EFTA00063136.pdf

1 DIGITALLY RECORDED SWORN STATEMENT OF OIG CASE #: 2019-010614 DEPARTMENT OF JUSTICE OFFICE OF THE INSPECTOR GENERAL SEPTEMBER 29, 2021 RESOLUTE DOCUMENTATION SERVICES 28632 Roadside Drive, Suite 285 Agoura Hills, CA 91301 Phone: EFTA00063136  2 APPEARANCES: OFFICE OF THE INSPECTOR GENERAL BY: BY: BY: WITNESS: OTHER APPEARANCES: NONE EFTA00063137  3 1 : The recorder has started. 2 My name is and I am a Senior 3 Special Agent with the U.S. Department of 4 Justice, Office of the Inspector General, New 5 York Field Office, and these are my 6 credentials. 7 : Okay. I see them. 8 : This interview with 9 Federal Bureau of Prisons employee, Hughwon 10 , is being conducted as part of an 11 official U.S. Department of Justice, Office of 12 the Inspector General, or DOJ/OIG 13 investigation. Today's date is September 29th, 14 2021. And the time is 8:16 a.m. This 15 interview is being conducted at the OIG New 16 York Field Office, located at 1 Battery Park 17 Plaza, New York, New York. Also present is 18 DOJ/OIG ASAC, or Assistant Special Agent-in- 19 Charge, . He is in person. And 20 Special Agent is joining us by 21 telephone. He is also with the DOJ/OIG. This 22 interview will be recorded by me, Senior 23 Special Agent . Could 24 everyone please identify themselves for the 25 record, and spell their last name? To start, EFTA00063138  4 1 again, I am DOJ/OIG Senior Special Agent Dennis 2 Matulewicz. 3 : I am Assistant Special Agent- 4 in-Charge 5 6 Electronics tech. Bureau of Prisons. 7 D-A-N-I-E-L. 8 : This is Special Agent 9 . D-A-N-I-E-L. 10 : All right. Thank you. 11 This is an official DOJ/OIG investigation into 12 the death of inmate Jeffrey Epstein, and the 13 surrounding circumstances, and you are being 14 asked to voluntarily provide answers to our 15 questions. Will you agree to a voluntary 16 interview with the DOJ/OIG? 17 : Yes. 18 : Thank you, sir. So, this 19 is the official Warnings and Assurances to 20 Employees Requested to Provide Information on a 21 Voluntary Basis. And in this line, I'm going 22 to say, this investigation pertains to, 23 it's job performance failure and security 24 failure, correct? 25 : Yes. EFTA00063139  5 1 : Job performance failure. 2 All right. So, it says, United States 3 Department of Justice, Office of the Inspector 4 General, Warnings and Assurances to Employees 5 Requested to Provide Information on a Voluntary 6 Basis. "You are being asked to provide 7 information as part of an investigation being 8 conducted by the Office of the Inspector 9 General. This investigation is being conducted 10 pursuant to the Inspector General Act of 1978, 11 as amended. This investigation pertains to job 12 performance failure and security failure. This 13 is a voluntary interview. 14 Accordingly, you do not have to answer 15 questions. No disciplinary action will be 16 taken against you if you choose not to answer 17 questions. Any statement you furnish may be 18 used as evidence in any future criminal 19 proceedings, or agency disciplinary 20 proceedings, or both." And there is a waiver 21 section. And it says, "I understand the 22 Warnings and Assurances stated above and I am 23 willing to make a statement and answer 24 questions. No promises or threats have been 25 made to me, and no pressure or coercion of any EFTA00063140  6 1 kind has been used against me." 2 So, take a look. If you understand it, 3 and are agreeing, and are willing to continue, 4 can you just please sign where it says employee 5 signature? Thank you very much for signing. 6 DO you understand the form? 7 : Mm-hmm. Yes, I do. 8 : Okay. Do you understand 9 this is a voluntary interview? 10 : Yes. 11 : Perfect. Thank you. 12 Okay. Today's date, again, is September 29th. 13 So, I'm writing 09/29/21. The place is OIG, 14 NYFO. And the time is 8:19 a.m. And I am 15 signing my name as the Special Agent. ASAC 16 , can you sign as a witness, please? 