101 1 FBI? 2 : I pulled the bad drives 3 out to replace them with good drives. Yes. 4 : And you put the two new 5 drives in? 6 : Drives in. Yes. 7 : So, what is it that the 8 FBI pulled? 9 : They pulled all the 10 drives. 11 : So, you were rebuilding 12 it. And when you rebuilt it, they came in and 13 they just pulled them all out? 14 : Yeah. They would pull 15 them all. 16 : So, it was never able to 17 rebuild? 18 : Yes. 19 : All right. So, they 20 pulled all the drives. And so, when they said 21 the DVR. Is that different from -? 22 : Yeah. The DVR because 23 they pulled everything from DVR-1, and that was 24 the one that wasn't working. And then, DVR-2, 25 the one that was working, the next day, I had EFTA00063236

102 1 to get all the - well, the same day - I could 2 get all the important parts of the prison on 3 DVR-1, that wasn't working, on DVR-2, which I 4 probably should have done the day before, but 5 6 : So, it's DVR-2 that we're 7 speaking about. Correct? 8 : Yes. That was the good 9 drive. 10 : Oh, DVR-2 was the good 11 drive? 12 : Yes. 13 : But DVR-1 wasn't. Okay. 14 So, DVR. 15 : And what does this say? 16 DVR. DVR-2 is the good drive. DVR-1 is the 17 bad drive. 18 : Okay. So, DVR-1 -- 19 : That's not - no - that's 20 not what you said before. You said DVR-1 was 21 all good. DVR-2 went bad. 22 : Yes. 23 : Okay. So, DVR-2 was the 24 bad drive. 25 : Yes. EFTA00063237

103 1 : So, as far as DVR-2 being 2 the bad drive, is the DVR, is that the 16 3 drives, or is there a separate box -- 4 : No. It's the 16 drives, 5 and then, you have, like, the brain, some 6 motherboard, you know, the other computer on 7 the bottom, but -. 8 : So, when you say, when 9 they say that the FBI agent was the one who 10 pulled out the DVR, you're talking about all 16 11 -- 12 : All the, they probably 13 pulled the -- 14 : -- drives and 15 motherboard. 16 : -- they probably pulled -. 17 Yeah. They probably took all of the 18 recordings. But they had to take -. When I'm 19 talking about that the next day, because we 20 already had the new set, when all this 21 happened, SigNet came the next day, and we had 22 the new system up and running. Everything was 23 in boxes. So, he had to just come in and 24 install it. 25 : Okay. So -- EFTA00063238

104 1 2 3 4 : So, the next day, the FBI took both drives, DVR-1 and 2. : So, on the 11th, the FBI came and just took it all? 5 : They took it all. Yes. 6 : Everything? 7 : Everything. 8 : All right. Okay. So, it 9 says that, " also advised that he knew 10 that, by replacing both hard drives, the system 11 would be wiped. 12 : Mm-hmm. 13 : And that he had advised 14 personnel at MCC of that." 15 : Yes. 16 : Now, when you say, 17 "Wiped," it means just everything -- 18 : It means -- 19 : -- that was on it before? 20 : -- everything is gone. 21 Yes. There is no video. There's nothing. 22 : And do you know how far 23 that would have gone back to? 24 : No. 25 : No? EFTA00063239

105 1 : No. 2 : So, was that the case, 3 could have we obtained video off of those -? 4 : Other drives? Yes, before 5 I started rebuilding. Yes. But that's what I 6 was told to do. So, that's what I was 7 (Indiscernible *01:02:17). 8 : So, just explain that. 9 What could have we got off of it? And you're 10 talking about DVR-2 now, the bad drive. Right? 11 : DVR-1 is the bad drive. 12 : So, this is where I'm 13 getting confused. I thought we just said that 14 DVR-2 is the bad drive. I've got to get this 15 straight. , you just - I thought we 16 said, we did say that, but then you just chimed 17 in and said it was DVR-2 that was bad. Which 18 one was it? DVR-1 or 2 that was bad? 19 : DVR-1 is bad. 20 : In the initial part of the 21 interview, he stated that DVR-2 went bad, and 22 DVR-1 drives were all good. 23 : All right. Because yeah, 24 on the thing, it says -- 25 : Yeah, because everything EFTA00063240

106 1 was on DVR-2. 2 : -- "He attempted to 3 replace the drives, and he started to rebuild. 4 During the rebuild process of the drives, the 5 drives were required to be taken out of raid on 6 DVR-2." 7 : Yeah. I would say on DVR- 8 2. I'm sorry. I got confused. 9 : All right. So, DVR-2 is 10 the bad drive -- 11 : The bad drive. Yes. 12 : All right. So, on DVR-2, 13 the bad drive -- 14 : Yeah. 15 : -- could video have been 16 obtained? 17 : Yes, before I started 18 doing anything. Yes. 19 : So, prior to you pulling 20 them out, we may have been able to obtain video 21 from the 9th? 22 23 24 25 recording. : Hmm. No. : August 9th? : No. Because it wasn't EFTA00063241

107 1 • 2 • 3 drives. 4 ■ : All right. : Because you had two bad : So, what video are you 5 talking about when we said we could have 6 obtained video? 7 : Oh, well, saying that 8 stuff there is a possibility in the background, 9 even if you have two bad drives that stuff 10 could have been recording over it, but that's 11 their technical jazz. Like, I don't know 12 anything about that. 13 : So, in saying that 14 : But saying that -. 15 it sounds like, okay, 16 it is possible that we could have gotten video 17 -- 18 : Video. 19 : -- for August 9th and 20 10th. 21 : Yes. It is a possibility. 22 Not a strong possibility, but yeah. 23 : So, it is possible, but 24 once the two drives 25 : Yes. EFTA00063242

108 1 : -- were pulled -- 2 : Pulled. Yes. That was a 3 -- 4 : -- that possibility 5 became 6 : Yeah. 7 : -- impossible. 8 : It was gone. Yes. 9 : All right. Now, are 10 those two drives, are you -? When the SIS 11 official told you on the 8th that they weren't 12 able to go back -- 13 : To do. 14 : -- and review the video - 15 - 16 : Mm-hmm. 17 : -- if something was 18 recording in the background, would you have 19 been - you know, like you were talking about, 20 there is a possibility - would you have been 21 able to tell at that time? 22 : No. I wouldn't have been 23 able to tell. That's something SigNet would 24 have, or some expert, video expert, would have 25 -. EFTA00063243

109 1 2 3 : All right. : That's nothing above me. : Was your only course of 4 action to replace those two bad drives? 5 : Yes. 6 : So, would, regardless, 7 that video have been, at some point, deleted? 8 : Yes. 9 : And you were -. Who 10 instructed you to actually pull out those two 11 bad drives? 12 : I would just have to - I 13 probably talked to SigNet, or -. Well, and I 14 told SIS this before, like, if I pulled two 15 drives, there is no video, especially if it was 16 bad. 17 : Did you talk to anybody 18 on August 10th, prior to pulling them, that 19 there was a possibility that video of the 20 Epstein incident could have been retrieved? 21 : No. 22 : So, you didn't tell 23 anybody that? 24 : I'm not saying I didn't 25 tell anybody that, but that was -. I think EFTA00063244

110 1 that's something I found out later. Because 2 that's when SigNet was talking to me. But 3 that's not something I would have known before 4 Epstein. 5 : All right. 6 : Because that was something 7 we talked about, like, the days after that 8 happened. 9 : Because this 302 says, 10 %•% advised that an FBI agent was the one 11 who pulled out the DVR. also advised 12 that he knew that, by replacing both hard 13 drives, the system would be wiped, and that he 14 had advised personnel at MCC of that." 15 : Mm-hmm. There would be no 16 video. 17 : When did you do that? 18 : Before I started doing 19 anything. If I'm going to change drives, 20 you're going to know, like, it's -. Because I 21 know this was going to be bigger than just me 22 fixing the recorders. Like, there is other 23 things that are going to happen, but I'm going 24 to tell you, hey, if I do this, this is what's 25 going to happen. EFTA00063245

111 1 : But I thought you just 2 said that that's something you found out later. 3 : Later. But no, as far as 4 there being video on the background. 5 : Oh. 6 : Yeah. As far as -- 7 : So -. 8 : -- me pulling out the 9 drives, I already knew that before because 10 that's what happened the last time, when I 11 replaced two drives, that there was no old 12 video. It was just the new video. 13 : So, on the 10th, your 14 understanding, that there was no video from the 15 9th -- 16 : Or the 10th. i7 -- or 10th. 18 : Yes. That was my 19 understanding. 20 : So, therefore, yeah, and 21 at that time, you didn't know that there was a 22 possibility -- 23 : Possibility -- 24 : If things were recording 25 -- EFTA00063246

112 1 : -- going in the 2 background. 3 : -- in the background. 4 : Yes. 5 : And once the DVR, that 6 the two drives were pulled, that possibility 7 became -- 8 : Became an impossibility. 9 : -- an impossibility. 10 : Yes. 11 : Okay. Before we move on 12 from that, did anybody want to clarify any of 13 that? 14 : Yeah. 15 : What -- 16 : Go ahead. 17 technically, when you pull 18 a drive -- 19 : Mm-hmm. 20 : -- like, what happens? It 21 might be a technical question. 22 : Yeah. 23 : Like, how does everything 24 wipe? Is that -? 25 : Oh, well, it's, like, EFTA00063247

