EFTA00114414.pdf

1 2 APPEARANCES: OFFICE OF THE INSPECTOR GENERAL BY: BY: WITNESS: DIGITALLY RECORDED SWORN STATEMENT OF OTHER APPEARANCES: NONE OIG CASE #: 2019-010614 DEPARTMENT OF JUSTICE OFFICE OF THE INSPECTOR GENERAL AUGUST 4, 2021 RESOLUTE DOCUMENTATION SERVICES Suite 285 Agoura Hills CA 91301 Phone: 3 4 1 MR. : The recorder is on. My 1 MR. : And you, sir? 2 name is , and I'm a Senior 2 MR. : I am Correctional Counselor 3 Special Agent with the U.S. Department of 3 . 4 Justice, Office of the Inspector General, New 4 MR. : Correctional Counselor? S York Field Office, and these are my S MR. : Yes, sir. 6 credentials. This interview with Federal 6 MR. : And what did you say 7 Bureau of Prisons employee is 7 that, what level was that? Nine? 8 being conducted as part of an official U.S. 8 MR. : GS-9. 9 Department of Justice, Office of the Inspector 9 MR. : GS-9. Great. Thank you, 10 General investigation. Today's date is August 10 sir. This is an official DO]/OIG investigation 11 4, 2021, and the time is 9:24 a.m. This 11 into the death of inmate Jeffrey Epstein, and 12 interview is being conducted at the 12 the surrounding circumstances, and you are 13 Metropolitan Correctional Center, known as the 13 being asked to voluntarily provide answers to 14 MCC, located in New York, New York. Also 14 our questions. Will you agree to a voluntary 15 present is DOJ/OIG Special Agent 15 interview with the DO]/OIG? 16 Do you want to show him your credentials? 16 MR. : Yes. 17 MR. : Thank you. 17 MR. : Thank you, sir. We have 18 MR. : This interview will be 18 a form, it's the DO]/OIG form 3-226/2. It's 19 recorded by me, SSA Could 19 the United States Department of Justice, Office 20 everyone please identify themselves for the 20 of the Inspector General, Warnings and 21 record and spell your last name? To start, 21 Assurances to Employee Requested to Provide 22 wain I am DOJ OIG Senior Special Agent 22 Information on a Voluntary Basis. "You are 23 23 being asked to provide information as part of 24 MR. I am DO]/OIG Special Agent 24 an investigation being conducted by the Office 25 , 25 of the Inspector General. This investigation EFTA00114414  5 6 1 is being conducted, pursuant to the Inspector 1 MR. : Thank you. All right. 2 General Act of 1978, as amended. This 2 The date and time, Wednesday, August -- 3 investigation pertains to job performance 3 MR. : Fourth. 4 failure and security failure. This is a 4 MR. : -- 4, 2021, and the time S voluntary interview. Accordingly, you do not S is 9:26 a.m. now. So, 8/4/21, at 9:26 a.m. 6 have to answer questions. No disciplinary 6 Place: MCC, New York. I am s tiring as the top 7 action will be taken against you if you choose 7 line. Once again, this is , 8 not to answer questions. Any statement you 8 and printing below. Special Agent , can 9 furnish may be used as evidence in any future 9 you just sign as a witness and then put your 10 criminal proceedings or agency disciplinary 10 name below? Thank you. 11 proceedings, or both." 11 MR. : This is Agent . I'm 12 And there's a waiver section. It says, "I 12 signing as a witness and printing my name. 13 understand the Warnings and Assurances stated 13 MR. : All right. So, before we 14 above, and I am willing to make a statement and 14 start the interview I would like to place you 15 answer questions. No promises or threats have 15 under oath. Mr. , can you please raise 16 been made to me, and no pressure or coercion of 16 your right hand? Do you swear to tell the 17 any kind has been used against me." If you 17 truth and nothing but the truth during this 18 want to take a second to look at that, if you 18 interview? 19 agree with it, you can, there's an employee 19 MR. : Yes. 20 signature where you would sign, and then you 20 MR. : Thank you, sir. What is 21 would print your name under here, where it says 21 your date of birth? 22 employee's name. 22 MR. 23 Thank you, sir, for signing. Do you 23 MR. : And our SSN? 24 understand the form? 24 MR. . 25 MR. : Yes. 25 MR. : Thank you. And your 7 8 1 current home address? 1 want to make sure that everything that they 2 MR. : , Bayville, 2 wrote is accurate. 3 New York, 11709. 3 MR. : Uh-huh. 4 MR. : And your current 4 MR. : And just stop me if S cellphone number? S anything is not accurate. 