17 : Mm-hmm. 18 : Thank you, sir. 19 : Thank you. 20 : All right. Before 21 starting the interview, I would like to place 22 you under oath. , can you please 23 raise your right hand? Do you swear to tell 24 the truth and nothing but the truth -- 25 : Yes. EFTA00063141  7 1 : -- during this interview? 2 : Yes. 3 : Thank you, sir. Again, 4 it's a voluntary interview, if you don't 5 understand any of my questions, please ask me 6 to rephrase. 7 : Yeah. 8 : Or ask for any 9 clarification. I would be happy to provide it. 10 Were you previously interviewed by the OIG at 11 the MCC on July 15th, 2021? 12 : Yes. 13 : Great. And that was by 14 me and Special Agent Correct? 15 : Yes. 16 : Great. Is it correct 17 that the MCC camera -. Or sorry. Before I go 18 on that, are you still at the MCC? 19 : Yes, I am. 20 : Are you still the 21 electronics technician? 22 : Yes, I am. 23 : Great. Has anything 24 changed since we spoke on July 15th, 2021? 25 : No. EFTA00063142  8 1 : No. Great. Is it 2 correct that the MCC cameras were not working 3 properly in August 2019? 4 : Yeah. Well, the recorders 5 wasn't working. The cameras were working. The 6 recorders weren't working. 7 : So, the live feed was 8 working, but the recordings were not. 9 : Yes. 10 : Correct. When did you 11 first learn that the MCC cameras were not 12 working properly? 13 : That day. This was, I 14 believe, that day. Towards the end of my 15 shift. I'm not sure what time. 16 : So, you still think it 17 was August 9th, 2019, that you learned? 18 : Yes. 19 : After giving it some 20 thought, do you think maybe it happened the day 21 before, on August 8th, 2019? 22 : I don't know if I spoke to 23 somebody. I don't know why it would be the 24 8th. 25 : All right. When we go EFTA00063143  9 1 over the reports, we will see if that can help 2 freshen, you know, help you recall. First, 3 we're just going to ask you some questions for, 4 like, you know, so you can, from memory, recall 5 exactly -- 6 : What happened. 7 : -- when it was, and then 8 we will go over the reports, and see if that 9 helps jog anything. But to your recollection, 10 it was on August 9th, 2019? 11 : Yes. 12 : And what is -- 13 : It was that Friday. 14 : -- what is it that makes 15 you think that it was on that Friday? 16 : Because that's when I went 17 to the room. That's the only thing I really 18 remember. Because it was a lot of hours after 19 that. 20 : Okay. 21 : That day. 22 : So, it was just 23 : Yeah. 24 : -- it was a lot of things 25 going on. EFTA00063144  10 1 : Yeah. There was a lot of 2 things going on. But I remember the 9th 3 because everything happened the next day. 4 : Okay. 5 : On Saturday. 6 : And are you aware, now, 7 after the fact, that the cameras stopped 8 recording on July 29th, 2019? 9 : No. 10 : So, you're not aware of 11 that? 12 : No. Nobody. It's the 13 first time somebody has told me that. 14 : Okay. So, by reviewing 15 the recording system, or anything like that, 16 you didn't learn that they stopped on July 17 29th? 18 : No. The recorders were 19 still working. Because the recorders were 20 still working for the building. All the -. 21 Not all the cameras were working, but some of 22 the recorders were working. (Indiscernible 23 *00:06:26). 24 : So, when we spoke last 25 time, you explained to us that on, like, August EFTA00063145  11 1 9th, is when you first noticed it, and that 2 half of the cameras, or -- 3 : Half of them was on -- 4 : -- half the cameras on 5 : DVR-1. 6 : DVR-1, and half were 7 on DVR-2. 8 : DVR-2. 9 : And one of the, one of 10 those DVRs, which included half of the cameras 11 -- 12 : Cameras. 13 : -- they stopped -- 14 : Yeah. Stopped working. 15 : -- working. 16 : Yeah. 17 : So, what is your 18 knowledge or recollection of when those half of 19 cameras -? 20 : I don't know when those 21 half the cameras stopped working? 22 : So, when you were trying 23 to obtain video after the fact, you never 24 learned, like, when they're 25 : This is the first time -- EFTA00063146  12 1 : -- the last video? 