MR. : And you mentioned before, 10 used to work here? 11 MR. : Yeah. He used to be BOP. 12 MR. : Just to clarify. Was he 13 working here during this Epstein time 14 (Indiscernible *01:39:07). 15 MR. : No, he was already gone. 16 MR. : Okay. 17 MR. : He's from the Marshals 18 Service. The Marshals Service. 19 MR. : But before, he said he was 20 working here, and now he's, I just want to 21 clarify for the record. 22 MR. : No, he was 23 MR. : Gone at that point? 24 MR. : -- gone long before that 25 happened. EFTA00061201

142 1 MR. : Thank you. Thank you. 2 MR. : This too? 3 MR. : Yes, please. The other 4 way, you can keep them in order. Thank you. 5 MR. : These too? 6 MR. : We're going to keep them, 7 just so if we have to refer to them. 8 MR. : Okay. 9 MR. : That's easier. All 10 right. So, what time is the daily activities 11 report and the lieutenant's log usually sent 12 out in the mornings for the day before? 13 MR. : It's done on the morning 14 shift. 15 MR. : So is it always supposed 16 to be done before 6 a.m.? 17 MR. : Yeah. As the morning watch 18 lieutenant, I have to make sure that before my 19 shift is done, I send out the whole thing, and 20 that's the roster, cause if you look at the 21 back, the last person to sign it is the evening 22 watch lieutenant. 23 MR. : Okay. 24 MR. : I now, as the morning watch 25 lieutenant, you know, the 10 to 6 or 12 to 8, EFTA00061202

143 1 whichever it is, this, I have to print out the 2 daily log, the three daily logs from the 3 midnight to 8, prior, the day shift, and the 4 evening watch and there's a thing that, and it 5 gets emailed to the exec staff, the captain, 6 and I believe it used to get emailed to the 7 executive assistant, if I'm not mistaken. 8 MR. : Okay. 9 MR. : There was a certain amount 10 of people on the thing. 11 MR. : But is it supposed to be 12 done, basically, the morning, the morning watch 13 shift ends at 6 a.m., correct? 14 MR. : Yes. 15 MR. : So it's supposed to be, 16 like, sent out before 6 a.m.? 17 MR. : Yes. 18 MR. : All right. So, I have 19 these emails from Tuesday, August 6, 2019. 20 This one was sent at 5:16 a.m. The next one 21 from August 7th was sent at 5:03 a.m. For some 22 reason, I wasn't able to look at Thursday, but 23 Friday, August 9th, was sent out at 5:11 a.m. 24 And then Saturday, August 10, 2019, it wasn't 25 sent out until almost, it says almost 9:30 a.m. EFTA00061203

144 1 9:26 a.m. Do you know why, any reason, why 2 that could have happened, if, if (Indiscernible 3 *01:41:21). 4 MR. : You know what? It might 5 have been because she didn't go home at the end 6 of her shift, because that kicked off. 7 MR. : But if that didn't kick 8 off until 6:33 a.m. -- 9 MR. : Uh-huh. 10 MR. : -- her shift, she says 11 she, the person relieved her by 6 a.m. -- 12 MR. : 5:30. 13 MR. : -- at 5, so somewhere 14 between 5:30 a.m. and 6 a.m. -- 15 MR. : Uh-huh. 16 MR. : -- is there a reason why 17 she wouldn't have sent it out before her shift 18 ended? 19 MR. : I don't know. 20 MR. : You don't know? 21 MR. : No, I don't know. 22 MR. : All right. And then the 23 next day, though, the next couple of days, 24 Sunday, August 11th, it actually doesn't, isn't 25 sent out until 6:15 a.m., and then the day EFTA00061204

145 1 after that, August 12th, it actually isn't sent 2 out until 6:36 a.m. 3 MR. : Yeah. It all depends on, 4 like, what, like I said, I mean, that's a 5 different story. That was an emergency 6 situation, but there's things, other things 7 that happen. You get tied up. You got to get 8 pulled, you know, got to go see the captain. 9 You got to go, you're in R&D, dealing with 10 something, and then you don't get to close out. 11 Especially if you're doing a double, too. 12 MR. : Okay. So, in this case, 13 though, in these cases, like, for the morning 14 watch Ops Lieutenant, do they sometimes get 15 relieved and that's when they work on, oh, I 16 got to get all the, I got to get the activity, 17 or I got to get the daily log and lieutenant's 18 log up-to-date now? 19 MR. : Uh-huh. 20 MR. : And then stay behind to 21 do that? 22 MR. : As far as, well, after 23 you're relieved? 24 MR. : Yep. 25 MR. : It does happen. EFTA00061205

146 1 MR. : Right. 2 MR. : You know, you can't, the 3 bottom line is, as a lieutenant, you should not 4 be leaving and leaving stuff incomplete. 5 MR. : Okay. And it's that Ops 6 Lieutenant's responsibility to complete it? 7 MR. : Yes. 8 MR. : And then once it's 9 completed, are they then supposed to send out, 10 send it out to everybody? 11 MR. : Yes. The morning watch 12 Operations Lieutenant -- 13 MR. : Right. 14 MR. : -- is the one that sends out 15 the paperwork. The daily paperwork. 16 MR. : All right. So, the fact 17 that, if something wasn't sent out before 9:30, 18 does that indicate to you, you know, you, well, 19 it's because she hadn't finished it yet, so she 20 stayed behind in order to finish it? 21 MR. : That definitely could be the 22 case. 23 MR. : Okay. Do you mind just 24 initialing and dating that? 25 MR. : Sure. EFTA00061206

147 1 MR. : All right. Thank you. 2 Now, here is the one that we were just talking 3 about, that sent out on 4 Saturday, August 10, 2019, at 9:26 a.m. As 5 you'll see, this is August 10th. So I just want 6 to draw your attention to a few things. 7 Friday, August 9th, that starts at 12 a.m., then 8 we get to 8:30 a.m. On this daily activities 9 log, it shows at 8:38 a.m., from the 10 SHU, or from ZO6-220 UAD to pre-remove. Who 11 would have filled that out? Do you know? 12 MR. : The Operations Lieutenant. 13 MR. : At the time? 14 MR. : Yeah. Day watch operations. 15 MR. : All right. So, is it R&D 16 should have called and told the Operations 17 Lieutenant, hey, this person is pre-removed and 18 that's how, how would they get that 19 information? 20 MR. : No, well, normally, we would 21 do a 38. 22 MR. : Okay. So, as in, that, 23 he would have been entered in the system at 24 that time, saying remove? 25 MR. : Uh-huh. That would, yeah, EFTA00061207