6 MR. . . 6 MR. : Okay. 7 MR. : And what is your current 7 MR. : All right. It says, "The 8 position wain? 8 following interview was conduciiiiiilAssistant 9 MR. : Correctional Counselor. 9 United States Attorne , AUSA, 10 MR. : And how long have you 10 , , and Office of the 11 been in that 'osition? 11 Insiector General, Special Agent 12 MR. : Since February 2020. 12 . Also present for the interview was 13 MR. : Okay. And what were you 13 Federal Bureau of Investigation Special Agent 14 prior to that? 14 11 15 MR. : A Lieutenant. 15 ," and it says your date 16 MR. : Great. Were you 16 of birth, "was interviewed at the United States 17 previously interviewed under this 17 Attorney's Office, , New 18 investigation? 18 York, New York. After being advised of the 19 MR. : Yes. 19 nature of the interview, and the identities of 20 MR. : All right. Awesome. I'm 20 the interviewing AUSA and Special Agents, 21 just going to review the report that was 21 $ ovided the following information." 22 generated, based upon your interview. I'm 22 " stated he worked for the Bureau 23 going to go kind of, a little slower through 23 of Prisons, BOP, since approximately January 24 it, so that you can actually grasp and 24 15, 2001." 25 understand what it is that they wrote. I just 25 MR. : Yes. EFTA00114415  9 10 1 MR. : "Prior to employment with 1 largely on which area of the prison he or she 2 the BOP, worked for the Building and 2 was assigned to, which rotated on a quarterly 3 Maintenance Union, the Marine Corps Reserve, 3 basis." 4 and the New York Police Department Auxiliary." 4 MR. : Yes. S MR. Yes. S MR. : "Those duties include 6 MR. : . stated he joined 6 operations, activities, solitary housing, 7 the BOP as a Correctional Officer and was 7 special investigations, and administration, as 8 promoted to Lieutenant in October 2015." 8 well as possible collateral duties, such as 9 MR. : Yes. 9 emergency irotection." 10 MR. : "He spent one year at the 10 MR. : Emergency preparedness. 11 Federal Correctional Institution, Fort Dix, 11 Same thin'. 12 when he first joined the BOP and had spent the 12 MR. : Okay. Preparedness? 13 remainder of his tenure at the Metropolitan 13 MR. : It would be the EPO is what 14 Correctional Center." 14 the title was. 15 MR. : Yes. 15 MR. : Sure. I understand. 16 MR. : "Captain 16 " stated he was assigned as the 17 was his supervisor." 17 Activities Lieutenant at the time of the 18 MR. : Yes. 18 interview, and worked the regular 2 p.m. to 10 19 MR. : Who is your supervisor 19 p.m. shift." 20 now? 20 MR. : Yes. 21 MR. : Right now, it's 21 MR. : And then on the daily 22 (Phonetic Sp. *00:06:15) He's my Unit 22 schedule, it actually listed 4 to 12, correct? 23 Manager. 23 You just came in two hours early? 24 MR. : Okay. " stated a 24 MR. : Well, what lieutenants were 25 GS-9 Lieutenant's responsibilities depend 25 doing, we always did two hour reliefs for each 11 12 1 other. 1 Watch Lieutenant would roll in, if they're 2 MR. : Okay. But if I was to 2 going by 8 to 4. Cause I, as an Evening Watch 3 actually look at that daily schedule -- 3 Activities Lieutenant, I worked 2 p.m. to 10 4 MR. : I believe it would show 4 to 4 p.m. But if, like, if the Day Watch Lieutenant 5 12, or actually, if it was activities, S was still there 8 to 4, I would be working two 6 Activities Lieutenants at that time were 6 to 2 6 hours with him or her. 7 and 2 to 10. Operations Lieutenants were on 7 MR. : Yeah, so, I guess what 8 the 8 to 4, 4 to 12, 12 to 8 rotation. 8 I'm asking is, I thought at this time, in 9 MR. : Okay. I see what you're 9 August of 2019, they were allowing the Ops 10 saying. So, there's no actual two hour change, 10 Lieutenants to come in two -- 11 when you're looking at an Activities 11 MR. : We were. We were doing two 12 Lieutenant? 12 hour reliefs for each other. 13 MR. : Yeah, no. 13 MR. : So, you were actually 14 MR. : It is what the actual 14 working the same hours? 15 daily assiiiiilioster said? 15 MR. : Same hours. 16 MR. : It is what the time, yeah. 16 MR. : Okay. 17 I forgot what the, it's been a while. I forgot 17 MR. : Yes, sir. 18 the shift number. 