2 : -- yeah, this is the first 3 time I heard that, was July. 4 : Okay. 5 : Yeah. 6 : So, when is the first 7 time you found out, then, that the recordings 8 were, in fact, not working? 9 : When I went to go try to 10 fix it on that Friday. 11 : Okay. On the 9th? 12 : Yeah. 13 : Okay. But on the 9th, 14 did you -. I thought you had told us you 15 couldn't gain access to it on the 9th. So, 16 when did you actually gain access to the room, 17 to be able to -- 18 : I went up there -- 19 : -- determine -? 20 : -- in the afternoon, to go 21 do work. They said I couldn't stay because 22 had to leave, so the video room. 23 : Okay. 24 : Yeah. 25 So, III had to leave, so EFTA00063147  13 1 you couldn't stay to do the work? 2 : Yeah. I couldn't stay to 3 do the work, because I don't have a key, I 4 don't have access to the room. Because it's 5 the property room. 6 : And when you say "they," 7 who was it that told you this? 8 : I was talking to Officer 9 III. But it's no -. Everybody knows that SIS, 10 that's their room, and I don't have access to 11 go in the room. At the time, I didn't have 12 access to fix the recorders. 13 : Okay. Did you ever talk 14 to a 15 : That day? 16 : Any day, about these 17 recordings. 18 : Yeah. I've talked to 19 people numerous times about me getting access 20 to the room, that I should have access to the 21 room. 22 : No, I'm talking about, 23 like, on August 8th or August 9th, about the 24 cameras. Do you recall having a conversation - 25 - EFTA00063148  14 1 : I don't recall. 2 : -- with lieutenant 3 4 : No. 5 : No. Or ? The 6 Associate Warden. 7 : I don't remember. 8 : No. Okay. So, you don't 9 remember learning that, on July 29th, 2019, the 10 cameras stopped recording? 11 : This is the first time 12 : From (Indiscernible 13 *00:08:19). 14 : I heard it. 15 : That's the very first 16 time you heard? 17 : That it was July. Yeah. 18 : Okay. 19 : Because that's, like, two 20 weeks out, I wouldn't - not know it was 21 recording for two weeks. That doesn't make any 22 sense. 23 : Okay. So, you don't 24 think that that would be accurate? 25 : No. EFTA00063149  15 1 : All right. Do you know 2 what stopped them from recording? 3 : I just know that the 4 system was old, and it had a lot of problems. 5 : Okay. Do you know if 6 someone did, like, an improper shutdown, or 7 that power surge created it to shut off? 8 : They were on UPSs, and no 9 power surge that would have created it. It 10 would have just been mechanical. 11 : Okay. 12 : Or, yeah, yeah. 13 : Just from age? 14 : Just from age, and wear 15 and tear. Yes. 16 : Okay. And again, on 17 August 8th, you don't recall ever having 18 conversations with anybody regarding these 19 cameras, or first learning on August 8th that 20 the cameras went down? 21 : August 8th? The day 22 before? I don't really recall (Indiscernible 23 *00:09:09). 24 : And you don't recall 25 having the conversation with SIS Lieutenant EFTA00063150  16 1 and about the cameras not 2 recording on August 8th, 2019? On Thursday? 3 : No. I don't recall. 4 : You don't. Do you 5 remember them, towards the end of your shift, 6 bringing you in the office because they 7 couldn't get the recordings to rewind, and 8 asked you to fix the problem? 9 : On the 8th? 10 : On the 8th. 11 : Hmm. I don't recall that. 12 No. 13 : Do you remember having - 14 at any time - a conversation prior to Epstein's 15 death, with lieutenant, with SIS Lieutenant 16 and 17 : Together? At the same 18 time? No. I don't recall it. Yeah. 19 : What about separately? 20 : Separately, probably. We 21 probably talked about it. But not together. 22 At the same time. 23 : Well, do you recall the 24 conversations that you had, then, prior to 25 Epstein dying on the - or being found - on the EFTA00063151  17 1 10th. What conversations did you have with 2 each of those individuals? 3 : Right. I was just busy 4 working. On the 10th, the day it happened, or 5 -? 