148 1 and then, cause as the inmates leave the 2 institution, this has to get updated. 3 MR. : But wouldn't, I mean, we 4 do have the 38 that I showed you at 8:38, but 5 would this be R& doing that, or the Operations 6 Lieutenant? 7 MR. : No. The day watch 8 Operations Lieutenant would print out a 38. 9 MR. : Okay. 10 MR. : To do this. To be able to 11 do this. 12 MR. : Okay. 13 MR. : Basically, we would read off 14 of that. 15 MR. : So, would only, so, for 16 this specific thing from 8 a.m. to 4 p.m., is 17 this the responsibility of, for instance, in 18 this case, 19 MR. : Day watch operations. Yes. 20 MR. : So, would, could, 21 should, could anyone after , like, you or 22 even , who sent this out -- 23 MR. : Anybody could go back in and 24 update the log. 25 MR. : And is that a problem, if EFTA00061208

149 1 they do that? 2 MR. : I don't know. I guess now 3 it is, but I don't 4 MR. : No, no, no. I'm not, I 5 don't know that it's a problem or not. 6 MR. : No, we, we, we, it's common 7 practice. It's like, if, you know, we could go 8 back and correct, cause this way, look, also, 9 if an incident happened on day watch, I'm not 10 talking about this incident. If, let's say, 11 there was a use of force. 12 MR. : Uh-huh. 13 MR. : And that day watch 14 lieutenant is running the use of force team, 15 the oncoming lieutenant could, like, update the 16 log, so that lieutenant could finish what, you 17 know, he or she was doing with the move. 18 MR. : Okay. But in this case, 19 at 8:38, now, he's listed as pre-removed right 20 here. 21 MR. : Uh-huh. 22 MR. : Who do you believe would 23 have entered that? 24 MR. : It should, in my opinion, it 25 would be the day watch Operations Lieutenant. EFTA00061209

150 1 MR. : And then, again, if it's 2 listed as pre-removed, would they have known, 3 hey, is gone? He's not coming back. 4 MR. : That should be an indicator, 5 yes. 6 MR. : Okay. And again, that 7 would have been , so entered this 8 and it actually says, pre-remove. Hey, 9 is gone. Epstein needs a new roommate or 10 cellmate? 11 MR. : Uh-huh. 12 MR. : All right. Do you 13 remember anything regarding, I know this is at 14 3:15 p.m., but it says, I.M. , placed 15 on dry cell from ZA." Do you remember anything 16 involving that? 17 MR. : I do not. I don't recall. 18 MR. : All right. I'll show you 19 some emails later. But, this, again, do you 20 believe that would have been the Ops Lieutenant 21 that would have entered that? 22 MR. : Yes. Only a lieutenant is 23 doing this log. 24 MR. : Okay. 25 MR. : That's the lieutenant's log. EFTA00061210

151 1 MR. : So, if someone after this 2 shift did this, would they have to, like, is 3 there a way to just kind of enter a line in 4 here to do, you know, extra? How would they 5 modify this? Would they have to modify 6 everything or can you just enter in 7 MR. : No. You could add a space. 8 MR. : Add a space? 9 MR. : Add a space. 10 MR. : And then do 11 (Indiscernible *01:46:31). 12 MR. : And then just enter the time 13 and enter it then. 14 MR. : And as far as you're 15 concerned, that's actually not an issue, if 16 they go back and correct something or -- 17 MR. : Not that they go back and 18 correct. If you go back and have to add, 19 because now you're involved in the thing. 20 Like, let's say if I was coming on and you were 21 the day watch Operations Lieutenant, I was the 22 evening watch, and I'm relieving you. 23 MR. : Right. 24 MR. : And you're like, hey, we got 25 a use of force going on upstairs. Right? I EFTA00061211

152 1 got to go run the team. Can you just finish my 2 log? That kind of thing. 3 MR. : Okay. 4 MR. : You know? Not so much go 5 back to dot another lieutenant's I's and cross 6 another lieutenant's T's. 7 MR. : Okay. 8 MR. : Just like piggyback off of 9 one another. 10 MR. : Okay. 11 MR. : And I'm sorry, I have to 12 keep leaning in, cause I don't have glasses. 13 MR. : No, no, no. I'm sorry. 14 I'm sorry. So, 3:15, there's this, and this is 15 where the confusing part is. We're not sure 16 who exactly, so this was your shift. 17 MR. : Uh-huh. 18 MR. : So, would have this top 19 part been something that you would have added, 20 or then brought over? It does say it up here. 21 So, does this all just get transferred from 22 this space over to here? 23 MR. : Yes. Uh-huh. And then, 24 anything then has to be added or added or taken 25 away. EFTA00061212

153 1 MR. : Okay. So, on this one, 2 it says, "I.M. , dry cell with staff 3 in R&D." It says, "Good verbal count 4 announced." Now, this is where it starts 5 getting a little tricky, because we have to -- 6 MR. : Uh-huh. Yeah. I had gone 7 home almost at 10:00. This is where, like I 8 said, where the piggyback would be. 9 MR. : Yep. 10 MR. would go, just and 11 close out, because she would be the one here, 12 when the clear count took place. 13 MR. : Okay. So, this is where 14 things get a little whacky, because we're 15 saying, it looks like somebody would have 16 possibly modified this, especially, see, look. 17 This one is Saturday, August 10, 2019. 18 MR. : Uh-huh. 19 MR. : Starting at 12 a.m., 20 Lieutenant G. assumes duties. The SHU 21 says 73-5. Well, at 12 a.m., it actually came 22 over as 72-5. At 12:35 a.m., minus one SHU 23 correction, , dry cell. was 24 not keyed out of SHU -- 25 MR. : Uh-huh. EFTA00061213

154 1 MR. : -- until 12:35, although 2 he was removed at 3:15 p.m. We're going to get 3 into the counts now, but all these counts are 4 off. That's not what the counts were. 5 MR. : Uh-huh. 6 MR. : The counts were actually 7 plus one for all of these, although they should 8 have been, these should have been the accurate 9 numbers, but they weren't. 10 MR. : Huh. 11 MR. : It came over, on the 12 counts, these are listed as 73, 73, 72, 74, 75, 13 76. 14 MR. : Always one more. 15 MR. : Right. And it's because 16 this was corrected to go back down to 72-5, and 17 this was 73. So, I'm just trying to piece this 18 together. Would that be, why would have she 19 done that, if she has got listed that there was 20 this correction, why would have she gone back 21 and changed all that stuff? 22 MR. : I don't know. Maybe cause 23 she didn't want to go back and change it. I 24 don't know. I can't -- 25 MR. : Does that make sense to EFTA00061214

155 1 do that, though? 2 MR. : I can't answer. 3 MR. : If it came over as 73-5, 4 and this list is listed at 72-5, does that make 5 any sense to do that? 6 MR. : No, I would want to go back 7 and verify everything, because then if the 8 count is not right. I would want to ensure 9 that the count is right. 10 MR. : All right. So, let's go 11 over the counts then. 12 MR. : I can't really answer the 13 question, though. I don't know why it was 14 done. 15 MR. : So, here, just to close 16 the loop with , here is, so, for 17 instance, here is a, to the lieutenants, it 18 says it's from (Phonetic Sp. *01:50:02) 19 20 MR. : PA, physician's assistant. 21 MR. : Okay. So, it says, you 22 know, inmate name. Here is another one that's 23 from the captain to you, asking you to use a 24 specific form. It looks like this is a 25 synopsis from on what actually, I guess, EFTA00061215

