📄 Extracted Text (17,517 words)
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APPEARANCES:
OFFICE OF THE INSPECTOR GENERAL
BY:
BY:
WITNESS:
DIGITALLY RECORDED
SWORN STATEMENT
OF
OTHER APPEARANCES:
OIG CASE #:
2019-010614
DEPARTMENT OF JUSTICE
OFFICE OF THE INSPECTOR GENERAL
APRIL 7, 2022
RESOLUTE DOCUMENTATION SERVICES
Agoura Hills CA 91301
Phone:
3 4
1 MR. : This is Special Agent 1 DO]/OIG Special Agent
2 . Today is April 7, 2022. The 2
3 time is 10:21 a.m. The recorder is now on. 3 MR. Assistant Special Agent-in-
4 My name is . I'm a Special 4 Charge
5 Agent with the U.S. Department of Justice, 5 MR.
6 Office of the Inspector General, New York Field 6 Electronics Technician. Last name,
7 Office. These are my credentials. 7
8 MR. : I'm going to -. Man. 8 MR. : ASAC , can you
9 MR. : This interview with 9 introduce ourself, please?
10 Federal Bureau of Prisons employee, 10 MR. : Yes, this is Special Agent-in-
11 , is being conducted as part of an 11 Charge
12 official U.S. Department of Justice, Office of 12 MR. : Thank you.
13 the Inspector General investigation. Today's 13 This is an official DOJ/OIG investigation
14 date is April 7, 2022. The time is 10:22 a.m. 14 into events surrounding the death of inmate
15 This interview is being conducted at the 15 Jesse Epstein, and you are being asked to
16 Department of Justice, Office of the Inspector 16 voluntarily provide answers to our questions.
17 General, New York Field Office. Also present 17 Will you agree to a voluntary interview with
18 are DOJ OIG Assistant Special Agent-in-Charge, 18 the DOJ/OIG?
19 , and via phone is DOJ OIG 19 MR. : Yes.
20 Assistant Special Agent-in-Charge, 20 MR. : Please review DOJ/OIG form
21 21 III-226/2. The form states, United States
22 This interview will be recorded by me, 22 Department of Justice, Office of the Inspector
23 Special Agent . Could everyone 23 General, Warnings and Assurances form,
24 please identify themselves for the record and 24 Assurances to Employee Requested to Provide
25 spell your last name. To start again, I am 25 Information on a Voluntary Basis. "You are
EFTA00126336
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1 being asked to provide information as part of 1 MR. Okay.
2 an investigation being conducted by the OIG. 2 MR. -- sign and print.
3 This investigation is being conducted pursuant 3 MR. I will sign and print.
4 to the Inspector General Act of 1978, as 4 MR. Do you understand the
5 amended. This investigation pertains to job 5 form?
6 performance failure and security failure. This 6 MR. : Yes.
7 is a voluntary interview. Accordingly, you do MR. : Thank ou.
8 not have to answer any questions. No 8 This is Special Agent I'm
9 disciplinary action will be taken against you 9 signing on the signature of the Office of the
10 if you choose not to answer any questions. 10 Inspector General Special Agent. And ASAC --
11 Any statement you furnish may be used as 11 MR. : This is --
12 evidence in any future criminal proceedings or 12 MR. sorr
13 agency disciplinary proceedings or both." 13 MR. ASAC
: I'm
14 The waiver states, "I understand the 14 I'm signin on the signature of witness line.
15 warnings and assurances stated above and I am 15 MR. : Before starting the
16 willing to make a statement and answer 16 interview, I would like to place you under
17 questions. No promises or threats have been 17 oath. Mr. , can you please raise your
18 made to me and no pressure or coercion of any 18 right hand? Do you swear to tell the truth and
19 kind has been used against me." This is the 19 nothing but the truth during this interview?
20 same form we've rovided you before. 20 MR. : Yes.
21 MR. : Yes. 21 MR. : Thank you. You can put
22 MR. : Please review it. If you 22 your right hand down. Please let me know if
23 understand, on the right side, please print 23 you don't understand any questions and I'll try
24 your name and sign your name. If you 24 to repeat it or try to rephrase it for you.
25 understand and agree -- 25 MR. : Okay.
7 8
1 MR. : Thank you. Thank you for 1 typical work schedule?
2 taking the time to meet with us today. We have 2 MR. : My schedule was 6:00 to
3 a few follow-u uestions. 3 2:00 p.m.
