EFTA00060373.pdf

1 DIGITALLY RECORDED SWORN STATEMENT OF OIG CASE #: 2019-010614 DEPARTMENT OF JUSTICE OFFICE OF THE INSPECTOR GENERAL JULY 14, 2021 RESOLUTE DOCUMENTATION SERVICES 28632 Roadside Drive, Suite 285 Agoura Hills, CA 91301 Phone: EFTA00060373  2 APPEARANCES: OFFICE OF THE INSPECTOR GENERAL BY: BY: WITNESS: OTHER APPEARANCES: NONE EFTA00060374  I 1 : The recorder is on. My 2 name is and I'm a Senior 3 Special Agent with the U.S. Department of 4 Justice, Office of the Inspector General, New 5 York Field Office and these are my credentials. 6 : Thank you, sir. 7 : This interview with the 8 Federal Bureau of Prisons employee 9 is being conducted as part of an 10 official U.S. Department of Justice, Office of 11 the Inspector General investigation. Today's 12 date is July 14, 2021 and the time is 1:14 p.m. 13 : Yes. 14 : This interview is being 15 conducted at the Metropolitan Correctional 16 Center in New York, New York, also known as the 17 MCC. Also present is DOJ OIG Special Agent 18 This interview will be recorded 19 by me, SSA Could everyone 20 please identify themselves for the record and 21 spell your last name. To start, again, I am 22 DOJ OIG Senior Special Agent 23 24 : This is DOJ OIG Special Agent 25 EFTA00060375  4 1 : Lieutenant 2 , work for the Bureau of Prisons at MCC 3 New York. 4 : Could you just spell your 5 last name for the record? 6 7 : Thank you, sir. This is 8 an official DOJ OIG investigation into the 9 death of inmate Jeffery Epstein and the 10 surrounding circumstances and you're being 11 asked to voluntarily provide answers to our 12 questions. Will you agree to a voluntary 13 interview with the DOJ OIG? 14 : Yes. 15 : Yes, thank you. All 16 right, so we got that form, it's the DOJ OIG 17 form I1I-226/2. It says, "The United States 18 Department of Justice, Office of the Inspector 19 General Warnings and Assurances to Employee 20 Requested to Provide Information on a Voluntary 21 Basis. You are being asked to provide 22 information as part of an investigation being 23 conducted by the Office of the Inspector 24 General. This investigation is being conducted 25 pursuant to the Inspector General Act of 1978, EFTA00060376  5 1 as amended. This investigation pertains to 2 security failure and job performance failure. 3 This is a voluntary interview. Accordingly, 4 you do not have to answer questions. No 5 disciplinary action will be taken against you 6 if you choose not to answer questions. Any 7 statement you furnish may be used as evidence 8 in any future criminal proceedings or agency 9 disciplinary proceeding or both." And there's 10 a waiver section. It says, "I understand the 11 warnings and assurances stated above and I am 12 willing to make a statement and answer 13 questions. No promises or threats have been 14 made to me and no pressure or coercion of any 15 kind has been used against me." And as 16 mentioned, this is something that we provide 17 everybody for voluntary interviews, so you're 18 being asked, you know, we just provide these 19 warnings to everyone just knowing it's 20 voluntary, you can stop at any time, you don't 21 have to answer our questions. Do you 22 understand? 23 : Yes, sir, I understand. 24 : All right. So, if you 25 want to review it yourself, please feel free, EFTA00060377  6 1 otherwise there's an employee signature and 2 then employee name below. Thank you for 3 signing, sir. I'm going to sign for the Office 4 of the Inspector General Special Agent. And 5 I'm writing my name, The 6 date is 7/14/2021. 7 : 1:16. 8 : The place is - the time 9 is 1:16 -- 10 : Sixteen. 11 : -- p.m. The place is MCC 12 New York. Special Agent , can you please 13 sign as the signature witness and place your 14 name as the name of witness. 15 : This is Special Agent 16 , I'm signing as a witness. 