EFTA00112079.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 EFTA00112079  2 APPEARANCES: OFFICE OF THE INSPECTOR GENERAL BY: BY: WITNESS: OTHER APPEARANCES: NONE EFTA00112080  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 Mr. Daniels. 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 MR. My name is Senior Special EFTA00112081  4 1 Agent 2 And these are my credentials. Okay. 3 MR. 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 7 And the last name ism 8 And my title is electronics 9 technician. 10 MR. So it'sillillffithout the 11 S. 12 MR. : Without the S. No S. 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. EFTA00112082  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 MR. 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, EFTA00112083  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. is 7 signing the form. All right. Special Agent is signing under line for signature of 8a 9 the Office of Inspector General Special Agent. 10 MR. : 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 17 oath. can you please raise your 18 right 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. EFTA00112084  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. Uh 7 8 MR. What's your date of birth? 9 MR. IIIIIIIIIIIIIII Date of 10 birth is 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 educa 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. La Guardia Community EFTA00112085  8 1 College. 2 MR. Okay. Is that in New 3 York 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 2004. 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? EFTA00112086  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. 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 from 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. EFTA00112087  10 1 MR Did you come back to the 2 MCC? 3 MR MCC New York as an 4 electron' ' 'an. 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. EFTA00112088  11 1 MR. 6:00 to 2:00? 2 MR. Day watch. 3 MR. Okay. 4 MR. Just before we go on. As 5 an electronics technician, when did you 6 actually become that? 7 MR. Um of 2015 - in March of 8 2015. 9 MR. And does that 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 MR. Okay. So what training 19 did you receive specifically in that field? 20 MR. IN the Bureau? Or -? 21 MR. Just overall. 22 MR. Oh. 23 MR. Since you said you only 24 did - you did college. I mean it doesn't' have 25 to be specifically. EFTA00112089  12 1 MR. Oh. 2 MR. 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 MR. 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 MR. 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 MR. Okay. 19 MR. I went to one telephone 20 school and that was about it. And a fire alarm 21 training. 22 MR. Okay. 23 MR. But everything is pretty 24 much on the job. 25 MR. Thank you. EFTA00112090  13 1 MR. Anything else on that? 2 MR. 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. EFTA00112091  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 hey my machine isn't working and I go take 5 a 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? EFTA00112092  15 1 MR. : After Epstein pretty much. 2 MR. : Okay. 3 MR. : Yeah. 4 MR. 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, I had a screen at my 18 desk. And make sure the um -. Because it went 19 to analog matrix. It's going to sound a little 20 confusing when I say analog matrix and digital 21 matrix because the old system we had was a 22 mixture of both. And kind of like the new 23 system too. It takes the old analog cameras 24 because we had a lot of old analog cameras. It 25 takes all of that. And then it transfers it to EFTA00112093  16 1 make it digital so you can start recording. 2 And that's how you - we'll get a video and look 3 back for video. But everything was analog. So 4 I would have the analog system in my office. 