113 1 looking for ones and zeros, and if nothing is 2 lined up, from what the SigNet explained to me, 3 is one drive being bad is not really a problem, 4 because the other drives are going to -. It's 5 the redundant. So, it's the backup, it's going 6 to take over for that drive that's not working. 7 : Okay. 8 : But now, since this drive 9 is not working, and this one that's working is 10 taking, any drive is taking over for this 11 drive, and that drive goes bad, that means we 12 have two bad drives. That means nothing is 13 going to be recording. 14 : So, they work in conjunction 15 - 16 : Yeah. 17 : -- with the other one? 18 : Yeah. 19 : But the death of -- 20 : The redundant. 21 the death of one 22 : (Indiscernible *01:07:27). 23 is (Indiscernible 24 *01:07:25). Gotcha. 25 : And then, when they both EFTA00063248

114 1 die, you're done. 2 : Gotcha. And there's no way to 3 recover anything? 4 : Well, at the time, they 5 told me no, and then they said, well, there is 6 a possibility that it could have been recording 7 8 : Yeah. 9 : -- in the background, 10 after the fact. 11 : Okay. 12 : But that was something 13 more technical than my understanding, because 14 at the time, if something goes bad, just, you 15 know, take the drives out, put it in. And 16 then, this became a bigger thing. So now, 17 we're, like, well, there was still kind of a 18 possibility that more things would have been 19 happening. From my understanding. That's what 20 SigNet told me. 21 : Okay. 22 : All right. And then, for 23 clarity purposes, when - again, on the 8th, you 24 found out that this was an issue, and that you 25 had to replace the drives -- EFTA00063249

115 1 : Mm-hmm. 2 : -- when did you obtain 3 the new drives? 4 : It had to be some time 5 during that day or the next day. I probably 6 was looking for drives, because if I -- 7 : Because you said -- 8 : -- if I knew -- 9 you got them, and you 10 got them from the CSM? 11 : Yeah. 12 : Okay. And you just don't 13 know if that, you got them from CSM on the 8th 14 or the 9th? 15 : The 9th. Yeah. I know I 16 got some drives from him before because we've 17 gotten, I've gotten old drives from him before. 18 And I know we've ordered drives. I'm not too 19 sure if I ordered a whole bunch of drives to 20 just replace all 16, or whatever, how many are 21 in the raid. But we were, that was going to be 22 the next step, to just rebuild everything. 23 : Now, if it was your 24 project, and you are the camera guy, why did he 25 have the drives and not you? EFTA00063250

116 1 : Because he has all the 2 hard drives in the building. Like, me having 3 the hard drives is not part of my job 4 description. But -- 5 : All right. So -- 6 -- I could have them, but 7 he's got more, like, readily available ones. 8 And everything that I had was from the old 9 stuff that wasn't working from before. 10 : Okay. 11 : So, if I pulled something 12 from that, something that wasn't working 13 before, I don't know if it was bad. That's why 14 it's on the shelf. Because nothing was labeled 15 bad. It was just on the shelf. That's, it was 16 a mess, that whole area was a mess. 17 : Okay. Where was his 18 equipment stored? 19 : Oh, the CSM? 20 : Yes. 21 22 23 near the -? 24 25 the first floor. : His is in the server room. : Is that within the SIS, : No. That's downstairs, in EFTA00063251

117 1 : Okay. So, the server 2 room is in the computer server room? 3 : Yes. Yeah. 4 : Nothing to do with the 5 cameras? 6 : No. 7 : All right. So, you would 8 have had to have gone to him 9 : Gone up to him -- 10 -- within the -? 11 -- with the, yeah, at the 12 time, like, hey, , you got some drives? I 13 don't have any drives. 14 : Okay. So, what -? Can 15 you just explain what steps it is? You found 16 out on the 8th. What steps did you take in 17 order to resolve this issue? Do you know if 18 you -? Did you call SigNet on the 8th, or did 19 you call them on the 10th? Because the way 20 that this -. The way that this reads, just 21 look at these comments. It says this comment 22 was made on the 8th, at 3:38 p.m. -- 23 : Mm-hmm. 24 : -- and where it says, "Hi 25 Unable to locate anything official -- EFTA00063252

118 1 : Mm-hmm. 2 : -- the basic steps are as 3 follows. Set the raid level -- 4 : Uh-huh. 5 : -- it none and save. It 6 will So, what is going on here? What are 7 these instructions? This is supposed to be 8 specific to this incident. 9 : Mm-hmm. 10 : Do you follow what's 11 going on there? 12 : Yeah. Oh, so, I called 13 them on Thursday. And I probably started to 14 rebuild on Friday. But I couldn't do the 15 rebuild on Friday. 16 : So, you called them on 17 Thursday? What, to obtain the instructions? 18 : I already knew what I had 19 to do. I always just call them to make sure 20 I'm doing everything right. 21 : All right. So, on 22 Thursday, you called them. 23 : Mm-hmm. 24 : And are these 25 instructions that I'm looking at, though, on EFTA00063253

119 1 this comment from August 8th, 2019, at 3:38 2 p.m.? 3 : Yeah. It looks like 4 that's right. When I - that's where I do the 5 rebuild, probably. Those are probably the 6 instructions to do the rebuild. 7 : Yeah. 8 : For two drives. 9 : And do you understand who 10 it's - when it says, "Hi Unable to 11 locate anything official." - do you know who it 12 is that is talking there? 13 : It could be 14 or 15 : Hey. Can I -- 16 : That was 17 can I clarify that? 18 Because I didn't -. We know that that comment 19 right there is by (Phonetic Sp. 20 *01:11:18). He's a Qognify support engineer. 21 : Okay. 22 : And that's the 23 instructions that he provided to give you. 24 : Okay. 25 : Okay. EFTA00063254

120 1 : All right. And do you 2 know when you would have received those 3 instructions? Would it have been on the 8th? 4 : Yes. 5 : Okay. And you're saying, 6 the reason why you didn't do it on the 8th is 7 because -- 8 : I didn't have the drives. 9 : -- you didn't have the 10 drives 11 : Uh-huh. 12 : -- to do it? 13 : Yeah. 14 : All right. So then, on 15 the 9th, you got -- 16 : The drives. 17 : -- the drives? 18 : Yes. 19 : But you got them later in 20 the day 21 : Late. 22 • -- is what you're saying? 23 : Yes. And I didn't have 24 access to go in the room. 25 : And III told you that you EFTA00063255

121 1 -- 2 : Can't go in there. 3 : -- couldn't be in there? 4 : Yes. 5 : And do you specifically 6 recall being the one who said you can't 7 come in here? 8 : Well, he's just, like, if 9 I'm gone for the day, there was nobody else 10 there. He was the only one with the key. 11 : So, again, if we speak to 12 him, is he going to say, yeah, I told him he 13 can't come in? 14 : Yeah. Yeah. He knows I 15 can't come in. Because it's the evidence room, 16 too. So, yeah. 17 : Yeah. We talked to SIS 18 about that. She said there was not an 19 evidence room in there. 20 : It's still an evidence 21 room right now. If you go there. 22 : Mm-hmm. 23 : That's where I 24 : Well, maybe now, but what 25 is it on the 9th? EFTA00063256

122 1 2 evidence room. 3 4 : -- it's always been the : Because she said, yeah : It's not going to be -- 5 : -- she said there were 6 files in there, but there's no evidence. 7 : Yeah. Every contraband 8 they get from inmates, that's where they store 9 everything. 10 11 12 13 14 -- 15 16 *01:12:28). 17 18 still, there's junk 19 video room. That's 20 had with this whole : In that area? : In that area. Yes. : Where the -? : Yes. And if you go there : Where (Indiscernible -- right now, there's in there. It's not just a the biggest problem that I thing, was that at other 21 institutions, when you have a video room, you 22 just have a video room. There is nothing else 23 in there. There's just the com techs. You go 24 in, you do whatever you got to do, you come 25 out. There should not be anything else mixed EFTA00063257

123 1 with the room. 2 3 : Okay. : And up to this day, there 4 is still evidence and garbage in that room. 5 : Okay. 6 : So, it is not a video 7 room. 8 : Can you just look on the 9 9th, what time did III work until? 10 : Hold on. 11 : Did you say 7:00 to 12 : On the 9th. Bear with me. 13 Nine. So, this falls under either 7:00 to 14 3:00, or 8:00 to 4:00. 15 : Okay. 16 : So, it was later than me 17 staying for And you could just check my 18 overtime, too, to see what time I stayed. So, 19 if I did overtime that day. 20 : All right. But point 21 being, is you didn't go in and fix them on that 22 day? 23 : No. 24 : All right. So, when you 25 say you didn't have access to the room, you are EFTA00063258

124 1 saying you didn't have access to the room after 2 3:00 p.m.? 3 : Yes. 4 : And you 5 : Or whatever time. 6 : -- because usually -- 7 : Yeah. 8 : -- your shift was from 9 6:00 a.m. to -- 10 : 6:00 -- 11 : -- 2:00 p.m. 12 : -- 2:00 -- 13 : Correct? 14 : -- yeah, but I was doing a 15 project. So, I don't know what overtime. I 16 was probably doing overtime. So, I was working 17 maybe 12 hours, 16 hours. 18 : And this is just one of 19 those things we're going to have really 20 reconcile here, because 21 : Mm-hmm. 22 : -- as you know, this is 23 such a big part of this thing -- 24 : Mm-hmm. 25 : -- that we don't have a EFTA00063259

125 1 video. Why didn't you, from 6:00 to 2:00, fix 2 this thing? 3 : Because I was doing other 4 things. This wasn't -. This was a priority, 5 but, and the fact, like I said, this was not, 6 like, the main priority in the building. Oh, 7 the recorders aren't working? Okay. Well, all 8 right, it's not, like, oh, not, this is what 9 you have to make. Now, after Epstein, like, 10 oh, this is the main thing you have to focus on 11 for the day. 12 : Okay. So, you didn't get 13 to it until after you took care of a bunch of - 14 15 : Other stuff. 16 : -- other stuff. 17 : Yes. 18 : And by the time you got 19 to it, at the end of your shift, basically, it 20 sounds like? 21 : Yes. 22 : That there wasn't enough 23 time to do it? 24 : To do it. Yeah. Yeah. 25 : But you could have gained EFTA00063260

