EFTA00113283.pdf

1 2 APPEARANCES: OFFICE OF THE INSPECTOR GENERAL BY: BY: WITNESS: DIGITALLY RECORDED SWORN STATEMENT OF OTHER APPEARANCES: NONE OIG CASE #: 2019-010614 DEPARTMENT OF JUSTICE OFFICE OF THE INSPECTOR GENERAL AUGUST 5, 2021 RESOLUTE DOCUMENTATION SERVICES 28632 Roadside Drive, Suite 285 Agoura Hills, CA 91301 Phone: (818) 431-5800 3 4 1 : The recorder is on. My 1 name? To start, wain, I am 00]/OIC Senior 2 name is , and I am a senior 2 Special Agent . M-A-T-U-L-E- 3 special agent with the U.S. Department of 3 W-I-C-Z. 4 Justice, Office of the Inspector General, New 4 MR. : This is DOJ/OIG Special Agent 5 York Field Office, and these are my 5 D-A-N-I-E-L. And these are my 6 credentials. 6 credentials. 7 : Thank you. 7 : Thank you, sir. 8 : All right. And this 8 And can you say and spell 9 interview with Federal Bureau of Prisons 9 your name for the record, and your position 10 emplo ee - is it ? 10 title? 11 . 11 : Okay. Senior officer 12 ? 12 atcialist. First name Last name 13 : Yes. 13 IIII. C-A-L-E. 14 , is being conducted 14 That's fine. We'll ask 15 as part of an official U.S. Department of 15 you more later. And how do you spell your 16 Justice, Office of the Inspector General 16 first name? 17 (DOJ/OIG) investigation. Today's date is 17 : K-I-M-A-N-A. 18 August Sth, 2021, and the time is 2:34 p.m. 18 Okay. Thank you, sir. 19 This interview is being conducted at the 19 This is an official DOJ/OIG investigation into 20 Metropolitan Correctional Center, or the MCC, 20 the death of inmate Jeffrey Epstein, and the 21 located in New York, New York. Also present is 21 surrounding circumstances, and you are being 22 DOJ/OIG Special Agent . This 22 asked to voluntarily provide answers to our 23 interview will be recorded by me, SSA 23 questions. Will you agree to a voluntary 24 . Could everyone please identify 24 interview with the DOJ/OIG? 25 themselves for the record, and spell your last 25 : Yes. EFTA00113283  S 6 1 Thank you, sir. This is 1 been made to me, and no pressure or coercion of 2 a form that we give to our voluntary - or to 2 any kind has been used against me." So, you 3 our employees who are requested to provide 3 can take a look, if you'd like, at this form. 4 information on a voluntary basis. It says, 4 And if you agree with it and understand it, you 5 United States Department of Justice, Office of 5 can sign where it says employee signature, and 6 the Inspector General, Warnings and Assurances 6 then print your name where it says employee's 7 to Employee Requested to Provide Information on 7 name. There you go (Indiscernible *00:02:51) 8 a Voluntary Basis. "You are being asked to 8 if you'd like. 9 provide information as part of an investigation 9 : Okay. Okay. You said sign my 10 being conducted by the Office of the Inspector 10 name ri ht here? 11 General. This investigation is being conducted 11 : Yeah. Where it says 12 pursuant to the Inspector General Act of 1978, 12 employee signature. And then, you can just 13 as amended. This investigation pertains to job 13 print your name underneath, where it says -. 14 performance failure and security failure. This 14 Okay. 15 is a voluntary interview. Accordingly, you do 15 My full name? 16 not have to answer questions. No disciplinary 16 MR. : Yes. 17 action will be taken against you if do not 17 • Yes, please. Thank you, 18 choose to answer our questions. Any statements 18 sir. Okay. And I am signing where it says 19 you furnish may be used as evidence in any 19 signature of Office of the Inspector General 20 future criminal proceedings, or agency 20 Special Agent, and I am rintin my name below. 21 disciplinary proceedings, or both." And 21 Again, this is . The date is 22 there's a waiver section. It says, "I 22 8/S/21, and the time is -- 23 understand the Warnings and Assurances stated 23 MR. : 2:38. 24 above and I am willing to make a statement and 24 25 answer questions. No promises or threats have 25 MR. : 38. 7 8 1 -- :38 p.m. Place, at 1 Newark, New Jersey. 