156 1 transpired. 2 MR. : Uh-huh. 3 MR. : I'm assuming maybe you 4 sent it to him or . So, here is one 5 that sent to you on Friday, August 9, 6 2019, at 6:07 p.m. 7 And this is the, you know, synopsis of 8 what happened. "On August 9, 2019, at 9 approximately 1:40 p.m., SOS , while 10 assigned to the Special Housing Unit, proceeded 11 to enter the 9 South visiting room. As I 12 walked towards the door, I observed through the 13 visiting door inmate attempt to grab 14 an unknown item from his visitor. Once inmate 15 reached to grab the item, I 16 (Indiscernible *01:50:55) the door and called 17 for a lieutenant. Once I was able to enter the 18 visiting room, I gave inmate a direct 19 order to walk to the visiting room to conduct a 20 visual search. Inmate complied and a 21 visual search was conducted. Operations 22 Lieutenant was contacted and inmate 23 was removed from the unit." 24 So, should have this been listed as 3:15 25 p.m., or should it have been listed as 1:40 EFTA00061216

157 1 p.m.? Do you know? 2 MR. : No, the 3:40 p.m. would be 3 the time that he was placed on dry cell. 4 MR. : Okay. 5 MR. : Would not necessarily be the 6 time of the incident. 7 MR. : All right. So, this, 8 where he did the visual search 9 MR. : This is the time, this is 10 the time of the incident. 11 MR. : -- but not the time, 12 okay. This is the time of the incident, dry 13 cell would have been a different thing. All 14 right. Do you remember, I mean, do you 15 remember at all that incident on that day? 16 MR. : I don't recall. It happened 17 so often, so. 18 MR. : Sure. Now, would 19 it says that he sent you this at 6:07 20 p.m. Would have he sent this to you from 21 inside the institution? 22 MR. : Yeah. It would have been 23 from the computer. Email. 24 MR. : Okay. So, if he's not 25 listed on anywhere. He's listed as leaving at EFTA00061217

158 1 1:50 p.m. Is it, we're able to tell where 2 was? 3 MR. : That's odd. That is very 4 odd. 5 MR. : And it all makes sense 6 that he was there at 6:07, because all these 7 inmates' emails are going back, you know, use 8 this one. That was at 4:38 p.m., from the 9 captain to you. And from the PA was the one at 10 3:11 p.m. So, I'm trying to figure out, why 11 was here at 6:07 p.m.? 12 MR. : That's very odd. I don't 13 recall. I don't remember. 14 MR. : No? 15 MR. : I don't recall. 16 MR. : But that would have had 17 to have been sent from in here? Especially 18 from an officer, right? 19 MR. : That's, yeah. An officer 20 doesn't have the outside email access. I 21 didn't, as a lieutenant. 22 MR. : Right. So he was 23 definitely here at 6:07 p.m.? 24 MR. : If that came through at that 25 time, that's on the government computer. EFTA00061218

159 1 MR. : Okay. Do you mind just 2 initialing and dating that? Sorry. 3 MR. : No problem. 4 MR. : All right. Now, here's 5 the inmate history move. Just to, so, again, 6 close that loop. So, it shows , here 7 are his inmate history quarters. And it shows 8 9 MR. : (Indiscernible *01:53:05) 10 MR. : -- that on 8/2/2019, he 11 was brought to the SHU, Z, and then it shows on 12 -- 13 MR. : 8/10, right next to it. 14 MR. : Yeah, I'm just, just give 15 me a second. So, yeah, then it says that 16 8/10/2019, at 0035, that's when he was moved 17 over, I guess, to, what does that stand for? 18 MR. : That's the R&D cells. 19 MR. : So, R01 is the R&D cells? 20 MR. : Uh-huh. 21 MR. : So, that's when he was 22 keyed out of the system, at 0035. Which does 23 correspond to that, 12:35 a.m. 24 MR. : Yeah, he was probably never 25 punched out, and they, somebody probably ghost- EFTA00061219

160 1 counted him. 2 MR. : Okay. So, do you mind 3 just initialing and dating that? Thank you, 4 sir. All right. Now, we're going to go into 5 these, just while these lieutenant sheets are 6 up, kind of go into some of these counts. All 7 right. So, here we got the 8/9/2019, Federal, 8 or, sorry, Bureau of Prisons count sheet. This 9 is the E-1, correct? 10 MR. : Yes. 11 MR. : And on the E-1, at ZA, 12 what does the number 6 show? 13 MR. : 77. 14 MR. : All right. So, 77. 15 Let's go back to this guy and see what the 16 number says. All right. So, it looks like 77. 17 Okay. Now, what does the /5 mean? 18 MR. : 10 South. 19 MR. : 10 South? 20 MR. : Wait, what, I'm sorry, what? 21 MR. : So, this /5? 22 MR. : Yeah, that's 9 South/10 23 South. 24 MR. : All right. So, on the 25 daily, on the daily lieutenant's log, it shows EFTA00061220

161 1 77/5, and on the E-1, it shows 77 for ZA and 5 2 for ZB. And we go, we look at the 3 corresponding count slip for ZB. It says 5. 4 For ZA, it says 77, correct? 5 MR. : Yeah. 6 MR. : All right. Mind just 7 initialing and dating that? 8 MR. : Is that the 5A one? 9 MR. : 5A, yeah. All right. 10 Thank you, sir. Okay. So, now this is where 11 we start getting a little bit into the weeds 12 here. So, this is the 4 p.m. count, correct, 13 on August 9, 2019? 14 MR. : Uh-huh. 15 MR. : All right. So, the E-1 16 shows for ZA, there is, it says for the census 17 column 76, for the count, 75. And is that 18 because one is -- 19 MR. : One is keyed out, right 20 here. Look. Right here, one is from attorney 21 conference. This Atty right here? 22 MR. : Yep. 23 MR. : Is attorney conference, so 24 you had one out count and two attorney 25 conference. EFTA00061221

162 1 MR. : So, Epstein is in 2 attorney conference. We got one there. So, 3 inside the SHU should be 75, correct? 4 MR. : Yes. 5 MR. : All right. So, for the 4 6 p.m. count, (Indiscernible *01:56:10) count in 7 progress, it shows there should have been 75 or 8 should, this said 76. What should that have 9 said there? 10 MR. : If he was keyed out -- 11 MR. : So, looking at this E-1 - 12 - 13 MR. : The E-1 is showing that he 14 was in attorney conference. 15 MR. : Right. So, should this 16 number on the lieutenant's log have said 75 or 17 76, based upon this? Should it have said this, 18 76 number or should it -- 19 MR. : It's whatever this is. 20 MR. : So, this should have said 21 75, as of this 22 MR. : Yes. Yes. 23 MR. : All right. Now let's go 24 look at the corresponding. ZE shows 5. ZA 75. 25 MR. : 75. EFTA00061222