17 : And as I mentioned, 18 Lieutenant , I believe, were you 19 interviewed prior by the 0IG and the FBI? 20 : Yes, I was. 21 : All right, as mentioned, 22 there's a report that I have here. I don't 23 even think that it's worth going over because 24 there's not really much in it. So, the reason 25 for us to - for interviewing you is to kind of EFTA00060378  7 1 - you were the OIC is our understanding on 2 August 9th, is that correct -- 3 : Yes. 4 : -- of 2019? And just to 5 kind of ask you questions related to what you 6 know about what happened on August 9th and 7 August 10th of 2019. Before starting the 8 interview, I'd like to place you under oath. 9 Lieutenant , can you please raise your 10 right hand. Do you swear to tell the truth and 11 nothing but the truth during this interview? 12 : Yes, I do. 13 : Thank you, sir. If it's 14 something that you don't understand, just ask 15 me to rephrase and I'll try to clarify anything 16 like that. What is your current home address? 17 18 19 : And what is your date of 20 birth? 21 22 : And what is your social 23 security number? 24 25 : What is your current cell EFTA00060379  8 1 phone? 2 -: 3 And what is your highest 4 level of education? 5 : High school. 6 : And where did you go to 7 high school? 8 : Graphic Arts in the city. 9 : In New York City? 10 : Yes, New York City. 11 : And what was it called. 12 : Graphic Communication of 13 Arts. 14 : Okay. Cool. Is that 15 like some kind of like -. 16 : It's on 49th Street and 17 10th Avenue. It was a 18 • Like a -. 19 : -- advertisement high 20 school. 21 • Oh, that's neat. 22 : Yeah. It was cool. 23 : This is not really to do 24 with the interview, but is that like something 25 you get to, like -. EFTA00060380  9 1 : Well I can draw a little 2 bit and do a little bit of graphic design -- 3 : Oh, neat. 4 : -- from high school. Not 5 too much but that's what I went to high school 6 for. 7 : That's neat. What did 8 you do prior to working for the BOP? 9 : I was in the United States 10 Army and I worked for a hotel. 11 : Okay. As far as being 12 with the Army, when were you in the Army? 13 : I started in 1998. I was 14 in the National Guard and then I went active 15 duty in 2005. 16 : Okay. When did you - are 17 you still in the Reserves? 18 : No, I'm completely done 19 with the military. 20 : When did you get out? 21 : 2011. 22 : Was it an honorable 23 discharge? 24 : Yes it was. 25 : And what was your rank at EFTA00060381  10 1 -. 2 : Corporal. 3 : Corporal? And what was 4 that? E what? 5 : E-4. 6 : E-4. Thank you for your 7 service. And then you said you worked for a 8 hotel, how long did you do that? 9 : Before the military, I did 10 it for three years. I came back, I did it for 11 one year and then I got this job. 12 : Okay. So just prior to 13 being with the BOP -- 14 : Correct. 15 : -- you did - and what did 16 you do there? 17 : Banquet Steward. 18 : And everything with 19 leaving there, was everything copacetic? 20 : Correct. 21 : Okay. How long have you 22 served with the Federal Bureau of Prisons? 23 24 would make seven years. 25 : Seven years? Okay. And EFTA00060382  11 1 do you know your specific enter on duty date? 2 3 : Thank you, sir. When did 4 you graduate from BOP training? 5 6 : Okay. And how long have 7 you been with the MCC? 8 : The whole time, seven years 9 10 : Okay. 11 : -- in September. 12 : You were here the whole 13 time? 14 : Correct. 15 : All right. And you said 16 you're currently a Lieutenant? 17 : Correct. 18 : When were you promoted to 19 Lieutenant? 20 : March 1, 2020, last year. 21 : Okay. And what was your 22 rank or title in August of 2019? 23 : I was a Senior Office 24 Specialist. 25 : Okay. And I have a staff EFTA00060383  12 1 roster here. Here's the - it's going to be on 2 August 9th and then August 10th, it's just for 3 you to refer to, so you don't have to 4 necessarily recall. But what shift did you 5 work on August 9th and August 10th? 6 : So, August 10th, which that 7 should be a Saturday, I was off the weekend and 8 Friday I worked from 6:00 to 2:00 in the 9 Special Housing Unit. 10 : Okay. And what was your 11 position when you were in the Special Housing 12 Unit? 13 : I was an OIC. 14 : And what does OIC stand 15 for? 16 : The Officer in Charge. 