126 1 access between -- 2 3 : 6:00. : -- at least when he was 4 working there, 7:00 a.m. to 3:00 p.m. 5 : Yes. 6 : But you just didn't? 7 : No. 8 : Okay. When you 9 : I have a few questions. 10 : yup. Go ahead. 11 : I have a question. I know 12 you might have actually answered this question, 13 but just I, I probably didn't hear it. But you 14 said that you spoke to MCC personnel about the 15 date of being wiped. Who specifically did you 16 speak to? 17 : It would be somebody in 18 SIS. 19 : It would be somebody 20 where? 21 : Or I'm pretty sure I told 22 the warden, too, because this was a big deal. 23 That on the, on that Saturday, when everything 24 happened, like, you know, if I pulled these, 25 there's going to be no video at all. EFTA00063261

127 1 : And is this the 2 conversation you had directly with the captain? 3 : No. This would have been 4 the warden, or SIS. I really didn't see the 5 captain that day. I don't remember seeing the 6 captain or talking to the captain. 7 : Was this a big -- 8 : I would just -- 9 -- sorry. 10 -- that day -- 11 : -- this was a big 12 conversation. 13 : -- yeah, when 14 : Yeah. 15 : -- everybody was asking me 16 questions. It was mainly SIS and the warden I 17 was dealing with. I wasn't really dealing with 18 anybody else. 19 : But you don't recall 20 exactly who you told, hey, I'm about to pull 21 the drives, but everything will be wiped? 22 : I'm not too sure. But 23 either the SIS or the warden. I'm pretty sure 24 of that. 25 : But again, he explained - EFTA00063262

128 1 - 2 : And do you -. 3 : -- that it was his 4 understanding that there was nothing on there, 5 anyway. He didn't find out until later that 6 there could have been some background. 7 : Okay. And then, the final 8 question is, when the FBI agent that came in, 9 do you remember who that FBI agent was that you 10 spoke to? 11 : No. I don't remember his 12 name. 13 : Okay. 14 : Okay. 15 : And you told him 16 specifically that, hey, listen, I pulled two 17 drives -- 18 : Two drives. Yeah. 19 -- and it's in the process 20 of being rebuilt? 21 : Yes. 22 : And you advised him that, 23 if they pulled the drives, at that point. 24 : That they were going to be 25 - yes. And I was on the phone with SigNet when EFTA00063263

129 1 this was going on. So, I could tell them 2 exactly what was going on. 3 : Well, let me clarify 4 that, then, because you said that you pulled 5 the two drives, and that would have wiped the 6 system, but you said the FBI came in and just 7 took everything. 8 : Yeah, they took -- 9 : So -- 10 : -- took everything. Yes. 11 : -- so, they didn't pull 12 the two drives. 13 : Drives. 14 : They pulled it all? 15 : All. Yes. 16 : You said the -. They 17 took all -- 18 : Yes. 19 : DVR-2 on the 10th -- 20 : Well, all the -- 21 : -- and they came back on 22 the 11th, took the rest -- 23 : The rest of it. 24 25 : Yes. of it. EFTA00063264

130 1 : Is that correct? 2 3 4 clarify that, 5 : Yes. : So, does that help : Yeah. Now, the last part 6 to this, I emailed you guys a snippet. Based 7 on the FBI's analysis, it looks like, they 8 indicated that there was a catastrophic disc 9 failures in their raid. And no reportings 10 would have been available after 7/29. 11 : Mm-hmm. 12 : You mentioned earlier in 13 the interview that there was a motherboard 14 failure. 15 : Yes. That was another 16 time. 17 : But that happened around 18 July. That's what you initially mentioned. 19 : I have If that's what 20 I said, then yes. But 21 : So, and you said the only 22 way you could have corrected that situation 23 would have been that, you went in, and you 24 verified that by reviewing, going back and 25 reviewing old footage, to see that the cameras EFTA00063265

131 1 were working. 2 3 : Yes. : And are you sure that you 4 did that? Because according to the FBI, based 5 on their analysis, it looks like there was a 6 catastrophic disc failures, and there is 7 nowhere, recordings in there since 7/29 anyway. 8 : I'm going to read you 9 what this says. 10 : Okay. 11 : It says, "On," it looks 12 like it would have been in September 18th, 13 2019, "A meeting was conducted with DVR vendor, 14 technical support representative, 15 , of SigNet Technologies. 16 provided an overview of the operation of the 17 system. A review of the DVR-2 controller logs 18 by and Senior Advisor 19 "indicated that there had been 20 catastrophic disc failures in the array, and no 21 recordings would have been available after 22 7/29/2019." 23 24 25 : So, on the -- : It says, " : -- (Indiscernible EFTA00063266

132 1 *01:18:31). 2 3 : Go ahead. 4 : -- and Computer Scientist 5 , "were provided 6 access to the beginning sectors of the 16 7 drives, to see if the structure would indicate 8 clues of a possible rebuild. None were 9 apparent." So, what it is saying is that, and 10 you could read the specific language, this 11 would be, like, but what it is saying is that - 12 - 13 : Yeah. 14 : -- on the 29th, nothing - 15 - 16 : Had been recorded. 17 : -- had recorded. 18 : Yes. 19 : Prior to that, it sounded 20 like you were, like, there is no possibility 21 that that could have happened. I would have 22 known. 23 : Mm-hmm. 24 : So -- 25 : Yeah. EFTA00063267

133 1 : -- now, when you're 2 seeing them, and did they go in and they look 3 at this, does that seem like they would be 4 right, and nothing recorded after 7/29? 5 : Yes. They're the experts. 6 So, they would know that nothing recorded. 7 : All right. So, from 7/29 8 to 2019, nothing recorded, but this is the 9 first time you are hearing of it? 10 : Yes. That is the first 11 time I'm hearing about that. 12 : And during the FBI 13 interview, that's not something they discussed 14 with you? 15 : No. Nobody told me that 16 was on the 29th. That that's the first time. 17 That's the first time I've heard that. 18 : Okay. Sorry, . Do 19 you want to go ahead? 20 : Yeah. You mentioned that, 21 earlier in the interview, I might have - based 22 on my notes here - that you did a motherboard 23 rebuild, and there was (Indiscernible 24 *01:19:44) could have happened around July 25 29th. And if this happened around July 29th, EFTA00063268

134 1 are you sure that you went in and you verified 2 that the cameras were actually operating? It 3 was actually recording? 4 : Yes. I would have to 5 verify everything was recording. 6 : Now, if it was recording, 7 how was it that, based on their analysis of 8 this stuff, that there is no recordings in the 9 system after 7/29/2019? 10 : The way I was taught to 11 look at the system, was to look at the Nice 12 Vision, and if I saw the red lights, like, the 13 system is recording. But then, I found out 14 later, the red lights on the system recording, 15 the way I was looking at it, it doesn't mean 16 that there was actual video recording. That's 17 something that SigNet told me later. 18 : All right. But then, that 19 contradicts what you stated earlier. Earlier, 20 you stated that you actually went back in, and 21 you reviewed -- 22 : Yeah. 23 : -- older footage. 24 : I would have to look for 25 video. Yes. EFTA00063269

135 1 : But now, it's different. 2 Now, you're stating that you went back in, and 3 you just looked to see if there was, like, a 4 dot -- 5 : No, no. 6 : -- to see if it was 7 recording. 8 : I'm saying, I did both. I 9 would have looked to see if there was video, 10 and then I would have looked to see that I got 11 the red lights, that everything was recording. 12 The initial thing to do is to look to see a red 13 lights, that those are working. And then, the 14 next thing was to do was to pull back to see if 15 there was video. Now, SigNet told me later, 16 after all of this happened, even on the new 17 recorder that we have, the red lights that 18 show, it don't mean that anything is recording. 19 The system is not recording. You would have to 20 go pull video from, like, a week before, or two 21 weeks before, to see if there was a failure. 22 But you would not know, like, looking at it, 23 that there was a problem. 24 : Okay. But you had said 25 based upon this comment by the FBI report -- EFTA00063270

136 1 : Yes. 2 : -- there was no recording 3 for you to go back and pull back -- 4 : Back. Yes. 5 : -- (Indiscernible 6 *01:21:21). 7 : Because it happened on the 8 29th. So, there must have been video that I 9 pulled back from maybe before the 29th. When I 10 was looking at it. 11 : So, what you're saying is 12 that, you reviewed the, you fixed the 13 motherboard, but when you checked to see the 14 video was recording, you didn't check to see if 15 video was recording from the time you checked 16 the -- 17 : No. 18 : -- fixed the motherboard 19 -- 20 : No. 21 : -- to the time that you 22 checked it, 23 you fixed -- 24 : Yes. 25 : -- the motherboard. you checked previous to the time EFTA00063271

137 1 2 3 4 : : wouldn't have known : Yes. So, therefore, you -- Known that. 5 : -- that it wasn't -- 6 : Yeah. 7 -- recording -- 8 : It wasn't recording. 9 -- at that point. 10 : Yeah. I wouldn't have 11 known that. I was just under the assumption 12 that everything, because I saw the video from 13 before. 14 : So, you saw -- 15 : That it was working. 16 -- the video from before, 17 but you would have seen that anyway -- 18 : Mm-hmm. 19 : -- what you needed to do, 20 actually, was check -- 21 : Check. 22 : -- from the point that 23 you fixed it -- 24 : To -. 25 : -- to the time -- EFTA00063272