4 MR. : Mm-hmm. 4 MR. : 6:00 to 2:00 p.m. Is that
5 MR. : You met with us twice 5 Monday thiiiiiiiiiday?
6 before. 6 MR. : Monday through Friday.
7 MR. : Yes. 7 During that time, I think I was working
8 MR. : And it's based on our 8 overtime because we started the camera project.
9 interview, from prior, we had a few follow-up 9 MR. : The camera project is?
10 questions in regards to that, and a few new 10 MR. : Before all this got
11 questions for ou too. 11 started, we were upgrading the cameras in the
12 MR. : Okay. 12 MCC. So, my schedule changed, and I was
13 MR. : Before we begin, what is 13 working, like, ten or 12 hours a day during
14 your curriiiiiiiiiyment status with the BOP? 14 this time.
15 MR. : I'm an electronics 15 MR. : So, Monday through Friday,
16 technician at MDC Brooklyn, Com Tech. Same 16 normal schedule could be 6:00 a.m. to 2:00
17 position I was in MCC. 17 p.m.?
18 MR. : And this is your permanent 18 MR. : Yes.
19 position nut.? 19 MR. : So, that would be about
20 MR. : Yes. 20 eight hours.
21 MR. : And you transferred over? 21 MR. : Yes.
22 MR. : Yes, when they closed it 22 MR. : So. if you're working ten
23 down. 23 to 12, that means you were working to, what,
24 MR. : Okay. So, let's take a 24 about 4:0iiiiiiiii:00 p.m.?
25 step back. In August 2019, what was your 25 MR. : Yes.
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1 MR. : Okay. And what about on 1 you had recalled having a conversation with SIS
2 the weekends? 2 Lieutenant You remember her, right?
3 MR. : I was working a little bit 3 MR. : Yes.
4 of overtime there during that time, too. 4 MR. : Thursday, August 8th, you
5 MR. : Okay. And is that 5 had a conversation with her about cameras not
6 somethingliiiiiiiied prior approval for, or -? 6 working inside the MCC. Do you recall that?
7 MR. : Yes. Well, they knew what 7 MR. : Thursday or Friday.
8 was going on, so I got pretty much prior 8 MR. : Thursday, August 8th.
9 approval. If I showed up, I showed up. If it 9 MR. : No.
10 didn't, they didn't really -. Because the 10 MR. : You don't recall having a
11 project was going on. I have a life, too. I 11 conversation with her?
12 can't just be working at the prison all the 12 MR. : The only time they spoke
13 time, so they understood if I didn't show up or 13 about it was Friday, about the cameras, that I
14 didn't come in for overtime. Because my 14 remember.
15 regular schedule is Monday through Friday, 6:00 15 MR. : So, you recall on Friday.
16 to 2:00. 16 Who did you have a conversation with?
17 MR. : Okay. And as needed, you 17 MR. : Lieutenant and
18 would come in, too? 18 that's when I spoke to IIII. She's the
19 MR. : Yes. 19 Associate Warden. That's when they told me
20 MR. : ASAC , did you have 20 that the cameras were down, on that Friday.
21 anything in regards to his schedule? 21 MR. : On that Friday?
22 MR. : I did not. Thanks. 22 MR. : Yes.
23 MR. : No problem. I'm going to 23 MR. : So, just to clarify a
24 move on. 24 little bit. So, Lieutenant wasn't
25 In our previous interview, you mentioned 25 working on Friday, August 9th. They were
11 12
1 actually workin -- 1 camera?
2 MR. : Mm-hmm. 2 MR. : They couldn't pull video
3 MR. : -- she was off on August 3 for whatever reason. They couldn't extract
4 9th. 4 video. They were looking for video for
5 MR. : August 9th. 5 something and couldn't find it.
6 MR. : Friday, August 9th. She 6 MR. : So, it wasn't recording,
7 was workin on Thursday, August 8th. 7 and they couldn't pull any video?
8 MR. : Yeah. 8 MR. : Yes.
9 MR. : According to the schedule, 9 MR. : Do you remember if there
10 she was working Thursday, August 8th, and the 10 were any cameras -? So, when they were trying
11 conversation that she told us about happened on 11 to pull video, where were they trying to pull
12 - she recalls - that it happened on Thursday, 12 video from?