17 : And what were those 18 duties and responsibilities as the OIC of the 19 SHU? 20 : Pretty much maintaining 21 paperwork, making sure everything is conducted 22 according to BOP policy. 23 : Okay. And who was your 24 supervisor? 25 EFTA00060384  13 ? It 2 wasn't 3 : Well, actually yes, yes, 4 , I'm sorry, yes. 5 : And he was the SHU 6 Lieutenant? 7 : Yes. 8 : Okay. Great. Now I'm 9 going to - we're going to keep these documents 10 in front of you because as we go through the 11 interview, I'll probably ask you about 12 different people and you can just refer to it. 13 When I do provide you - do you have an extra 14 pen? When I do provide you with documents, do 15 you mind just so that for interview purposes, 16 we - it's not to certify anything is accurate, 17 it's simply to say this is the document that I 18 showed you. So can you just like initial and 19 date on the top of each document that I show 20 you, and it doesn't mean, go through the 21 packet, it's just the top page. So, this one 22 for instance, is the daily assignment roster 23 for Saturday, August 10, 2019 and this one is 24 the daily assignment roster for Friday, August 25 9, 2019. And again, it's simply to - you don't EFTA00060385  14 1 have to do each page, it's just -. 2 : You're not attesting to it. 3 : Yeah. 4 : It's just -. 5 : Yeah. 6 : It's just -. 7 : You're not attesting that 8 it's certified or anything, you know, that it's 9 accurate. It's just to say that these are the 10 documents that we looked at. 11 : Yes, sir. 12 : Would you mind - thank 13 you for initialing. You mind just putting the 14 date? It's 7/14 -- 15 : 14. 16 -- 2021. Thank you, sir. 17 All right. Are you familiar with inmate 18 Jeffrey Epstein? 19 : Yes. 20 : Did you work in the SHU 21 while Epstein was assigned to the SHU in July 22 and August of 2019? 23 : Yes. 24 : During that time, did 25 Epstein have a cellmate? EFTA00060386  15 1 : Yes, he did. 2 : Do you recall who that 3 cellmate was? 4 : I don't know, it was a 5 Spanish guy, I don't remember his name exactly. 6 : So I'm assuming you're 7 talking about the second of the two inmates. 8 : The first one was 9 The second one maybe 10 , does that sound -. 11 , yes. 12 : Okay. So -. 13 : Older gentleman -- 14 : Okay. 15 : -- walked with a cane. 16 : And do you know if there 17 was a specific reason why those cellmates were 18 assigned to Epstein? 19 : I think Psychology said 20 it's just their category, they're older, same 21 age. 22 : Okay. So are you aware, 23 since you said Psychology, did Psychology say 24 that Epstein was required to have a cell mate? 25 : Well, we always practice, EFTA00060387  16 1 if somebody comes off of suicide watch, they 2 have to go with a cellmate until Psychology 3 clears them to be alone. 4 : Okay. 5 : But whoever has history of 6 trying to commit suicide has to go with a 7 bunkie. 8 : Okay. So were you aware 9 that Epstein had attempted to commit suicide on 10 July 23rd -- 11 : Yes, I was. 12 : -- of 2019? Were you one 13 of the responding officers? 14 : No, I was not. 15 : Do you know what 16 transpired on that date? 17 : No, I do not. 18 : Did you hear anything 19 about him either trying to commit suicide or 20 potentially that attempted to harm 21 him? 22 : I saw that in the papers 23 that wanted to harm him but all I 24 heard that he was trying to commit suicide. 25 : All right, do you - is EFTA00060388  17 1 there any reason for you to believe that 2 was trying to harm him? 3 : No. 4 : No? 5 : They always got along. 6 : They did always get 7 along? 8 : Yes, sir. They'd always 9 get along. 10 : Okay. And then you said, 11 following that attempt, he was placed - Epstein 12 was placed on suicide watch? 13 : Yes, with being watched on 14 the second floor. 15 : Okay. And what floor is 16 the SHU on? 17 : 9th. 18 : The 9th floor. Okay. So 19 the suicide watch and the psychological 20 observation area is all on the 2nd floor? 