6 : No. Prior to the 10th. 7 So, the 8th, the 9th, or anywhere back to the 8 July 29th, really. 9 : Oh. That we were working 10 on the problem, trying to figure out what was 11 causing it, and that's when I ordered new hard 12 drives to replace all the drives. That was my 13 next step. That's what I was going to do that 14 day. But I couldn't. 15 : And what made you do 16 that, though? Who told you to replace the hard 17 drives? 18 : Talking through SigNet, 19 and the former com tech, he's the 20 computer services manager and we talked about 21 buying hard drives. I actually got a purchase 22 order, too. Yeah. 23 : So, who was the computer 24 service manager? 25 EFTA00063152  18 1 : Can you spell the first 2 and last name? 3 . And 4 M. S : And did you say 6 1? 7 . III Yes. That's an 8 L. Yeah. 9 or -? 10 Yeah. III 11 So, no.. 12 Noll. 13 : Okay. 14 And that's an- 15 : And that was the CSM? 16 : Yup. 17 I'm sorry. And it's All Not will At the 18 end. 19 : All right. So, 20 -M? 21 : Yes. 22 : Okay. Great. And who 23 was that person? 24 : He was the previous com 25 tech before I got there, and now, he was - at EFTA00063153  19 1 that present time - he was the computer 2 services manager. 3 : He was? 4 : Yes. 5 : Okay. So, he was 6 actually working at the MCC? 7 : Yes. 8 : And he was your boss? 9 : No. It's just, I talked 10 to him about computer stuff, because he knows a 11 little bit more than I do. That's his 12 specialty. 13 : Okay. What was his kind 14 of, like, job role at the time? 15 : His job role was to take 16 care of the computers. Infrastructure of the 17 building. 18 : Okay. 19 : Yeah. 20 : And what was the 21 conversation you had with him, and where? 22 : I think, that's when we 23 were talking about actually just replacing all 24 of the hard drives because they keep failing 25 all the time. So, the next step was to replace EFTA00063154  20 1 all the hard drives. 2 : And do you remember when 3 you had that conversation? 4 : A few days before this 5 happened. And we've had numerous conversations 6 about this for weeks because - and probably 7 months - because of the way the hard drives 8 kept failing. The drives would, the recorders 9 would stop working. 10 : So, did you know, then, a 11 few days before this? I'm assuming, when you 12 say "this," August 9th, 2019, that the hard 13 drives had failed? 14 : I knew it was a 15 possibility they failed. At the time, or the 16 before I left, I knew everything was working. 17 : Before you left when? 18 : I'm not too sure, but I'm 19 just saying, like, overall, as far as, like, as 20 far as everything recording, because I've 21 checked the recorders. It looked like 22 everything was recording. 23 : What day are you speaking 24 about, though? 25 : Oh, specifically, before EFTA00063155  21 1 the incident happened, on the 9th. 2 : So, on the 9th, 3 everything was recording? 4 : Well, when I checked it, 5 of course it wasn't recording. That's why I 6 went up there to check. 7 : It was not? 8 : It was not recording. 9 : Okay. So, when is the 10 first time you found out that it was not 11 recording? 12 : Oh. I guess the 9th. 13 Everybody keep saying the 8th, but I don't 14 really remember the 8th. 15 : Okay. So, the 9th, and 16 is that when you -- 17 : Because I -. 18 : -- are saying you had the 19 conversation with 20 : Yes. Well, I had the 21 conversation before, with , about what I 22 was going to do next. 23 : Okay. 24 : Because it happened 25 before, so the next step was just to replace EFTA00063156  22 1 all the hard drives. 2 : Like, it happened long 3 before, or when are you talking about -- 4 : It happened -- 5 : -- it happened? 6 : -- multiple times before, 7 where the recorders would stop working. 8 : Okay. 9 : Yes. 10 : So, you were trying to 11 preemptively stop that from happening? 12 : Happening again, yes. 13 : Okay. So -- 14 : So -. 15 : -- you didn't talk to 16 him based upon the system stopping recording. 