13 August 8th, Associate Warden also stated 13 MR. : I have no idea. I don't
14 it happened on Thursday, August 8th. 14 really remember that they were trying to pull
15 MR. : Oh, so it must have been 15 video froiiiiiiiii.
16 Thursday. 16 MR. : Which office were you guys
17 MR. : Okay. 17 in?
18 MR. : I'm not too sure because 18 MR. : Probably on the second
19 everythiniiiiiiiiibled in. 19 floor by the - maybe the SIS Office, or it was
20 MR. : Okay. And do you recall 20 in the Video Room.
21 what the issue was with the cameras? 21 MR. : All by the -. What's the
22 MR. : They said they wasn't 22 difference?
23 recording. 23 MR. : The Video Room is where
24 MR. : Was that the only issue 24 they have the monitors and the SI Office is
25 you remember? Was there anything else with the 25 right down the hallway, where the SIS Office
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1 would be. 1 goes to the video matrix, and then it's split,
2 MR. : Okay. And do you remember 2 and it goes to all the other cameras.
3 standing there tr ing to help them pull video? 3 MR. : So, you're saying if it's
4 MR. Yes. 4 in the SIS Shop, and there was issues in the
5 MR. : And when you were trying 5 SIS Shop?
6 to pull video, do you remember looking up at 6 MR. : No, if it was in the SIS
7 the screens and seeing any blank screens? 7 Shop, that's the network. They're on the
8 MR. : In the SIS Shop? 8 computer and they're trying to pull video. If
9 MR. : In the SIS Shop, or on the 9 they're in the Video Room, it's the live feed
10 monitors. There's a lot of monitors. 10 that's goin to the cameras.
11 MR. : Oh, the SIS, that was, 11 MR. : Okay.
12 that has been in and out forever. That was not 12 MR. : And it's inputted on the
13 really working properly even when I got there. 13 screen. It's split going to the recorder, and
14 There's been issues. There was issues with 14 it's split on the output going to the actual
15 that. 15 screens. Yeah.
16 MR. : Can you explain that a 16 MR. : So, which ones had issues
17 little further? 17 where you couldn't see anything?
18 MR. : Okay. So, was it in the 18 MR. : I don't know. Because it
19 Video Room or the SIS Shop? 19 was a lot of stuff not working at that time. I
20 MR. : I'm not sure where this 20 can't reaiiiiiiiii
21 happened, so based on recollection, if you can 21 MR. : Do you remember any
22 tell me, iiiiiiiiicall where this happened? 22 screens being black, like blanked out with X's
23 MR. : If I was looking at 23 on them, iiiiiiiilioint?
24 multiple monitors, it probably was in the Video 24 MR. : I don't know. It was -
25 Room. That's where they have -. The live feed 25 that room was always a mess when I got there,
15 16
1 as far as stuff not working or working. 1 coming from the network. They'd be trying to
2 MR. : But you don't remember 2 pull video from the actual recorders.
3 them, Lieutenant or IIII, mentioning, 3 MR. : So that's where basically
4 hey, listen these screens are blank. There's 4 you can IS
5 X's on them, they're not working. You just 5 MR. : You log in and you try to
6 mentioned that - just on topic - you just 6 pull video.
7 mentioned that there were always issues. 7 MR. • : Okay. So, you can - the
8 MR. : Yes, there were always 8 SIS Shop had the ability to log in --
9 issues. Sometimes, I would go in there and 9 MR. : Yes, pull video.
10 stuff was working. Sometimes, I'd go in there, 10 MR. -- and review video.
11 stuff was not working. Exactly what was 11 MR. : Yes.
12 working or not working, I'm not too sure of. 12 MR. : So, but the other part,
13 MR. : So, which one was it? 13 the video monitoring --
14 Just to clarify. I missed that. Which one was 14 MR. : That's just live --
15 it that wasn't working -- 15 MR. : -- had to be live wired.
16 MR. : So, what -. 16 MR. : -- that's just live wire,
17 MR. : -- the SIS or the Video 17 yeah. That's everything coming in.
18 Room? 18 MR. : And if the live wires were
19 MR. : It would be the Video 19 removed by any chance, would that be a black
20 Room. It wouldn't be in SIS, because -. Okay, 20 screen?
21 the Video Room is the live feed coming from the 21 MR. : Yeah, it would be a black
22 analog matrix onto the actual screens. Some of 22 screen, yes.
23 the cables got disconnected because there was 23 MR. : So ,is it possible this
24 issues. And then SIS, that would be all of the 24 conversatioiliiiit have taken place with
25 cameras in the institution. They would be 25 Lieutenant inside the Video Monitor
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1 Room? If she recalls that there was -- 1 about the live view.