21 : Correct. 22 : All right. Was he 23 removed from suicide watch? 24 : Yes he was, afterwards. 25 : Do you have any idea EFTA00060389  18 1 around when that was? 2 : That I do not remember. 3 : Does July 30, 2019 sound 4 about right? 5 : I wouldn't -. 6 : Or, I guess I should ask 7 this question first. Is there a difference 8 between suicide watch and psychological 9 observation? 10 : Well, psychological 11 observation, you would have all your clothes 12 on. 13 : Okay. 14 : Suicide watch is because 15 you attempted suicide so you're going to be 16 with a smock, in the nude, just a suicide smock 17 and some booties 18 : Okay. 19 -- with nothing else. 20 : And do you know if the 21 entire time that Epstein was on the 2nd floor 22 outside of the SHU, was he in the suicide watch 23 or was he both suicide watch and psychological? 24 : If I'm not mistaken, he was 25 on suicide watch the whole time. EFTA00060390  19 1 : Okay. So you believe 2 that he was actually -- 3 : Yes. 4 : -- in a smock the whole 5 time. 6 : Correct. 7 : Okay. And what does 8 suicide watch entail? 9 : You're being watched 24 10 hours. 11 : By who? 12 : By an inmate or staff. 13 : Okay. And do you know if 14 Epstein was watched by either or, or both. 15 : I think he was just by 16 inmates, if I'm not mistaken. 17 : Inmates and what is the 18 inmates' responsibilities while they're 19 watching him? 20 : Well, they constantly 21 observe you in every - they got to annotate 22 every round that they do, or every 15 minutes 23 they write down what the inmate is doing. 24 : Okay. Did you ever hear 25 of any issues or anything while he was on EFTA00060391  20 1 there? 2 : No. 3 : No? 4 : No. 5 : And what's the 6 difference, what does the psychological 7 observation? 8 : Psychological observation 9 is pretty much is - you're in the same place, 10 just with your clothes on. 11 : And same, you have an 12 inmate (Indiscernible *00:12:35) -. 13 : You have an inmate watching 14 you at all times, yes. 15 : Okay. So for both, it's 16 the same, just the clothes is the only 17 difference? 18 : Correct. 19 : Okay. Did you receive 20 instructions from anyone regarding Epstein 21 being assigned a cellmate after he came back 22 from the 2nd floor and placed back into the 23 SHU? 24 : No. I just did it on my 25 own. EFTA00060392  21 1 : Okay. So no one - you 2 don't recall ever being instructed -- 3 : No, I -. 4 : -- to place him with -. 5 : I don't recall getting a 6 phone call saying, "Put him -" - like I said 7 before, it's we practice, if you're leaving the 8 2nd floor, you automatically go upstairs with a 9 celimate. 10 : Okay. So, did you ever 11 receive any kind of information from either 12 or Psychology saying that 13 Epstein was required to be housed with a cell 14 mate? 15 : Well we knew already and 16 pretty much said, "G, don't 17 forget to put him with a bunkie." 18 : Okay. Did you - and I 19 don't believe that you received it directly, 20 but did you ever see this email? It says - 21 sorry, let me see, it's , who is 22 that? 23 : That used to - she was a 24 Psychologist, one of the Psychologists in the 25 building. EFTA00060393  22 1 : Okay. And it says, it's 2 to "Suicide Watch/Psych Observation update." 3 It says it's dated July 30, 2019 at 12:30 p.m. 4 The subject of the email says, "Inmate Epstein 5 is being taken off of psych observation and 6 needs to be housed with an appropriate 7 cellmate." Did you ever see that by chance? 8 : No. I don't remember this. 9 : Okay. But you knew that 10 he was required to have a cellmate. 11 : Yes. 12 : All right. And you said 13 did inform you? 14 : Correct. 15 : Okay. Did you mind just 16 -- 17 : Oh. 18 : -- initialing and dating 19 that? So you don't recall ever receiving any 20 other written 21 : No. 22 : -- communication 23 regarding the matter? After 24 spoke with you about him being required to have 25 a cellmate, did you communicate that EFTA00060394  23 1 requirement to anyone else in the SHU? 2 : Just in SHU. "All right 3 guys, he needs a bunkie." 