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1 DIGITALLY RECORDED SWORN STATEMENT OF OIG CASE #: 2019-010614 DEPARTMENT OF JUSTICE OFFICE OF THE INSPECTOR GENERAL SEPTEMBER 22, 2021 RESOLUTE DOCUMENTATION SERVICES 28632 Roadside Drive, Suite 285 Agoura Hills, CA 91301 Phone: EFTA00127626 2 APPEARANCES: OFFICE OF THE INSPECTOR GENERAL BY: BY: WITNESS: OTHER APPEARANCES: NONE EFTA00127627 3 1 : It's Senior Special Agent 2 . He's also assisting on the 3 case. 4 MR. : Is it 5 : Yeah. 6 MR. 7 : Yeah. I'm right here. 8 I'm the Senior Special Agent here. So, yeah. 9 Like here just said, where we just want 10 to ask you a couple questions regarding August 11 8th through the 10th of 2019. 12 MR. : Okay. 13 : And just so you know, all 14 of our interviews are recorded. 15 MR. : Okay. 16 : And just for 17 documentation purposes. Just so you know. 18 MR. : Understood. 19 : All right. Great. So, 20 is going to take it. I'll only jump in 21 if we need some clarifying information. 22 MR. : Okay. 23 : Perfect. And I'm going to 24 start the recording. 25 MR. : Okay. EFTA00127628 4 1 : My name is , and 2 I'm a Special Agent with U.S. Department of 3 Justice, Office of the Inspector General. New 4 York Field Office. This interview is with 5 former SigNet employee, . And it 6 is being conducted as part of an official U.S. 7 Department of Justice, Office of the Inspector 8 General investigation. Today's date is 9 September 22nd, 2021. The time is 9:03 a.m. 10 This interview is being conducted 11 telephonically, via phone number 12 . Did I get that right? 13 MR. : Yes. 14 : Okay. Also present -- 15 MR. : I'm going to read that 16 back. I'm sorry. 17 : Yes. Perfect. Also present 18 is DOJ/OIG Senior Special Agent 19 This interview will be recorded by 20 me, Special Agent Could 21 everyone please identify themselves for the 22 record, and spell your last name? To start, 23 again, I am DOJ Special Agent 24 25 : Senior Special Agent EFTA00127629 5 1 with the DOJ/OIG. 2 3 -; , can you introduce 4 yourself, please? 5 MR. : Former SigNet employee, 6 - or , full name - 7 8 9 calling you —. 10 MR. : That's - no, no - I go by 11 12 : All right. 13 MR. : But I gave you my formal. 14 : Yeah. Thank you. This is an 15 official DOJ/OIG investigation into the death 16 of inmate Jeffrey Epstein, and the surrounding 17 circumstances. And you are being asked to 18 voluntarily provide answers to our questions. 19 Will you agree to a voluntary interview? 20 MR. : Yes. 21 : Thank you. Please let me 22 know if you do not understand any questions I 23 ask, and I will repeat it, or try to rephrase 24 it. 25 MR. : Okay. EFTA00127630 6 1 : Okay? I'm going to go 2 through some of your background, and then we'll 3 go into the service request. What is your 4 current home address? 5 MR. : Current home address is 6 7 8 9 : Okay. And -- 10 MR. : Zip code is 11 : -- thank you. What is your 12 date of birth? 13 MR. 14 : Is this your cell phone 15 number, the number? 16 MR. : Yes. 17 : Okay. And what is your 18 highest level of education? 19 MR. : High school. One year of 20 college. 21 : All right. Where did you 22 attend college? 23 MR. : I went to Liberty 24 University. 25 : Where is that? EFTA00127631 7 1 MR. : Lynchburg, Virginia. 2 : Was there a major you were 3 following? 4 MR. : It's just business 5 management. 6 : Okay. And what did you do 7 prior to working for SigNet? 8 MR. : Prior to SigNet, I actually 9 delivered Little Debbie cakes for six months. 10 : Excellent. And when did you 11 begin working for SigNet? 12 MR. : When did I pick up working 13 there? 14 : Yeah. When did you begin 15 working for SigNet? 16 MR. : Oh. I'm sorry. I'm sorry. 17 I'm going back too far. Sorry. SigNet. I 18 actually worked for Orion Systems Group. That 19 as in Fairfax, Virginia. Sorry. I skipped a 20 whole bunch of years there. 21 : No problem. 22 : Yeah. 23 MR. : I'm thinking before the 24 security industry. Sorry about that. Okay. 25 : And -. EFTA00127632 8 1 MR. : Yeah. Oh, no. Go ahead. 2 : No, no. No problem. And 3 when exactly did you work, start, begin work 4 for SigNet? 5 MR. : That was April 2011. 6 : Okay. And what was your 7 position with SigNet? 8 MR. : I came on as a service 9 tech, initially. And then, I entered into the 10 role, I want to say it was probably somewhere 11 in 2012, middle of 2012, or maybe early 2013. 12 I think it was the middle of 2012, they put me 13 as the senior customer support representative. 14 : And that was your position in 15 August 2019? 16 MR. : Yes. 17 : Okay. And what did that - as 18 a senior customer representative - what did 19 that position entail? 