5 And I would pretty much look and see if that's 6 working. If that was working I know I was 7 pretty much good. 8 Ma= 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. EFTA00112094  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 wasn't modern but it was 13 more up to date than this. And so like the 14 camera system I had was maybe five to ten years 15 old. And when I came here, this one was over 16 ten years old and it was on 365 a day. Like 24 17 hours for the like the last 12 years. The 18 system was always on. And something as simple 19 as shutting down the time and change - because 20 you got to get recording times right. When the 21 seasons change, you would have to wait like a 22 whole day to shut down a recorder. It takes a 23 whole day for it to come back up after shutting 24 it down. And where I came from, that was not 25 the standard. Like it should be like an hour EFTA00112095  18 1 maybe thirty minutes. Maybe even ten minutes 2 if it's a newer system. You shouldn't even 3 have that much down time as far as the 4 recording. So one of the first things I did 5 when I came here was I addressed that - the 6 recorders needed to be upgraded. And -. 7 MR. Who did you address that 8 with? 9 MR.IIIIIIIIIk: Um my Facility Manager. I 10 talked to upper management. 11 But like during this whole time I was 12 doing -. I actually started the camera project 13 and that's why I was doing overtime around this 14 time. And we had people come from other 15 institutions. There was a camera project to 16 upgrade the cameras. Everybody's fear was the 17 actual cameras not the recording software of 18 the cameras. But I stated over and over again 19 the problem you're going to have is the 20 recorders. And we even had the new recorders. 21 They were in the warehouse. We have them 22 stockpiled. They was ordered. But we were on 23 the bottom of the list as far as install. So 24 even though we had the new equipment, we 25 weren't a priority to get anything installed. EFTA00112096  19 1 So we had to wait until something happened. 2 MR.-: And you said there was a - 3 you mentioned that to your Facilities Manager. 4 Who was that? 5 MR. When I first got here it 6 was (Phonetic Sp. *00:13:22) 7 and as a facility manager. I 8 think we were in between facility managers when 9 this happened because we didn't really have 10 anybody. 11 MR. So there was no one during 12 August 9th and 10th there was nobody? 13 MR. I'm not too sure if my new 14 facility manager took over at that time. But I 15 don't believe he was here. I think he came 16 after. He was here visiting but I don't think 17 he took the job. 18 MR. And you mentioned it to 19 upper management too? 20 MR Yeah. 21 MR Who in upper management 22 did you mention it to? 23 MR. My old AW - my Associate 24 Warden - still - he's no longer - he's returned 25 from the Bureau. EFTA00112097  20 1 MR. Who is the old AW? 2 MR. Associate Warden IIIII 3 (Phonetic Sp. *00:13:53). That was his last 4 name. I forgot the first name. But I 5 mentioned to him and of course I talked to the 6 wardens about it. 7 MR. Who was the warden at that 8 point? 9 MR. Um it was And 10 before it was 'lig' (Phonetic Sp. 11 *00:14:04). Because they wanted me like to add 12 more cameras and do upgrades. And I'm like, 13 well you've got to spend money because this 14 stuff is old. Like you can't just start adding 15 cameras to old systems. It's not going to 16 work. 17 MR. And you said there was as 18 project started around that time. Before 19 Epstein's death? 20 MR. Before Epstein's death. 21 Yeah. 22 MR. How far before? 23 MR. I would have to look at 24 documents. I'm not too sure. Me and pretty 25 much - we have an engineering tech - EFTA00112098  21 1 (Phonetic Sp. *00:14:25) - when we 2 started. Because we had problems with the 3 recorders before where we submitted paperwork 4 to the regional office saying hey the recorders 5 are going down. It's end of life. What can we 6 do to upgrade? What's the steps? And that's 7 why we got funded all the money that we got to 8 start the project. 9 MR. : Before Epstein's death, do 10 you recall what exactly the project entailed? 11 What were you guys upgrading? 12 MR. Uh we were trying to go 13 from analog cameras to IP cameras and trying to 14 upgrade the recorders. The recorders were like 15 the main thing. Upgrading the recording 16 system. 17 MR. But not the cameras 18 itself? 19 MR. Not the cameras itself. 20 Because they can still work. And they still 21 work now. 22 MR. Were majority of the 23 cameras working during that time? 24 MR. Yes. Pretty much all the 25 cameras were working. Maybe we had maybe ten EFTA00112099  22 1 probably that weren't working. But for the 2 majority all of the cameras were working. They 3 weren't being recorded - that was the problem. 4 MR. So the cameras were 5 working but it wasn't actually -- 6 MR. Recording yeah. 7 MR. -- recording into the -. 8 MR. Yes. 9 MR. Now think. I know it's 10 been two years. Do you recall which were the 11 ten cameras were that weren't working. 