2 MR. : Yeah, if there were 2 MR. : Okay.
3 screens -- 3 MR. : That's something I would
4 MR. • -- screens that -. 4 have to worry about later. But the main thing
5 MR. : -- that's in the Video 5 was to make sure the cameras are recording in
6 Room, yes. 6 the institution.
7 MR. : Black screens, okay. So, 7 MR. : Okay. And so, this
8 do you recall her mentioning on August 8th - by 8 happened, well based on the fact that this
9 any chance, do you recall? I know it's been a 9 happened on Thursday, August 8th, do you recall
10 couple years -- 10 coming in August 9th fixing anything? On
11 MR. : Hmm. 11 August 9th?
12 MR. : -- it's hard to remember, 12 MR. : I'm pretty sure I did. I
13 but do you recall her mentioning anything 13 must have followed up. Because I was going to
14 about, hey, there's blank screens, access that 14 come back Saturday to do something, so I know
15 needs to be fixed? 15 on FridayIII/Llwhen I went back to the room.
16 MR. : I was working on that 16 MR. IIIIIIIII: Okay. I'm going to show
17 since I got there. I was still working on 17 you a memo. There's a memo dated August 10th,
18 that, until I was leaving, so -. It was an 18 from , SIS Lieutenant. That would be
19 ongoing issue I knew about. But the main thing 19
20 was, even if the screens were blank, that 20 MR. : Yeah.
21 everything would be recorded, going to the 21 MR. : To , Captain.
22 recorders. Like, the live view in the Video 22 MR. : Mm-hmm.
23 Room, that's extra. But if you could pull 23 MR. : Subject was "NiceVision
24 video from the recorders, that's the main thing 24 Camera System." And for the record, I'm going
25 I was worried about. I wasn't really worried 25 to read it, and then I'll show it to you.
19 20
1 MR. : Okay. 1 her on August 9th, you told her on August 10th
2 MR. : "On August 8, 2019, at 2 that, when you came into work on August 9th,
3 approximately 3:45 p.m., while reviewing the 3 you fixed the camera issue. Do you recall
4 Nice Camera System, I attempted to recover 4 that?
5 video footage from the Unit 5 South Housing 5 MR. : No. (Indiscernible
6 Unit. At this time, I was unable to recover 6 *00:12:58).
7 any previous recordings from the camera, this 7 So, I was working after 3:4S. So, I was
8 prompting me to review all of the cameras. 8 on overtime that day she called me?
9 None of the cameras on the system were able to 9 MR. : It might have been.
10 record. Therefore I called the communication 10 MR. : Because I leave at 2:00.
11 technician via radio." That would be 11 MR. : So, you -.
12 you, right? 12 MR. You want to just read
13 MR. : Yes. 13 through that a ain --
14 MR. : Okay. "At approximately 14 MR. : Yeah.
15 4:00 p.m., responded to the third floor 15 MR. : Yeah. Read through it for
16 Monitoring Room to check the cameras and 16 yourself.
17 notified me that the cameras were not recording 17 MR. : -- and just -.
18 and there was no way to retrieve any video. 18 MR. : "At approximately 3:45
19 stated he fixed the camera system on 19 p.m. on the Nice System, I attempted to recover
20 Friday, August 9, 2019, when he arrived to 20 -. At the time I was -."
21 work." 21 MR. : There might be some
22 So, it looks like the memo was written on 22 grammatical -.
23 August 10th and this is in regards to a 23 MR. : Yeah, that doesn't really
24 conversation she had with you on August 8, 24
25 2019, and at the end, she stated that you told 25 MR. : Does that seem accurate, to
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1 your recollection? 1 key to get in the room.
2 MR. : No. 2 MR. : Okay.
3 MR. : So, you don't call fixing 3 MR. : I didn't have access to
4 anything? 4 get in the room.
5 MR. : I might have been looking 5 MR. : Because no one was there
6 at something, but I have to make sure that it's 6 in the SIS Sho
7 fixed, like, before I say, hey, you can pull 7 MR. : Yes, nobody was -. Yes.
8 video and I have to pull video myself. 8 MR. : And normally, there would
9 MR. : But she said there's a 9 be someboiiiiiiiiiring the phones, right?
10 possibility that, when you came in on the 9th, 10 MR. : Yes, there should be a
11 you might have fixed the issues with the blank 11 phone monitor, if somebody was there, unless
12 screens. 12 they got ulled to work a different post.
13 MR. : Okay. 13 MR. : Yeah.
14 MR. : And then, you might have 14 MR. : But they're supposed to be
15 came back in on August 10th, which would be 15 - that's be a post.
