EFTA00112221.pdf

1 DIGITALLY RECORDED SWORN STATEMENT OF OIG CASE #: 2019-010614 DEPARTMENT OF JUSTICE OFFICE OF THE INSPECTOR GENERAL JULY 15, 2021 RESOLUTE DOCUMENTATION SERVICES 28632 Roadside Drive, Suite 285 Agoura Hills, CA 91301 Phone: (818) 431-5800 EFTA00112221  2 APPEARANCES: OFFICE OF THE INSPECTOR GENERAL BY: BY: WITNESS: OTHER APPEARANCES: NONE EFTA00112222  3 1 MR. : This is Special Agent 2 Today is Thursday, July 15, 3 2021. The time is 2:15 p.m. My name is 4 . I'm a Special Agent with the U.S. 5 Department of Justice Office of the Inspector 6 General New York Field Office. And these are 7 my credentials. This interview is with Federal 8 Bureau of Prisons 9 MR. : Hmph. 10 MR. : And it is being conducted 11 as part of an official U.S. Department of 12 Justice Office of the Inspector General 13 investigation. Today is July 15, 2021. The 14 time is 2:16 p.m. The interview is being 15 conducted at Metropolitan Correctional Center 16 located at 150 Park Row. We are in the 17 executive assistant's office. Also present is 18 DOJ OIG Senior Special Agent 19 And the - also this interview will be recorded 20 by me, Special Agent . Could 21 everyone please identify themselves for the 22 record and spell your last name. To start, 23 again I am Special Agent 24 • 25 : My name is Senior Special EFTA00112223  4 1 Agent 2 And these are my credentials. Okay. 3 MR. can you, if 4 you can, state your first and last name and 5 spell them both for the record. 6 MR. : My first name is 7 And the last name is 8 . And my title is electronics 9 technician. 10 MR. : So it's without III 11 I. 12 MR. : Without 13 MR. : Okay. I apologize for 14 that. This is an official DOJ OIG 15 investigation into the death of Inmate Jeffrey 16 Epstein and the surrounding circumstances. You 17 are being asked to voluntarily provide answers 18 to our questions. Will you agree to a 19 voluntary interview? 20 MR. : Yes. 21 MR. : Please review DOJ OIG Form 22 3-26226-2. The form states, U.S. Department of 23 Justice Office of the Inspector General 24 Warnings and Assurances to Employee Requested 25 to Provide Information on a Voluntary Basis. EFTA00112224  5 1 You are being asked to provide information as 2 part of an investigation being conducted by the 3 Office of the Inspector General. This 4 investigation is being conducted pursuant to 5 the Inspector General Act of 1978 as amended. 6 This investigation pertains to job performance 7 failure and security failure. I'm writing that 8 in here. 9 : And that doesn't' mean 10 your job performance failure. That means 11 that's what the investigation is involving. 12 MR. : This is a voluntary 13 interview. Accordingly, you do not have to 14 answer any questions. No disciplinary action 15 will be taken against you if you choose not to 16 answer any questions. Any statement you 17 furnish may be used as evidence in any future 18 criminal proceedings or agency disciplinary 19 proceedings or both. The waiver states I 20 understand the warnings and assurances stated 21 above and I am willing to make a statement and 22 answer questions. No promises or threats have 23 been made to me. And no pressure or coercion 24 of any kind has been used against me. Please 25 review the form. And if you understand it, EFTA00112225  6 1 please sign where it says employee signature. 2 And print your name below it. Do you 3 understand the form? 4 MR. : Yes. I understand the 5 form. 6 MR. : Okay. Mr. is 7 signing the form. All right. Special Agent 8 is signing under line for signature of 9 the Office of Inspector General Special Agent. 10 : And I'm Senior Special 11 Agent and I am signing as a 12 signature of witness and I will write the date 13 as July 15, 2021, and the time is 2:19 p.m. at 14 the MCC New York. 15 MR. : Before starting the 16 interview I would like to place you under oath. 17 Mr. can you please raise your right 18 hand? Do you swear to tell the truth and 19 nothing but the truth during this interview? 20 MR. : Yes. 21 MR. : During the interview if 22 you don't understand any of the questions I 23 ask, please ask me. Please let me know. I'll 24 rephrase it or I'll try to repeat it for you. 25 MR. : Okay. EFTA00112226  7 1 MR. : I want to clarify. This 2 interview is specifically regarding Inmate 3 Jeffrey Epstein on August 9th and 10th and the 4 circumstances that surround it. What is your 5 current home address? 