12 MR. M.: I have no idea. I would 13 have to look at that list there. 14 MR. How about during that time 15 in the SHU. Were the cameras working? 16 MR. Yes. The cameras in SHU 17 were working. They were recording. Well they 18 were working. They weren't recoding. But they 19 were working. 20 MR. So what is that? Explain 21 that to me. 22 MR. : Okay. So you like - if 23 so like I said. We had an analog system and a 24 digital system. The old system would never 25 show me like the recorders failed. Like if EFTA00112100  23 1 there was an error on the old software. Like I 2 would have to physically be in the room to say 3 hey. Because the room was upstairs on the 4 third floor. Which I didn't have access for. 5 You would have to go in the room and then you 6 go see like - because there's a redundant 7 drive. So you have like an A side and a B 8 side. And say if the A side isn't working, you 9 have one drive goes bad. That's not a problem. 10 As soon as the second drive goes bad, that's 11 when you run into problems. And after the 12 second drive runs into problems, that's when 13 you stop recording. And once that happens, you 14 have to take the drive out, and we have to 15 scrounge around for old drives and see if those 16 will work. During that time I actually - prior 17 to that I actually purchased maybe 24 drives to 18 actually redo a whole bay - like A or the B 19 side. I was actually going to do that. 20 MR. Did you know at that point 21 that SHU cameras weren't recording? 22 MR. At that point towards the 23 end of the day I did. I believe I did know at 24 the end of the day. 25 MR. On August 9th during the EFTA00112101  24 1 day? 2 MR. Yeah. And I called -- 3 MR. It wasn't the 10th? 4 MR. SigNet. That's my 5 point of contact. I usually - any time I have 6 a problem or something's not working because I 7 wasn't really familiar with the whole system. 8 I had like a newer system. It kind of worked 9 the same, as far as the software side goes, as 10 far like as like the hardware, it was 11 different. So I would always have to call them 12 for like tech support. Like okay I'm having a 13 problem today. Can you document it? You know 14 it builds our case when I have to submit stuff 15 to Regional Office. Me just saying it's not 16 going to work, that's not going to fly. And 17 usually they help me troubleshoot through the 18 whole process of what I should have to do - A, 19 B, C, okay take this drive out, put that drive 20 in. And like previously, probably six months 21 before that, we actually had a mother board - 22 which was my main computer - like go out. And 23 I had to actually replace that and they had to 24 walk me through it over the phone. I went to 25 scrounge round parts from another institution EFTA00112102  25 1 to get it working. I know I'm giving you like 2 a lot of stuff but -. 3 MR. So let's step back. So 4 you said the - it wasn't working. There was 5 possibly a work order already created. Right? 6 MR. Yes. Possibly. Yes. 7 MR. Who approved the work 8 order? 9 MR. Um that has to go through 10 my general foreman or facility manager. 11 Whoever's in charge. 12 MR. Do you think - do you 13 recall if this was before Epstein's death or 14 after? 15 MR. This was probably before 16 Epstein's death. There was a few work orders 17 before Epstein's death. 18 MR. And if these work orders - 19 . Are these work orders still maintained? A 20 copy anywhere? 21 MR._: They should be in the 22 facilities folder somewhere. 23 MR. : Who would have access to 24 it now? 25 MR. Um my facility manager, EFTA00112103  26 1 she'll know where they're at. And the 2 engineering tech would pretty much. Well I'm 3 not saying engineering tech. But the facility 4 manager should know if those records are kept 5 or they're maintained. 6 MR. And when this work order 7 was created, this work order specifically 8 addressed the fact that the SHU cameras weren't 9 recording? 10 MR. o. No. All of the 11 cameras. It's not going to just be SHU. It's 12 going to be all the cameras. 13 MR All the (Indiscernible 14 *00:18:28) cameras. 15 MR. : Yeah. 16 MR. : Okay. So at that point, 17 how come some cameras recorded? He said 18 there's redundancy. So there's either going to 19 -- 20 MR. A side and B side. 21 MR. -- A drive or B drive? 22 MR. Yeah. 23 MR. How come some recorded on 24 -? 