2 MCC, New York. Special Agent , can you 2 : Okay. And what is your 3 please siiiiiiithe witness? 3 date of birth? 4 MR. : This is Agent , signing 4 8 30/1975. 5 as the witness. 5 : And what is your SSN? 6 Did you understand that 6 : The last four or the whole 7 form? 7 thing? 8 : Yes. 8 The last four is fine. 9 : Okay. You understand 9 10 this is voluntary. You can choose to leave at 10 P And what is your current 11 any time. Thank you. Before star." I'd 11 cell hone number? 12 like to place you under oath. , could 12 13 you please raise your right hand? Do you swear 13 And what is your highest 14 to tell the truth and nothing but the truth 14 level of education? 15 durin this interview? 15 Hi h school. 16 : Yes. 16 : High school. And where 17 Thank you, sir. Please 17 did you o to high school? 18 let me know if you don't understand any 18 : Malcom X Shabazz. Newark, New 19 questions. I will repeat it or try to rephrase 19 Jersei 20 it. Okay? is our current home address? 20 : And when did you graduate • 21 21 high school? 22 (Phonetic Sp. *00:04:26 22 1993. 23 Zip code is 23 : Thank you, sir. And what 24 Thank you, sir. And 24 did yiiiiiiiiior to working for the BOP? 25 that's in Newark? 25 : I used to work for private EFTA00113284  9 10 1 corrections, CCA. Corrections Corporation of 1 : I'm a senior officer 2 America. 2 specialist. 3 . Okay. Great. Now, do 3 And what does that 4 military service? 4 position entail? 5 . No, sir. 5 : It just means that, you know, 6 And how long have you 6 I've worked every post, and I've been on -. 7 served with the Federal Bureau of Prisons? 7 Worked about every post, and I'm a little bit 8 February will be 20 years. 8 more trained than the people that's now getting 9 : Okay. Great. Do you 9 hired. 10 remember our entry on duty date? 10 Okay. So, and it's in 11 12 13 I=I February 10th of 2002. : Thank you, sir. And do 12 you recall when you graduated from BOP 11 13 the custody side of the house? : Yes. Okay. Great. What is 14 trainin around, like, the - even the year? 14 your iiiiiiiivel? 15 : I can't. I don't remember. 15 : My grade level is eight, step 16 Would it have been right 16 ten. 17 away, in 2002? 17 : Great. Thank you. And 18 : No. It was a little later. 18 are you familiar with Jeffrey Epstein? 19 : But you've attended it? 19 Yes. 20 Yes. 20 : Was he housed within the 21 : And that is correctional 21 MCC in Jul and August of 2019? 22 officer training down at FLETC? 22 : I believe so, but I'm not too 23 Yes. 23 sure. Because E stein wasn't a big deal to me. 24 : Okay. Great. And what 24 : Okay. And what do you 25 is your current position with the BOP? 25 mean by that? 11 12 1 : Meaning that, he's just - he 1 Yes. 2 was somebody that was being processed through 2 -- as well? Perfect. And 3 the federal government for committing a crime. 3 they're the same duties and responsibilities 4 : Okay. What about after 4 that you just described? Basically, like, a 5 the fact, that knowing, you know, how much news 5 very knowled eable correctional officer? 6 attention and everything that had been placed 6 : Yes. Yes. About that. Yeah. 7 upon it, did you think it became a little bit 7 Okay. Did you have any 8 bigger of a deal then? 8 interactions or involvement with Epstein during 9 : I guess it was a big deal of 9 his stay at MCC? 10 how, you know, the job was treating them. You 10 No. 11 know? Meaning that, you know, he was a high- 11 No. Did you even 12 profile inmate, he shad - you know - he shad 12 communicate with him at all? 13 been on Ten South, or he shad been on suicide 13 No. 14 watch. 14 : Did you see him at all? 15 : Okay. And you're saying 15 : I seen him once. I think he 16 that based upon the fact that he killed 16 was down on suicide watch. One time. 17 himself? 17 : Okay. And were you 18 : Yes. 18 workiiiiiiiiiicide watch? 19 : Okay. And we can get 19 No. I think I was activities, 20 into that more later. What was your position 20 maybe. So, I had to go through, sign the 21 at the MCC in July and August of 2019? 