6 MR. 7 8 MR. : What's your date of birth? 9 MR. 10 11 MR. : Your Social Security 12 number? 13 MR. : Uh 14 MR. : What is your current cell 15 phone number? 16 MR. : Uh 17 MR. : What is the highest level 18 of education. 19 MR. : Uh some college. 20 MR. : What college? 21 MR. : Community college. Like a 22 first year. 23 MR. : Do you know the name of 24 the college? 25 MR. EFTA00112227  8 1 2 MR. : Okay. Is that in .my 3 City? 4 MR. : Yes. 5 MR. And was there a specific 6 major you were -? 7 MR. : Electrical engineer. 8 MR. : Okay. What did you do 9 prior to working for the BOP? 10 MR. : I worked at TSA. I was a 11 transportation security officer. 12 MR. : Okay. And do you have any 13 military service? 14 MR. : Yes. Four years. Active 15 duty from 2000 to 20014. United States Marine 16 Corps. I was a 2846 Regular Repairman. 17 MR. : And was it an honorable 18 discharge? 19 MR. : Yes. 20 MR. : How long have you served 21 with the Federal Bureau of Prisons? 22 MR. : Uh since March 24, 2013 to 23 present. 24 MR. : March 24, 2013. And you 25 were working at TSA directly before this? EFTA00112228  9 1 MR. : Yes. 2 MR. : All right. What was your 3 Enter on Duty Date? 4 MR. : To here is March 24, 2013 5 I believe. 6 MR. : When did you graduate from 7 BOP training? 8 MR. : I don't know. That was 9 probably I don't know. Probably the following 10 March. So maybe March of 2014. 11 MR. : Okay. And were you with 12 the MCC the whole time? 13 MR. : Uh no. I started off in 14 Brooklyn as a correctional officer 2013 to 15 2015. And in 2015 to about 2017, I went to 16 Terre Haute. And that's when I became an 17 electronics technician. 18 MR. : Where did you go? 19 MR. : Uh Terre Haute, Indiana. 20 So Federal complex. 21 MR. : Okay. 22 MR. : Another prison. And 23 that's where I became an electronics technician 24 and I stayed there for about a year and a half. 25 Then I moved back to New York City. EFTA00112229  10 1 MR. : Did you come back to the 2 MCC? 3 MR. : MCC New York as an 4 electronics technician. 5 MR. : What year did you come 6 back to the MCC? 7 MR. : I believe four or five 8 years ago, so 2016 around that time - 2017. 9 MR. : Okay. 10 MR. : I'm not too sure of the 11 dates. 12 MR. : And you've been here at 13 the MCC since then? 14 MR. : Yes. I've been here since 15 then. 16 MR. : And what was your - what's 17 your current position? 18 MR. : Electronics technician. 19 MR. : Okay. And what shift were 20 you on? 21 MR. : Uh. 22 MR. : Normally. What's your 23 normal? 24 MR. : My normal day is 6:00 to 25 2:00. EFTA00112230  11 1 MR. : 6:00 to 2:00? 2 MR. : Day watch. 3 MR. : Okay. 4 : Just before we go on. As 5 an electronics technician, when did you 6 actually become that? 7 : Um of 2015 - in March of 8 2015. 9 : And does that not involve 10 like specialized training? 11 MR. : Uh yes. What the Bureau 12 gives you and my background because I did a - 13 before I started with the Bureau I had about 15 14 years in electronics with the military and 15 government contractor and in the private 16 sector. I did electronics for about 15 years 17 before. 18 : Okay. So what training 19 did you receive specifically in that field? 20 MR. : IN the Bureau? Or -? 21 : Just overall. 22 MR. : Oh. 23 : Since you said you only 24 did - you did college. I mean it doesn't' have 25 to be specifically. EFTA00112231  12 1 MR. : Oh. 2 : I mean just like in 3 general. 4 MR. : Well I could troubleshoot 5 certain cores at component level like a 6 starter. Use hand tools. 7 : So are you talking about 8 like on the job experience? 9 MR. : Yes. Everything's pretty 10 much on the job. And then in the Marine Corps 11 I went for training for about a year in 12 electronics. 13 : Oh. So one electronic - 14 one year with the Marine Corps and then what 15 about with the BOP? Did they provide training? 16 MR. : Um it's pretty much on the 17 job. 18 : Okay. 19 MR. : I went to one telephone 20 school and that was about it. And a fire alarm 21 training. 22 : Okay. 23 MR. : But everything is pretty 24 much on the job. 25 : Thank you. EFTA00112232  13 1 MR. : Anything else on that? 2 : Hm-mm. 3 MR. : On August 9, 2019, were 4 you working? 5 MR. : Yeah. August 9th. That's 6 the Friday or the Saturday? 7 MR. : Friday. 8 MR. : Yes. 9 MR. : And what was your position 10 on that day? 11 MR. : Electronics Technician. 