25 MR. : Okay. Oh there's going to EFTA00112104  27 1 be another problem too. Okay. So there's an A 2 side and a B side. And it's supposed to be 3 redundant but it's not redundant because it's 4 not really redundant when one side goes bad so 5 it just knows to record channels. Let's say 6 one through 50 is on this side. And 51 through 7 100 is on this side. Everything is working. 8 It doesn't work. Okay. I can take over for 9 this one because it's not working. But as soon 10 as that one goes, I can kind of record over 11 here. As soon as the second drive goes, I have 12 to just record what I'm recording. I can't no 13 longer help out the other drives. 14 MR. Okay. So some channels 15 inside the SHU were recording on one drive? 16 MR. Yes. 17 MR. Some were on the other 18 drive? 19 MR. Yes. 20 MR. So the ones - which drive 21 was the one that stopped recording altogether? 22 MR. I believe it was the first 23 drive. So like the A side. Like the first. 24 Because the SHU cameras are on the first - 25 they're like the first 50-some cameras. Well EFTA00112105  28 1 not the whole 50 but they're on that side. In 2 this string. 3 MR. But some were also on the 4 B side? 5 MR. Yeah. On the B side. 6 Yeah. And that's just because they wired it 7 the way they wired it. 8 MR. Okay. I'm going to show 9 you a map of the SHU. I know this is kind of 10 old. I'm not sure if this is still exactly how 11 it is. 12 MR. You have the updated one 13 right in front of him. 14 MR. Updated one. Okay. I 15 kind of wanted you to mark off where the 16 cameras were (Indiscernible *00:19:47) right 17 here on the -- 18 MR. : Oh. 19 MR. : -- big one. So let's - 20 I'll give you both. 21 MR. : Oh that's fine. 22 MR. : See if - let's point it 23 over here. 24 MR Okay. So. 25 MR You recognize this? Where EFTA00112106  29 1 this is? 2 MR. Yes. That's the Special 3 Housing Unit. 4 MR. MM Is this -? How many 5 levels are there? 6 MR. L: There's an upper tier and 7 a bottom tier. 8 The one you're looking at. MR. MM .: 9 Is that the upper tier or lower tier? 10 MR. This is 9 South upper 11 tier. Yeah. 12 MR. Upper tier. Can you point 13 out -? Do you -? I know you were 14 MR. Approximately. I know 15 where all the cameras are. Okay. So at the 16 end of each tier there's a camera here. 17 MR. So which tier is that? 18 MR. Uh G tier. 19 MR. You said at the end of 20 each tier? 21 MR. Each tier. There's one 22 camera looking this way - looking to the front 23 of the grill. This is the grill. 24 MR. So G tier. J tier. 25 MR. J Tier. L Tier. And M EFTA00112107  30 1 should be. 2 MR. En And that camera. What 3 would it have shown? 4 MR. Um it would just show 5 whoever's coming on to the Tier to do rounds or 6 whatever they're doing on the Tier. 7 Okay. And as per your MR. EM 8 recollection, on August 9th, were those cameras 9 actually working? Running? 10 MR. The cameras were working. 11 The recording no. 12 MR. Okay. Where else in the 13 SHU are there cameras? 14 MR. Also there's one in the 15 common area I think. Oh the - let me see. 16 Okay. So you have one over here like looking 17 at the common area over here. And then you 18 have another two like looking this way. 19 MR. So you're pointing to the 20 right of L Tier? 21 MR. Yes. 22 MR. o the right of L Tier. 23 And that would oversee -? 24 MR. Like the common area this 25 way. Yeah. EFTA00112108  31 1 MR. And would that also -? 2 What's over here? 3 MR. That's the officer's 4 station. 5 MR. Use this and just have 6 him mark on there. So if you could, these 7 numbers don't match up but the tier - the 8 letters should be the same. So can you just -? 9 MR. Here. So this is L Tier. 10 MR. And can you just mark -? 11 MR. M Tier is the top tier. 12 So. 13 MR. Can you mark maybe like a 14 circle and then point like an arrow toward the 15 direction that it would be recording? 16 MR. Oh. 17 MR. That it would be viewing. 18 MR. Uh. 19 MR. And this is on August 9th 20 and 10th we're talking about. 21 MR. Just um. Okay. So. 22 MR. So if you said at the end 23 of each tier, just where they were actually 24 Just maybe you can put like a star or whatever 25 you decide to make for the camera. And then EFTA00112109  32 1 like an arrow pointing in the direction that 2 they would be recording. 3 MR. Okay. So (Indiscernible 4 *00:21:53). Second one (Indiscernible 5 *00:21:55). 6 MR. Keeping the (Indiscernible 7 *00:21:55) by arrow pointing in the direction. 