4 : Okay. And was that 5 something that you communicated only on the 6 date he came back on July 30 or would that be 7 something that you all would communicate 8 throughout his stay in the SHU? 9 : Well, we constantly just 10 made sure since he was a high-profile inmate 11 and we actually placed him right on the top 12 tier so where we can see - where the OIC bubble 13 was right on top just because of that reason 14 and we, "Hey, you got a bunkie?" "Yes." 15 Because he was always going to his legal visits 16 pretty much the whole day. 17 : Right. 18 : When he came back, made 19 sure he had a bunkie. 20 : Okay. And would you also 21 work then that night watch in the SHU? 22 : Was I working? 23 : Not that day, but in 24 between July 30th and August 9th, do you know 25 if you would have worked that night watch? EFTA00060395  24 1 : I'm pretty sure I did. I'm 2 pretty sure I did. And all my overtime was 3 always in the SHU. 4 : Okay. And do you believe 5 then that everyone who worked in the SHU would 6 have known that inmate Epstein was required to 7 have a cell mate? 8 : Yes. 9 : All right. And what 10 makes you believe that? 11 : It's part of pretty much 12 the SHU training. 13 : Okay. When you say, "SHU 14 training," what training are you referring to 15 and what was taught? 16 : Special Housing Unit 17 training is, once again, the policy of what to 18 do in Special Housing Unit, how to conduct 19 rounds, how to deal with an inmate that is 20 coming off of suicide watch and part of our SHU 21 training is the psychologists speaking to us 22 and breaking down and what to do when an inmate 23 comes off suicide watch, what signs to look for 24 and pretty much making sure you're doing the 25 right thing when somebody comes up from suicide EFTA00060396  25 1 watch. 2 : Okay. So is there any 3 way that people would know that if they didn't 4 attend the quarterly - you're talking about the 5 quarterly SHU training? 6 : Correct. 7 : Is there any way that 8 people that didn't - like people on overtime 9 shifts or people that didn't actually get to 10 take that quarterly training yet, would know 11 that Epstein was required to have a cell mate? 12 : No, they would not know 13 that. 14 : They would not know? 15 : They would not know that. 16 : And did you communicate 17 with people though? I know you're saying that 18 they knew based upon training, but did you ever 19 communicate with the people working in the SHU 20 that Epstein was required to have a bunk mate 21 at all times? 22 : Well, whoever worked in SHU 23 would pass it down, "Hey, make sure this guy 24 stays with - whether it's him or anybody 25 else, I know we're talking specifically about EFTA00060397  26 1 him, but whether it was him or anybody else, we 2 all would say, "Hey, make sure this guy has a 3 bunkie." 4 : Okay. But you can't 5 remember any specific conversations? 6 : No. No. 7 : Okay. Were there any 8 signs hanging up anywhere in the SHU that said 9 Epstein was required to have a cell mate? 10 : No. 11 : All right. 12 : Not that I -. 13 : So someone mentioned that 14 -. 15 : So, I put one of my own - 16 it was in bright orange paper. I put it next 17 to the computer. It's nothing like from BOP or 18 anything, it was just something between us, 19 that said, "Make sure rounds are conducted and 20 he has a bunkie at all times." Yes, that was 21 me. 22 : Okay. So this document 23 I'm showing, it says, "Mandatory rounds must be 24 conducted every 30 minutes on Epstein, as per 25 God." This is what you're referring to? And EFTA00060398  27 1 where was this hanging? 