12 MR. : What schedule were you on? 13 MR. : I believe 6:00 to 2:00. 14 MR. : 6:00 to 2:00 meaning 15 morning watch? 16 MR. : 6:00 a.m. to 2:00 p.m. 17 That's day watch. Or - yeah. Day watch. 18 MR. : Okay. And what does your 19 position entail? What's your daily duties? 20 MR. : I just well I make sure 21 anything in the building as far as 22 communication is working. So the first thing 23 you do is check the phones, radios, telephones, 24 radios I said, make sure the cameras are 25 recording if they're working. And what ese. EFTA00112233  14 1 Anything communication-wise. If anybody's 2 having a problem, they usually get to me. Even 3 something as simple as a voice mail. They'll 4 say he my machine isn't working and I go take a 5 look at it. And where somebody's computer is 6 not working. So. 7 MR. : And since you mentioned 8 also daily when you come on the job at 6:00 9 a.m. you check to see if the phone, cameras, 10 everything is working? 11 MR. : I don't have to check. 12 It's - there's no set standard or like okay you 13 should come in and check it. You just like 14 kind of look to see what's going on. You kind 15 of know what hasn't been working and what's 16 been working. You kind of make a checklist for 17 yourself. There's no set standard of what you 18 should do at that time. Now there is more stuff 19 that you do. Day to day. Where before there 20 was really no standard of okay you come in, you 21 start, and this is the first thing you've got 22 to go and do. And no. There was never 23 anything written down as far as what should be 24 done during your shift. 25 MR. : When did that change? EFTA00112234  15 1 MR. : After Epstein pretty much. 2 MR. : Okay. 3 MR. : Yeah. 4 MR. LARGENT: So that day when you came 5 in, do you recall - I know it's been two years. 6 Do you recall doing a checklist? Trying to see 7 if everything was working. 8 MR. : I usually - because I 9 don't get a radio in the morning. I usually - 10 first thing I do is I call for the elevator so 11 I know the phones are working. 12 MR. : Okay. 13 MR. : And then I go downstairs, 14 turn on the radio, listen to radio traffic so I 15 know the radios are working. And as far as the 16 camera goes, I have - that time I had like the 17 old system that had a (Indiscernible 18 *00:10:18). And make sure the um Because 19 it went to analog matrix. It's going to sound 20 a little confusing when I say analog matrix and 21 digital matrix because the old system we had 22 was a mixture of both. And kind of like the 23 new system too. It takes the old analog 24 cameras because we had a lot of old analog 25 cameras. It takes all of that. and then it EFTA00112235  16 1 transfer it to make it digital so you can start 2 recording. And that's how you - we'll get a 3 video and look back for video. But everything 4 was analog. So I would have the analog system 5 in my office. And I would pretty much look and 6 see if that's working. If that was working I 7 know I was pretty much good. 8 MR. : Now the analog - if - 9 before it was converted over to digital. 10 MR. : Mm-hmm. 11 MR. : How would the analog be 12 recorded? 13 MR. : Um the analog -. I wasn't 14 here -. Well it's -. It's not really - well 15 it is converted. It's used - well they use the 16 encoder to take the analog signal and make it a 17 digital signal and put it on a recorder. 18 MR. : Okay. And what was it 19 recorded on? 20 MR. : The old hard drives. It 21 was two of them - two hard drives. 22 MR. : Was it on a server or -? 23 MR. : It was pretty much like a 24 server. Yeah. It was two computers pretty 25 much. EFTA00112236  17 1 MR. : Okay. And once it was 2 recorded, do you remember checking the cameras 3 that day? Seeing if it was working? 