18 MR. : Great. So, you were, 19 MR. : Absolutely. But, so, the 19 both Ops and Activities were 2 to 10 at the 20 Activities and the Ops Lieutenant were working 20 time? 21 the same hours? 21 MR. : Yes. 22 MR. : They will, they piggyback, 22 MR. : Perfect. 23 but let's say, like, the 2 p.m. Activities 23 MR. : Well, I think that's what I 24 Lieutenant, I would be here on the, still under 24 was assigned to. I can't recall 100%. 25 the Day Watch Lieutenant, and then the Evening 25 MR. : Sure. And these are -- EFTA00114416  13 14 1 MR. : When I got interviewed. 1 shifts with other officers." 2 MR. : Sure. So, I'm going to 2 MR. : We're not officers. We're 3 give you, right now, the daily assignment 3 lieutenants. 4 rosters for both Friday, August 9, 2019, and 4 MR. : That's probably what they S Saturday, Au ust 10, 2019. S (Indiscernible *00:09:11). 6 MR. : Uh-huh. 6 MR. Okay. 7 MR. : It's just so that, if it 7 MR. : : So, switched shifts with 8 helps you refresh your memory, cause we're 8 other lieutenants, to be able to fill in for 9 tiiiiiiiabout so long ago. All right. 9 the Activities Lieutenant, is what you're 10 " stated he was assigned as the 10 saying? 11 Activities Lieutenant at the time of the 11 MR. : Yeah. Or, a lot of the 12 interview and worked the regular 2 p.m. to 10 12 times, we •ot mandated to stay. 13 p.m. shift. His regular days off were Mondays 13 MR. : Right. But only 14 and Tuesdays. He would, on occasion, work 14 lieutenants could actually fill those 15 overtime hours or switch shifts with other 1S positions is what you're saying? 16 officers." 16 MR. : Yeah. Only, well, a 17 MR. : Wait, I'm sorry. Can you 17 lieutenant, only a lieutenant can fill an 18 read that wain? I apologize. 18 Operations Lieutenant. 19 MR. : Absolutely. Okay. So, 19 MR. : Correct. 20 after the 2 p.m. to 10 p.m. shift, which we 20 MR. : You could have a GS-8 21 just discussed. 21 Officer cover as an Activities Lieutenant. 22 MR. : Uh-huh. 22 MR. : Okay. 23 MR. : It says, "His regular 23 MR. : Cause, like, that Friday 24 days off were Mondays and Tuesdays. He would, 24 evening, the night before, I was Operations and 25 on occasion, work overtime hours or switch 25 I had an 8 as my Activities Lieutenant. I had 15 16 1 an officer actin. as Activities. 1 officer. 2 MR. : Okay. So, then, people 2 MR. : Okay. 3 could switch that were officers? 3 MR. : She was my Activities that 4 MR. : No. Only, a lieutenant 4 night. S can't switch with an officer to fill a post. S MR. : I got you. All right. 6 They can backfill, if there's, a lieutenant 6 "As there were no Activity Lieutenants assigned 7 calls in sick. If a lieutenant is not there. 7 during the overnight hours, he had no relief 8 MR. : Okay. So you can't -- 8 officers." I don't know why they would have 9 MR. : They can use a GS -- 9 wrote that sentence in there. So, I'm going to 10 MR. : -- you can't ask an 8, 10 read thi2magraph again, just to help clarify 11 say, hey, can you switch with me? It's only if 11 this. "IIIIIII stated he was assigned as the 12 -- 12 Activities Lieutenant at the time of the 13 MR. : No. Like, as an Activities 13 interview and worked the regular 2 p.m. to 10 14 Lieutenant, I would have to call in sick to the 14 p.m. shift." 15 Captain. If I wanted a shift off, I could 15 Again, on Friday, August 9,12gliere 16 switch with another officer. I can't 16 actually the Ops Lieutenant and 'I'll' was the 17 necessarikSi sp with an 8 officer. 17 Activities Lieutenant. It says, "His regular 18 MR. : Okay. And looking at 18 days off were Mondays and Tuesdays. He would, 19 this daily assignment roster, I'm assuming you 19 on occasion, work overtime hours or switch 20 noticed that were actually Ops Lieutenant? 20 shifts with other lieutenants." And in this 21 MR. : Yes. I was Evening Watch 21 case, again, ou explained -- 22 Operations the night before. 22 MR. : Uh-huh. 23 MR. : On August 9th? And then 23 MR. : -- that you can't 24 was actually an 8, Acting Lieutenant? 24 actually switch with lieutenants, only if you 25 MR. : Yeah, she was a GS-8 25 get bumped and that position is filled, can an EFTA00114417  17 18 1 8 officer -- 1 There's only an Activities Lieutenant until 10 2 MR. : Yes. 2 p.m. 3 MR. : And then it says, "As 3 MR. : Right. " stated 4 there were no Activity Lieutenants assigned 4 the responsibilities of an Activities S during the overnight hours, he had no relief S Lieutenant include making rounds and placing 6 officers." You weren't doing overnight? 