16 that Saturday, to fix the recording issue. Do 16 MR. : And that Friday, nobody
17 you think that be accurate? 17 was there? On August 9th, I think they had
18 MR. : No. That doesn't really 18 left earl or something to that effect --
19 make any sense to me, either. 19 MR. : Mm-hmm.
20 MR. : Okay. Do you recall if - 20 MR. : -- and then, you couldn't
21 I remember we spoke about this before, I don't 21 get in. Do you recall - Lieutenant
22 know if your memory hasn't recollected any of 22 mentioned to us that Captain had the
23 it - but about you not being able to access the 23 ability to et ou into the room - do you know
24 SIS Shop because no one was in the SIS Shop. 24 if Captain had his own set of keys for
25 MR. : Yeah, and I don't have the 25 that room?
23 24
1 MR. : Yes, he did. 1 MR. : That's not behind glass?
2 MR. : Separate from? 2 MR. : No. I don't know how they
3 MR. : Yeah. The Captain I 3 do the Captain's. I know the SIS Shop, that
4 think, or the SIS could get in that room. I'm 4 was the main key and if I tried to get in, it
5 not too sure. 5 was behind lass, to get in the room.
6 MR. : I know SIS -. Lieutenant 6 MR. : Do you recall approaching
7 had her awn set of keys. 7 Captain , asking him for access to that
8 MR. : Yeah, could get in with a 8 room on August 9th?
9 key. Yeah -- 9 MR. : I don't remember.
10 MR. : Okay. 10 MR. Okay. Because I know,
11 MR. : -- but I think the Captain 11 based on Captain , Captain was in
12 had the key to let me in the room. I'm not too 12 the facility until about 8:00 p.m. on that
13 sure. Honestl 13 Friday night, August 9th? He worked until about
14 MR. You're not certain? 14 8:00 p.m.
15 MR. : I'm not certain. 15 MR. : Hmm. I didn't know that.
16 MR. : So, the SIS Lieutenant's 16 MR. : So, but you don't recall
17 keys are kept behind some kind of box in the 17 ever seeing him, or talking to him, or asking
18 (Indiscernible *00:15:22). 18 for access to that room to fix the cameras?
19 MR. : Yeah, everything is kept 19 MR. : No. I don't remember.
20 behind glass and the technician's, their keys 20 Maybe I did, maybe I didn't. I don't - that's
21 are kept behind glass. And whoever is in the 21 -. I donL112211y-.
22 Video Roolls_itIltehind glass. 22 MR. IIIIIIIII: Okay. But if needed, you
23 MR. IIIIIIIII: Okay. But does the 23 could have asked Captain , he could have
24 Captain have his own set of keys? 24 let you in?
25 MR. : Yes. 25 MR. : He would have locked the -
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1 if he had_112_ke1y. yes, he would let me know. 1 go repair the thing. and just couldn't get in
2 MR. IIIIIIIII: Okay. ASAC 2 because no one was there, or the phone monitor
3 anything on that topic? 3 was leaving. So, we were surprised to see that
4 MR. : Yeah, in regard to the memo. 4 there was a statement that you may have told
5 Mr. , I know that time on August 8th, 5 someone that you had repaired it on August 9th.
6 that seems way off based on what you had told 6 So, we just wanted to confirm whether or not
7 and before, and -- 7 .ro ad told someone, specifically Lieutenant
8 MR. : Mm-hmm. 8 , that you had repaired that system on
9 MR. -- frankly, what had 9 August 9th.
10 told us. The key thing that we yianted to find 10 MR. : I don't believe so, no.
11 out is that last line. The " stated he 11 Because I was still working on it so --
12 fixed the camera system on Friday, August 9th 12 MR. : Okay.
13 when he arrived to work." 13 MR. -- I couldn't do it.
14 MR. : Mm-hmm. 14 MR. : Very good. Th4LLy2u, sir,
15 MR. : So, that's the main thing 15 and that is all I have on that IIIIII, thanks.
16 we just wanted to confirm. 16 MR. : Thank you. Just as
17 MR. : I don't think I did that. 17 normal, can you initial and date it? You're
18 MR. : Yeah, because the last time, I 18 attesting to the accuracy, it's just a document
19 know our guys explored pretty in depth what 19 that we showed ou.
20 happened on Au ust 9th. 20 MR. : Hmm.