4 MR. : I checked them later in 5 the day. I went up to the video room. Because 6 we were having - the thing about this whole 7 process was when I came here, the first thing I 8 saw was the video room. And the biggest thing 9 was all the equipment in that room was out of 10 date. It was old. It was - I came from 11 another institution. Like I said before where 12 everything kind of was modern but it was more 13 up to date than this. And so like the camera 14 system I had was maybe five to ten years old. 15 And when I came here, this one was over ten 16 years old and it was 365 a day. Like 24 hours 17 for the like the last 12 years. The system was 18 always on. And something as simple as shutting 19 down the time and change - because you got to 20 get recording times right. When the seasons 21 change, you would have to wait like a whole day 22 to shut down a recorder. It takes a whole day 23 or it to come back up after shutting it down. 24 And where I came from, that was not the 25 standard. Like it should be like an hour maybe EFTA00112237  18 1 thirty minutes. Maybe even ten minutes if it's 2 a newer system. You shouldn't even have that 3 much down time as far as it recording. So one 4 of the first things I did when I came here was 5 I addressed that - the recorders being 6 upgraded. And -. 7 MR. : Who did you address that 8 with? 9 MR. : Um my Facility Manager. I 10 talked to upper management. 11 MR. : Who? 12 MR. : But like during this whole 13 time I was doing I actually started the 14 camera project and that's why I was doing 15 overtime around this time. And we had people 16 come from other institutions. There was a 17 camera project to upgrade the cameras. 18 Everybody's fear was the actual cameras not the 19 recording software of the cameras. But I 20 stated over and over again the problem you're 21 going to have is the recorders. And we even 22 had the new recorders. They were in the 23 warehouse. We have them stockpiled. They was 24 ordered. But we were on the bottom of the list 25 as far as install. So even if we had the new EFTA00112238  19 1 equipment, we weren't a priority to get 2 anything installed. So we had to wait until 3 something happened. 4 MR. : And you said there was a - 5 you mentioned that to your Facilities Manager. 6 Who was that? 7 MR. : When I first got here it 8 was (Phonetic Sp. *00:13:22) 9 and was a facility manager. I 10 think we were in between facility managers when 11 this happened because we didn't really have 12 anybody. 13 MR. : So there was no one during 14 August 9th and 10th there was nobody? 15 MR. : I'm not too sure if my new 16 facility manager took over at that time. But I 17 don't believe he was here. I think he came 18 after. He was here visiting but I don't think 19 he took the job. 20 MR. : And you mentioned it to 21 upper management too? 22 MR. : Yeah. 23 MR. : Who in upper management 24 did you mention it to? 25 MR. : My old AW - my Associate EFTA00112239  20 1 Warden - - he's no longer - he's returned 2 from eh Bureau. 3 MR. : Who is the old AW? 4 MR. : Associate Warden 5 (Phonetic Sp. *00:13:53). That was his last 6 name. I forgot the first name. But I 7 mentioned to him and of course I talked to the 8 wardens about it. 9 MR. : Who was the warden at that 10 point? 11 MR. : Um it was . And 12 before it was (Phonetic Sp. 13 *00:14:04). Because they wanted me like to add 14 more cameras and do upgrades. And I'm like 15 well you've got to spend money because this 16 stuff is old. Like you can't just start adding 17 cameras to old systems. It's not going to 18 work. 19 MR. : And you said there was as 20 project started around that time. Before 21 Epstein's death? 22 MR. : Before Epstein's death. 23 Yeah. 24 MR. : How far before? 25 MR. : I would have to look at EFTA00112240  21 1 documents. I'm not too sure. Me and pretty 2 much - we have an engineering tech - 3 (Phonetic Sp. *00:14:25) - when we 4 started. Because we had problems with the 5 recorders before where we submitted paperwork 6 to the regional office saying hey the 7 recorder's going down. It's end of life. What 8 can we do to upgrade. What's the steps. And 9 that's why we got funded all the money that we 10 got to start the project. 11 MR. : Before Epstein's death, do 12 you recall what exactly the project entailed? 13 What were you guys upgrading? 14 MR. : Uh we were trying to go 15 from analog cameras to IP cameras and trying to 16 upgrade the recorders. The recorders were like 17 the main thing. Upgrading the recording 18 system. 19 MR. : But not the cameras 20 itself. 21 MR. : Not the cameras itself. 22 Because they can still work. And they still 23 work now. 24 MR. : Were majority of the 25 cameras working during that time? EFTA00112241  22 1 MR. : Yes. Pretty much all the 2 cameras were working. Maybe we had maybe ten 3 probably that weren't working. But for the 4 majority all of the cameras were working. They 5 weren't being recorded - that was the problem. 