8 MR. Yep. 9 MR. Okay. 10 MR. The common area. This is 11 H. And I believe they're on top of this tier. 12 There's a camera over here looking this way. 13 MR. Is that the upper tier or 14 lower tier? 15 MR. Uh upper tier. There's a 16 camera on the upper tier - on the outside of 17 the upper tier looking that way. 18 MR. Is that the one that's 19 like outside of 10 South? 20 MR. Yes. 21 MR. And -. 22 MR. Do you mind, on that 23 camera that you just said that's outside of 10 24 South. Can you just put 10 S there so we know 25 what you're talking about?" EFTA00112110  33 1 MR. 10 S. Um before you get 2 to 10 South, there's actually - that's the 3 camera that you guys probably saw the 4 recording. That's the 46 door. 5 MR. That's the one that you 6 just wrote 10 S next to? 7 MR. h no. It's actually -- 8 MR. Oh. 9 MR. - up the stair. There's 10 not one 11 MR. So that's not that one. 12 MR. 'eah. You can't put it on 13 the drawing because of where it's at. 14 MR. Okay. So the one that 15 you just drew actually - where is that in real 16 - relation to 10 South? 17 MR. Urn that would be like the 18 top of H Tier I believe. 19 MR Okay. So can you maybe - 20 hm. How are we going to differentiate the fact 21 that you said a different one is 10 S. Uh the 22 one that we have - that's recording? 23 MR. Oh. 24 MR. Can you write -- 25 MR. That's not 10 South then. EFTA00112111  34 1 MR. -- that? 2 MR. That's not 10 South. I 3 crossed it out. So that's going to be - so 4 let's say H Tier number one. And this will be 5 H Tier number two. And this would be K Tier 6 number one. And I'm not sure where the second 7 one is. I don't' think it's this one. I think 8 it's maybe this one on this side. That's one 9 I'm saying is K two. On this one. And this 10 will be M Tier number one. Looking that way. 11 And the - so this would be L Tier. One. Let 12 me get G on there. 13 MR. Where would the officers' 14 station be? 15 MR. Uh the officers' station 16 will be next to M Tier like right in this area. 17 MR. Can you put a box there? 18 MR. I believe it's right here. 19 MR. And put OS for Officers' 20 Station? 21 MR. Was there a camera pointed 22 directly at the officers' station? 23 MR. Yes. I believe there is 24 one out here in the common area. 25 MR. And this is on August 9th EFTA00112112  35 1 and 10th. Right? 2 MR. Yes. I'll just write uh 3 common area. And that's there. And for the 46 4 camera. Because it's not on the drawing, I'll 5 just write it up here. Top of 10 South. 6 MR. That's perfect. And 7 that's the one you're going to mark as 10 S? 8 MR. Yeah. Ten. 9 MR. And that's the one and 10 only that we have that was actually working? 11 MR. Yeah. That's the 46 door. 12 MR. Now where would the 13 entrance be? Where inmates are moved in and 14 out of the SHU? 15 MR. Uh that's the um - the 16 front entrance right here by the elevators. 17 MR. Was there a camera there? 18 MR. Uh no. There's only a 19 camera in the hallway. There was no cameras in 20 there when they're moving back and forth. 21 MR. If someone had to come in 22 and out of the SHU and control had to buzz 23 them, was there a way control buzzes who was -- 24 MR. Uh yeah. 25 MR. -- coming in and out? EFTA00112113  36 1 MR. The way that the doors 2 worked at that time was - because we changed 3 some of the cameras. But before control pops 4 the door, they pretty much acknowledge that -. 5 Well before - especially with 9 South. 9 South 6 is different because the officer has the key on 7 their hip to - there's an inner door inside 8 here. And they won't even - well they're not 9 supposed to - crack the outer door without 10 somebody in SHU calling for that door. So I 11 can't go up to 10 South - or 9 South - right 12 now and say hey, let me get the 27 door. 13 Somebody from SHU has to call for the 27 door. 14 Because the inner door they have the key before 15 you come inside of 9 South. 16 MR. But there was no cameras 17 at that point? 18 MR. No. There was a live 19 feed. There's always a live feed. 20 MR. But nothing recording? 21 MR. Nothing recording. I mean 22 the live feed goes to the control center. And 23 the control center officer sees who is at the 24 door. And they will pop the door. 25 MR. Where would that camera EFTA00112114  37 1 be? 2 MR. Um that camera would be 3 ... in the hallway. I think that camera was 4 looking this way. So 9 Sally. I just labeled 5 it 9 Sally. And it just like looks down this 6 way. 7 MR. Okay. So you pointed out 8 there's one on each tier. That would make it 9 six cameras. 