21 logbook, maybe. I don't -. I can't remember 22 : If I remember correctly, I was 22 what post, or what post I was on, or maybe I 23 internal number two. 23 was internal. You know, and, you know, we have 24 : Okay. I'm sorry. Were 24 a shortage of staff. So, I wear many different 25 you a senior officer specialist -- 25 titles during the day. EFTA00113285  13 14 1 : Sure. 1 the dail 2 : So, I can't really tell you how 2 : I was -. 3 I saw him that particular day, but I know I did 3 • -- receipt, and I'll try 4 see him. 4 to -. Here you go, and here is the daily 5 : Okay. So, when he was on 5 assignment roster for both Friday, August 9th, 6 suicide watch, you remember, you know, you have 6 2019, and Saturday, August 10th, 2019. I have 7 acted as the activities lieutenant, though, in 7 taken the liberty of just highlighting your 8 the past? 8 name next -- 9 : Yes. 9 Okay. 10 : Okay. Great. 10 -- position title. 11 : But that day, I can't remember 11 : Control one. And internal 12 what 12 number two. 13 : Sure. Do you happen to 13 So, on August 9th, you 14 remember if you worked at the MCC on August 9th 14 were control number one, and then, August -. 15 and 10th of 2019? The day leading up to and the 15 : No, now, which one is the day 16 day he was - the day of - finding him in his 16 of? 17 cell? 17 And so, we got the day 18 : Yeah. I believe so. The day 18 leadin' to it will be the 9th. 19 of? I was certainly here. The day before? I 19 • Okay. 20 can't remember. 20 And that's where it says 21 : Okay. Great. Do you 21 that 22 know what you were doing that day? And I have a 22 Control one. Yes. 23 duty a ent - I have a -- 23 -- you were control one. 24 : Uh-huh. 24 Okay. And that says that you were control one 25 : I'm going to give you 25 from 4:00 p.m. until midnight? 15 16 1 : Yes. 1 the eves and the ears for the lieutenant. 2 : Okay. Great. And then, 2 Okay. 3 the following day, it says Saturday, August 3 : We reviewed the camera, and we 4 10th, 2019. You were internal number two, on 4 watched the cameras a little bit. We popped 5 overtime, from midnight through 8:00 a.m.? 5 doors. We answered phones. If anybody is 6 : Yes. 6 calling, asking about their loved ones that are 7 : Perfect. Thank you, sir. 7 incarcerated here. 8 And I'm just going to keep this here, in case 8 So, you're in the control 9 we ask ou about anything -- 9 center, correct? 10 : Okay. 10 Yes. 11 : -- with regard to, you 11 : Are you one of two 12 know, either you or other people that were 12 officers in the control center? 13 working on that, on that day. So, as - let's 13 Yes. 14 do it one at a time - as August 9th, 2019, you 14 : All right. So, what is 15 state that you were control number one. What 15 the difference between what the control number 16 did those duties and responsibilities entail? 16 one officer does, and the control number two 17 : Okay. For control number one? 17 officer does? 18 : Control number one. 18 : Okay. Control number one 19 Correct. 19 officer. Control number one officer actually, 20 : The duties entail -. 20 you know, popped the doors, do all the 21 : And specifically, we're 21 paperwork. 22 talking about for that shift, for the 4:00 to 22 : Okay. So, when you say 23 midniiiiiiiiit. 23 paperwork, like, if they're counts, you fill 24 : Okay. 4:00 p.m. to midnight 24 out tiiiiiiiiwork? 25 shift. Duties entail of just, you know, being 25 : Not the counts. That's the CNA EFTA00113286  17 18 1 officer, or the internal unit two officer. The 1 actually would be the person that's supposed to 2 control officer, the control officers handles 2 be doin the counts? 3 the door, the popping of the doors, listening 3 : Yes. 4 to the radios. 4 : All right. And what 5 Answer it. Okay. And 5 about for, on Saturday, August 10th, 2019, for 6 so, and who actually is supposed to take care 6 internal number two, from midnight through 8:00 7 of the counts, then, during that time? 7 a.m. What were your duties and 8 The counts are CNA. Or 8 responsibilities? 