6 MR. : So the cameras were 7 working but it wasn't actually 8 MR. : Recording yeah. 9 MR. : -- recording into the 10 MR. : Yes. 11 MR. : Now think. I know it's 12 been two years. Do you recall which were the 13 ten cameras were that weren't working. 14 MR. : I have no idea. I would 15 have to look at that list there. 16 MR. : How about during that time 17 in the SHU. Were the cameras working? 18 MR. : Yes. The cameras in SHU 19 were working. They were recording. Well they 20 were working. They weren't recoding. But they 21 were working. 22 MR. : So what is that? Explain 23 that to me. 24 MR. : Okay. So you like - if - 25 so like I said. We had an analog system and a EFTA00112242  23 1 digital system. The old system would never 2 show me like the recorders failed. Like if 3 there was an error on the old software. Like I 4 would have to physically be in the room to say 5 hey. Because the room was upstairs on the 6 third floor. Which I didn't have access for. 7 You would have to go in the room and then you 8 go see like - because there's a redundant 9 drive. So you have like an A side and a B 10 side. And say if the A side isn't working, you 11 have one drive goes back. That's not a 12 problem. As soon as the second drive goes bad, 13 that's when you run into problems. And after 14 the second drive runs into problems, that's 15 when you stop recording. And once that 16 happens, you have to take the drive out, and we 17 have to scrounge around for old drives and see 18 if those will work. During that time I 19 actually - prior to that I actually purchased 20 maybe 24 drives to actually redo a whole - like 21 A or the B side. I was actually going to do 22 that. 23 MR. : Did you know at that point 24 that SHU cameras weren't recording? 25 MR. : At that point towards the EFTA00112243  24 1 end of the day I did. I believe I did know at 2 the end of the day. 3 MR. : On August 9th during the 4 day. 5 MR. : Yeah. And I called -- 6 MR. : It wasn't the 10th. 7 MR. (Phonetic Sp. 8 *00:16:54). That's my point of contact. I 9 usually - any time I have a problem or 10 something's not working because I wasn't really 11 familiar with the whole system. I had like a 12 newer system. It kind of worked the same, as 13 far as the software side goes, as far like as 14 like the hardware, it was different. So I 15 would always have to call them for like tech 16 support. Like okay I'm having a problem today. 17 Can you document it? You know it builds our 18 case when I have to submit stuff to Regional 19 Office. Needless to saying that doesn't work. 20 That's not going to fly. And usually they help 21 me troubleshoot through the whole process of 22 what I should have to do - A, B, C, okay take 23 this drive out, put that drive in. And like 24 previously, probably six months before that, we 25 actually had a mother board - which was my main EFTA00112244  25 1 computer - like go out. And I had to actually 2 replace that and they had to walk me through it 3 over the phone. I went to scrounge round parts 4 from another institution to get it working. I 5 know I'm giving you like a lot of stuff but -. 6 MR. : So let's step back. So 7 you said the - it wasn't working. There was 8 possibly a work order already created. Right? 9 MR. : Yes. Possibly. Yes. 10 MR. : Who approved the work 11 order? 12 MR. : Um that has to go through 13 my general foreman or facility manager. 14 Whoever's in charge. 15 MR. : Do you think - do you 16 recall if this was before Epstein's death or 17 after? 18 MR. : This was probably before 19 Epstein's death. It was a few work orders 20 before Epstein's death. 21 MR. : And if these work orders - 22 . Are these work orders still maintained? A 23 copy anywhere? 24 MR. : They should be in the 25 facilities folder somewhere. EFTA00112245  26 1 MR. : Who would have access to 2 it now? 3 MR. : Um my facility manager, 4 she'll know where they're at. And the 5 engineering tech would pretty much. Well I'm 6 not saying engineering tech. but the facility 7 manager should know if those records are kept 8 or they're maintained. 9 MR. : And when this work order 10 was created, this work order specifically 11 addressed the fact that the SHU cameras weren't 12 recording? 13 MR. : No. No. All of the 14 cameras. It's not going to just be SHU. It's 15 going to be all the cameras. 16 MR. : All the (Indiscernible 17 *00:18:28) cameras. 