2 On the SHU OIC computer, 3 right next to it. 4 : All right. Awesome. So 5 I was assuming that this might be a confusion, 6 but someone mentioned that there was also a 7 color document saying that Epstein was required 8 to have a cell mate. Was that ever on the OIC 9 computer or anywhere else? 10 : You know what? If it was 11 color, it was - I probably made it because we 12 always had a stack of orange, that was my 13 telling everybody, "Do what you're supposed to 14 do." 15 : Okay. 16 : But I did this, I know, 17 because I typed it up and I put it up there. 18 Now the 19 : So this is the one that 20 you remember is the -- 21 : Correct. 22 : -- one I just showed you. 23 : Correct. 24 : Okay. And that was on 25 the OIC's computer? EFTA00060399  28 1 : There's two computers on 2 the desk. If you see, it's right like you 3 can't miss it. 4 : And is -. 5 : It's bright orange paper 6 and black lettering. 7 : And is that where 8 everybody that works in the SHU, are they all 9 in that same area? 10 : Everybody goes to that 11 station. 12 : So everybody that was in 13 the SHU or ever worked in the SHU would have 14 seen at least that document that you created? 15 : Yes. 16 : And do you remember when 17 that document was created? 18 : I think I did that maybe a 19 couple of weeks after he came upstairs. 20 : And is that initially or 21 after he came back from suicide watch? 22 : The first time he went 23 down, when he came up the second time. 24 : Okay. 25 That - when he was EFTA00060400  29 1 : Sometime after July 30th 2 but prior to August 9th -- 3 : Correct. 4 : -- it would have been up. 5 : Correct. 6 : Okay. You can't remember 7 - sometime between there. Definitely prior to 8 August 9th. 9 : Definitely prior to him 10 coming - or that happening. 11 : And do you believe it was 12 at least a few days prior to that as well? 13 : It think it was maybe as 14 soon as he came upstairs from suicide watch -- 15 : Okay. 16 : I put it up there. 17 : Okay. But certainly 18 prior to August 9, 2019. 19 : Correct, yes. 20 : Okay. 21 : Yes. 22 : And you do not require 23 any signs identifying Epstein's cellmate 24 requirement? Was there ever anything on 25 Epstein's cell door, even on July 30th or EFTA00060401  30 1 anything like that? Do you recall anything 2 like that? 3 : I mean, we had orange paper 4 hanging all over the place, but I don't recall 5 one saying he has to have a bunkie. 6 : Okay. 7 : We practice, you come up 8 from suicide watch, you get a bunkie 9 : All right. 10 : -- no matter who you are. 11 : Got a question here. 12 : Yeah, go ahead. 13 : As for God, is that referring 14 to somebody or God? 15 : That's just, you know, 16 okay, God is watching us, we got to do the 17 right thing. 18 : Okay. 19 : So you're referring to 20 this is the question I had before. Are you 21 referring to God himself, not calling the 22 Warden or the Captain or somebody God? 23 : Oh no, just God himself. 24 : All right. So that's the 25 one sign you can remember that was up -- EFTA00060402  31 1 : Yes. 2 : -- requiring rounds but 3 nothing to do with a cellmate. 4 : Nothing to do with a 5 cellmate. 6 : All right. What is the 7 hot list? 8 : The hot list is inmates 9 that have tried to commit suicide in the past 10 and that's posted in Special Housing Unit. 11 : Okay. And where in the 12 Special Housing Unit would have been the hot 13 list located on August 9th? 14 : Right next to the second 15 phone, next to the cage where we keep MIR 16 (Phonetic Sp. *00:20:31), camera, radio 17 holders. 18 : Would it have been like 19 on the desk or behind the desk or -. 20 : Well, we have a hot list, 21 it's next to the phone, that's where it's at. 22 It's a yellow - or it was a yellow binder. 23 : Is there only one phone 24 in the SHU? 25 : There's three. EFTA00060403  32 1 : Three? 2 : Three. 3 : So one of the phones it 4 was next to? 5 : Correct. 6 : Was it hanging on the 7 wall? 8 : Yes. 9 : Okay. Is it like some 10 kind of a bulletin board type of area or like - 11 . 12 : It's a - we have our cage 13 with some of the equipment -- 14 : Okay. 15 : -- and the phone right next 16 to it, it's right in between. That's where it 17 was before. 