9 now/internal two. 9 : Yes. That was me, internal 10 Okay. And what does CNA 10 number two. My duties was to generate the 11 stand for? 11 count. Generate the PPE1. Make any moves, if 12 : CNA is - what is that - Counts. 12 any inmates move from one unit to the next 13 Oh, it's been a long time since I had to, like, 13 unit. Answer the hones. 14 pronounce the abbreviation for CNA. But CNA is 14 : So, when you say inmates 15 15 move from one unit to the next unit, do you 16 Is that somebody that's 16 mean, like keying them into different -- 17 listed on this sheet? 17 : Yes. Keying them into -- 18 : -- internal number two. 18 -- so, keying them out of 19 : Oh, so, CNA is internal 19 one, and ke ing -- 20 number two? 20 -- key them out of a -- 21 Yes. 21 -- into the other. 22 : Okay. So, in this case, 22 -- out of a housing unit, and 23 it's 23 movin them to the next. 24 : Yes. 24 : Okay. So, not the actual 25 : All right. So, he 25 physical movement -- 19 20 1 Yes. 1 Yes. 2 -- you're talking about 2 -- housing unit? Okay. 3 electronically. 3 So, that's what you were doing in that specific 4 Electronical. 4 date? 5 : Okay. In the BOP 5 Yes. 6 databases. 6 : Or is that always the 7 Yes. 7 internal number two goes and counts Nine North? 8 : Perfect. So -. 8 : Yeah. That's how they have 9 : And also, my duties are to 9 internal number two set up for their post. 10 actually go upstairs and do the count. To help 10 So, always counting the 11 out internal with the count. 11 same housing units, every -- 12 : Okay. So, not only are 12 : Yeah. 13 you taking the count and filling out the 13 -- every shift? 14 paperwork, but you're actually physically going 14 : Basically, we help out 15 somewhere? 15 internal. If you was working as the internal 16 Yes. 16 officer, and you needed my help to, you know, 17 : And where are you going 17 because Jou know that I'm supposed to help you. 18 to? 18 Okay. 19 : I have to go - at that time - I 19 : You would say, hey, IIII, I 20 had to count Nine North, and unit two. 20 need you to count nine and two, or just say, I 21 Okay. And then, so, I 21 need you to count both sides of 11. 22 know Nine South. What is Nine North? 22 Gotcha. Okay. 23 Nine North is a housing unit. 23 I'm - 24 : Okay. So, just a normal, 24 So, you're basically the 25 regular general pop housing -- 25 EFTA00113287  21 22 1 Yeah. 1 : During your shift. 2 -- control number - I 2 : Yes. 3 mean, is it control number one, that we're 3 : And then, you're saying 4 talking about? 4 that on Saturday, August 10th, 2019, when you 5 Control number two. 5 were internal number two, that's when you would 6 Control number one is 6 have left your shift, and helped with the 7 kind of, like, in charge -- 7 counts? 8 : Yeah. 8 : Yes. 9 -- and then, control 9 : Okay. But as their 10 number two -- 10 internal number two, you were actually taking 11 : Control number one -- 11 the counts and writing in the documentation? 12 -- is the assistant. 12 : I'm taking count, and also, I'm 13 -- do not leave control. 13 going upstairs to actually physically do the 14 : Control number one stays 14 count. 15 in there the whole time? 15 : Okay. 16 Yes. 16 : In two houses. 17 : Okay. Control number two 17 : All right. But as 18 actually is the one that -. Okay. So, the 18 control number one, the day before, you weren't 19 person who is control number -. Control number 19 actually supposed to be involved with the 20 one doesn't leave? 20 counts? 21 Yes. 21 : No. The only thing I do is sit 22 : All right. So, you 22 there. Once you complete the count and you 23 wouldn't have left then on Friday, August 9th. 23 tell me, and we have a good verbal, I announce 24 You would have been in there the whole time? 24 it on the radio, I log it in the logbook, and 25 : Yeah. 25 then, you say, clear count. I announce it on 23 24 1 the radio. Write it in the logbook. Clear 1 : Ithink he went home at 10:00. 2 count. 2 : At 10:00? 