6 inmates in Special Housing. During rounds, 7 MR. : No. I got relieved and went 7 they ensure officers are properly carrying out 8 home that evenin'. 8 their job responsibilities and give the inmates 9 MR. : I'm not exactly, were you 9 the opportunity to address with them any 10 doing overtime shifts for the morning watch? 10 concerns. stated he often attempted to 11 Is that wilHie would have wrote that? 11 walk all the tiers, based on time." 12 MR. : It could possibly be. I 12 So, on this, we have heard different 13 mean, we worked overtime shifts constantly. At 13 things from different people. As an Ops 14 one point in time, we were short-staffed 14 Lieutenant, or an Activities Lieutenant, are 15 lieutenants like you wouldn't believe. We were 15 you required to go into the SHU, and I'm 16 filling this building with five or six 16 talking specifically at this time, so August 17 lieutenants, we were running the whole 17 9th, August 10th of 2019. Was a lieutenant, or a 18 building. That's one of the reasons why I 18 SHU lieutenant, was a lieutenant responsible to 19 became a counselor. I was never home. 19 go to the SHU and walk the tiers and do a round 20 MR. : Okay. So that is a 20 with the inmates? 21 little confusing. What it's trying to say, 21 MR. : With the inmates? 22 though, is that if you're the Ops Lieutenant, 22 MR. : Yeah. So -- 23 on the morning watch, there is no Activities 23 MR. : Well, a lieutenant is 24 Lieutenant? 24 supposed to, is mandatory, supposed to make 25 MR. : No. Yeah, that, no. 25 rounds. 19 20 1 MR. : So what is the definition 1 actual round, you have to actually walk the 2 of a lieutenant round? 2 tiers. Diiiiiiinow that to be the case? 3 MR. : A lieutenant round? Well, 3 MR. : Well, yeah. Cause the 4 in the Special Housing or general pop? 4 officer has to let you down range. S MR. : Let's talk just Special S MR. : Okay. 6 Housing. 6 MR. : The officer has the grill 7 MR. : Okay. Special Housing, one, 7 key. Nobody could just go down range in SHU. 8 the lieutenant walks through the 27 door, 8 MR. : Sure. 9 that's the outer door of the SHU. Sign in, in 9 MR. : So, the officer would have 10 the log book. Go in, go, sit down on the 10 to open the grill. You go down range and then 11 computer, login, do the True Scope rounds. Got 11 have to sign the rounds sheet at the end of 12 to enter your rounds in SHU. Go up to 10 12 each range. 13 South. Make the rounds up there. Same thing. 13 MR. : And I think I understand 14 Enter the information in True Scope. 14 what you're saying. You're saying sometimes, 15 MR. : So, when you go into 9 15 there just wasn't time to do it -- 16 South, though, and you're entering in that you 16 MR. : Uh-huh. 17 conducted a round, what does the round entail? 17 MR. : -- but does that actually 18 MR. : Well, making sure that the 18 constitute a round, actually walking down the 19 officers are doing their job. And like I said, 19 range for a lieutenant? 20 if time permits, if you can, you know, do it, 20 MR. : Well, not so much, the 21 go down the range. Go one range, two ranges, 21 officers are supposed to be making the 30 22 three ranies. 22 minute rounds. 23 MR. : And that's where, so, 23 MR. : Sure. 24 this is where we have gotten, some people are 24 MR. : The lieutenant just has to 25 saying they had to do, in order to conduct an 25 make sure that that that, he or she has to go EFTA00114418  21 22 1 in that unit and make sure that the officers 1 purpose behind the 30 minute log book. 2 are doing their rounds. Check the rounds 2 MR. : Right. 3 sheets or the log book, log into True Scope, 3 MR. : The 30 minute round sheets. 4 and, you know, make, basically, is that 4 MR. : Okay. " stated on S lieutenant is confirming that staff are doing S weekdays, the prison takes a count at 4 p.m. 6 their job. 6 The Activities and Operations Lieutenant take a 7 MR. : So, the lieutenant didn't 7 verbal count by speaking with each unit and 8 actually have to walk the tiers? 