138 1 : That I checked. 2 : -- that you checked. 3 : Yeah. 4 : Needed to be that 5 recording. 6 : Yes. 7 : And you didn't do that? 8 : There was no video. So. 9 : But are we certain -- 10 : There was no. 11 : -- that July 29th, 2019 12 would have been the day that you fixed the 13 motherboard? That's what this information 14 says, but it says the motherboard failed on 15 that day, at least, but we don't know that 16 specifically, that that's the day that you 17 tried to fix it, or do we? 18 : No. 19 : Because the only other 20 service request I have for 2019 is this one on 21 February 28th, 2019. Would have they put in a 22 service request if you were fixing the 23 motherboard? 24 : I would have -. I had the 25 emails before, maybe with , with the EFTA00063273

139 I motherboard. 2 : You do? 3 : Yeah. 4 : Could that 5 : Because I have the 6 : -- can that be the third 7 thing we ask you for 8 : -- because I had -- 9 : -- if you could get us 10 those emails? 11 : -- we have to get it from 12 another jail, because they didn't have it. And 13 he was the one that walked me through because I 14 had to -. He walked me through and I'm, like, 15 one of their engineers had to walk me through 16 how to pull that thing out. The motherboard. 17 : All right. Can you give 18 me all your emails from and 19 and 20 : Mm-hmm. 21 : That will be the third 22 thing I'm going to ask. Is that okay? 23 : Yes. 24 : Can you tell me, this 25 service request number, 22855, it says, date EFTA00063274

140 1 created February 28th, 2019. It was a 2 , and 3 again. By looking at this, can you tell me 4 what it was -? This is the only other one we 5 could, we've received with that -- 6 : (Indiscernible *01:23:38). 7 : -- from that calendar 8 year. Can you tell me what that would have had 9 to do with? 10 : Hmm. Yeah, yeah, yeah. 11 Okay. Rebuilt the raid. So, there was a -. 12 It doesn't say what drive or anything. Right? 13 : I don't know. I'm asking 14 you. Because it's not as detailed as this 15 other one, it kind of looks like more 16 instruction type things. 17 : Yeah, yeah. Hmm. 18 : Because you said that the 19 drives had gone bad in the past -- 20 : Yes. 21 : -- and you knew that they 22 would do it again. 23 : Again. 24 : Is this what you're 25 talking about? Is this February 20 -- EFTA00063275

141 1 : Yes. 2 : 28th, would that have 3 been when the drives went bad last time? 4 : The last time. Yes. And 5 it probably went bad a time before that, also. 6 : But on this date, is that 7 when you said that you had previously ordered 8 the new drives -- 9 : Yeah. 10 : -- based upn 11 : No. This would have been 12 -- 13 : -- (Indiscernible 14 *01:24:23). 15 -- it would have been a 16 little bit later on, I ordered the drives. It 17 would have been before all of this happened, 18 that I ordered -. 19 : But point being, is, you 20 told us that the reason why you ordered them is 21 because that it had gone bad in the past -- 22 : Mm-hmm. 23 : -- and they told you it 24 would go bad -- 25 : Bad again. EFTA00063276

142 1 : -- again in the future. 2 : Yes. 3 : Is this the last event 4 that, when they went bad? And the reason why 5 they would have told you that information. 6 : If that's when I called 7 them. That probably would have been the last 8 event. 9 : Okay. 10 : Yeah. 11 : So, earlier that year. 12 : Yeah. 13 : Okay. So, approximately 14 six months before. Okay. And that's why you 15 would have ordered the new drives, though, and 16 had them on hand? 17 : Yes. 18 : Okay. Just before we -. 19 Can you just initial and date these before we 20 continue moving on? I just -. Wait. We have 21 -. As you know, we have everyone initial and 22 date these things. 23 : Mm-hmm. 24 : So we know what it is 25 that we're talking about, for the future. EFTA00063277

143 1 2 3 4 : Mm-hmm. : I mean, the date is : Mm-hmm. : -- again, September 29th, 5 2021. And I'm making sure, making sure we have 6 those. Let me see what else. All right. So, 7 when you realized that you could not resolve 8 the recording issue on August 8th, 2019, did 9 you notify anyone that you needed more time? 10 : No. 11 : No. And why didn't you? 12 So, if the SIS told you, hey, we need this 13 fixed, why didn't you notify him that it -- 14 : past -- 15 : -- could (Indiscernible 16 *01:26:14). 17 -- practice, so just go 18 home, . It's not that important. You 19 will come back tomorrow, and deal with it 20 tomorrow. 21 : That was past practice. 22 But not -- 23 : Yes. 24 : -- that didn't actually 25 occur on August 8th. That was just your -- EFTA00063278

144 1 : Mm-hmm. 2 : -- your experience had 3 taught you that you could fix it the next day? 4 : The next day. Just come 5 in the next day. 6 : Okay. But no one 7 actually told you to come in the next day? 8 : Hmm-mm. No. 9 : Okay. Was it your 10 understanding about how important it was that 11 the camera issue was resolved before you went 12 home? 13 : Pfft. At that 14 institution? No. 15 : No? 16 : It was never made clear to 17 me, like, this was important. Because this 18 happened, like I said, numerous times before. 19 : Okay. 20 : Yes. 21 : So, when SIS Lieutenant 22 says that it was her understanding that 23 she told you that it was not only important, 24 but it had to be fixed on the 8th, you 25 : Yeah, because -- EFTA00063279

145 1 : -- (Indiscernible 2 *01:26:56). 3 : -- if this happened before 4 and I was fixing stuff, it wasn't like I fixed 5 it that day, and it works that day. It takes a 6 couple of days. It's not going to -. And me 7 magically snap my fingers. Like, I go in the 8 room and I just fix it, and it starts 9 recording. That's not the case. 10 : All right. Would have 11 you, then, told her, though, I will get on it 12 immediately -- 13 : Yeah. 14 • -- but in your mind, you 15 knew it would take a few days, but she didn't 16 know that? Would that be a possible scenario 17 to that? 18 : That's a possibility. 19 They might not know how long it would take me 20 to fix stuff. 21 : Did you tell them how 22 long it would take? 23 : They just would see me 24 back there working. They wouldn't really know 25 how intense, or what I was doing. EFTA00063280

146 1 : All right. So, she would 2 have said, make sure -- 3 4 5 6 : Mm-hmm. you fix this : Fix this. and you would have 7 : And I -- 8 : -- started -- 9 : -- fixing it -- 10 : -- working on it 11 : -- yeah, but it wouldn't 12 have been fixed that day. No. 13 : Gotcha. And what 14 instructions did you receive from Lieutenant 15 , or regarding 16 the cameras, the camera issue being resolved 17 ASAP? 18 : I can't recall, but I 19 don't really ever believe anybody tells me 20 anything. That it has to be resolved ASAP. 21 With the recordings. I've never -. 22 : Hmm. Okay. So, what we 23 have is, it says, you know, " 24 spoke with the Captain and wrote a memo 25 regarding cameras not working. EFTA00063281

147 1 told her the issue must be resolved ASAP. She 2 relayed that to , and agreed to 3 work overtime to resolve that." Does that -? 4 : The same day? 5 : Well, she said that she 6 thought it was going to be resolved the same 7 day, but she said that you agreed to work 8 overtime. So, it sounds like there was some 9 miscommunication -- 10 : Miscommunication. Yeah. 11 It was a miscommunication. They already knew I 12 was working on the project. I was going to be 13 there. So. 14 : So, were you already -. 15 And you said you were already working overtime. 16 : Yes. 17 : On other things. 18 : On things. Yes. 19 20 21 22 23 : And you had TDY people : People with me. : -- with you? : Yes. : So, does it sound to you 24 that she did tell you that it needed to be 25 resolved ASAP. You did say, I'll work overtime EFTA00063282

148 1 to fix it. But you just weren't meaning that 2 you were going to fix it that same day? 3 : Hmm. No. That -- 4 : Is it -- 5 : -- yeah. I won't. 6 : -- is that correct, the 7 way I said that? 8 : It wouldn't have been 9 fixed that same day. So -- 10 : That's what I mean. 11 : -- yeah. Yeah. It 12 wouldn't have -. There is no way it would have 13 been fixed that same day. 14 : So, she would have 15 understood you're staying that same day, 16 overtime, to fix it. 17 : But I, how would I stay if 18 I don't have access to the room? That's my 19 question. 20 : Well, she said that she 21 spoke with you in the room. 22 : In the room. Yeah. But 23 after she leaves, after they leave, I don't 24 have access to the room. So, how could I stay 25 in the room when I don't have access to it? EFTA00063283

149 1 : Right. And then, the 2 following day, when you did come back, and you 3 did have access, you actually just didn't go 4 until the very end -- 5 : End of the day. 6 : -- of the day. 7 : Yes. 8 : And then, you no longer 9 had access. 10 : Access. Yes. 11 : And then, you said you 12 were going to go back on Saturday, in the 13 morning -- 14 : Morning. I had, because I 15 had the drives. I got the drives from the 16 Because I remember carrying the drives 17 to the room. 18 : All right. And did you 19 agree to work overtime on August 8th, 2019, to 20 resolve the issue before you went home on 21 August 8th, 2019? 22 : No. No. Somebody would 23 have had to -. My supervisor would have had to 24 tell me, whoever was in charge, would hey, 25 like, this is, you need to stay and, EFTA00063284

150 1 you know, I couldn't just, like, I'm going to 2 stay. Like, no. 3 : Okay. 4 : Somebody's got to say, 5 well, you have to stay, or we have to, you 6 know, talk about what's going on with me 7 staying. 8 : Well, she told, well, she 9 said that she was with , and her, and 10 they said you've got to stay to work overtime. 11 : Pfft. That's the -. 12 She's not my supervisor. So, that 13 : Right. 14 : -- doesn't work. It's 15 whoever is in charge of main facilities, and AW 16 is my, like, supervisor, but there is 17 still somebody -- 18 : So, who would have -- 19 : -- before her. 20 • -- been your supervisor? 21 : It would have been the 22 general foreman of facility managers, whoever 23 is assigned, and they would have had to say, 24 hey, , you have to stay. 25 : All right. So -- EFTA00063285