18 : And do you know if 19 Epstein was listed on the hot list on or around 20 August 9th? 21 : If I'm not mistaken, I 22 think he was. 23 : Okay. 24 : I think he was. 25 : Would have he been listed EFTA00060404  33 1 on the hot list when he came back on July 30? 2 : Yes. 3 : Okay. And how do people 4 get placed on - if he was on July 30th, when 5 would an inmate be removed from that hot list? 6 : Well, that's Psychology 7 once their finished with their whatever they 8 do, reports or evaluations on the inmate. 9 : So how does that work? 10 Is it they - an inmate is removed from the hot 11 list if they're no longer a threat of 12 committing suicide? 13 : I think that's what it is. 14 : Okay. 15 : I never really looked into 16 that one. 17 : And does Epstein - I 18 mean, not does Epstein, does Psychology, are 19 they the ones that provide you the hot list? 20 : Yes. 21 : Who do they provide it 22 to? 23 : They usually come upstairs 24 and change it on their own. 25 : So they actually post it EFTA00060405  34 1 on the -- 2 : Yes. 3 : -- board themselves? 4 : Yes. 5 : Does everybody that works 6 in the SHU know what the hot list is? 7 : Yes. 8 : Do you believe -. 9 : It's part of our training. 10 : As a -. 11 : Not just the SHU training, 12 but that's like when you start working here, 13 everybody should know that that's - when 14 Psychology Department comes to see you, they 15 make you - or they tell you to be aware of the 16 hot list. 17 : Okay. That's a good 18 point. On your annual training that you take 19 at the MCC, would that hot list information be 20 provided during that training? 21 : Yes, it should. 22 : What about the training 23 that we talked about previously when we talked 24 25 : The SHU training? EFTA00060406  35 1 : Yes. 2 : That definitely is. 3 : And in the annual? 4 : Yes. 5 : So, in the annual, the 6 training that you said, you know, we talked 7 about of, they're not in the SHU training, they 8 might not have gotten it, that same information 9 would have been passed along during the annual 10 training? 11 : Yes. 12 : And that's with 13 Psychology letting people know that people -. 14 : Psychology does their part 15 on the training in their class time and they 16 should have or they should because I think 17 that's what they always do. Psychology - any 18 training, everybody takes it and you go over 19 everything pretty much from when you first 20 start -- 21 : Okay. 22 : -- on what to do as an 23 officer. 24 : So, point being, if 25 people come off of suicide watch and are placed EFTA00060407  36 1 in somewhere like the SHU, during annual 2 training, they tell everybody that takes that 3 training that they need to. 4 : Make sure you go over the 5 hot list and deal with who is on it 6 : And who was your 7 -- and if you feel somebody 8 should be on it, just pass it down to 9 Psychology. 10 : To make sure those people 11 have cellmates? 12 : Correct. 13 : Okay. And is that right, 14 if you're on the hot list, unless you have some 15 kind of requirement next to you that you can't 16 be housed with a bunkie, you're supposed to 17 housed with a cell mate? 18 : Yes, yes. 19 : Okay. And is that kind 20 of the purpose of it, to make sure that you're 21 knowing that they're not only suicidal but 22 they're also required to have a cellmate? 23 : Correct. 24 : Okay. 25 : In comparison to the OIC EFTA00060408  37 1 desk, where would that hot list be? Like if 2 you're looking at the desk right now, where -. 3 : So, if I'm sitting on the 4 desk, it should be about not even 10 feet away 5 from me on the next phone. 6 : Okay. 7 : And do the other COs that 8 worked in the SHU know that everyone on the hot 9 list was required to have a cellmate? 10 : They should. 11 : They should, okay. 12 : There's a lot of "shoulds" 13 in this building. 14 : Who replaced you in the 15 SHU on August 9, 2019? Do you remember? And 16 here's the -. 17 : It should have been Officer 18 and Officer 19 : Okay. Do you need to 20 refer to this at all or you just know that from 21 memory? 