163 1 MR. : All right. So, that's 2 correct, then? 3 MR. : Yes. 4 MR. : Based upon that? 5 MR. : Yep. 6 MR. : All right. Do you mind 7 initialing and dating? 8 MR. : Just a question on that. 9 Keep in mind, you started off the day at 77. 10 MR. : Uh-huh. 11 MR. was removed. 12 MR. : We'll get into that. 13 MR. : Okay. 74. 14 MR. : Yeah, I'm just, what's 15 that? 16 MR. : Shouldn't this be 74? 17 MR. : I'm just, I just want to 18 know, according to this, cause we can go back 19 to things. 20 MR. : Okay. 21 MR. : All right. So, here is 22 the 8/9/2019. It shows, this is for the 10 23 p.m. count. So, this ZA says 73 and 73, 24 correct? 25 MR. : Yes. EFTA00061223

164 1 MR. : All right. So, the 10 2 p.m. count, good verbal announced. What does 3 that say? 4 MR. : 72. 5 MR. : 72, so the daily 6 lieutenant's log says 72 here, but this says 7 73. 8 MR. : Uh-huh. 9 MR. : Okay. Do you know why 10 that would be? 11 MR. : I don't know. There might 12 have been somebody, math was messed up, as far 13 as the lieutenants. As long as this is right, 14 and this jives with the officer's counting in 15 the units, that's what matters. That means we 16 don't have an escape. This, you know, people, 17 I'm not the greatest mathematician in the 18 world. 19 MR. : Okay. 20 MR. : You know, you make a, what's 21 the word, an arithmetic mistake. 22 MR. : Sure, sure. Do you 23 believe, though, this would have said 73, since 24 this over here says 73, on the next day? 25 MR. : I mean, it should. If there EFTA00061224

165 1 was no movement. 2 MR. : Right. 3 MR. : Between the evening watch 4 and the morning watch. 5 MR. : Right. And we'll go 6 through the numbers, like you were just 7 suggesting, later. I'm just trying to 8 correlate what this says, what this says, with 9 what this says. 10 MR. : Uh-huh. 11 MR. : You know, so they are 12 different numbers here. All right. So, the 13 fact that this says on it? 14 MR. : Uh-huh. 15 MR. : Would that mean that he 16 would have been the one that actually takes the 17 count? 18 MR. : He was the one that took the 19 count. 20 MR. : So, even though, when we 21 go back before you said that, I think you said 22 that Control 1 would have been doing the keys 23 and all that stuff. 24 MR. : Uh-huh. 25 MR. : And , did I EFTA00061225

166 1 pronounce that? 2 MR. 3 MR. would have been, 4 but looking at the actual E-1, it looks like K. 5 actually took the count? 6 MR. : Yeah. Well, at 10:00, 7 though, nobody is coming in or out, except 8 basically whoever is on 2 to 10. 9 MR. : Okay. 10 MR. : And also at 10:00, he's 11 alone. 12 MR. : Oh, he's alone? So, 13 is not there? 14 MR. : Yeah, cause goes home 15 at 10:00. 16 17 18 19 20 p.m. Okay. So, is the one who did the 21 10 p.m. All right. Now we're on the same 22 page. Now we're going to look at the 23 corresponding count slips. You would have been 24 gone by this count, correct? 25 MR. : Yeah. MR. : All right. So, is there. MR. Who was the one on the -: 4 p.m.? MR. : Okay. did the 4 EFTA00061226

167 1 MR. : All right. So you're 2 gone now. So here's R&D. We get 1. But on 3 the, where would it have shown R&D on this? 4 MR. : Wherever he was keyed out 5 of. 6 MR. : Would it have been this 7 RA? 8 MR. : Yeah. It should have been 9 ZA. It should have been somewhere over here in 10 this column. 11 MR. : All right. So, we got 12 no, we got a count slip for R&D 1. 13 MR. : Uh-huh. 14 MR. : But nothing on the E-1, 15 saying there was anybody in there. And then 16 we've got ZA, 73. So, this one says 95 plus 1, 17 on top of the R&D 1, and then we go over to the 18 ZA count slip. Or not, sorry. 19 MR. : 9 South plus 1. 20 MR. : 9 South plus 1. Sorry. 21 MR. : That's why, they ghost- 22 counted him from 9 South in R&D. 23 MR. : All right. So, if you 24 read this, this one says, for ZA, says 73 plus 25 1. EFTA00061227

168 1 MR. : Yeah, plus 1. 2 MR. : Does that mean that that 3 actually should be 74, if they're saying plus 4 1? 5 MR. : Unless that's the plus 1, I 6 don't know how they did the numbers. How they 7 did the math. 8 MR. : Okay. Have you ever seen 9 anything like this before? Plus ls? 10 MR. : I've seen them ghost- 11 counting. 12 MR. : Have you seen plus is on 13 our count slips? 14 MR. : No. 15 MR. : All right. What about 16 the fact that -- 17 MR. : Cause honestly, in 21 years, 18 this is the first time I'm seeing a plus 1 on a 19 count slip. 20 MR. : Okay. So you have never 21 seen a plus 1 before? 22 MR. : No. 23 MR. : What about, have you ever 24 seen anything where every single count slip is 25 crossed off, aside from these two? EFTA00061228

169 1 MR. : Yes. I don't know about 2 these two. I know as, when you're taking the 3 count -- 4 MR. : Yep. 5 MR. : I normally, that's how we 6 get the clear count. 7 MR. : Sure. 8 MR. : When we do the good verbal 9 by, what we do is, we make one line. When the 10 unit officers call 11 MR. : On the E-1, right? 12 MR. we make the one line on 13 the E-1. Once I get all the paper, cause what 14 we'll do is, like, once I have a good verbal, I 15 do the one line and I see every unit has got a 16 good verbal. That's when I tell Control, we 17 got a good verbal count at whatever time. And 18 then we say, awaiting paper. And once internal 19 brings down all the count slips, whoever that 20 person is that's taking the count will have 21 those count slips in front. Not everybody does 22 it. I do it. I would, I'm a crosser. And 23 what I do is I verify everything and that's 24 when I make my X on the E-1. 25 MR. : Does this suggest EFTA00061229

170 1 anything to you, though, the fact that every 2 one of these count slips is crossed off, aside 3 from R&D, where there is no one actually on the 4 E-1 -- 5 MR. : And SHU. 6 MR. : -- and then SHU, which 7 has the 73 plus 1, on the E-1, it says 73. On 8 the count slip, it says 73 plus 1, but on the 9 daily log, it says 72. Any, does that indicate 10 anything to you, the fact that those aren't 11 crossed out? 12 MR. : The only thing that jumps 13 out at me is that it might have been somebody 14 else that did these two count slips versus 15 these. 16 MR. : Like someone who was 17 taking the count, like Would 18 would have been the person that, like, crossed 19 these things out? 20 MR. 21 crosser or not. 22 MR. 23 : I don't recall if he was a : But who, if it wasn't K. who would it have been? 24 MR. : At that point in time, it 25 was only him in Control. EFTA00061230