151 1 : Like, I work for , but 2 I don't work for —. 3 : -- but so -- 4 : Mm-hmm. 5 • was out, and 6 this is something we discussed in our last 7 interview. 8 : Mm-hmm. 9 : He wasn't there. 10 : Yeah, there. 11 : And here has an out of 12 office assistant that we have from you. You 13 sent an email on Friday, August 9th, 2019, at 14 6:51 a.m. 15 : Mm-hmm. 16 : To . It says, "I 17 will be out," and his automatic response -- 18 : Mm-hmm. 19 was, "I will be out of 20 the office on Monday, August 5th through 21 Friday, August 9th." 22 : Mm-hmm. 23 : "I will have limited 24 phone and email access. Acting for me is 25 on Monday 8/5, and Tuesday 8/6." EFTA00063286

152 1 : Mm-hmm. 2 : "She will be reached at," 3 and then, it says -- 4 : The number. 5 : -- the number. 6 : Mm-hmm. 7 : "And/or via radio track 8 four. Wednesday through Friday, 9 will be Acting, and he will be reached 10 at" -- 11 : Track four. 12 13 14 : -- the phone number. : Yeah. : Or track four radio. So, 15 would have you, so, the last time we spoke, you 16 were certain that you requested overtime on 17 that Saturday -- 18 : Yeah. 19 : -- and that your boss 20 approved it. 21 : Approved it. Yeah. 22 : Is that still your 23 recollection? Because now it sounds like you 24 had, like, a blanket over, a blanket -- 25 : We were in the middle of a EFTA00063287

153 1 project. So, it was probably just a blanket 2 overtime. 3 : So, there wouldn't have 4 been somebody that you specifically requested? 5 : No. 6 : All right. Because, 7 yeah, that was something we talked about -- 8 (Indiscernible *01:31:36). 9 : -- for a long time -- 10 : Yeah. 11 : -- last time. 12 : Yeah. 13 : So, when you're thinking 14 of it, there is not someone that you went to? 15 : If he wasn't actually 16 there, they were just acting, it was probably 17 just a blanket overtime. 18 : Yeah, and we spoke to all 19 three of them, and they said -- 20 : Yeah. 21 : -- he never talked to us. 22 We didn't even know anything about the camera 23 issue. They all - all three of them said you 24 never talked to them about overtime. And no 25 idea anything about the camera issue. EFTA00063288

154 1 : Yeah. 2 : Does that sound right? 3 : Well -- 4 : They knew about it after 5 August 10th -- 6 : Yes. 7 : -- but they said they 8 didn't know about it on the 8th or the 9th. 9 : Well, because they're not 10 really in charge. So, that's, like, you can't 11 tell them, because they're not -. I would have 12 to tell , or whoever is in charge of it. 13 : But he was out. So, who 14 -- 15 : Yes. 16 : -- would have you spoken 17 with? 18 : Whoever was in charge, but 19 there, obviously, there is nobody in charge. 20 That doesn't even make sense. 21 : Well, the acting, and 22 during that time, says, you know -- 23 : It was 24 : -- right. 25 : Said I didn't talk to him. EFTA00063289

155 1 : So, you didn't actually 2 speak with anybody about these camera issues, 3 prior to going home on the 8th? You just were 4 working on it? 5 : I was working on it. 6 Yeah. 7 : Okay. So, you didn't 8 notify anybody, though, hey, these cameras are 9 out, and they're not, it's not resolved? 10 : They would have known 11 that, before I left, like, they still - I'm 12 still working on it. It was not, like, I'm 13 going to do fix it right away. 14 : Okay. Now, this actually 15 is, this email from you to your boss -- 16 : Mm-hmm. 17 : -- it looks like these 18 are, like, your priority for things that you 19 were working on at the time. Is that correct? 20 : Yes. 21 : Why aren't the cameras 22 listed on there, if that was on August 9th? 23 : I have no idea. Mm-hmm. 24 : So, if you found out on 25 the 8th, which we have clarified that you did, EFTA00063290

156 1 2 this is what you're telling : Is going on -- 3 : -- is going on in the 4 institution -- 5 : -- in the institution. 6 : -- and what you need to 7 work on. 8 : On. Well, the -- 9 : Wouldn't you have put 10 that 11 : -- that -- 12 : -- on there? 13 : -- yeah. I would have put 14 that on there. But the camera thing was, like, 15 a constant thing. It wasn't, like, it wasn't 16 anything new. Like, they were having problems 17 with the cameras. 18 : But it wasn't new, but it 19 wasn't new that the recordings weren't 20 : Working. 21 : -- weren't recording. 22 : Yeah. 23 : So, should have that been 24 on there? 25 : It should have been on EFTA00063291

157 1 there. Yes. It should have been on there. 2 : So, being that it wasn't 3 on there, does that make you re-think, huh, 4 maybe I didn't even work on it on the 9th, or 5 try to work on it on the 9th? 6 : I did work on it, if 7 that's what I said before. 8 9 10 : Okay. : But yeah. : Because they were writing 11 that, it sounds like, based upon a conversation 12 with you on the 9th, they don't know that you 13 don't have access to do them on the 9th. 14 That's what they're writing, based upon what 15 you told them. 16 : Mm-hmm. 17 : Like, oh, yeah, I'm doing 18 it today because on the 9th, I couldn't gain 19 access -- 20 : Yes. 21 : -- to the room. 22 : Mm-hmm. 23 : So, looking at this, and 24 what you were working on, it looks like you 25 sent them an email of what you were working on EFTA00063292

158 1 that day. And now that you're seeing what you 2 were working on that day, and the fact that the 3 cameras weren't listed on there, were you 4 actually working on it on the 9th? 5 : Yes. 6 : And you are positive you 7 went on the 9th and tried to gain access 8 : Because I had -- 9 : -- to that room? 10 : -- and I had to get the 11 drives from I did get the drives from 12 13 : Okay. But you are 14 positive you actually tried to access that 15 room, and III told you -? 16 : After I leave, that's it, 17 you can't stay. 18 : All right. And that's, 19 your positive about, on the 9th, even though 20 it's not listed on your to-do list, on the 8th 21 22 : Yeah, because that was 23 probably something in -. This is probably all 24 the stuff that I fixed during that week, or 25 stuff I was looking at. EFTA00063293

159 1 : Okay. 2 : Mm-hmm. 3 : Just, but the reason why 4 the camera issue isn't on there is why? 5 : It's a recurring thing. 6 Like, it's not something -. Like -- 7 : Okay. 8 : -- after I fixed it, 9 that's where I would give them the stuff I 10 worked on. It's not if I'm working on, this is 11 the stuff, like, I've been working on or fixed 12 before. This is the stuff that is pending, or 13 has to get done. Because those are work 14 orders. 15 : So, from your 16 understanding, the camera issue wouldn't be 17 listed on this? 18 : It wouldn't be listed on 19 here. No. 20 : And you wouldn't have 21 notified that the cameras were down, and 22 not recording? 23 : Mmm, no. That would have 24 been up to whoever was in charge. Like, I'm 25 not -. I'm just the guy that fixes stuff. EFTA00063294

160 1 : Oh, I thought you said 2 you tell This is your supervisor -- 3 : Direct supervisor. 4 : -- direct supervisor. 5 : Yeah. 6 : I thought you said you 7 would always tell your direct -- 8 : Supervisor. 9 : -- supervisor. 10 : Yeah. 11 : But you didn't? 12 : No. 13 : So, this is just the 14 things we need to reconcile. 15 : Reconcile. Okay. 16 : Is this something that 17 you should have told him? 18 : If he wasn't in charge, 19 then I didn't tell him. No. 20 : Well, you didn't tell 21 We know that. But he is still your 22 - you said that he is not my real boss. 23 : Yeah. I can't tell -- 24 : But 25 : -- and I can't tell him EFTA00063295

161 1 about cameras, anyway. So, if it was , and 2 and , that's probably the only 3 people that would know about the camera 4 situation. 5 6 7 : So, from the 8th? : From the 8th. Yes. : And -. Okay. So, from 8 looking at this, though, you don't see anything 9 wrong with not telling him that, when you're 10 talking about your to-do list? 11 : Hmm. He's not in the 12 institution. That's, like, yeah. 13 : Okay. So, the camera, 14 the camera issue should not have been listed on 15 here? 16 : Hmm. 17 : And when we go back -- 18 : This is -- 19 : -- to , or talk to 20 the warden 21 : -- this is -- 22 • -- will they say the same 23 thing? 24 : -- this is everything that 25 I've closed out over the -- EFTA00063296

162 1 2 3 4 : outs? : that I've done. Yes. Oh, these are your close -- yeah, this is stuff 5 : All right. So -- 6 : For the week. 7 -- and that's why there's 8 not much -- 9 : (Indiscernible *01:36:10). 10 : -- there's nothing, other 11 than your things. 12 : No. 13 : So, this is the things 14 that you've completed? 15 : Completed. Yes. 16 : These aren't things that 17 you're working on. 18 : Working on. No. 19 : Okay. And you are sure 20 of that? 21 : Yes. 22 : Perfect. All right. Can 23 you initial and date that? 24 : Mm-hmm. 25 : In retrospect, should EFTA00063297