17 You were talking about it -- 18 : Mm-hmm. 19 : -- doing preventative 20 maintenance? 21 : Maintenance. Yes. 22 : Is that correct? 23 : Yes. 24 : Okay. But you don't 25 remember exactly when you spoke with him? EFTA00063157  23 1 : No. Some time around that 2 time, because I have to get the purchase, I 3 have to get the parts to make the repairs, or 4 change the drives out. 5 : All right. So, until we 6 go over this, I'm going to run through these, 7 just so we keep on track. But it sounds like 8 I'm going to have to show you these documents, 9 to help maybe clarify some things. 10 : Mm-hmm. 11 : Do you know, did you know 12 that the recorders - that the cameras weren't 13 recording prior to August 9th, 2019? 14 : Yeah. I know there was 15 failures in the system. Yes. 16 : So, you knew that they 17 were not recording? 18 : Not that day. But I know 19 that, overall, there was going to be system 20 failures. 21 : And did you know that it 22 was half of them, all on DVR-1 or 2? 23 : I wasn't too sure what it 24 was. 25 : Okay. EFTA00063158  24 1 : But I know there was a 2 failure. I didn't check to see exactly where 3 they were. 4 : So, you knew there was a 5 failure with the system, prior to August 9th. 6 You just didn't know what the failure was? 7 : Yes. 8 : And how did you know 9 that? 10 : Well, I would have to go 11 check if there was video, there was no recorder 12 videos, live videos, but there was no recorder 13 video. 14 : So, you personally had 15 checked to see if there were recorded video? 16 : Yes. 17 : And when did you do that? 18 : I had, well, I had checked 19 that day, before I had to go upstairs to look 20 at everything. 21 : August 9th? 22 : August 9th. Yes. 23 : So, that's where I'm 24 saying. So, when you say, prior to the time, 25 you're talking about the same day, August 9th, EFTA00063159  25 1 is when you checked the -- 2 : Checked the recording. 3 : -- the recording. 4 : Yeah. 5 : Prior to August 9th, did 6 you check the recording to see if it was 7 recording? 8 : Multiple times before. 9 Yes. 10 : And were they recorded? 11 : From what I believe, yes. 12 I'm not too sure. 13 : Okay. Would you check 14 that system to check on the recordings, every 15 day? 16 : No. There was nothing 17 that says I have to check it. 18 : Sure. 19 : The thing with the 20 recorders is, I'm not really supposed to, like, 21 mess with the system. I just, I'm maintenance. 22 I'm not really supposed to, like, oh, today, 23 SIS, that's their job to tell me, hey, 24 there is no video, or something, there is a 25 problem. EFTA00063160  26 1 : So, how did you know that 2 the recording wasn't being able to rewind, and 3 check recording? Why were you in there 4 checking that? 5 : I just, I guess I spoke to 6 somebody, or maybe I checked it. I'm not too 7 sure. 8 : But it would have been 9 based upon someone requesting you to do so? 10 : Yes. 11 : And you believe that 12 happened on the 9th? 13 : Yes. 14 : Okay. 15 : And just, and the call 16 dropped. Let me get back on. 17 : Absolutely. 18 : Agent 19 : Hey, . You hear us fine 20 now? 21 : Yes. I apologize. I 22 don't know why the call dropped. 23 : Mm-hmm. 24 : Okay. 25 : All right. So, we were EFTA00063161  27 1 just talking about the recording and how Mr. 2 would not go in and review a recording 3 without someone requesting him to do so. He 4 doesn't recall specifically who made that 5 request for him to review the recording, but he 6 believes that he reviewed the recording on the 7 9th, and that's when he determined that it 8 wasn't recording properly. Is that correct? 9 : Yes. 10 : All right. And you - and 11 again - you don't remember why you were 12 reviewing that recording? 