171 1 MR. : All right. And it was 2 MR. : If the lieutenant was in 3 there, she would, her name would be here. 4 MR. : So who would have taken 5 over for you? You said you only worked until 6 10? 7 MR. : I worked until 10. 8 MR. : So who would have taken 9 over at 10? 10 MR. -: relieved me that 11 night. 12 MR. : So, would have 13 relieved you at 10? 14 MR. : And then she worked until 6 15 in the morning. 16 MR. : Okay. So, she didn't 17 start at midnight. She started at 10. Okay. 18 MR. : Yeah. That's why I was 19 saying the Ops Lieutenant, we used to do the 20 two hour differences. 21 MR. : So, is it possible that 22 actually took this count? 23 MR. : I'm trying to, may I? 24 MR. : Yeah. Absolutely. Are 25 you able to even tell -- EFTA00061231

172 1 MR. : She did take it. This is 2 her signature. 3 MR. : All right. So, 4 took the 10 p.m. count? 5 MR. -: prepared the count. 6 MR. : Okay. 7 MR. : This is her, this is her 8 loop in there, taking the count. 9 MR. : All right. So, 10 took the 10 p.m. count. Okay. And then, this 11 is where, so, can you tell from this E-1 on 12 August 10, 2019, at the 12 a.m. 13 MR. : 3, this is 3:40. 14 MR. : Sorry. Oh, no, no, no. 15 So, you're saying the 12 a.m. count, 16 took? 17 MR. : Yes. 18 MR. : All right. Not the 10 19 p.m.? 20 MR. : The 10 p.m., did by 21 himself. 22 MR. -: took, so, forget 23 that. 24 MR. : I'm sorry, the time is, I 25 mean. EFTA00061232

173 1 MR. : Yeah, absolutely. So, 2 did the 10 p.m., the ones that have the 3 count slips with the 9 South plus 1, and the 73 4 plus 1. did the 12 a.m. count. 5 MR. : 12, yeah. 6 MR. : And the 12 a.m. count is 7 the one where it goes from the E-1 at 10 p.m., 8 the day before, with 73, the 12 a.m. E-1, is 9 72, and now let's go to the corresponding count 10 slips. ZA, what's the number on that? 11 MR. : 73. 12 MR. : 73. So the count slip 13 says 73 for 12 a.m., but the E-1 says 72. 14 MR. : Yeah. 15 MR. : Can you think of why that 16 would be? 17 MR. : Like I said, the only thing 18 that comes to mind is a ghost count. 19 MR. : Okay. Then the RA still 20 says 1, though. Can you ghost count someone if 21 they're putting in count slips for 1? 22 MR. : No, cause then there would 23 be, it would be off by plus 1. 24 MR. : And then R&D now has 1 in 25 there, correct? EFTA00061233

174 1 MR. : One, yeah. 2 MR. : So, 72 in ZA, 1 in RA. 3 MR. : This is, this is jiving with 4 this. That's working. 5 MR. : Now it's working, here it 6 wasn't. 7 MR. : From what I understand. 8 From what I'm, the way I'm reading it. 9 MR. : Right. Have you ever 10 seen anything like this before? 11 MR. : I have never seen plus is 12 written on the count slip. 13 MR. : Plus, what about count 14 slips that aren't corresponding with what's -- 15 MR. : I have seen staff, but 16 normally, you have, you call that unit officer 17 and be, like, hey, I need a new count slip. 18 The count slip is wrong. That I have seen. 19 MR. : All right. 20 MR. : Plus is, I have never seen. 21 I have never seen anybody write a plus 1 on a 22 count slip. 23 MR. : Okay. And then 3 a.m. 24 again is a . Does this mean that -- 25 MR. : Cause he's alone, yeah. A EFTA00061234

175 1 lieutenant only has to do one count on a shift. 2 MR. : Sure. And is there any 3 indication that anybody on here did anything, 4 other than 5 MR. : No. That's his -- 6 MR. : Okay. And then again, ZA 7 says 72, 72. Z-- 8 MR. : ZB? 9 MR. : ZB says 5. And RA says 1 10 and 1. 11 MR. : Uh-huh. 12 MR. : And again, there are the 13 corresponding count slips now. The count slips 14 for ZA do say 72, and ZB says 5, and the RA 15 says 1. Same thing with the -- 16 MR. : 5 a.m. 17 MR. : -- the 5 a.m. count. 18 Same deal. We don't need to go into the rest 19 of them for this. So, does this indicate to 20 you for all, does this indicate anything to you 21 for all of this? Does it indicate that they 22 weren't conducting their counts at all? Let's 23 take this out of the picture and let's directly 24 focus on the E-1 and the count slips here. The 25 fact that at the 10 p.m. count, they're listed EFTA00061235

176 1 73. The count slip says 73 plus 1. And then 2 the 12 a.m. says 72. Count slip says 73. And 3 then on the daily lieutenant's log, the guy, 4 , is keyed out at 035 hours, because 5 he was keyed into the SHU the whole time. 6 MR. : Uh-huh. 7 MR. : And then everything is, 8 from that point forward, is corrected to 72. 9 So he was never present in the SHU. We have 10 got the 10 p.m. and the 12 a.m. counts, we both 11 have count slips for, saying that he's there in 12 RA, and somehow, their numbers, there is only 13 72 people in the SHU. So the count slips are 14 showing 73 people. There's only 72 people in 15 there. The E-1 at 10 p.m. says 73, even though 16 there's only 72 people in there. 17 MR. : Two. 18 MR. : The E-1 at midnight does 19 show 72, but that's only because at 12:35 -- 20 MR. : It was corrected. 21 MR. : It was corrected. And 22 the count slip says 73, although there were 23 only 72 people in there. Does that indicate to 24 you that the people in the SHU were just 25 basically going off of what the E-1 should have EFTA00061236

177 1 said, versus counting it themselves? 2 MR. : It's possible. I mean, I 3 know that they are charged with falsifying 4 documents. 5 MR. : Yep. 6 MR. : I know they say that they 7 did not conduct a count, so I guess so. I 8 guess that's what they, I don't know. 9 MR. : How would have they 10 gotten the number 73? So, 73 is what is on the 11 E-1. 12 MR. : Uh-huh. 13 MR. : There is only 72 people 14 in the SHU. But they're listing 73 on the 15 count slip. 16 MR. : It could have been easily, 17 in my opinion, it could have been easily as 18 they were going off of the SHU locator, and the 19 locator wasn't corrected. 20 MR. : What's the SHU locator? 21 MR. : It's basically a chart with 22 the cell assignments and the inmates names and 23 numbers written in it. So, basically, you have 24 what inmates are in where. Right? 25 MR. : So, it's like a document? EFTA00061237