163 1 have you notified that the camera issues 2 weren't working? The cameras weren't 3 recording. 4 : The thing about that, if 5 you're not in the building, and there is an AW, 6 and an SIS told me the cameras are not working, 7 like, why should I call you at home to tell you 8 the cameras aren't working? 9 : Yeah, yeah. 10 : It's not -. You're not in 11 the building. 12 13 14 : Okay. : So. : So, is it your 15 understanding that, after III left, there was 16 no way for you to access that room? 17 : I would have to break 18 glass, and write a memo, and all this other 19 stuff. So, why I have to stay in the room? 20 And it's the evidence room. So, I can't really 21 just willy-nilly go in there by myself where I 22 shouldn't be, you know? 23 : Okay. And how serious it 24 is if you have to break the glass, to obtain 25 those keys? EFTA00063298

164 1 : I just have to write a 2 memo and tell the lieutenant why I would have 3 to stay behind. But I was coming back the next 4 day. So, and I was probably working overtime 5 all week. And it was just time for me to go. 6 : Okay. 7 : I've been doing some long 8 hours. 9 : Okay. So, because you 10 had worked the hours, you made it, you made 11 that decision based upon your own experience 12 that I'm going to work it on the next day, I'm 13 not going to fix it today? 14 : Mm-hmm. Yeah. 15 : So, you -- 16 : And the past practice of 17 just deal with it tomorrow. But I've been told 18 by my other supervisors, hey, just deal with it 19 tomorrow. 20 : Okay. But you weren't 21 told, in this situation -- 22 : No. 23 : -- you made that 24 independent decision on your own, though. 25 Correct? EFTA00063299

165 1 : Yes. From what I've been 2 experienced from before. Yes. 3 : Okay. But you could have 4 broken the glass, wrote a memo, and stayed to 5 fix it? 6 : Yes. 7 : Okay. And you did not 8 ask the captain, and any AWs, or the warden if 9 you could come back the following day to fix 10 it? 11 : I was already coming back 12 for overtime. So. 13 : Right. Point being is to 14 notify them, hey, these cameras, the recordings 15 are still down? 16 : The recordings were down 17 months at a time. I'm sorry. Like -- 18 : Whoa, whoa, whoa. Tell 19 us more about that. 20 : -- you -. 21 : So, there were 22 23 24 25 : I'm sorry. : -- there were -- : I'm sorry. : -- no, no, no. We need EFTA00063300

166 1 to know this stuff. So -- 2 3 4 : I'm sorry. : -- this is -- : Like, this is not, like, 5 everybody -. It looks like I'm the fall guy, 6 or, like, something isn't working, like, you 7 keep asking me the same question. The thing 8 about these cameras, these cameras weren't 9 working for, like, weeks at a time. Like, this 10 hasn't been the first time where these 11 recordings weren't working, and nobody checked 12 them. 13 : Well, that's what we need 14 to know. 15 : Yes. 16 : And we didn't -. So, 17 this is the first we're hearing that there was 18 weeks at a time that the -- 19 _: Yes. Of course -- 20 21 working. 22 23 time. 24 : Well then -- 25 : This happened before. -- recordings weren't : -- there were weeks at a EFTA00063301

167 1 : -- well then, tell us. 2 So, here. Open, open discussion. Tell us 3 exactly what was going on with these 4 recordings, and when they weren't working. 5 : Well, when I fist got to 6 the institution, that's why I started a 7 project. I would look for video, and they 8 would tell me there is a problem, and I'm, 9 like, oh, you can't keep running the 10 institution like this. If there is no video, 11 you have to fix the system. You have to get an 12 upgrade. I've called SigNet about the problem. 13 And I informed everybody, hey, this is a 14 problem. You can't have a jail where you can't 15 find video whenever you need video. Or the 16 recorder is always failing. 17 I was in Terre for a year and a half. I 18 don't remember, maybe a couple times where 19 something - as far as video, pulling back 20 video, you would always find a video. There 21 was never a time where you couldn't find a 22 video. Maybe some cameras weren't working, but 23 as far as pulling back video for a jail, there 24 is no time where you can't find video. And my 25 experience, when I got there, was, like, oh, EFTA00063302

168 1 it's not a big deal, it's not a big deal. 2 And I'm, like, well, this is a jail, with 3 funding and whatever else problems they had. 4 Nobody considered anything here a priority or 5 an emergency. So, after Epstein, that's when 6 it was, like, oh, well, now you've got to stay, 7 now you have to do everything. And I've been 8 screaming at the hilltop when I got there. 9 Like, hey, you have a problem, you've got to 10 fix it. That's why I did the money for a 11 project, hey, you need to get new recorders in, 12 you've got to put the -. You've got to 13 upgrades. Like, you haven't done anything at 14 all. Like, you have to spend money. Like, 15 this stuff is old. 16 : But tell us specifically 17 about times where there were weeks at a time 18 that the recorders -- 19 : Well, not weeks -- 20 : -- were down. 21 : -- at a time, but I'm just 22 saying, like, if this happened at this time, 23 right, and I replaced the drives the other 24 time, weren't they looking for video, and 25 another time they couldn't find video, and I EFTA00063303

169 1 fixed it, and then, they were, like, oh, well, 2 everything is fine now. And then, a month 3 later, or two months later, we have the same 4 problem again. Oh, can't find video. They 5 were just concerned about video they could find 6 for that specific time. They were never 7 concerned about finding a video for the whole 8 time. 9 : Okay. So, it - from what 10 we have, from our records - it suggests that, 11 in February, was the last time -- 12 : No. 13 : -- (Indiscernible 14 *01:40:26). 15 : This happened before. 16 That's why I -- 17 18 19 20 21 22 February -- 23 : This was the last time? -- yes. : Okay. It may -- : The last time. : -- have happened before : Yeah. Yeah. But there 24 was more times where it happened before 25 February. Since I touched down and got to MCC, EFTA00063304

170 1 New York, this was a problem. 2 : So, it was a constant 3 reoccurring problem -- 4 : Yes. 5 : -- where this was 6 happening? 7 : Yes. 8 : And what have you been 9 telling them all along was that we need to fix 10 -- 11 : The problem. 12 : -- recurring -- 13 : Yes. 14 : -- problem. 15 : Yes. So, that's why I had 16 a brand-new hard drive downstairs. And it 17 wasn't a priority. 18 : Right. 19 : Because you've got other 20 things to worry about. 21 : But when the -. And 22 correct me if I'm wrong, though. I understand 23 what they're saying that, like, you're saying 24 that it wasn't a priority for them to install a 25 whole new system, but it did sound like it was EFTA00063305

171 1 a priority, once the recordings went down -- 2 : Down. Yes. 3 : -- that they need to be 4 fixed. 5 : Fixed. Yeah. They need 6 to be fixed. Yes. 7 : Right. So, that's where 8 I want to make sure we're clarifying, when you 9 make a statement such as, it would be weeks at 10 a time that there is no recordings. 11 : I'm just, not weeks at a 12 time, but there would be days where there is no 13 video. 14 : Okay. 15 : Like, they always try to 16 get video, there is no video. This isn't the 17 first time -- 18 : Right. 19 : -- this happened. 20 : And that was what 21 happened, it looks like, back in February 22 : Yes. 23 : -- it would have been 24 about six months before 25 : And this happened -- EFTA00063306

172 1 2 *01:41:23). 3 : -- (Indiscernible : -- before then, and it 4 happened a couple times before then -- 5 : Right. 6 : -- because that's when I 7 started Whenever I started working at that 8 prison, I probably noticed it within the next, 9 the first three to four months I was there. 10 Like, hey, what's going on with the recorders? 11 Why is there no video? 12 : Right. 13 : And then, especially when 14 I had to do the time change, because we had to 15 do a time change in October, on the year 16 changes, and I'm, like, why is it taking a 17 whole day and a half for them, for the 18 recordings to start to rebuild and change the 19 time on the recordings. It shouldn't take a 20 whole day to do that. 21 : And -- 22 : Because you have to stop 23 and start stuff, and it's, like, well, why is 24 the system so old? Like, what are you guys 25 doing? EFTA00063307

173 1 2 3 4 : And did you already have a new system to install at this point? : No, I didn't. : It wasn't on there? 5 : No. I had to submit a 6 project. I went with the engineering tech -- 7 : No, no, no. Prior to 8 August 10th, 2019. 9 : Yeah. 10 : Did you already have a 11 new system -- 12 : Yes. 13 : -- at that time? 14 : At the time. At the 15 location. Yes. 16 : So, you did have a new 17 system -- 18 : System. 19 : -- you just hadn't 20 installed -- 21 : Installed it. 22 : -- it yet. 23 : Yes. 24 : And why didn't you 25 install it, prior? EFTA00063308

174 1 : Because it wasn't a 2 priority. Like I said before. 3 : Okay. But your priority, 4 or whose priority? 5 : Whoever - Signet - or 6 whoever is on the list for them to install the 7 new, our recorders. 8 : Okay. So, you don't 9 : They have a list. 10 : -- install it? 11 : No. I do not install it. 12 I help the -- 13 : Signet would have -- 14 : -- technician who will 15 come and install it. Yes. 16 : -- and when was SigNet 17 scheduled to install this? 18 : I have no idea. 19 : Whose job would it be to 20 call SigNet and to schedule them to install the 21 new recorders? 22 : That's not my -- 23 : That's not you? 24 : -- that's not me. 25 : As the camera guy, you EFTA00063309

175 1 wouldn't have anything to do with it? 2 : No. That's upper 3 management, and SigNet. 4 : So -. 5 : Or . Like, hey, 6 when is this thing -? But that's not my call. 7 It's here. Like, you know, they have to 8 schedule it and work that out. 9 : So, if it's on the 10 premises, and you have the new system at the 11 MCC, how long was it actually at the MCC prior 12 to this time? 13 : It was a few months. 14 : So, the new system -- 15 : Yes. 16 : -- probably was ordered 17 after the February timeframe. 18 : No. It was ordered way 19 before then. 20 : So, maybe -- 21 : It was ordered because it 22 was This happened in 2019. The new system 23 was here, and the money from 2018. 24 : So, you've had this new 25 camera system on hand for almost a year, if not EFTA00063310