8 match that number with the count slip from 9 MR. : No. 9 Internal. If correct, they clear the 10 MR. : Okay. 10 institution count. They cannot clear a count 11 MR. : No. 11 until they receive a good verbal count from 12 MR. : And the ranges? All 12 every unit. He was not aware of any instances 13 right. So, that was your understanding? So 13 in which the count was cleared without speaking 14 when you're assigning the actual round that you 14 with ever unit." 15 conducted, it's to say that you basically did a 15 MR. : No. 16 round with your officers, to ensure they were 16 MR. : So that's correct, 17 doing their ob? 17 though? 18 MR. : Their job, and you go into 18 MR. Yeah. Yeah. 19 the 10 South and do the same. 19 MR. : . stated he would 20 MR. : Okay. But not that 20 attempt to watch the camera monitors as the 21 you're actuall conducting a round? 21 corrections officers performed the count to 22 MR. : Huh-uh. 22 ensure officers were properly counting. He 23 MR. : Like, as far as 23 could not monitor at all times, due to the 24 conductiniiiiiiind with inmates? 24 amount of activity in the Control Room." 25 MR. : No. No, that's, the whole 25 MR. : Well, it depends. During 23 24 1 the count m job is mainly taking the count. 1 that? 2 MR. : Right. 2 MR. : Yes. 3 MR. : You know, I could look up at 3 MR. : And about how many people 4 the cameras, you know, but you have a lot of 4 are present in Control when that count is being S movement oin around in Control. S conducted? 6 MR. : Sure. 6 MR. : If we're fully staffed, 7 MR. : You know, throwing keys. 7 we'll have two officers and the lieutenant in 8 If, let's, and there's been many times where we 8 the Control Center. 9 were so short-staffed, we had one officer in 9 MR. : Okay. Okay. So it's 10 Control. 10 three peoile in there? 11 MR. : Uh-huh. 11 MR. : Yeah. It's the Control Room 12 MR. : So, while I'm taking the 12 Officer, the C&A Officer, and it would be the 13 count, I'm also doing C&A. I'm helping him 13 lieutenant, Activities or Ops. 14 throw keys. You know, but as far as clearing 14 MR. : What does C&A stand for? 15 the count, yes. You cannot clear the count 15 MR. : Counts, truth be told, I 16 until you get a verbal, verbal, good verbal 16 have a total brain (Indiscernible *00:17:03). 17 count from the Unit Officer, cause we have the 17 Count -- 18 PP1, the El, in front of us with the actual 18 MR. : So, it's like Control 19 accurate count, as per Sentry. So we have to 19 Number 1, Control Number 2 -- 20 compare those numbers. You write it down. We 20 MR. : Two, yeah. 21 compare it. So, you cross it off on the Sentry 21 MR. : -- and you're saying 22 paperwork... ol I'll call in a good count. 22 Control Number 2 is -- 23 MR. : But, as far as, like, the 23 MR. : Control Number 2 is C&A. 24 4 p.m. count, the Activities or Ops Lieutenant 24 MR. : Okay. 25 has to actually be present in Control to do 25 MR. : Old school, it used to be EFTA00114419  25 26 1 called C&A. 1 10. 2 MR. : Okay. 2 MR. : So, as far as the 4 p.m. 3 MR. : I know it's Counts and 3 count, that would not have been ? 4 Accountability, I think is what the acronym 4 MR. : Well, viould have been 5 was. 5 in Control, cause he would have been the 6 MR. : Okay. So that's the 6 Control 1 Officer. 7 person who actually, like, receives the counts 7 MR. : Oh, I thought it was 8 from people? 8 Control 2 for him. 9 MR. : Yes. 9 MR. : Control, no, Control 1, 10 MR. : Is that what you're 10 is Control 1 and is Control 2. 11 saying? 11 MR. : Oh, okay. So, okay. So, 12 MR. : C&A is the one that does all 12 what would Control l's typical responsibilities 13 the Sentry work for all the movement, you know, 13 have been? 14 to make sure the roster is accurate, the 14 MR. : At 4:00, the same thing. At 15 counts, or the unit base counts and unit counts 15 4:00, people are leaving, so that person would 16 are accurate. 16 be over at the window, throwing keys. We call 17 MR. : That's Control Number 2? 17 it throwin ke s. 18 MR. : Yeah. 18 MR. : Okay. 19 MR. : So, in this case, if 19 MR. : It's just, it's an 20 you're looking at August, Friday, August 9, 20 expression. He would be taking the keys, 21 2019, would that Control Officer Number 2, can 21 radios, OC and stuff like that from the 22 you tell me who that would have been? 22 departing staff, putting it back on the board, 23 MR. : (Phonetic2. 