178 1 MR. : It's not, like, an official 2 BOP thing. It's something that was brought, 3 it's like made in Word. It's basically like, 4 almost like a blueprint. But it's of, it will 5 have the cells, and it will state what names, 6 like, the SHU staff use it to also, when 7 they're doing the showers, right, they'll mark 8 off who got their showers. 9 MR. : Okay. 10 MR. : And everything like that. 11 MR. : Is that something that 12 only the SHU staff has? 13 MR. : That's only, that's 14 upstairs. Unless you're -- 15 MR. : Does the E-1 people, does 16 Control have access to that? 17 MR. : Not everybody has access to 18 a PPE-1. 19 MR. : So, the thing, though, 20 that, if they're using this thing that you 21 just, what did you call it again? 22 MR. : The locator. 23 MR. : So, if they're, the SHU 24 staff is using a locator, does the people in 25 Control have access to that locator? EFTA00061238

179 1 MR. : Not to the locator, no. 2 That's a SHU thing. 3 MR. : All right. And then some 4 people in the SHU could have had access to, 5 what are the people in the Control utilizing? 6 MR. : Control have the E-1 access. 7 Lieutenants have an E-1 access. 8 MR. : All right. 9 MR. : Not everybody has full 10 Sentry access. 11 MR. : All right. So, going to 12 this 10 p.m. count, do you know if, so who, on 13 the ZA count slip, it says and Noel, 14 correct? 15 MR. : That's definitely 16 Yeah, Noel, all right. I don't know what I'm 17 looking at. I'm sorry. I don't have my 18 readers. 19 MR. : Sure. 20 MR. : N-O-E-L, yeah. 21 MR. : Do you know if either of 22 these people would have had access to this E-1 23 data? 24 MR. : I do not know if they had 25 it. EFTA00061239

180 1 MR. : You don't know? 2 MR. : I do not know. 3 MR. : Okay. 4 MR. : Computer Services would have 5 a record of who has access to what on Sentry. 6 MR. : All right. Fair enough. 7 And do you know anything about them falsifying 8 their counts? 9 MR. : I do not. 10 MR. : No? 11 MR. : Like I said, I only know 12 what I have read and what I hear. 13 MR. : Okay. And what have you 14 heard? 15 MR. : The same thing that you, 16 they're being charged with. I heard that they 17 were sleeping and they didn't count and -- 18 MR. : Had you heard at all that 19 either the 4 p.m. or the 10 p.m. counts weren't 20 conducted? 21 MR. : No. I heard the overnight 22 counts. 23 MR. : All right. So just the 24 midnight, 3, and 5? 25 MR. : Yes. EFTA00061240

181 1 MR. : But you hadn't heard 2 about the 4 or 10? 3 MR. : I was told that at 10:00, 4 not that I was told, from what I heard, at 5 10:00, he was alive. 6 MR. : Okay. Again, though, 7 going back to this lieutenant -- 8 MR. : Do you want me to sign this? 9 MR. : Yeah. I'm going to have 10 you do that now. Going back to these 11 lieutenant logs, do you know why, how that 12 could be off, too, though, if the E-1 and the 13 count slips are all saying 73 at 10 p.m., why 14 would they be writing 72 here? 15 MR. : Honestly, I don't know. 16 Like I said, some people are better in math 17 than others. It could be just a simple 18 arithmetic mistake. 19 MR. : But do you think that 20 being that it came over as 73, 21 is the one that corrected being out, 22 and then she doesn't send the activities report 23 daily log out until 9:30 a.m. Do you think 24 that she would have gone back in there and 25 maybe she just -- EFTA00061241

182 1 MR. : I don't know. I don't know. 2 MR. : Would have she been 3 authorized to do that? 4 MR. : No. I don't know. I can't 5 answer that question. I have, I'm not 6 MR. : But you had mentioned 7 that people can go in and (Indiscernible 8 *02:11:57). 9 MR. : It can be done. You can go 10 back and do it. 11 MR. : Now, should she have? 12 MR. : No. Not that I know, unless 13 she saw that, unless she was trying to make the 14 correction, to make sure that everything was 15 right with the count. 16 MR. : And that's what I mean. 17 MR. : Which we, you know, we all 18 try to look, you know, to better, at the end of 19 the day, remember, accountability is the most 20 important thing. 21 MR. : Yeah, yeah. 22 MR. : So, we would try to make 23 sure that it's there, and it's not to, like, 24 cover up or anything like that, cause at this 25 point in time, nothing was wrong. So, you're EFTA00061242

183 1 not covering up anything. And at that point in 2 time, once that happened in the morning, she 3 wouldn't have been able to do this anyway, 4 cause the FBI was already here, taking 5 everything. 6 MR. : Well, if someone says 7 that at 9:30, well, this is all, this is all 8 done electronically, right? She sent this out 9 electronically? 10 MR. : You get, have to email that, 11 yes. 12 MR. : Right. And is it my 13 understanding that this is actually created in, 14 like, a Word document, that is in a shared 15 folder? 16 MR. : It's in the shared folder. 17 It's in, but only lieutenants have access to 18 that. 19 MR. : Right. 20 MR. : And the captain. 21 MR. : So, if someone is in that 22 shared folder, and they can tell, someone is 23 modifying that thing right now, and it's at, 24 like, 9:30. 25 MR. : Oh, well, that's the thing. EFTA00061243

184 1 But if there is, only one person can be in 2 there at the time. 3 MR. : Right. 4 MR. : If I try to go into that log 5 program and another lieutenant was on it, I 6 wouldn't be able to. 7 MR. : Right. So, if the 8 captain notices that someone is in there, 9 modifying that log 10 MR. : Uh-huh. 11 MR. : -- at that time, is that 12 okay? 13 MR. : I'm sure that would bring, 14 like, flag something. The captain would be, 15 like, what's going on? 16 MR. : Right. 17 MR. : Yeah. 18 MR. : But, okay. But if you 19 were , and you were the one 20 modifying this thing, and you are going back 21 and basically, you know, changing this stuff, 22 do you think that would be acceptable? Or 23 should have she left it as it was and just left 24 her one saying 73, I corrected it, brought it 25 back to 72 and left the day before, the August EFTA00061244

185 1 9th date alone and just stuck with August 10th? 2 MR. : I believe so. 3 MR. : You believe she should 4 have just stuck with August 10th? 5 MR. : I do my own things. 6 MR. : Right. 7 MR. : It's not my job to correct 8 another lieutenant. 9 MR. : All right. And do you 10 believe there would be something wrong with her 11 doing that, though? Going back to August 9th 12 and changing things? 13 MR. : No. Because it was past 14 practice. 15 MR. : Okay. 16 MR. : You know, it's something 17 that we have always done that, you know, from 18 the very first time. I personally don't like 19 correcting other people. 20 MR. : All right. 21 MR. : But you mentioned it would 22 have been that, if you piggyback off each 23 other. 24 MR. : Yeah. 25 MR. : Something came up. She EFTA00061245