21 MR. : Mm-hmm. 21 MR. : Today's the 7th.
22 MR. : That was that Friday where it 22 MR. It's that you reviewed it.
23 sounds like -- 23 MR. : Oh, today is four --
24 MR. : Yes. 24 MR. : 4/7.
25 MR. : -- you got the hard drives to 25 MR. : 4/7/22.
27 28
1 MR. : We can move on to the next 1 going to read this out because it's --
2 topic. 2 MR. : It's very (Indiscernible
3 MR. : Okay. 3 *00:18:26iiIIIIIII
4 MR. : You mentioned, previously 4 MR. : This states the - the
5 and even now, that there was a camera upgrade 5 contract states up top - it says, MCC New York.
6 going on durin that time. 6 And the contract number is GS-07F-, as in
7 MR. : Yes. 7 Frank, 0322T, as in Tom. The award effective
8 MR. : Do you recall if there was 8 date is 9/21/2018. And the order number is
9 a contraciiiiiiiiie for these upgrades? 9 15B-, as in boy, NYM-, as in Mary, 18F-, as in
10 MR. : Yeah, it was supposed to 10 Frank, 1-, as in Tom, P-, as in Peter, 120150.
11 be NiceVision, but we just ended up doing 11 And the requisition number is 1064-18.
12 pretty much everything inhouse because it was 12 Now, that's the document you were
13 taking 13 reviewing, and you believe that is the camera
14 MR. : Okay. I'm going to show 14 upgrade?
15 you a contract. 15 MR. : The initial, probably the
16 MR. : Yes. 16 initial
17 MR. : Do you recognize that 17 MR. : When you say initial?
18 contract? 18 Were theriiiiiiiii?
19 MR. : Yes. This looks like all 19 MR. : Yeah, because they had a
20 the stuff we put in for to upgrade the camera 20 contract. This was the original contract, as
21 system. 21 far as upgrade goes, and then, like a year
22 MR. : lust so -. Give me one 22 later, there was another bid that we put in for
23 second. 23 more upgrades.
24 MR. : Okay. 24 MR. : Okay.
25 MR. : Just for the record, I'm 25 MR. : But this was the original.
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1 MR. : And this is dated when 1 the point of contact?
2 again? 2 MR. : That would be the Facility
3 MR. : 2018. (Indiscernible 3 Manager, whoever that was. Or the General
4 *00:19:31iiiiiiiii/21/2018. 4 Foreman. I'm lust
5 MR. : 2018. Were you involved S MR. : Who?
6 in this? 6 MR. -- in 2018, so that was
7 MR. : Yes. 7 (Piiiiiiiiiiiiii0:20:12)
8 MR. : Who was the point of 8 probably, and then was the
9 contact for this? 9 General Foreman.
10 MR. : Steve Smith. He's, like, 10 MR. had left
11 the head of Nice. And then, but the main 11 by August 2018 right?
12 person I would talk to was Justin Houston, but 12 MR. : Okay.
13 Steve Smith is the brains behind it. I really 13 MR. : And then,
14 wouldn't talk to Steve because he was, like, 14 stepped in?
15 overseeing it. The main person I would talk to 15 MR. : Yes.
16 was Justin Houston. 16 MR. : But said that
17 MR. : Justin Houston. Okay. 17 he never really communicated in regards to
18 MR. : And I called him asking 18 this.
19 him every question, because I never did fiber 19 MR. : Yes.
20 before, or network camera systems, so. 20 MR. : Because he said that he
21 MR. : All right, so Justin 21 doesn't recall the materials arriving --
22 Houston is the Si Net point of contact then? 22 MR. : Mm-hmm.
23 MR. : Yes. 23 MR. : -- or any of that stuff.
24 MR. : Okay. Who was the point 24 MR. : No, he wasn't there when I
25 of contact for BOP then, at the MCC? Who was 25 don't think any of this arrived.
31 32
1 MR. : And he never spoke with -- 1 there?
2 MR. : Anybody. 2 MR. : I don't know. Honestly, I
3 MR. : SigNet. 3 don't. It's around this time, like, August or
4 MR. : SigNet, yeah. 4 July of 2019.
5 MR. : So, who spoke with SigNet 5 MR. : Okay. Can you flip to
6 in regards to the materials and all that? 6 page four of that?
7 MR. : It was just kind of like a 7 MR. : Yes.
8 thing -. I would just call this, every once in 8 MR. : And you mentioned it
9 a while, hey, did the stuff come in, or what's 9 before, right? What was the name of the
10 going on? But there was really -. 10 recording system that was ordered for the MCC?
11 MR. : So, you communicated with 11 The Nice --
12 SigNet? 12 MR. : Nice or -.
13 MR. : Yeah. SigNet, yes. 13 MR. -- the Nice, NiceVision?
14 MR. : Okay. Was there anybody 14 MR. : Yeah, NiceVision. Yes.
15 else that communicated with SigNet? 15 MR. : And that's the type of
16 MR. : No, not until got 16 system that was ordered, right?
17 there. 17 MR. : Yes.