23 giving them their chits and receiving chits for 24 1)0:17:49) for the 6 to 2 shift, and IIII 24 equipment for the oncoming staff. 25 (Phonetic Sp. *00:17:51) for the 2 to 25 MR. : Okay. So, in this case, 27 28 1 it should have been, at least at 4 p.m., the 1 Again, you said that you might glance up, but 2 person that would be signing the documents and 2 you're not actually, like -- 3 taking the count should have been this 3 MR. : Yeah. Yeah, I wasn't 4 and not 2 4 staring. S MR. : With the lieutenant. S MR. : Sure. Absolutely. 6 MR. : With the lieutenant. 6 MR. : You know? I would be 7 Okay. And after we're done with this, we'll 7 answering the phones, writing down the actual 8 just go over some of the counts, just to -- 8 count -- 9 MR. : Okay. 9 MR. : Totally. 10 MR. : But we'll move on, just 10 MR. : -- you know, the crossing 11 to make sure we can keep moving on this. I'm 11 off, and, you know, making the, especially if I 12 just going to read it over to, I can't remember 12 had seen that, like, if a count was being 13 exactly where I left off. 13 delayed, I would be, like, what's the problem? 14 MR. : Fourth paragraph. 14 And I would look. You know. 15 MR. : Third_p_lagraph? 15 MR. : I got you. So, you're 16 MR. : Fourth. M stated he 16 not, like, yeah, making sure they're doing 17 was normally relieved (Indiscernible *00:19:24) 17 their job -- 18 before 10 •.m. 18 MR. : It's not, I'm not glued to 19 MR. : I'm just to read 19 the camera. 20 this last paragraph over. "IIIIIII stated he 20 MR. : -- cause you have your 21 would attempt to watch the camera monitors as 21 own job to be doing, is what you're saying? 22 the corrections officers performed the count to 22 MR. : Yeah. 23 ensure officers were properly counting. He 23 MR. : Okay. " stated he 24 could not monitor at all times, due to the 24 would normally relieve, be relieved before 10 25 amount of activity in the Control Room." 25 p.m., prior to evening count. He had heard of EFTA00114420  29 30 1 an instance where the count was not properly 1 in the past." Any information on that? 2 completed, but he had, but it had been some 2 MR. : No. I mean, it was 3 time in the past." So, if you're that 2 to 10 3 probably, I remember when I said that. It was, 4 shift, do you do the 4, the relieving shift 4 you always hear of the horror stories, and when S would typically do the 10 p.m., is what you're S you come home, come in off your days off, you 6 saying? 6 would be, like, oh, you know, what happened the 7 MR. : Yes. 7 other day? Or this, that, and the third. You 8 MR. : Okay. Do you ever do the 8 know. 9 10 p.m.? 9 MR. : Right. 10 MR. : On nights that I was coming 10 MR. : That kind of thing. 11 in for the overni'ht. 11 MR. : Okay. 12 MR. : But, I mean, as the 2 to 12 MR. : But I have never heard it 13 10 shift, do ever do the 10 p.m.? 13 where it has been detrimental. 14 MR. : I probably have, but I can't 14 MR. : Okay. But it wasn't 15 even recall when the last time I was. 15 talking specifically about, like, August 9th 16 MR. : Yeah, yeah. It's 16 (Indiscernible *00:21:12). 17 typically that relieving officer's duty, 17 MR. : No, no. I'm talking, like, 18 though? 18 ten years. I wasn't even a lieutenant at the 19 MR. : Yeah. The relieving 19 time. 20 lieutenant. 20 MR. : Okay. 21 MR. : Lieutenant, right. 21 MR. : You know, I was still an 22 MR. : Yeah. 22 officer. 23 MR. : And then it says, "He had 23 MR. .. " stated, as a 24 heard of an instance where the count was not 24 lieutenant, he viorked to enforce policy through 25 properly completed, but it had been some time 25 verbal counseling and by example. Taking the 31 32 1 count is one of the most important duties 1 them doing the K2 or, you know, making weapons 2 corrections," I keep on saying corrections, but 2 or tattooin' or things of that nature. 3 I know it's correctional officers "perform as 3 MR. : Sure. 4 professionals." 4 MR. : You know, so, of course, S MR. : Right. It's accountability. S making rounds, being visible. That's what we 6 Inmate accountability is the most important 6 like to say, and, like, when we're training or 7 thing here. Maintain security. 7 whatever. Be visible. 