18 MR. : Yeah. 19 MR. : Okay. So at that point, 20 how come some cameras recorded? He said 21 there's redundancy. So there's either going to 22 -- 23 MR. (Indiscernible *00:18:34) 24 MR. -- A drive or B drive. 25 MR. : Yeah. EFTA00112246  27 1 MR. : How come some recorded on 2 -? 3 MR. : Okay. Oh there's going to 4 be another problem too. Okay. So there's an A 5 side and a B side. And it's supposed to be 6 redundant but it's not redundant because it's 7 not really redundant when one side goes bad so 8 it just knows to record channels. Let's say 9 one through fifty is on this side. And 51 10 through 100 is on this side. Everything is 11 working. It doesn't work. Okay. I can take 12 over for this one because it's not working. 13 But as soon as that one goes, I can kind of 14 record over here. As soon as the second drive 15 goes, I have to just record what I'm recording. 16 I can't no longer help out the other drives. 17 MR. : Okay. So some channels 18 inside the SHU were recording on one drive? 19 MR. : Yes. 20 MR. : Some were on the other 21 drive? 22 MR. : Yes. 23 MR. : So the ones - which drive 24 was the one that stopped recording altogether? 25 MR. : I believe it was the first EFTA00112247  28 1 drive. So like the A side. Like the first. 2 Because the SHU cameras are on the first - 3 they're like the first 50-some cameras. Well 4 not the whole 50 but they're on that side. In 5 this string. 6 MR. : But some were also on the 7 B side? 8 MR. : Yeah. On the B side. 9 Yeah. And that's just because they wired it 10 the way they wired it. 11 MR. : Okay. I'm going to show 12 you a map of the SHU. I know this is kind of 13 old. I'm not sure if this is still exactly how 14 it is. 15 : You have the updated one 16 right in front of him. 17 MR. : Updated one. Okay. I 18 kind of wanted you to mark off where the 19 cameras were (Indiscernible *00:19:47) right 20 here on the 21 MR. : Oh. 22 MR. : -- big one. So let's - 23 I'll give you both. 24 MR. : Oh that's fine. 25 MR. : See if - let's point it EFTA00112248  29 1 over here. 2 MR. : Okay. So. 3 MR. : You recognize this? Where 4 this is? 5 MR. : Yes. That's the Special 6 Housing Unit. 7 MR. : Is this -? How many 8 levels are there? 9 MR. : There's an upper tier and 10 a bottom tier. 11 MR. : The one you're looking at. 12 Is that the upper tier or lower tier? 13 MR. : This is 9 South upper 14 tier. Yeah. 15 MR. : Upper tier. Can you point 16 out -? Do you -? I know you were -. 17 MR. : Approximately. I know 18 where all the cameras are. Okay. So at the 19 end of Visa (Phonetic Sp. *00:20:10) there's a 20 camera here. 21 MR. : So which tier is that? 22 MR. : Uh G tier. 23 : You said at the end of 24 each tier? 25 MR. : Each tier. There's one EFTA00112249  30 1 camera looking this way - looking to the front 2 of the grill. This is the grill. 3 MR. : So G tier. J tier. 4 MR. : J Tier. L Tier. And M 5 should be. 6 MR. : And that camera. What 7 would it have shown? 8 MR. : Um it would just show 9 whoever's coming on to the Tier to do rounds or 10 whatever they're doing on the Tier. 11 MR. : Okay. And as per your 12 recollection, on August 9th, were those cameras 13 actually working? Running? 14 MR. : The cameras were working. 15 The recording no. 16 MR. : Okay. Where else in the 17 SHU are there cameras? 18 MR. : Also there's one in the 19 common area I think. Oh the - let me see. 20 Okay. So you have one over here like looking 21 at the common area over here. And then you 22 have another two like looking this way. 23 MR. : So you're pointing to the 24 right of L Tier? 25 MR. : Yes. EFTA00112250  31 1 MR. : To the right of L Tier. 2 And that would oversee -? 3 MR. : Like the common area this 4 way. Yeah. 5 MR. : And would that also -? 6 What's over here? 7 MR. : That's the officer's 8 station. 9 : Use this and just have 10 him mark on there. So if you could, these 11 numbers don't match up but the tier - the 12 letters should be the same. So can you just -? 13 MR. : Here. So this is L Tier. 14 : And can you just mark -? 15 MR. : M Tier is the top tier. 16 So. 17 : Can you mark maybe like a 18 circle and then point like an arrow toward the 19 direction that it would be recording? 20 MR. : Oh. 21 : That it would be viewing. 22 MR. : Uh. 23 : And this is on August 9th 24 and 10th we're talking about. 25 MR. : Just um. Okay. So. EFTA00112251  32 1 : So if you sit at the end 2 of each tier, just where they were actually -. 