176 1 2 3 4 -- : Not a year, but a few months. Yeah. We had -- : So, a few months. 5 : -- it for a few months. 6 Yeah. 7 : And it obviously can't be 8 SigNet's decision 9 : Decision. 10 : -- to put it in. 11 : It's -- 12 : Is it? 13 : -- no, it's not SigNet's. 14 The facility. Who is in charge of the 15 facility? 16 : So, who is the person 17 that was in charge of getting that new camera 18 system installed? 19 : Whoever was in charge. 20 : Who? 21 : That would be the facility 22 manager. Whoever was -- 23 : So, 24 : -- well, he just got 25 there. We were at limbo. There was nobody in EFTA00063311

177 1 charge. 2 : So, there was no one to 3 actually schedule this thing to get -- 4 : Installed. Yeah. 5 : -- and -- 6 : Nobody to take charge and 7 say, hey, I can't call Signet, hey, I need you 8 to come I'm -. What am I? 9 : Who knew that the new 10 camera system was there? 11 : I did. I think I did, and 12 that was probably about it. Because -- 13 : Okay. Was that anyone's 14 -- 15 : -- it was too much -. 16 Like, at the time, we didn't have a general 17 foreman or a facility manager. There was 18 nobody that really -. We started a project. 19 It was just, like, a whole big mess of 20 confusion. 21 : All right. 22 23 24 *01:44:12). 25 There was really nobody -- Because (Indiscernible -- to say, hey, this is, EFTA00063312

178 1 you know -. 2 : So, you always say that 3 the cameras are the captain's baby. Would it 4 have been the captain that should have taken 5 responsibility for that, to say, like, hey, get 6 these -- 7 : These cameras -- 8 : -- these new cameras -? 9 -- you got the new 10 recorders, hey, get them in. Yeah. But 11 Yeah. 12 : Because you keep on 13 saying, hey, this has been an ongoing problem. 14 Well, it looks like the problem - the solution 15 was there. 16 : Yes. But nobody -- 17 : But it was never actually 18 19 : -- (Indiscernible 20 *01:44:33). 21 : -- implemented. 22 : No. It was never 23 implemented. 24 : So, I know you said, 25 like, oh, it looks like you're saying, well, EFTA00063313

179 1 you know, I'm the fall guy. Well, I'm asking 2 you, who is? Who is the guy that should have 3 made sure that that was fixed? 4 : I'm just the maintainer of 5 the system. 6 : Right, right, right. 7 : I'm not the installer of 8 the system. 9 : And I'm not saying that 10 you are the guy. 11 : Yeah. 12 : I'm asking you the 13 question. 14 : I helped install 15 : Who -? 16 : -- the system. 17 : So -. 18 : I maintained the system. 19 I fixed the problem when you tell me, hey, 20 , there is a problem. I go check it out. 21 I call SigNet. And we work on the issue. 22 : And -. 23 : That's it. That's all I 24 do. 25 : And I'm asking questions. EFTA00063314

180 1 I'm not making accusations. 2 3 4 responsible -- 5 : Accusations. : Not once did I say you're : You're responsible. 6 : -- what I'm asking is, 7 who is responsible? 8 : It would be, probably be, 9 the facility manager, or the general foreman, 10 or -, 11 : And because there was no 12 one there -- 13 : Yeah. 14 : -- who, then, would 15 become responsible? 16 : Well, then it would be the 17 AW. Whoever is in charge. 18 : And who was the AW in 19 charge at that time? 20 , probably. 21 : So, it would be , not 22 23 24 yeah. 25 : Oh. Oh. She was -. Oh, was there, too. Yeah. : So, one of the two? EFTA00063315

181 1 : One of the two. Oh, well, 2 , and was. Before them, it was 3 (Phonetic Sp. *01:45:34), because I remember, I 4 had to talk to him about this whole camera 5 thing. 6 : And who is 7 : He was another AW, before 8 took over. This is, like, before 9 all this got started, it was -. Back with my 10 old manager and , when I was telling 11 them, hey, you need to upgrade your camera 12 system. 13 : Okay. All right. And 14 there was nothing on -. Nothing scheduled to 15 actually get the new system installed? 16 : No. And from what I know, 17 we weren't on the list to get anything 18 installed. 19 : And the reason why you 20 were able to install it, you said on the 11th? 21 : It's because of whatever 22 happened with Epstein. 23 : So, Epstein happened. 24 You had this 25 : Everything (Indiscernible EFTA00063316

182 1 2 3 *01:46:06) there. : -- new system already 4 : Yes. 5 : So, on the 11th, you were 6 able to immediately -- 7 : Immediately. 8 : -- install it. 9 : Install it no problem. 10 : So then, the day after 11 (Indiscernible *01:46:11). 12 : -- Epstein's found, there 13 is a new camera system there? 14 : There is a new camera 15 there. 16 : Who installed it? 17 : It was and 18 myself. 19 : So, he flew in? 20 : Yes. 21 : And installed it -- 22 : With me. 23 : -- with you? 24 : Yeah. Well, I put the 25 rack in, and helped him. Well, he pretty much EFTA00063317

183 1 did everything. But get the rack and the UPS 2 in. 3 : All right. And who 4 contacted to make sure he came 5 down? 6 : I was on the phone with 7 SigNet after all this happened. I was on the 8 phone the whole time with SigNet. 9 : So, who made the ultimate 10 decision to, hey, it's time now to get this new 11 system installed? 12 : Probably , when he 13 got a hold of what was going on. 14 : Okay. So, would 15 have 16 : Yeah. 17 : -- been able to make that 18 decision? 19 : Make that decision. Or 20 maybe when I was Because I think I, when I 21 was on the phone with that they were, 22 like, well, we got to get out there right away, 23 because whatever is going on. 24 : Now, was , was he, 25 did he have knowledge that this camera system EFTA00063318

184 1 was old and needed to be replaced? 2 : Yes. 3 : So, should have he had 4 the -. He should have made this a priority, to 5 make sure that the new camera system was put in 6 place, since he had been there for, I think, a 7 few months? 8 : Well, we already started 9 the project. I don't think anybody knew the 10 gravity of the recorders at the time. Like, if 11 I knew how important the recording was. 12 Everybody else, they were just, like, oh, it's 13 just, it's broken again. And I'm, like, well, 14 you know, it's not just broken again, it 15 shouldn't be broken at all. 16 : Okay. And then, did you 17 tell people that? 18 : Yes. 19 : And who did you tell 20 that? 21 : I've talked to my co- 22 workers, and I've talked to my facility manager 23 about the problem. And I even talked to the 24 regional com tech, because we have a regional 25 guy in charge of the cameras, and that work EFTA00063319

185 1 stuff, like, like, this stuff is unacceptable. 2 Like, when I came and, like, the way the 3 building was laid out, and some of the wiring 4 issues in the building, this was just not 5 acceptable. 6 : Okay. But knew, 7 prior to August 10th, how important this was to 8 get this new camera system in? 9 : It was. That's why we 10 started the project. Yeah. 11 : And when you say you 12 stared the project, what did you start on the 13 project? 14 : Trying to figure out how 15 we were going to upgrade, like, because not 16 only did the recorder was bad, it was also the 17 housing units, there was only one camera in the 18 housing unit. So, if anything was to happen on 19 the housing unit, you would see no video. 20 : Okay. 21 : It would just be a blanket 22 camera footage of the common area. There would 23 be no additional video. 24 : And you said the new system 25 was purchased with year-ends '18 -- EFTA00063320

186 1 : Mm-hmm. 2 money? 3 : Yeah. 4 : So then, how long was this 5 system sitting around? You said a couple 6 months, but that's more than a couple of 7 months. 8 : A few. It's a few months. 9 I'm not too sure when everything got ordered, 10 or when it was sitting around. Because even if 11 we ordered it, I think everything was on back 12 order. That's why it didn't come right away, 13 the recorder. 14 : Oh, okay. 15 : The recorder. 16 : Okay. 17 : Yeah. 18 : But it was post that February 19 date? 20 : Before the -. I'm sorry. 21 Can you repeat that, please? 22 : Yeah. So, I mean, it was, it 23 was, if it was on back order, it probably 24 arrived some time in, what, '19 versus '18? 25 : I am not too sure when it EFTA00063321

187 1 arrived. 2 : Okay. 3 : So, because 4 : Can I ask a question? 5 : -- yeah. Go ahead. 6 Please. 7 based on your 8 understanding, how important is it that the 9 cameras are recording on a day to day basis? 10 : It's very important. And 11 it should be checked on a day to day basis. 12 And the way, at my last institution, that I was 13 aware that anything wasn't working, was I would 14 actually get a report from SIS, this camera is 15 bad, that camera is out. This camera is not 16 working. Now, after Epstein happened, they 17 wanted to task me with that job. I refused 18 because I can't be the same person cooking the 19 food, telling you that the cameras are bad, or 20 the food is good. So then, it became up to 21 somebody else to check the cameras. Daily. 22 Now, they check it every day. There is a 23 report that's sent up. But before Epstein, 24 there was never a daily report of the cameras 25 are recording, or we have an issue. There was EFTA00063322