3 : Okay. And on these dates 3 : And I -- 4 - and I'm sorry to pop back and forth - but on 4 : So then -. 5 Friday, August 9th, 2019, when you were control 5 -- probably was in there by 6 number one, who would you be primarily be 6 myself for a few, but I can't remember. I 7 workin iat i? 7 can't remember. 8 : At that time, shortage of 8 No, that makes a lot of 9 staff, ou could have any -. 9 sense. We're going to go over the actual 10 : I mean, on this specific 10 counts because you actually took the count at 11 11 10:00 '.m. 12 No. 12 : Okay. 13 -- date. 13 : So, that makes sense. 14 : You have a different partner 14 So, was he supposed to go home, or he had to go 15 almost every lain this specific be 15 home -? 16 working with , if he was in - 16 Yes. He's supposed to go home. 17 if he was internal number two. 17 : Okay. So, at the 10:00 18 : Okay. So, the two of you 18 p.m. count, then, as control number one, you 19 would be working together? 19 actuaiiiiiiii it -? 20 : Yeah. But I really don't think 20 : Yeah. Like, when you're in 21 I was with that day. I think it was 21 there by yourself, and there's a shortage of 22 Marrugo, and then, he went home, because 22 staff you of to lay both roles. 23 Marrugo goes home at 10:00. Because I was 23 : Okay. At 10:00 p.m., 24 workin with Marru o, and then he went home. 24 though, was there supposed to be two people in 25 : When did he go home? 25 there? EFTA00113288  25 26 1 : Yeah. Until 10:00 p.m. 1 time control goes in. At this time, when he 2 : So, that's what I mean. 2 was on eights, when he was on eights, every 3 So, like, at the 10:00 p.m., are you -. Only 3 shift was 8:00 to 12:00, 12:00 -. My fault. 4 until 10:00 p.m. So, but at 10:00 p.m., the 4 8:00 to 4:00, 4:00 to 12:00, and then, 12:00 to 5 count happens after the person - control number 5 8:00. When CNA comes in for evening watch, 6 two - leaves. Right? 6 evening watch is 4:00 to 12:00. 4:00 to 12:00. 7 : Yes. So, control number two is 7 When evening watch comes in, control one comes 8 supposed to print up everything, and since he's 8 in, control two comes in. Now, somebody, you 9 off duty at 10:00, I will take the paperwork 9 know, had a big idea and said, hey, you need 10 that he enerated and do the count for him. 10 to, you know, we need to stop generating money. 11 : Okay. So, control number 11 We need to modify the hours. So, we don't need 12 one is actually responsible for the 10:00 p.m. 12 two people in control. So, they modified the 13 count. Correct? 13 hours, and made control number two. 14 : Control number one is not 14 Yeah. 15 responsible for the count. But if - I mean, if 15 : From that time. 16 you are in there by yourself, now that's your 16 : Right. So, at this 17 second 'ob. 17 18 : Okay. So, who is 18 : So, I think this is, what, 2:00 E- 19 responsible for it, then? 19 20 : Whoever is supposed to be 20 So -- 21 posted CNA. So, I'm -. Okay. It's two 21 : -- 2:00 to 10:00 22 different. Like, see here, we have a lot of 22 -- 2:00 to 10:00 -- 23 job titles that kind of, like, they took from 23 : - now? 24 us. CNA is supposed to be a post. CNA is 24 -- Correct. So, that's 25 supposed to be a post that goes in at whatever 25 where I'm saying, it's, like, if they're 27 28 1 leavin at 10:00 -- 1 No. 2 : Yes. 2 -- it would have just 3 -- and the count is being' 3 been you? Okay. All right. Because I was 4 conducted at 10:00, and they usually get, you 4 getting confused. All right. And then, as far 5 know, they leave usually a couple minutes 5 as on August 10th, 2019, as internal number 6 before, too. It sounds like, at this time, on 6 two, you would have also taken the count. 7 August 9th -- 7 Correct? 8 : Now, I -- 8 Yes. 9 : -- you would have been 9 : The 12:00 a.m., 3:00 10 the one -- 10 a.m., and 5:00 a.m.? 11 : -- took the count. 11 : Yes. If they filled that post, 12 : -- who took the count. 