8 MR. : Okay. 8 MR. : Sure. 9 MR. : You got to make sure that 9 MR. : Make the inmates see you. 10 they're all here at the end of the day. 10 MR. : So, counts are basically 11 MR. : So, are you saying, like, 11 to ensure everybody is there. And rounds are 12 basically, counts and rounds are the most 12 to ensure that inmates are kind of doing what 13 important things that a correctional officer 13 they're su osed to be doing? 14 does? 14 MR. : Yes. 15 MR. : Count, I mean, everything, 15 MR. : Okay. 16 controlling contraband, shaking down. 16 MR. : And that's a perfect, what's 17 Nowadays, with the K2, it's ridiculous. 17 the word I'm looking for? Perfect expression. 18 MR. : Right. 18 MR. : Okay. Perfect example. 19 MR. : You know, there's a lot on 19 Okay. 20 an officer's shoulders. 20 MR. : Yeah. 21 MR. : Right. 21 MR. : " stated the 22 MR. : But of course, you know, we 22 Special Housing Unit is responsible for doing 23 only do the counts at certain periods 23 rounds every 30 minutes. As the lieutenant, he 24 throughout the day. You know? The officers 24 would sign round forms, if they were correct. 25 making rounds are what helps reduce the fact of 25 He had never signed off on forms that were EFTA00114421  33 34 1 filled out in advance, and would report any 1 MR. : But you never really, you 2 instances of that to his supervisors, if he was 2 never witnessed it? 3 aware of it." So, I'm assuming what you mean 3 MR. : But, I was trained 4 there is, if you knew they were filled out in 4 differently. I was trained, you don't put your S advance? S ink to paper unless it's the way it's supposed 6 MR. : I wouldn't sign them. 6 to be, and if it is, tell the boss. 7 MR. : Right. 7 MR. : Now, back then, August of 8 MR. : I'm not putting my John 8 2019, had you heard that people were filling 9 Hancock on that. I would tell them 9 them out in advance? 10 (Indiscernible *00:22:58). 10 MR. : No. I didn't. 11 MR. : But, how would you know 11 MR. : No? 12 if they had filled it out in advance? You 12 MR. : No. 13 mean, if -- 13 MR. : Okay. So you're not 14 MR. : If I went there and sat, and 14 aware of anybod filling them out in advance? 15 if I walked into the SHU unit and it was 1:00, 15 MR. : No. I have no personal 16 I'm just throwin the time out there -- 16 knowledge. 17 MR. : Sure. 17 MR. : "He trained officers to 18 MR. : 1:00 p.m., but I saw the 18 defer their round patterns, so inmates would 19 rounds sheet, it was 1:00 when I walked in, but 19 not be aware of their timing." 20 I look at the rounds sheet and the 1:30 rounds 20 MR. : Yes. 21 are alread filled out. 21 MR. : And that means it's just 22 MR. : And would that happen? 22 not to be on an exactly 30 minute -- 23 MR. : Very rarely. But I might, I 23 MR. : Yeah. Don't always make 24 don't think I have seen it as a lieutenant, but 24 your rounds at 1:05, 1:35, 1:45. Alternate 25 I have heard of it happening. 25 your rounds. The policy states, every 30 35 36 1 minutes, not to exceed 40. 1 fact, that people weren't conducting their 30 2 MR. : Right. 2 minute rounds? 3 MR. : You know? 3 MR. : The only thing I heard is 4 MR. stated he had 4 the same thing everybody else has heard, out on S heard stories of officers not completing their S the street. 6 30 minute rounds in the SHU. Other than the 6 MR. : Okay. 7 Jeffrey Epstein death, he had not heard of an 7 MR. : What you hear in the media, 8 instance for a roximately five to ten years." 8 what you hear on social media, what you hear in 9 MR. : Yes. 9 the newspa ers. They were very quiet here. 10 MR. : So, I'm assuming what 10 MR. : Okay. 11 you're sa in here is -- 11 MR. : I was here that morning of, 12 MR. : Back in the days. 12 after the fact, and we didn't get told 13 MR. : But I'm assuming what you 13 anything. 14 said, when you say other than Jeffrey Epstein, 14 MR. : Are you talking about 15 you did hear that they did not complete their 15 August 10th? 16 30 minute rounds? 16 MR. : Yeah. That Saturday. 17 MR. : I mean, bureau-wide. People 17 MR. : Okay. 18 have gotten in trouble for it before. 18 MR. : You know. There was a total 19 MR. : Right. 19 blackout. We were kept in the dark. 20 MR. why, like, this 20 MR. : And you hadn't heard 21 whole, this was all new with the fact that how 21 anything about, like, people not conducting 22 serious it ot. 22 counts or rounds? 