188 1 never anything set up at MCC, as far as that 2 goes. 3 : So, you think before 4 Epstein had happened, no one had a day to day 5 responsibility to make sure the cameras were 6 working? 7 : No. 8 : Who would have been the 9 next - if no one had the day to day 10 responsibility - who could have checked? 11 : That would have been SIS's 12 responsibility, because my 13 : Okay. 14 : -- my previous jail, SIS 15 would be the one telling me, hey, , there 16 is a camera out, or there is other issues, 17 because I don't just work on cameras. I work 18 on all the communications in the building. So, 19 cameras are, yes, that is, like, one my main 20 things, but if there is other issues in the 21 building, like, I can't just focus on cameras. 22 And at the time, I was by myself. I was the 23 only electronics technician in the building for 24 a while. 25 : What other types of things do EFTA00063323

189 1 you do? I know you fix the (Indiscernible 2 *01:50:45). 3 : Fire alarm. Cameras. 4 Radios. And I install the network. Like, if 5 you need a cat five (Phonetic Sp. *01:50:50) 6 cable, or anything communication lines -- 7 : Mm-hmm. 8 : -- in the building. The 9 fire alarm for the building. The doors. 10 : All right. I'm just 11 going to -- 12 : I'll get back on again. 13 : -- oh, he dropped again? 14 : Looks like he dropped. Yeah. 15 : Hey. Hey. Can you hear 16 me? 17 : Yeah. 18 : Yeah. 19 : Hey. I apologize. A call 20 reception is going in and out. I apologize for 21 that. 22 : Okay. 23 : Based on the question I 24 was asking, if, you said there was a few 25 instances where the cameras went down, it EFTA00063324

190 1 wasn't working for a few days. 2 : Yes. 3 : How bad do you think that 4 the situation is, where the camera is not 5 recording for a few days? 6 : I think it's pretty bad 7 when you're in a prison, and, you know, like, 8 in my experience, because I was custody 9 (Indiscernible *01:51:52) before, like, there 10 has been assaults on inmate on inmate, among 11 our staff, or somebody possibly bringing 12 contraband in the building. And you have no 13 recording to see what was going on. Then you 14 have pretty bad video at that, that it was a 15 priority. 16 : Okay. 17 : Yeah. All that stuff 18 should be fixed. 19 : And based on those 20 instances, did you ever write up any reports -- 21 : Yes, I did. 22 -- did you send it to -? 23 : I did. Before I got the 24 money approved for the new camera system, I got 25 together with the engineering tech, and I wrote EFTA00063325

191 1 -. I also, I wrote a work order over $10,000, 2 because the camera system as an asset is worth 3 over $10,000. To get that fixed. Because I 4 had that problem, I had also the fire alarm 5 was, I had a problem with that. I had a 6 problem with that. I had a problem with the 7 voicemail system. Everything. When I got to 8 the building, everything was just at a pretty 9 bad state. That wasn't the only thing that was 10 looked over as, like, oh, we need to get this 11 fixed. The whole building was, as far as 12 communication wise, it was pretty bad. 13 : Yeah. But the question I 14 had was, did you write any reports or 15 : I -. 16 : -- any emails to upper 17 management -- 18 : Yes. 19 : -- saying, hey, listen -? 20 : Yes. 21 : Okay. Do you recall who 22 you sent it to? 23 : I would have sent it to 24 and he was my first facility 25 manager. EFTA00063326

192 1 2 3 4 name? 5 6 know. 7 : Is it 8 9 10 11 • : Can you spell that last -. I don't : -- or : So, it would be 12 : No. He spells it weird. 13 . Oh, 14 : All right. So, can that 15 be the fourth request, then? So, we talked 16 about the emails between SigNet -- 17 : And then, my -- 18 (Indiscernible 19 *01:53:53), but also -- 20 : -- and then, 21 . He's the engineering tech. He's the 22 one that actually wrote up the report to get 23 sent to the regional office, as far as the 24 money for the camera project. 25 : All right. So, those EFTA00063327

193 1 emails. And any other emails -- 2 : And then -- 3 : -- you can find. 4 . He was 5 also the general foreman when this happened, 6 too. 7 : All right. So, can you, 8 at least those three people, as well as anybody 9 else. 10 : Mm-hmm. 11 : So, all the emails from 12 SigNet, and any, really, emails with regard to 13 14 : Okay. 15 : -- the cameras issue -- 16 : Camera issue, i7 : -- that you can provide 18 to us. That would be greatly beneficial for 19 us, that we know who was notified, when -- 20 : Mm-hmm. 21 : -- who, you know -- 22 : That's fine. 23 : -- what actions should 24 have been taken, and when they should have been 25 taken. EFTA00063328

194 1 : Mm-hmm. 2 : I just want to real 3 quickly follow up on these things, to make sure 4 what we have is accurate. Specifically, with 5 regard to the FBI report that said, "There was 6 a system failure of DVR-2 on July 29th, 2019, 7 and a motherboard failed on DVR-2 on August 8 8th, 2019. The hard drive failure occurred on 9 August 10th, 2019." Again, is that information 10 that you provided to them, or did they obtain 11 that themselves? 12 : I think they obtained that 13 themselves. They would have -- 14 : All right. And do you 15 know -- 16 : -- the exact dates. 17 : -- do you know the 18 difference between, like, a system failure, a 19 motherboard failure, and a hard drive failure? 20 : Yes. 21 : All right. So, I'm going 22 to read you what we have obtained regarding 23 this, and I want you to tell me if it's 24 accurate or not. 25 : Okay. EFTA00063329

195 1 : So, it says, "Per 2 from SigNet," regarding, this is still 3 regarding a system failure, "this looks to be 4 an error coming from the video management 5 server. 6 : Mm-hmm. 7 : There is an application 8 within the video management system software 9 called Supervision. This application monitors 10 connection between the main application server, 11 which manages authentication -- 12 : Authentication. 13 : -- for users to access 14 live recorded video, and an ability to export 15 video, along with many other customizable 16 features. And system devices, such as DVRs, 17 cameras, video encoders, or video decoders. If 18 this is the case, then this would have been the 19 message from the Supervision application, 20 showing that there was a lost connection to 21 DVR-2." 22 : DVR-2. Right. 23 : Does that sound accurate 24 to you? 25 : Yes. It's -. Yeah. EFTA00063330

196 1 : So, they would have 2 obtained this information, it sounds like, from 3 that application, Supervision? 4 : Yes. 5 : Okay. But you didn't 6 check that. Correct? 7 : No. 8 : All right. So, do you 9 know what caused that system failure on July 10 : No. I have -- 11 : 29th? 12 : I have -. No. 13 : But you said you were 14 working on the mother -. Or you were -- 15 : Yeah. 16 you were working on 17 the system right around that time? 18 : Yes. 19 : All right. So, likely, 20 it was whenever you were working on the system 21 around July 29th, 2019, that caused the DVR, 22 the recorders to stop recording? 23 : No. I checked everything 24 before I -. 25 : Well, we just talked EFTA00063331

197 1 about previously, is that you checked 2 everything when you were working on it, for the 3 time prior -- 4 : Prior to me -- 5 : -- to when you worked on 6 it. 7 : -- to me working on it. 8 Yeah. 9 : So, likely, that's when 10 the -- 11 : When the -- 12 : -- recorders stopped? 13 : -- yeah. 14 : Okay. So, whatever, 15 whatever work you were doing on it, likely 16 stopped the recordings, but no one presented 17 the issue to you until August 8th, 2019? 18 : Yeah, but I always check 19 everything after I'm done. That's very strange 20 that I -- 21 : Well, again, we think you 22 checked it, but it looks like, it sounds like 23 you checked it for the time 24 : Yeah. 25 : -- period prior to when EFTA00063332

198 1 you fixed, you thought you fixed it. 2 : I fixed it. Yeah. 3 : So -. 4 : But that doesn't sound 5 like me. I'm sorry. Just how I am 6 : Well, no, no, no, this is 7 what you told us. 8 : -- yeah. 9 : So -- 10 : Yes, yes. But I would 11 have checked to make sure, like, a couple days 12 later, okay, it's still working. Or -- 13 : And do you recall 14 (Indiscernible *01:57:17). 15 : -- because I'm pretty sure 16 I looked at the Nice Vision, and the Nice 17 Vision looked like it was fine. But there 18 could have been another problem. But I don't 19 pull video. Like, I don't go back to pull 20 video for, I told you, I don't. 21 : So, you just don't recall 22 if you ever went back and checked? 23 : I'm pretty sure I checked. 24 I'm more than definite. After I fixed it, I 25 would have checked to make sure it was working. EFTA00063333

199 1 : Because the information 2 we have is that there is no video from July 3 29th -- 4 : 29th. 5 : -- on. 6 : On. Yes. 7 : So -. 8 : And that's the last time I 9 worked on it. That's what it says, right? 10 : No, it doesn't. It just 11 says that there was a system failure of DVR-2 12 on July 29th, 2019. 13 : Yeah. 14 : And just from talking 15 with you, it sounded like you knew that there 16 was a system failure, prior to that time, and 17 that's when you worked on it, and thought you 18 resolved the issue. 19 : I probably -. Hmm. Can 20 you - I'm sorry - can you repeat that one more 21 time for me? 22 : We spoke an hour or so 23 ago -- 24 : Uh-huh. 25 : -- about how, prior to EFTA00063334

200 1 this issue, you knew about a system failure 2 : Failure. 3 : -- and you went in and 4 you fixed 5 : Fixed the issue -- 6 : -- the issue -- 7 : -- yeah. 8 : -- or you thought -- 9 : That I fixed the issue. 10 : -- you fixed the issue. 11 : Okay. 12 : So, what this is saying, 13 that there was a system failure on July 29th, 14 2019. And the information that we have is, 15 there was no -- 16 : Follow ups. 17 • -- recordings -- 18 : For after that. 19 • from the 29th 20 : Yeah. 21 : -- so, the 29th on. 22 : On. Yes. 23 : So, it sounds like you 24 thought you fixed the issue 25 : The issue -- EFTA00063335