12 like, my name is there, so, they filled that 13 : Yes. 13 post with overtime. So, that was me. 14 : So, that's where I just 14 Okay. 15 want to make sure we're not getting -. Because 15 : So, I did that post. I worked 16 I'm getting confused with all this. 16 that post. I generated the El. I went 17 : Yeah. 17 upstairs, conducted the count on the two 18 : So, on August 9th, 2019, 18 housing units that I have to count, and then, I 19 as control number one, you would have taken the 19 would go back downstairs, and finish the count 20 count? 20 on my El, meaning the cross, as units call me 21 : Yes. If my name is on that 21 up, saying, hey, this is EN with the count of 22 form, I took the count. 22 14, and I would say, good count, bad count, and 23 : Right. And no one else 23 then, cross it off the on paperwork. 24 would have been in there with you to take that 24 : Okay. And then, we 25 count -- 25 talked about who you worked with on August 9th. EFTA00113289  29 30 1 You said that, although this says Marrugo, you 1 -- with him. But you're 2 think it's somebody else? 2 also takin the counts? 3 : I think it's somebody else. I 3 • Yes. 4 can't remember. 4 : Okay. Thank you. And 5 : Sure. 5 who did you report to on these days? Are you 6 : And then -- 6 always re rting to the Ops Lieutenant? 7 : It's been a while. 7 : Yes. 8 -- on August 10th, 2019, 8 : Okay. So then, so on 9 it says you were internal two, internal one was 9 Au ust 9th ou would have been reporting to 10 - does that say Dupre? 10 , I think, both times, because 11 : Yeah. He don't come in -. Oh, 11 Cannata, although he's listed, he was relieved 12 well. He's internal. So, that's the person 12 at 10:00 p.m. back then. They were working two 13 that I'm hel in to conduct the count with. 13 hours before the start of their shift. So, 14 : Okay. So, he is doing 14 started at 10:00 .m. So you 15 all -- 15 would have been reporting to 16 He's -. 16 then, for both shifts? 17 -- he's actually 17 : Yes. 18 physicall oing to the different units? 18 : Okay. 19 : Yes. 19 : Yeah. I don't - you know - I 20 Collecting count slips, 20 don't recall (Indiscernible *00:21:20). The 21 and thins like that. 21 only thing I could try to recall was what I was 22 Yes. 22 doing because that's all I could do. 23 : And you're assisting, you 23 : Well, per these 24 said -- 24 documents, at least, it shows 25 Yes. 25 would have -- 31 32 1 Yeah. It shows her name. 1 Andrews Plaza, New York, New York. Present for 2 -- been the person you're 2 the interview were FBI Special Agent 3 reporting to. Okay. Were you previously 3 FBI Task Force Officer, TFO 4 interviewed under this investigation? 4 Office of the Inspector General Special 5 : Yes. You know, the first time. 5 Agent , and Assistant United States 6 Yeah. 6 Attorney AUSA MI advised 7 Were you interviewed more 7 that the interview was in lieu of an appearance 8 than once? 8 before the federal rand jury, and is 9 No. lust once. 9 voluntary. SA provided with an OIG 10 : Okay. I'm going to just 10 Warnings and Assurances to Employee Requested 11 review the report that was written in regard to 11 to Provide Information on a Voluntary Basis 12 that interview. I just want you to - I'm not 12 form, which IIII signed, and was witnessed by 13 going to provide it to you because it's written 13 SA's and Moore. SA retained the 14 on an FBI document - but however, the OIG was 14 original, and a copy is attached in the 1A 15 present. So, it's our information to have. 15 section of this report. After being advised of 16 So, I'll read it to you. And just, if you can 16 the identity of the interviewing investigators, 17 just stop me if there is anything in there that 17 and the nature of the interview, MI provided 18 is not accurate. 