23 MR. : Okay. But you had heard 23 MR. : No. Just, well, like I 24 that, had you heard that on August 9th and 10th, 24 said, the same thing you heard out on the 25 then, and I am assuming this means after the 25 street. EFTA00114422  37 38 1 MR. : But, I mean, not from 1 MR. : I would just assume 2 inside the institution? 2 people would have been talking inside the 3 MR. : No. 3 institution. I wanted to make sure that you 4 MR. : No one was speaking about 4 also heard it inside the institution, not just S that? S through the media? 6 MR. : Well, I mean, the whispers, 6 MR. : Yeah. No, I mean, I, like, 7 here and there but nothing was confirmed. 7 as far as a whisper here and a rumor here, I 8 MR. : Okay. 8 chose to stay away from it, because, one, I was 9 MR. : You know? Of course, when 9 a supervisor and two, I know what was coming 10 something like this, look, it's, I have been 10 down. 11 doing this almost 21 years. When something, 11 MR. : Sure. 12 God forbid happens like this, everybody Monday 12 MR. : I knew how serious it was 13 morning quarterbacks. 13 going to be. And I was not going to entertain 14 MR. : Sure. 14 any of that. 15 MR. : Everybody talks, oh, they 15 MR. : Sure. So, you had heard 16 must have done this, or they didn't do this. 16 people saying that there were rounds and counts 17 That's all I have heard. 17 weren't complete; however, you didn't put any 18 MR. : Uh-huh. 18 credibilit to it -- 19 MR. : I didn't hear nothing 19 MR. : No. 20 official, if that's what you're asking. 20 MR. : -- because it wasn't 21 MR. : Yeah. No, no, no. 21 official? 22 MR. : I have heard rumor mills. 22 MR. : No. It wasn't, it wasn't 23 MR. : I just wanted to know -- 23 official. It was just rumor mills. It was 24 MR. : There were whispers. This, 24 whispers. It was Monday morning 25 that, and the other thing. 25 quarterbacking, for lack of better terms. 39 40 1 MR. : Okay. But that was a 1 what you're saying is that since you have 2 correct, was that a correct assessment, which I 2 worked, miiiiiiiere was about two suicides? 3 just -- 3 MR. : I had one, I was personally 4 MR. : Yes. Yes. 4 involved in one in 2003, and that's the one S MR. : Okay. S that I was, that I referenced. There was one 6 MR. : I apologize. I don't mean 6 years later. I don't recall what year it was, 7 to go lone-winded on it. 7 or the outcome of that one. I just know that 8 MR. : No, no, no. lust cause 8 the one that I was involved in, the officer in 9 when I said it, you said, no, but I just wanted 9 charge in the SHU unit got suspended for it. 10 to make sure 'au actually meant yes. 10 MR. : Okay. 11 MR. : Yeah, no. Like, I heard -- 11 MR. : So, the rounds were made, 12 MR. : With what, I know, I 12 but they weren't within that 30 to 40 minute, 13 understand -- 13 so the OIC sot hit on that one. 14 MR. : -- nothing official. Yeah. 14 MR. . And do you know why the 15 MR. : Right, yeah, yeah. I 15 OIC? 16 just, cause for the transcript, it will read 16 MR. : I think the rounds, I think, 17 that you're contradicting what I said, and I 17 if I can recall correctly, I think when he 18 just want to make sure -- 18 entered the round, about 40 minutes, but it 19 MR. : No problem. 19 turned out it didn't jive with the camera. So 20 MR. : -- what I said was 20 they suspended him. 21 actually accurate. Okay. 21 MR. : All right. So, if the 22 MR. : Uh-huh. 22 time that he wrote on the paper didn't show -- 23 MR. . stated he 23 MR. Didn't jive with the camera. 24 recalled suicides taking place in MCC in 2003 24 MR. : : (Indiscernible 25 and another several years later." So, I guess, 25 *00:27:38). EFTA00114423  41 42 1 MR. : Like, the reason, the camera 1 MR. : Okay. So it happened 2 showed we were making rounds. We just didn't 2 actually in the afternoon? 3 make them between 30 and 40, that 30 minute, 3 MR. : Yeah. That was on day 4 not to exceed 40, I believe it just didn't jive 4 shift. S with the camera. 5 MR. : Did he have a cellmate at 6 MR. : Okay. 6 the time? 7 MR. : And they hit him. 7 MR. Yes, he did. 8 MR. : And were you actually 8 MR. : : And the cellmate didn't 9 working in the SHU at the time? 9 notice? 10 MR.