3 Just maybe you can put like a start or whatever 4 you decide to make for the camera. And then 5 like an arrow pointing the direction that they 6 would be recording. 7 MR. : Okay. So (Indiscernible 8 *00:21:53). Second one (Indiscernible 9 *00:21:55). 10 MR. : Keeping the (Indiscernible 11 *00:21:55) by arrow pointing in the direction. 12 MR. : Yep. 13 MR. : Okay. 14 MR. : The common area. This is 15 H. And I believe they're on top of this tier. 16 There's a camera over here looking this way. 17 MR. : Is that the upper tier or 18 lower tier? 19 MR. : Uh upper tier. There's a 20 camera on the upper tier - on the outside of 21 the upper tier looking that way. 22 : Is that the one that's 23 like outside of 10 South? 24 MR. : Yes. 25 MR. : And -. EFTA00112252  33 1 : Do you mind on that 2 camera that you just said that's outside of 10 3 South. Can you just put 10 S there so we know 4 what you're talking about?" 5 MR. : 10 S. Um before you get 6 to 10 South, there's actually - that's the 7 camera that you guys probably show the 8 recording. That stuff 46 door. (Phonetic Sp. 9 *00:22:49). 10 : That's the one that you 11 just wrote 10 S next to? 12 MR. : Uh no. It's actually 13 : Oh. 14 MR. : -- up the stair. There's 15 not one -. 16 : So that's not that one. 17 MR. : Yeah. You can't put it on 18 the drawing because of where it's at. 19 : Okay. So the one that 20 you just drew actually - where is that in real 21 - relation to 10 South? 22 MR. : Um that would be like the 23 top of H Tier I believe. 24 : Okay. So can you maybe - 25 hm. How are we going to differentiate the fact EFTA00112253  34 1 that you said a different one is 10 S. Uh the 2 one that we have - that's recording. 3 MR. : Oh. 4 : Can you write -- 5 MR. : That's not 10 South then. 6 : -- that? 7 : That's not 10 South. I 8 crossed it out. So that's going to be - so 9 let's say H Tier number one. And this will be 10 H Tier number two. And this would be K Tier 11 number one. And I'm not sure where the second 12 one it. I don't' think it's this one. I think 13 it's maybe this one on this side. That's what 14 I'm saying is K2. On this one. And this will 15 be M Tier number one. Looking that way. And 16 the - so this would be L Tier. One. Let me 17 get G on there. 18 MR. : Where would the officers' 19 station be? 20 MR. : Uh the officers' station 21 will be next to M Tier like right in this area. 22 : Can you put a box there. 23 MR. : I believe it's right here. 24 : And put OS for Officers' 25 Station. EFTA00112254  35 1 MR. : Was there a camera pointed 2 directly at the officers' station? 3 MR. : Yes. I believe there is 4 one out here in the common area. 5 MR. : And this is on August 9th 6 and 10th. Right? 7 MR. : Yes. I'll just write uh 8 common area. And that's there. And for the 46 9 form? Right. Because it's not on the 10 (Indiscernible *00:25:09). I'll just write it 11 up here. Top of 10 South. 12 : That's perfect. And 13 that's one you're going to mark as 10 S? 14 MR. : Yeah. Ten. 15 : And that's the one and 16 only that we have that was actually working? 17 MR. : Yeah. That's the 46 18 though. 19 MR. : Now where would the 20 entrance be? Where inmates are moved in and 21 out of the SHU? 22 MR. : Uh that's the um - the 23 front entrance right here by the elevators. 24 MR. : Was there a camera there? 25 MR. : Uh no. There's only a EFTA00112255  36 1 camera in the hallway. There was no cameras in 2 there when they're moving back and forth. 3 MR. : If someone had to come in 4 and out of the SHU and control had to bus them, 5 was there a way control buses was 6 MR. : Uh yeah. 7 MR. : -- coming in and out? 8 MR. : The way that the doors 9 work at that time was - because we changed some 10 of the cameras. But before control pops the 11 door, they pretty much acknowledge that -. 12 Well before - especially with 9 South. 9 South 13 is different because the officer has the key on 14 their hip to - there's an inner door inside 15 here. And they won't even - well they're not 16 supposed to - crack the outer door without 17 somebody in SHU calling for that door. So I 18 can't go up to 10 South - or 9 South - right 19 now and say hey, let me get the 27 door. 20 Somebody from SHU has to call for the 27 door. 21 Because the inner door they have the key before 22 you come inside of 9 South. 23 MR. : But there was no cameras 24 at that point? 