186 1 (Indiscernible *02:14:29). 2 MR. : Like I said, like, for 3 instance, I go home at 10, right? She is 4 relieving me at 10, but there is still going to 5 be a good verbal and a clear count after I'm 6 gone. 7 MR. : And that's true. 8 MR. : But then she would have to 9 go -- 10 MR. : She's actually starting 11 on August 9th. 12 MR. : She would have to be going 13 back into mine in order to put the, clear the 14 count, because she can't put 10:30 good verbal 15 and 10:45 clear count on her log, cause it's 16 after midnight. Does that make sense? So, she 17 will go, like, things like that, you piggyback. 18 Just like if, like, we end up, we do the two 19 hour relief thing, you know, you got to, you 20 piggyback, but otherwise, I don't go back to, 21 like, correct another person. That's me, 22 personally. 23 MR. : But she did start on 24 August 9th, and what you're saying is you don't 25 find it problematic that she did correct EFTA00061246

187 1 something? You don't think there's anything 2 wrong with it? You just wouldn't have done it? 3 MR. : I wouldn't have done it 4 personally. 5 MR. : Right. 6 MR. : But I don't think there's 7 nothing wrong with what she did. 8 MR. : Did you want to talk 9 about these anymore, about the lieutenant logs? 10 MR. : No. We covered it. 11 MR. : All right. Okay. 12 MR. : I don't know if there is a 13 certain order I'm supposed to -- 14 MR. : No, yeah, I just keep it, 15 I kept them in order. They're all in order of 16 the counts. Thank you for initialing and 17 signing everything. And we had to go past 18 that, so, this would be, thank you, sir. 19 MR. : You're welcome. 20 MR. : This is the last thing we 21 have got. All right. So, we have only got two 22 more documents or something. So, these are 23 the, what are these? 24 MR. : These are the round sheets. 25 MR. : So, is this L tier? EFTA00061247

188 1 Would that be where Epstein was housed for 2 8/9/2019, in the SHU? 3 MR. : Yes. 4 MR. : All right. And did you 5 say you had heard that these were not 6 conducted? 7 MR. : Well, like, for instance, 8 case in point, I don't know who this is, but I 9 wouldn't have, when I made rounds, unless he 10 made rounds around this time, or prior to this 11 time, these were never finished. 12 MR. : Okay. So, this person, 13 if you didn't go do the round, who, do you 14 believe, would have gone in and actually signed 15 off on that? 16 MR. : It would be the either/or. 17 I don't recognize -- 18 MR. : Does that look like -- 19 MR. : I know this is me. 20 MR. : Okay. So, you actually 21 did a round in there? 22 MR. : I did the rounds somewhere, 23 no, wait a minute, is this me? 24 MR. : I thought you said 25 did the round. EFTA00061248

189 1 MR. did make the round in 2 SHU. I don't know why I'm, I don't know why my 3 signature is on here. 4 MR. : That is your signature, 5 though? 6 MR. : It looks like my MC. But I 7 didn't make rounds in SHU. I know that. I 8 didn't make the evening watch rounds. 9 MR. : Shoot. I didn't print 10 off the list for the lieutenants, cause 11 there's, but that is your signature on there? 12 MR. : That looks like my MC. 13 MR. : And would have you had to 14 have gone to the actual SHU to do that? 15 MR. : Yes, I would have had to 16 have, and I didn't make rounds up there that 17 night. 18 MR. : Any idea how that would 19 have gotten on there, if you didn't, you 20 weren't in there? 21 MR. : No. No. I don't. 22 MR. : Do you know if anyone 23 asked you after the fact to sign off on 24 something? 25 MR. : Not necessarily. No. But I EFTA00061249

190 1 know I didn't make rounds up there, but that 2 looks like my MC. And this is the first I'm 3 seeing this. 4 MR. : Yeah. It does look 5 exactly like what you have been doing. I 6 didn't even notice that before. So, this is 7 your signature on the 8/9/2019 -- 8 MR. : Uh-huh. 9 MR. : -- 30 minute check sheet, 10 but you did not visit the SHU on August 9th? 11 MR. : No. I did not make rounds. 12 My Activities Lieutenant made rounds that 13 night. 14 MR. : Would it have anything to 15 do with the fact that she was an Acting 16 Activities Lieutenant? 17 MR. : I mean, no, because I don't 18 remember, I don't recall signing the round 19 sheet for that shift. 20 MR. : Cause it looks like all 21 of, it looks like all of them are you, right? 22 MR. : Well, some, one thing right 23 here, too, it's not signed off on here, either. 24 MR. : So the bottom aren't 25 signed off on. Well, who -- EFTA00061250

191 1 MR. : The morning watch went, upon 2 coming in, oh, you know what? I'm 3 not, I don't remember doing it, but the only 4 thing I could think of is when it gets picked 5 up, but the thing is, this don't get picked up, 6 it don't get sent down until morning watch. 7 So, I don't, I don't remember, I really don't 8 remember signing that. But I really don't 9 remember signing that, and it looks like the 10 morning watch lieutenant didn't sign, either. 11 Cause then if you look at this, I wouldn't have 12 signed, if I saw rounds not done. Remember, I 13 said that earlier. 14 MR. : So does this at all look 15 like it could have been, like, cut and paste or 16 why, why would that be modified? 17 MR. : I don't know. 18 MR. : Do you have any reason to 19 believe that that is not your signature? 20 MR. : I don't recall signing it, 21 but that looks like my MC. I always initial. 22 I don't ever fully sign. I always do the MC, 23 as you can see, I do the MC in the circle. 24 Yeah. Yeah, I don't, I don't know. I don't 25 recall. I don't recall signing it, but that is EFTA00061251

192 1 my signature. I didn't make rounds. The only 2 thing I could, I could assume is maybe 3 asked me to sign because she made the round, 4 but she is not an actual lieutenant. But I 5 don't recall. 6 MR. : But would have she had, 7 like, literally have been allowed to bring, 8 take the -- 9 MR. : No. No. That's the thing. 10 They can't leave the unit until morning watch. 11 This gets sent down for the morning watch. 12 MR. : All right. 13 MR. : Like, when came in 14 for Saturday morning watch -- 15 MR. : Uh-huh. 16 MR. : -- this, after midnight, 17 between 11:30 and 12 is the last round for the 18 evening shift. Then this gets sent out. 19 That's why I'm looking at this, look, it's on 20 this one. It's on this one, but where is it 21 here? It's not here. It's not here. So, 22 what, was one tier, two tiers done and not the 23 other? There's six tiers up there. 24 MR. : And they're all for 25 8/9/2019? So, we got some kind of discrepancy EFTA00061252