18 the following information. I. worked for 19 Okay. 19 Corrections Corporation of America from 20 : Okay? So, it says that, 20 approximately 2000 until 2002, when he started 21 , Senior Officer Specialist at the 21 workin for the BOP at MCC. On August 10th, 22 Bureau of Prisons, Metropolitan Correctional 22 2019, was assigned internal two on the 23 Center," and it says, yada, yada, yada. "Was 23 morning watch, which is 12:00 a.m. to 8:00 a.m. 24 interviewed at the United States Attorney's 24 This post helps with the count, getting 25 Office, Southern District of New York, 1 St. 25 paperwork and rosters ready for the count, and EFTA00113290  33 34 1 sometimes helps conduct the count of some of 1 : Yes. 2 the units. Units Nine South and Ten do not 2 : Does that sound accurate. 3 require help for the count because there are 3 : Yeah. It sounds accurate. 4 officers stationed in those units that do the 4 : All right. Because the 5 counts. Duringthe morning watch shift of 5 person said -. I thought she said that 6 August 10th, prepared the coatJa getting 6 she wasn't taking the calls. 7 the paperwork together. Officer IIIIII, as the 7 : Okay. 8 control officer, took officer's phone calls, 8 MR. : She wasn't taking the calls? 9 receiving the verbal count for the 12:00 a.m., 9 : Oh, yeah. 10 3:00 a.m., and 5:00 a.m. counts. When an 10 : So -. 11 officer calls into control with the count for a 11 : We help each other. 12 particular unit, control advises if the number 12 : Okay. 13 was a good count or a bad count. Control has 13 : Mm-hmm. You know, we help each 14 many different functions. So, when an officer 14 other. So, if I'm upstairs doing a count, and 15 calls in a count, control takes the officer's 15 it takes me a little longer to come downstairs, 16 word that the count was conducted. didn't 16 she will ick u the phone and take the counts. 17 think that control received the verbal count 17 Okay. 18 from the Special Housing Unit for that shift. 18 : Now, if I go upstairs, and the 19 However, he could not say for sure because he 19 counts, you know, it's a little faster, I will 20 wasn't the one taking the calls for the counts. 20 come downstairs and I will take over the 21 was assistin in doing the counts in the 21 paperwork, just, like, you pass me your 22 other units. signed off on the counts 22 paperwork, I will let you do what you do -. 23 because during that shift, he was the senior 23 Let you finish doing your task, and I will take 24 ranking officer. On the morning of August 24 it ri ht back over where you left off. 25 10th, 2019 -." Is that all correct? 25 : Okay. 35 36 1 : And I will -- 1 an I gotcha moment, this is just - I just want 2 : Because, yeah -- 2 to make sure I understand, because your 3 -- (Indiscernible *00:25:11). 3 responsibility on August 10th was actually to 4 I think her 4 take the calls, and take the verbal -- 5 explanation was, she helped with, like, you 5 : Yes. 6 know, everything else, you were involved with 6 : -- counts. Correct? 7 the counts, taking the counts on the phone, and 7 : Yes. 8 8 : Okay. Great. "On the 9 Yeah. 9 morning of August 10th, 2019, a bod alarm went 10 -- and writing the 10 off at approximately 6:33 a.m. responded 11 counts. Is that accurate, actually? 11 to the SHU where the body alarm had sounded, 12 Yes. That's accurate. 12 along with another officer. The Nine South 13 : So, this actually is 13 officers, medical, and Lieutenant IIII were 14 inaccurate the way it says that she took all 14 already at the location. With medical 15 the counts and the phone calls, then? 15 performing CPR. went to get a stretcher 16 : I mean, I can't really remember 16 and assisted in taking Jeffrey Epstein to the 17 17 medical unit. When emergency medical surveys 18 19 20 ... Okay. 18 what actually happened, but 19 like I said, we try to help each other out -- 20 arrived, they started performing CPR, took Epstein out to an ambulance, and transported him to the hospital. followed the 21 • Sure. 21 ambulance to the hospital in another secure 22 because we all have -- 22 vehicle. IIII stayed at the hospital until he 23 • But as your -- 23 was relieved from duty." 24 many different jobs. 24 : Yes. 25 . -- and this isn't, like, 25 Okay. "IIII doesn't EFTA00113291  37 38 1 recall any specific state that Epstein was in 1 Did you see his eyes 2 when he responded to the scene. did 2 open? 3 recall that Epstein was still loose, because 3 : -- honestly, I cannot really 4 Epstein had to be put in restraints before he 4 tell you what he looks like. 5 could be transported. However, there was no 5 Okay. 6 movement by Epstein on his own." So, was 6 : Because it's been so long ago. 7 Epstein still alive? 