18 MR. : And after that it was 18 MR. Okay. Do you recall - and
19 7 19 this was laced in September of 2018.
20 R. : Yes. 20 MR. : Yes.
21 MR. : Or was it both of you guys 21 MR. : Do you recall when all the
22 together? 22 NiceVision, all that stuff in that order was
23 MR. : It was pretty much 23 delivered to the MCC?
24 He's in c.v. know. 24 MR. : It was coming in piece-by-
25 MR. : Okay. When did get 25 piece.
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33 34
1 MR. : Piece-by-piece. 1 the hard drives would come in. That's the line
2 MR. : Yeah. 2 item two would come in. The decoders would
3 MR. : It wasn't delivered 3 come in. So, that's line item five. AMS would
4 together? 4 come in, line item six. Line item seven would
5 MR. : It might have been, but 5 come in. Oh not - yeah. Line item seven would
6 the warehouse was, like, a mess. So, whenever 6 come in. Cameras never came in. Line item ten
7 they told me I had packages, I would go and get 7 would come in. And the wall mount never came
8 it. 8 in, and a media cabinet. So, that line item
9 MR. : Okay. So, what do you 9 14, yeah.
10 recall, what came in first? 10 MR. : So, they call came in
11 MR. : As far as what came in, 11 around when do ou think?
12 mainly the recorders and the new rack, and 12 MR. : I'm not too sure.
13 probably the UPS. 13 MR. : You think soon after the
14 MR. : Recorders, and what else? 14 order was laced -?
15 MR. : The UPS and the rack that 15 MR. : It was a little while
16 the recorders would go in. 16 because there was stuff on backorder, so it
17 MR. : All right. So, the 17 wasn't, like, ri ht away.
18 terminoloiiiiiiiiiver my head. 18 MR. : So, was it in 2018, '19?
19 MR. : Okay, so just the metal 19 MR. : Probably in the early part
20 hardware that the UPS would go in, and the 20 of 2019.
21 recorders. 21 MR. : Early part of 2019?
22 MR. : So, based on, if you could 22 MR. : Yeah.
23 look at that and tell us what you're thinking, 23 MR. : All right. I'm going to
24 and off of the a e number four. 24 show you an email. This email - I'm going to
25 MR. : So, Nice. So, it would be 25 go back - it looks like it's an email from you
35 36
1 dated October 7th, that's 1 MR. : Like, he responded back
2 That's That's you? 2 with trackin numbers for 2018.
3 MR. : Yes. 3 MR. : 2018. Okay.
4 MR. : It's dated October 7, 4 MR. : Does that help recollect
5 2019. 5 your memoiiiiiiiii about when those -?
6 MR. : October 7. 6 MR. : I don't remember when all
7 MR. : And this is to 7 this stuff -. It was a lot of stuff, and I was
8 that's 8 trying to get space for it, so I'm not -. If
9 MR. : Mm-hmm. 9 that's when they said it came in, that's
10 MR. : John Hodge and Justin 10 probably when it came in.
11 Houston -- 11 MR. : Does that email look
12 MR. : Hmm. 12 familiar?
13 MR. . -- at SigNetinc.com. 13 MR. : Yes. This email looks
14 MR. : Hmm. 14 familiar.
15 MR. : And you were asking, "Just 15 MR. : So, that is a
16 following up on the order for the outside PTC 16 communication between you and Justin, and it
17 cameras ex ected date of delivery." 17 looks like
18 MR. : Mm-hmm. 18 MR. : Yes.
19 MR. : And looked like Justin 19 MR. : -- and Hodge?
20 Houston responded back on Molictober 7th, 20 MR. : Yeah, later on because,
21 2019, right? And he says, " , everything 21 when was this? Yes.
22 was delivered. Most of it on 11/23/2018. The 22 MR. : Who's Hodge?
23 tracking numbers are below." So, it looks like 23 MR. : He's the new contact. He
24 this is in 2019. 24 came in after the Epstein thing.
25 MR. : Yeah. 25 MR. : Okay. And what's the
EFTA00126344
37 38
1 communication about the PTC cameras? 1 some of it got misplaced because nobody knew
2 MR. : Oh, those are outside 2 what it was, so it went to Building Four, the
3 cameras. 3 warehouse.