13 : No. Because we're in the 14 middle of a -. Well, no, this -. Before 15 Epstein happened, we were in the middle of a 16 camera project, we had people TDY. So, I was, 17 like, the lead in the building, trying to tell 18 everybody what needs to get done. And I think 19 the day before, I was on 10 South, I was 20 putting in a rack or something, so I was busy 21 that day, and I had a TDY guy on me. 22 : And when you - on the 23 8th? 24 : Yeah. 25 : You got a TDY guy with EFTA00063162  28 1 you. 2 : Yeah. 3 : And who was that TDY guy? 4 With you? 5 . His last name was 6 , and I don't remember his first name. 7 He was an electrician. 8 : An electrician. Do you 9 know which facility he came from? 10 : No. I'm not too sure. 11 : You don't know the first 12 name? 13 : I forgot his first name. 14 We just call everybody by their last name. 15 : But he's not from MCC? 16 : No. He's not in from MCC. 17 : After the interview, can 18 you just see if you can identify who that 19 person is, and then send me an email? 20 : Okay. 21 : Of the person's name. 22 But the August 8th, 2019, you believe this -- 23 : Yeah. 24 : -- this TDY employee, 25 , was with you? EFTA00063163  29 1 : Yeah. He was with me. We 2 were together all day because we were doing the 3 piping, and trying to put the rack in. 4 : And what is a rack? 5 : Where the Well, for 6 the new camera system, that's where the power 7 supply, the switch would go, the camera feed, 8 the cat five cables would go. Everything will 9 go on the rack. 10 : So, it had to do with the 11 camera system? 12 : The upgrading the new 13 camera system. Yes. 14 : Is that anything that 15 could have possibly caused the cameras to stop 16 recording? 17 : No. That's -. Nothing 18 was hooked up. It was just the hardware. 19 There was no wiring or nothing. 20 : Okay. So, that could not 21 have affected the camera? 22 : The cameras? No. 23 : All right. And do you 24 remember, prior to August 9th, checking on the 25 camera system, though, to make sure it was EFTA00063164  30 1 recording? 2 : Yes. After we had the 3 problem, yes. 4 : No, no, no. Prior to the 5 9th. 6 : Yes. Prior to the 9th. 7 : And when did you check 8 on, prior, like, how many days before? Do you 9 remember? 10 : I don't really remember. 11 : Are you talking about, 12 like, a few days leading up, a day leading up, 13 or are you talking about, like, a month or two? 14 : Maybe, like, weeks. Not 15 months. It wouldn't have been a month. 16 : Like, a few weeks? 17 : Yeah, because I had to 18 order the parts. I don't know when I ordered 19 the parts. But I had to know that they weren't 20 working. 21 : But I thought you just 22 said that they were working, and you only 23 ordered them as preventative maintenance? 24 : Well, I - yeah -. Well, 25 they weren't working before. So, I had to EFTA00063165  31 1 rebuild one of the drives. I had to change one 2 of the drives out. 3 : Okay. 4 : That's when I went to say, 5 let me order a whole bunch of drives, to 6 replace all the drives together, at once. 7 : And are you able to 8 determine when you made that order? 9 : Yes. We have a purchase 10 order. Yes. 11 : All right. So, those two 12 things so far. Can you give me the name of 13 , and the second thing is the purchase 14 order, with regard to -- 15 : Yeah. 16 : -- when you made that 17 order -- 18 : Yeah. 19 • -- for the new drives? 20 : Mm-hmm. 21 : I'll send you an email 22 after this. 23 : Okay. 24 : Just kind of reminding 25 you of what it is we're hoping to get. And EFTA00063166  32 1 there, but again, you ordered that because 2 there was a problem with the -- 3 : Recorders. 4 : -- with the recorders -- 5 : Yes. 6 : -- you fixed that 7 problem. 8 : Temporarily. But I knew 9 it was going to happen again. And the best 10 thing to do was replace all the drives. 11 : Okay. So, you knew that 12 it would stop recording again? 