10 MR. Yeah. 11 MR. There is one in the corner 12 -- 13 MR. In the corner. 14 MR. -- of H tier? 15 MR. Yeah I believe so. 16 MR. That would make it seven. 17 There's one in the corner of -. 18 MR. I'm not too sure about 19 that one. I think there's one in that corner. 20 But I know there's one definitely in the common 21 area. I know these two are definitely here. 22 That other one I'm not too sure about. Because 23 I don't remember seeing that. 24 MR. Okay. That's eight 25 cameras and then there's one in the Sally. EFTA00112115  38 1 MRS Yes. 2 MR And where's the 10 S 3 camera? 4 MR It's up here. 5 MR Okay. So nine cameras 6 total that you're aware of. That should have 7 been recording? 8 MR. Um. Recording, yes. All 9 the cameras were working though. Because you 10 could see. 11 MR. Where could you see it 12 from? 13 MR. Uh the live matrix. 14 MR. On a matrix? 15 MR. Yes. 16 MR. Who had access to the live 17 matrix? 18 MR. Um whoever would have a 19 keypad. Not a lot of people have access to 20 that. So like SIS would have it - at the time. 21 Um control center would have it. And um 22 lieutenant's office don't have it. So it's 23 SIS, SIA, I have access, and that's pretty much 24 about it. And then our command center. 25 MR. Is there something that EFTA00112116  39 1 they would have to key in to see? Or is it 2 just running? 3 MR. No. You would have to key 4 in the cameras to see the actual camera call 5 up. You have to call up and hit the button and 6 know what camera it is to call up. 7 MR. Did anyone like the SIS 8 office or even the control have like the 9 cameras - you know like the feed just running 10 on their screen at all times? 11 MR. Yeah. But they would have 12 to go through all the cameras. They usually 13 just - it just sits on one camera. It doesn't' 14 keep scrolling through all the cameras. 15 MR. : Okay. Do you have 16 anything on that? 17 MR. A lot. Yes. A lot. 18 MR. o ahead. 19 MR. Um. And maybe you 20 answered some of this and maybe just being a 21 layman I didn't understand. But so going back 22 to the beginning. How many cameras are in the 23 MCC? Or were there in August 9th and 10th? 24 MR. I would have to look 25 through those right now. EFTA00112117  40 1 MR Well approximately. 2 MR Old partner would always 3 tell me there's like 200. I probably think 4 like 150 if that. 5 MR. All right. 6 MR. I don't even think it was 7 150. 8 MR. And you said at the time 9 there were approximately ten that were not 10 working? 11 MR. Yes. 12 MR. What does that mean - 13 "not working"? 14 MR. It probably needs to get 15 re-, umm out of focus, just the video is 16 probably grainy - not the best video. 17 MR. Okay. 18 MR. Yeah. 19 MR. So they're on but they 20 were So differentiate for me, because you 21 said that there are cameras in the SHU were 22 working but they weren't recording. 23 MR. Uh-huh. 24 MR. So what's the difference 25 between working and not working when you're EFTA00112118  41 1 talking about that? 2 MR. Okay. So if you have a 3 camera working, you can see the video, but it's 4 not recording. That's a totally different 5 problem. 6 MR. Okay. So the ones that 7 you say that are not working. There's a 8 problem with what you're seeing. 9 MR Yeah. 10 MR But they are recording or 11 they're not recording? 12 MR It could possibly they could 13 be recording or can't be recording. 14 MR. All right. And then when 15 we just talked about the SHU. There's 16 approximately ten -- 17 MR. Ten, ten cameras. 18 MR. -- cameras in the SHU? 19 MR. Yeah. 20 MR. And the cameras in the 21 SHU. Only one out of ten was not re - only one 22 was recording? 23 MR. Only one. Yes. Because 24 it was on a different recorder at the time. 25 Yes. EFTA00112119  42 1 MR And on August 9th you 2 said that you knew some were not recording. Is 3 that what you were saying? 4 MR. I knew yeah something was 5 going on. I went up to the room and I was 6 about to change everything out and I didn't 7 have access. So I had to leave for the day. 8 MR. And that is on August 9 9th? 10 MR. August 9th. The end of 11 the day. 12 MR. And that was the very 13 first time you knew that they were not 14 recording? 15 MR. m. That day, yes. 16 MR. Okay. 17 MR. owards the end of the 18 day. 19 MR. And did you know all of 20 them were not recording at that time? Aside 21 from the one? 22 MR. I didn't know exactly 23 what wasn't recording on the recorder. 24 I do