25 MR. : No. There was a live EFTA00112256  37 1 feed. There's always a live feed. 2 MR. : But nothing recording. 3 MR. : Nothing recording. I mean 4 the live feed goes to the control center. And 5 the control center officer sees who is at the 6 door. And they will pop the door. 7 MR. : Where would that camera 8 be? 9 MR. : Um that camera would be 10 in the hallway. I think that camera was 11 looking this way. So 9 Sally. I just labeled 12 it 9 Sally. And it just like looks down this 13 way. 14 MR. : Okay. So you pointed out 15 there's one on each tier. That would make it 16 six cameras. 17 MR. : Yeah. 18 MR. : There is one in the corner 19 -- 20 MR. : In the corner. 21 MR. -- of H tier? 22 MR. : Yeah I believe so. 23 MR. : That would make it seven. 24 There's one in the corner of 25 MR. : I'm not too sure about EFTA00112257  38 1 that one. I think there's one in that corner. 2 But I know there's one definitely in the common 3 area. I know these two are definitely here. 4 That other one I'm not too sure about. Because 5 I don't remember seeing that. 6 MR. : Okay. That's eight 7 cameras and then there's one in the Sally. 8 MR. : Yes. 9 MR. : And where's 10 camera? 11 MR. : It's up here. 12 MR. : Okay. So nine cameras 13 total that you're aware of. That should have 14 been -. 15 MR. : Um. Recording yes. All 16 the cameras are working now. Because you could 17 see. 18 MR. : Where could you see it 19 from? 20 MR. : Uh the live matrix. 21 MR. : On a matrix? 22 MR. : Yes. 23 MR. : Who had access to the live 24 matrix? 25 MR. : Um whoever would have a EFTA00112258  39 1 keypad. Not a lot of people have access to 2 that. So like SIS would have it - at the time. 3 Um control center would have it. And um 4 lieutenant's office don't have it. So it's 5 SIS, SIA, I have access, and that's pretty much 6 about it. And then our command center. 7 MR. : Is there something that 8 they would have to key in to see? Or is it 9 just running? 10 MR. : No. You would have to key 11 in the cameras to see the actual camera call 12 up. You have to call up for them hit the 13 button and know what camera it is to call up. 14 MR. : Did anyone like the SIS 15 office or even the control have like the 16 cameras - you know like the feed just running 17 on their screen at all times? 18 MR. : Yeah. But they would have 19 to go through all the cameras. They usually 20 just - it just sits on one camera. It doesn't' 21 keep scrolling through all the cameras. 22 MR. : Okay. Do you have 23 anything on that? 24 : A lot. Yes. A lot. 25 MR. : Okay. EFTA00112259  40 1 : Um. and maybe you 2 answered some of this and maybe just being a 3 layman I didn't understand. But so going back 4 to the beginning. How many cameras are in the 5 MCC? Or were there in August 9th and 10th? 6 MR. : I would have to look 7 through those right now. 8 : Well approximately. 9 MR. : Old partner would always 10 tell me there's like 200. I probably think 11 like 150 if that. 12 : All right. 13 MR. : I don't even think it was 14 150. 15 : And you said at the time 16 there were approximately ten that were not 17 working. 18 MR. : Yes. 19 : What does that mean - 20 "not working"? 21 MR. : It probably needs to get 22 if we're out of focus, just the video is 23 probably grainy - not the best video. 24 : Okay. 25 MR. : Yeah. EFTA00112260  41 1 : So they're on but they 2 were So differentiate for me because you 3 said that there are cameras in the SHU were 4 working but they weren't recording. 5 MR. : Uh-huh. 6 : So what's the difference 7 between working and not working when you're 8 talking about that? 9 MR. : Okay. So if you have a 10 camera working, you can see the video, but it's 11 not recording. That's a totally different 12 problem. 13 : Okay. So the ones that 14 you say that are not working. There's a 15 problem with what you're seeing. 16 MR. : Yeah. 17 : But they are recording or 18 they're not recording? 19 : It could possibly they could 20 be recording or can't be recording. 21 : All right. And then when 22 we just talked about the SHU. There's 23 approximately ten -- 24 MR. : Technically ten cameras. 25 : -- cameras in the SHU? EFTA00112261  42 1 MR. : Yeah. 2 : And the cameras in the 3 SHU. Only one out of ten was not - it was only 4 one was recording. 5 MR. : Only one. Yes. Because 6 it was on a different recorder at the time. 7 Yes