13 : I knew there was going to 14 be a problem again. Yes. 15 : Okay. And what made you 16 know that 17 : Talking to the vendor, and 18 talking to , and the age of the unit, 19 because it was, like, 15 years old. And the 20 fact that it's on 365, 24 days, and on 24 hours 21 a day, like, it just constantly goes on. And 22 then, when you try to do maintenance, something 23 as simple as changing the time, the recording 24 would stop for, like, a whole day, day and a 25 half. Because for the drives rebuilding, you EFTA00063167  33 1 have to change the time. 2 : Okay. 3 : And before all of this 4 happened, I actually put in a camera project. 5 That's why I was in the middle of a camera 6 project, to replace everything. 7 : Now, when you say that 8 the people you spoke to, you mentioned 9 and then, you said the customer service people 10 -- 11 : Yeah. SigNet. 12 : -- Signet. 13 : Yeah. Mainly 14 , and I would talk to him. 15 • was your • 16 main point of contact? 17 : Yes. 18 : What about a 19 ? Would you recall -? 20 was the one that came 21 after Epstein. That's the guy that showed up 22 when we had to put in the new drives. Because 23 we ordered the new We ordered the new 24 recorders. But everything was downstairs in 25 the basement. And we weren't really a priority EFTA00063168  34 1 on the list until, of course, Epstein happened. 2 That's when SigNet came the next day, and put 3 the new recorders in. 4 : Okay. So, prior to 5 August 10th, 2019, your main point of contact 6 was SigNet, with 7 8 : I mean, -. 9 Yes. 10 : And what was his role and 11 responsibility with SigNet? 12 : He is just, like, the guy 13 we will call if there is a problem, or if 14 training, or if I don't know the system. 15 Because, like, this system, I never had 16 training on it. So, like, when I saw it, 17 because the last institution I was, was, like, 18 maybe two versions ahead of this one. So, when 19 I saw this recording, I was, like, this stuff 20 is old, like, I don't know anything about it. 21 Like, what should I do? So, I called 22 and , like, pretty much would walk me 23 through trouble shooting, if there is a 24 problem. 25 : And what was the system EFTA00063169  35 1 again? 2 : Raid (Phonetic Sp. 3 *00:21:08). 4 : Nice Pro, or something 5 like that? 6 : I don't -. I know it was 7 a raid system. A raid array. I remember 8 that's what he kept saying. Raid array. 9 : Okay. 10 : It was raid. 11 : And do you know what that 12 means? Raid array? 13 : Just the way the drives 14 would go. So, if, the way he explained that to 15 me, if one drive would go bad, that's not so 16 bad. But as soon as two drives go bad, that's 17 when all the recordings pretty much stops. 18 : So -- 19 : Because it was a redundant 20 system. 21 -- okay. So, when one 22 drive goes bad, does any, do any recordings 23 stop? 24 : No. It will keep 25 recording. EFTA00063170  36 1 : So, it will automatically 2 shift over to the other drive? 3 : To the other slot. Yes. 4 : Okay. 5 : And then, when two drives 6 go bad, that's when all the recordings stop. 7 : So, what is the 8 difference between ours, where is one -. Is 9 what you're talking about a DVR-1 and a DVR-2? 10 : No. That's the drive in 11 the DVRs, because there's 16 drives. That's 12 what - I think - that's what it was. So, out 13 of the 16 like, in DVR-1, if one goes bad, 14 that's not a problem. As soon as the second 15 drive goes bad, then that's when you have a 16 problem. And that's when the recording would 17 stop. 18 : Okay. So, what is your 19 understanding of what happened here? 20 : Oh. The drive went bad. 21 : One of them? 22 : Two of them. Yeah. 23 : Two of them 24 : I believe. 25 • -- did go bad? EFTA00063171  37 1 : Yes. Because that's why - 2 - 3 : And is it two of 16, or 4 is it two out of two? 5 : Two out of 16. 6 : So, if two out of 16 go 7 bad -- 8 : Go bad. 9 : -- then -- 10 : Mm-hmm. 11 they all. 12 : The recordings stop. Yes. 13 : For all of them? 14 : Yes. 15 : Okay. 16 : On that drive. All the 17 recording stops. 18 : And the DVR-1 and DVR-2, 19 that's simply the recording system? 20 : Yes. 21 : That's not the, anything 22 to do with the -. The drives are what's making 23 -- 24 : Mm Hmm. 25 : -- the recording, but EFTA00063172  38 1 they're saving it to DVR-1 -- 2 : Yes. 3 : -- and DVR-2. 