193 1 going on with these. 2 MR. : I don't remember signing 3 that. 4 MR. : (Indiscernible *02:21:12). 5 MR. : And you would, you would 6 have signed it before 10 p.m.? Before you 7 left? 8 MR. : Yeah. Before I left. 9 MR. : So you don't remember 10 ever visiting the SHU? 11 MR. : I might have been up in the 12 SHU, like, to move an inmate or whatever have 13 you, or like, to lock somebody up, but I don't 14 even remember if I did or not, honestly. I 15 don't remember. 16 MR. : Do you believe that you 17 didn't? 18 MR. : I don't remember signing it. 19 MR. : Okay. 20 MR. : I do not remember signing 21 the round sheet and I know made rounds 22 that night. 23 MR. : So, what, I guess what 24 I'm asking is, what is this? So, this one 25 still says 8/9, but fox ZB EFTA00061253

194 1 MR. : That's 10 South. 2 MR. : But 10 South, you got to 3 go through the SHU to get to 10 South. 4 MR. : Yes. 5 MR. : Who is that person? 6 MR. : I'm not sure. I don't know. 7 I don't recognize it. It could be 8 It looks like an R and something else. 9 MR. : So, do you believe that 10 in some way, then, do you believe that you did 11 not sign the 8/9/2019 count sheet? 12 MR. : I don't remember signing it. 13 MR. : Right. Right. 14 MR. : I could have very well -- 15 MR. : I guess what I'm asking 16 is, like, do we now have to look into, oh, 17 crap, this stuff might have been, like, copied 18 and pasted and put onto something else? 19 MR. : I don't know. Well, 20 actually, I don't know. I can't answer that 21 question. I just don't, I do not, I can tell 22 you I do not remember signing it, but I do 23 remember, I did not make rounds in SHU. I 24 don't remember signing it. I don't. 25 MR. : All right. EFTA00061254

195 1 MR. : But that is, I can't, that's 2 my MC. 3 MR. : All right. So, your 4 signature is on these, but you don't recall 5 signing it, and you did not do rounds? 6 MR. : I did not make the round in 7 SHU. 8 MR. : So, if you didn't do a 9 round in SHU, were you off, could have you 10 signed it? 11 MR. : What do you mean? Wait, I'm 12 -- 13 MR. : So, you signed it, saying 14 that you did a round, but you didn't actually 15 do a round? 16 MR. : I didn't make the rounds in 17 SHU. And I don't remember signing this. 18 MR. : Okay. 19 MR. : Could I have signed it, 20 like, hey, you missed a signature? Possibly. 21 But I don't remember signing it. Cause I know 22 I didn't make rounds that night. 23 MR. : Right. So, your 24 signature is on there, saying you did a round, 25 but you did not do rounds? EFTA00061255

196 1 MR. : Huh-uh. But I didn't, I 2 wasn't there. I didn't make the round in SHU. 3 MR. : Why do you clearly remember 4 that you didn't go in the SHU that night? 5 MR. : I'm sorry? 6 MR. : Why do you remember that you 7 never went -- 8 MR. : Because I was trying to hire 9 overtime for the morning watch shift most of 10 the night. At that point in time, with how 11 short we were lieutenants, and how short we 12 were staffed, an Operations Lieutenant would 13 spend at least four hours a shift, trying to 14 just fill the overtime. And I remember, cause 15 I even, I think, if I recall correctly, I 16 remember, I even mandated Noel to work in SHU 17 that night, for the overnight. 18 MR. : So you think you spent most 19 of the time in the office, trying to -- 20 MR. : Yes. I was doing the 21 roster, trying to fill the roster when Bullock 22 said, hey, I got it, Lou. I'll take Epstein 23 upstairs, the night before. 24 MR. : Do you think anyone could 25 have filled your signature in? EFTA00061256

197 1 2 3 4 MR. : it. MR. be your signature? Unless, unless they traced : But that does appear to 5 MR. : It's my MC, but it doesn't 6 look the same on all of them, like, this one, 7 it looks a little different than here. 8 MR. : But, for, I guess, the 9 10 next person to come in and sign would have been this individual. 11 MR. : That's 12 MR. • • • 13 MR. : Yeah. 14 MR. : So, do you have any 15 16 reason to believe that would have signed for you? 17 MR. : No. No. 18 19 MR. block was empty? : If she noticed that this 20 MR. : No. No. 21 MR. : So you don't believe 22 would have done that? 23 MR. : No. I don't believe 24 would have done that at all. 25 MR. : So you do believe that EFTA00061257

198 1 this is your signature? 2 MR. : I believe it's my signature, 3 but I just don't remember signing that. I 4 don't. 5 MR. : And you don't remember 6 even going to the SHU. 7 MR. : I didn't make rounds that 8 evening, no. 9 MR. : And you don't remember 10 actually even going into the SHU that -- 11 MR. : Not that I recall. No. 12 MR. : So that's (Indiscernible 13 *02:25:05) like how could have your signature 14 got on there? 15 MR. : You would have to, you would 16 have to, you would have to review the cameras, 17 but I don't recall signing this paper. And I 18 know I didn't make rounds, because even when I 19 went in with you guys in the FBI and the AUSA, 20 she even told me name before I even 21 said it. I said, my Activities Lieutenant made 22 rounds that night in SHU, and she said, that's 23 Acting Lieutenant, Ms. . I 24 said, you are, I said, correct. I still 25 recall, I recall that interview. EFTA00061258

199 1 MR. : So, because this has such 2 a high level focus now -- 3 MR. : Uh-huh. 4 MR. : -- this is something that 5 is actually, unfortunately, brand-new to us 6 MR. : Uh-huh. 7 MR. : -- we're going to have to 8 somehow resolve that. 9 MR. : Uh-huh. 10 MR. : Do you have any, any kind 11 of explanation to how that could have happened 12 then? You didn't do rounds in SHU. You never 13 even went in the SHU, and you could only sign 14 this document from within the SHU. 15 MR. : Uh-huh. 16 MR. : And this is the documents 17 that were obtained. 18 MR. : No, this could get signed in 19 the lieutenant's office, after it's collected. 20 MR. : All right, so this could 21 have been collected -- 22 MR. : Every night, this gets, the 23 six round sheets gets sent down to the 24 lieutenant's office. 25 MR. : So, do you think -- EFTA00061259

200 1 MR. : That might have been when I 2 signed it, but this would have, I wasn't here 3 on morning watch. 4 MR. : What about on August 10th, 5 when you did come back from the hospital? You 6 came back, right, on August 10th? 7 MR. : Yeah. I was here the whole 8 day. I didn't go home. I don't remember 9 exactly, but I know it was, like, around 4:00 10 ish, 5:00 ish, when I got home, when I left. 11 MR. : So, I mean, it doesn't 12 look like, these things look like they were 13 taken right away, you know? 14 MR. : Uh-huh. 15 MR. : After Noel -- 16 MR. : That might have very well 17 been what happened. 18 MR. : That you signed it the 19 next day? 20 MR. : I might have signed it when 21 it was sitting on the lieutenant's office pile. 22 MR. : All right. Can you give 23 me the 4 p.m. count again, now that you're 24 saying that it's sparking my memory that people 25 are saying that other documents weren't signed, EFTA00061260