4 MR. : Okay. 4 MR. : Where's that?
5 MR. : Those didn't really have 5 MR. : That's in Brooklyn. It's
6 nothing to do with the recorders or anything. 6 right next to Steiner Studios.
7 Those are, like, secondary. They had nothing 7 MR. : This is the Brooklyn Navy
8 to do with the recording. Again, the recorders 8 Yard?
9 and stuff. 9 MR. : Yeah, Brooklyn Navy Yard,
10 MR. : But you think - when he 10 yes.
11 says that's in 2018 - you think those are the 11 MR. : What about the other
12 NiceVision recorders and the decoders and all 12 items? You said some went over.
13 that mentioned over here? 13 MR. : I think there was a time,
14 MR. : Yes. 14 Like, maybe this was the other order that the
15 MR. : You think those were 15 decoders got sent over there. Something got
16 delivered - based on Houston's email - it was 16 sent over there, it was sent, and nobody knew
17 delivered in the -. 17 what it was, and so they just sent it to
18 MR. : In the end of November, 18 Building Four.
19 during the holidays, so I probably didn't get 19 MR. : Okay. And who received
20 it until maybe January, the first week of 20 these orders, do ou know?
21 January. 21 MR. : The warehouse.
22 MR. : Okay. Where do you think 22 MR. : The warehouse?
23 these items were stored? Once they got 23 MR. : Yes.
24 delivered? 24 MR. : It was shipped to the MCC?
25 MR. : They were - and I mean 25 MR. : Yes.
39 40
1 MR. : Do you know who signed off 1 that we get stuff in, and there was part of the
2 on these? 2 Lock Shop. So, if I had storage, or didn't
3 MR. : No. 3 have space for it, I would ask the Lock Shop,
4 MR. : Okay. But someone 4 hey, can I put this in your room because I
5 received them and somehow, it ended up in 5 don't haviiiiiiiii
6 Building Four? 6 MR. : And it's locked up, it's
7 MR. : Yes. 7 secured?
8 MR. : Okay. And what about - 8 MR. : Yes, secured. Yeah.
9 you said that's some of them - what about the 9 They're the only ones with a key. Nobody else
10 other items? Was there anything housed at the 10 could get in there.
11 MCC? 11 MR. : So, we mentioned
12 MR. : Yeah. I had the 12 everything that's on there, pretty much all the
13 recorders, and I had the rack. I had it stored 13 NiceVision equipment, except for the cameras.
14 downstairs or in another room. I remember, 14 MR. : Hmm.
15 because it was important, so I made sure when I 15 MR. : What happened to the
16 came in, I ut it in MCC. 16 cameras?
17 MR. : Where? 17 MR. : That's what happened. I
18 MR. : So, we didn't have to go 18 think the cameras went to Building Four. I was
19 look for it. It might have been in the 30 19 looking for it, and that's what ended up at
20 Percent Room or in my Video Room, but I think 20 Building Four and maybe some decoders.
21 it was in the 30 Percent Room. 21 MR. : So, you think all, but
22 MR. : What's the 30 Percent 22 that's - you mentioned right now that all the
23 Room? 23 NiceVision e ui ent ended up there.
24 MR. : It's, right before you go 24 MR. : Hmm.
25 to the loading dock, there's like a Ready Room 25 MR. : So, you think the cameras
EFTA00126345
41 42
1 also got lsi l, 1 MR. : Hmm.
2 MR. : Yes. Well, they might 2 MR. : -- around this time or
3 have got shipped, but nobody told me. Whenever 3 back in November 2018? So, that's two
4 they came in came in. I'm not too sure. 4 differentiiiiiiiiiwe're talking about.
5 MR. : You're not sure what S MR. : Yeah, two different
6 happened to the cameras? 6 timing, yeah.
7 MR. : Yeah. 7 MR. : So, when do you think the
8 MR. : Do you believe the cameras 8 cameras and sent to -?
9 got shipped or no? 9 MR. : I think the cameras came
10 MR. : Yeah, they got shipped, 10 later.
11 but they ended up going to Building Four. 11 MR. : Okay.
12 Whenever they came in because I remember 12 MR. : The recorders and
13 looking for them and that was one of the 13 everythin came right away.
14 things, I had to figure out what happened to 14 MR. : Okay.
15 the actual - because we were going to network 15 MR. : Yeah.
16 cameras - so I had to figure out where they 16 MR. : So, when do you think the
17 were at. And they weren't at the rear gate. 17 cameras came?
18 MR. : Okay. When do you recall 18 MR. : Probably after all of
19 looking for them? 19 this, so ma
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