4 : Yes. 5 : So, what is the 6 difference between if a DVR-1 goes bad, but not 7 DVR-2? Is that just -? 8 : The physical location over 9 it. Because everything on the old system was 10 analog. So, like, cameras one through whatever 11 are on this drive, on DVR-1, and our other 12 cameras are on DVR-2. 13 : So, does each DVR have 16 14 drives? 15 : Yes. 16 : All right. So -- 17 : So -. 18 : DVR-1 has 16 drives. 19 DVR-2 has 16 drives. 20 : Yes. 21 : And either DVR-1 or DVR- 22 2, two of those drives went bad? 23 : Yes. 24 : And stopped that DVR-2 25 from recording. EFTA00063173  39 1 : From recording. Yes. 2 : But the drives on DVR-1 3 were all good? 4 : All good. Yes. 5 : Okay. 6 : And another thing I've 7 learned also, through my time, is that SigNet 8 replied to me this, you could look at the 9 camera software, until you physically look at 10 the drives, you would think that everything is 11 recording. That's something we went over 12 recently. 13 : Well, what about a -. I 14 was told that there was an application that you 15 would have, that was called Supervision. 16 : Yeah. I don't look at 17 Supervision. 18 : You don't. 19 : You can. I have access to 20 look at it, but I didn't get trained on it, so 21 I don't really look at Supervision. I would 22 just go in the regular Nice Vision, and look at 23 it that way. 24 : Yeah. We were told that, 25 in order to determine if there were problems EFTA00063174  40 1 with the drives -- 2 The drives. You would 3 have to -- 4 : -- that's through -- 5 : -- yes. 6 -- yeah, you go into 7 Supervision, and that would, in fact, tell you? 8 : And which, I have no 9 training on. 10 : So, you've never -- 11 : Obviously. 12 : -- looked at that? 13 : No. 14 : Did anyone else have 15 health -- 16 : At the time, no. 17 : -- did anyone else have 18 access? 19 : No. 20 : So, you were the only 21 person with access to Supervision? 22 : Yes. Pretty much. Yes. 23 : All right. And do you 24 know if someone accessed the application 25 Supervision, they could have taken the drives EFTA00063175  41 1 offline, or the recordings offline? 2 : Hmm, yeah. But yeah, 3 nobody would have that access. 4 : Would they be able to do it from there, though? 6 : Yes. They probably would, 7 yes. 8 : But you are confident no 9 one had access to it? 10 : No. 11 : Okay. So, you would be 12 the one and only person with access to 13 Supervision? 14 : Yes. 15 : And there is no, like, if 16 you're not there, somebody else has 17 : There is nobody -- 18 : -- a way to -- 19 : -- there is nobody. Yeah. 20 : -- how would they do 21 that? From SigNet? To get access again. 22 : Oh, no. They would just 23 have to know the password, to log in. 24 : Well, that's what I mean. 25 So, if you ended up not being able to show up, EFTA00063176  42 1 or you left, or something like that, how would 2 someone gain access to that? 3 : That's something they 4 would have to try to figure out, but yeah. I 5 don't 6 : But to your knowledge, 7 you're the only person that had the password to 8 access Supervision? 9 : Yes. 10 : Okay. And SigNet 11 wouldn't be able to remote in? 12 : No. They have no access 13 to remote in. That's BOP. They don't want 14 them to be able to backdoor remote into 15 anything. 16 : Okay. And when did you - 17 - 18 : Oh. Well, they -. The 19 old system, they were able to, if you had a 56K 20 (Phonetic Sp. *00:25:06) modem, they were able 21 to do maintenance, and tell me, like, the 22 status of the drives. But I would have to 23 physically hook up 56k modem. But at the time, 24 that wasn't hooked up. Because we did some 25 repairs before, when I was trying to figure EFTA00063177  43 1 stuff out, and I couldn't figure it out, where 2 they would - through a modem - they would 3 remote into the -. Well, I would have to grant 4 them access to look at the drives, to help with 5 the drives. 6 : So, how -- 7 : And we've done that 8 before. Yes. 9 so, you had