7 And the only thing I know, they was performing 8 : Their policy states that nobody 8 CPR. I ran to go get the gurney. Because if 9 passed away inside the institution. Like I 9 you're performing CPR, he's definitely going to 10 said, when I responded, when I got to the post, 10 have to o down to medical. 11 in Nine South, he was already doing, performing 11 : Okay. So, you can't 12 CPR, from medical staff and Nine South staff. 12 recall - even though this was a big incident, 13 : Okay. 13 and pretty traumatic - you can't recall if his 14 : They was already performing 14 eyes were open, or if he was breathing, or 15 CPR. So, since they was performing CPR, 15 anythin like that? 16 someone needs to go get that gurney so they can 16 I can't recall. 17 carry him down to medical. So -- 17 : Okay. "I'll acknowledged 18 : And I understand -- 18 that he wrote a memo about the incident. This 19 : -- (Indiscernible *00:27:13). 19 was due to the fact that when one responds to a 20 : -- that you're not able 20 body alarm, it has to be documented. did 21 to say if he was officially alive or dead, but 21 not recall any interactions with Epstein prior 22 was he showing any signs of life? 22 to Epstein's death." And that's the end of 23 : I don't know. Once I see 23 that. 24 somebody performing CPR, that means something 24 Okay. 25 bad is going on. So -- 25 : Does all that seem 39 40 1 accurate? 1 the SHU, 77, and R&D is zero. And this one, 2 Yes. 2 it's 8/9/2019. This one looks like it was for 3 : Okay. I'm not going to 3 the 4:00 p.m. count. RA says zero. All right. 4 attach that. All right. So, we are going to 4 So, R&D was zero. It says the SHU was 76. One 5 go over the count sheets that were done. Oh, 5 in attorney conference. And one in -. Or I'm 6 shoot. All right. So, these are just the 6 sorry. 75 that were actually physically 7 count sheets for the (Indiscernible *00:28:43). 7 present in the SHU. Correct? 8 This one is -. I'm going to move this over 8 : Mm-hmm. 9 here. So, this one wasn't you. I'm just 9 : All right. And then, 10 showing you, kind of, where I have highlighted 10 we're going to go back, and now we'll start 11 just the time, and then, I have, you know, what 11 looking at these count slips, just so we can 12 we're particularly interested in, are going to 12 kind of get an idea. All right. On the second 13 be RA and ZA. 13 to last page, there's a ZA, it shows 75. I 14 Okay. 14 just highlighted that. That was on 8/9/19, 15 : ZA stands for the SHU. 15 time 4:00. It says Noel and signed for 16 Correct? 16 them. Correct? 17 Yes. Nine South. 17 : Okay. 18 : The Special Housing Unit. 18 : And then, attorney. It 19 And RA stands for R&D. Correct? 19 actually says three. A total of three, because 20 Yes. 20 they were from other units. All right. So, 21 : All right. Great. So, 21 and one of them being from the SHU. Correct? 22 here is the one for 8/9/2019. It looks like 22 : Yes. 23 this was the 5:00 a.m. count. Correct? 23 : All right. So, we've got 24 Yes. 24 the 75 on that, 75 there. All right. Now, we 25 : All right. It shows in 25 get to where you come in. So, this is the EFTA00113292  41 42 1 10:00 o.m. count. Correct? 1 here, we have an NS+1. And then, here, for ZA, 2 Yes. 2 we got a 73+1 8:00, 9:00, 10:00 p.m., it looks 3 : So, on 8/9/2019, this was 3 like a and a Noel. Correct? 4 printed out at 9:33 p.m. According to this, RA 4 Yes. 5 - or R&D - both show zero. 5 : Would you be the ones 6 Yes. 6 that was crossing off all of these count slips? 7 : ZA - which is the SHU 7 Yes. 8 shows 73 on both columns. Correct? 8 : Do you know why these 9 Yes. 9 were not crossed off?