22 : I think I'm right. 23 : And I think you're right 24 as well, but I just want to make sure that -. 25 : Memory is so far so good, EFTA00060409  38 1 yes. 2 : So you're looking at the 3 daily assigned roster. 4 : Yeah, it's and 5 6 : Anyone else? 7 : No, I only saw those two. 8 : Was there also? 9 Did he replace you? 10 : So I left that 2:00. 11 : Okay. 12 : I knew was coming 13 because that's usually my relief and was 14 a 2:00 to 10:00 officer. 15 : Okay. And where did 16 fit in on this? Do you know? 17 : He was probably doing 18 just coming in. 19 : Okay. So we have a memo. 20 Is this - do you - this memo, it says it's from 21 you and it's dated August 12, 2019. Is this - 22 do you recognize that memo? 23 : No, that's me. 24 : Okay. And did you create 25 that memo? EFTA00060410  39 1 : Yes, I did. 2 : All right. Great. So 3 what it says is, it says it's to the Warden. 4 How do you pronounce the Warden's last -. 5 6 It says, "On 7 Friday, August 9, 2019 at approximately 1:50 8 p.m., I, SOS passed on to oncoming 9 staff member Officer and present shift 10 staff SOS and Officer that inmate 11 Reyes, number 85993-054, was going WAB and 12 possibly may not return. Also that inmate 13 Epstein will be needing a cellmate upon arrival 14 from his attorney visit." What does WAB mean? 15 : With all belongings. 16 : Okay. And is that 17 : That's when you leave the 18 institution. 19 : Okay. Great. And do you 20 recall actually passing that information on to 21 22 : I - , I 23 probably did speak to them, but in -. 24 : Okay. So I guess I 25 should ask, the way that I interpreted this was EFTA00060411  40 1 that you told but those other people were 2 present in the SHU. Did you have a 3 conversation then, you believe, with both 4 and 5 : I had a conversation with 6 because he relieved me at 2 o'clock. 7 : Okay. 8 : And I told him, "Make sure 9 you pass it down to - but I don't - I know I 10 spoke to because I was still town driver 11 and I saw him outside, but I don't 12 remember seeing him. 13 : Okay. What do you 14 remember - what specifically do you recall 15 saying to 16 : Like, " is going, he's 17 leaving, so make sure Epstein gets a bunkie." 18 : And what do you remember 19 specifically telling to 20 : Same thing. "Hey, you 21 know, I think is going to be gone, 22 Epstein needs a bunkie." "All right." 23 : Okay. And again, who is 24 inmate 25 . That was Epstein's bunkie. EFTA00060412  41 1 : Up until August 9th it 2 sounds like? 3 : Correct. 4 : Okay. And do you know 5 how he was selected to be Epstein's cell mate? 6 : Through, again, Psychology 7 recommends, "Oh, they're about the same age. 8 They both are pretty much have -" - not similar 9 charges, but, "This guy is an older man. This 10 guy has a cane. There's not going to be any 11 problems, we should put them in together." 12 : Are you aware of anything 13 like the Captain and the Warden and even the 14 Regional Director going through and vetting 15 Epstein's cell mates or are you unaware of 16 that? 17 : No. 18 : All right. So, you're 19 understanding was that Psychology made that 20 determination? 21 : Correct. 22 : Okay. When did you 23 become aware that inmate Efrain Reyes was 24 likely to be removed from the MCC on August 9, 25 2019? EFTA00060413  42 1 : When I walked both of them 2 to the door. 3 : And what time would that 4 have been? 5 : I would say - because R&D 6 usually starts calling people down around 9 7 o'clock, 9:00, 9:30, and that's pretty much 8 around the same time that Epstein is walking to 9 go to his legal visit. 10 : Okay. 11 : I won't - well, it's not me 12 alone with the two of them, but we walked 13 towards the door and I told him he needed - he 14 was going to get a bunkie. 15 : So were Reyes and Epstein 16 both together? 17 : Correct. 18 : And you're the one who 19 was - one of you that was escorting them? 20 : Yes. 21 : And at that point, at 22 9:00 a.m. on August 9th, you did know that 23 Reyes wasn't coming back or likely -. 24 :