20 MR. : So, that was basically 21 traveling to the Federal Bureau of Prisons, 22 whenever they needed their VMS video system 23 server upgrades. Basically, any swap outs of 24 their systems, when they expired or went out of 25 warranty. And then, if I wasn't traveling, EFTA00127633 9 1 doing the upgrades, I was at home, working from 2 my house, and doing technical support for the 3 video systems at the prisons. 4 : Okay. So, the main client 5 that you worked with was the Federal Bureau of 6 Prisons? 7 MR. : Yes. 8 : Okay. And when did you leave 9 SigNet? 10 MR. : That was December 30th, 11 2019. 12 : Where are you employed now? 13 MR. : I am at a UK based company 14 called ONVU Technologies. That's O-N-V-U. 15 : Okay. Thank you. 16 MR. : Off of (Indiscernible 17 *00:05:36) and . (Indiscernible 18 *00:05:39). 19 : Thank you. As part of your 20 job at SigNet, in 2019, do you recall working 21 on projects, or work orders, for the 22 Metropolitan Correctional Center in New York 23 City? 24 MR. : Yes. 25 : Do you recall working on a EFTA00127634 10 1 project that started August 8, 2019? 2 MR. : Yeah. I remember the 3 project. I don't know the exact date, but that 4 sounds about right. 5 : Hey. I just want to clarify. 6 You mentioned the ONVU, that where you work, 7 have you been working there since December 8 2019? 9 MR. : No. I worked at -. When I 10 left SigNet, I went to another company. It's 11 called Enterprise Security Solutions. 12 : Okay. And that was in 13 December 2019? 14 MR. : Yeah. It was December 15 31st, or yeah, basically. 16 : (Indiscernible *00:06:28) 17 MR. : January. 18 : Okay. And you were there for 19 how long? 20 MR. : Until July, pfft. What was 21 that? July. July. It was July this year. 22 Look it up. 23 : And in July, you came over to 24 our -. You started working at ONVU? 25 MR. : Yes. So, my last day at EFTA00127635 11 1 ESS was July 9th. And my first day at ONVU was 2 on July 12th. 3 : Okay. 4 MR. : 2021. Yeah. 5 : Okay. Thank you for 6 clarifying that. 7 MR. : Yup. 8 : Now, as part of - and I'm 9 going to go back to that last question I asked 10 - as part of your job at SigNet in 2019, do you 11 recall working on projects, or work orders, for 12 the Metropolitan Correctional Center in New 13 York City? 14 MR. : Yes. 15 : Who were you dealing with at 16 the MCC? 17 MR. : I believe that was 18 -: 19 MR. 20 : Okay. And we have a copy of 21 SigNet service request, 24975. Because this is 22 telephonically, I know I can't show it to you, 23 but I will read it to you. Is that all right 24 with you? 25 MR. : Yeah. EFTA00127636 12 1 : It says, "Raid (Phonetic Sp. 2 *00:07:32) just crashed." That's under the 3 service request. And this was created on 4 August 8, 2019. That status shows FBOP 5 assigned, and it's assigned to 6 (Phonetic Sp. *00:07:41), and 7 The contact we have is, 8 , and the service location is for 9 150 Park Row, New York, New York. Is your 10 understanding that is for the MCC? 11 MR. : Yes. I believe so. I 12 don't know their exact address, but yeah 13 : Okay. 14 MR. : -- it sounds 15 : Now, this says 16 MR. : -- familiar. 17 is this an emergency 18 request? It says, yes. Must call. The 19 problem was reported by And - 20 - 21 : 22 I apologize. 23 It's And I'm going to read the 24 comments here. The earliest comment, it looks 25 like, is on - it's by you - on August 8th, at EFTA00127637 13 1 3:36 p.m. It states that the a ssignment on 2 August 8th to 16th, all day for 3 , and was been 4 created. It says will be working 5 on this. Get a case started with Qognify? 6 : Do you want to start with 7 August 8th first. Is that what you started 8 with? 9 : Yeah. 10 : Okay. Sorry. 11 : It's Qognify. That's Q-O-G- 12 N-I-F-Y. Is that your internal system? 13 MR. : No. So, Qognify is the 14 video manufacturer of the software that they 15 were using. At the time, though, they were - I 16 believe - their system was a Nice Vision 17 (Phonetic Sp. *00:08:57) system, just to give 18 you guys a little background on it. So, Nice 19 Vision was the prior company. 20 : Okay. 21 MR. : When most of the prisons 22 got their video systems. And then, Qognify 23 basically purchased, or bought, Nice Vision. I 24 want to say that was probably in, like, 2018. 25 Maybe 2017. EFTA00127638 14 1 : Okay. So, and that's why -- 2 MR. : So, they rebranded, 3 basically, the new systems that they were 4 putting in. 5 : Understood. Okay. And then, 6 the assignment was created at 3:36 p.m. There 7 is a comment by - that's you, 8 right? - at 3:38 p.m. And -- 9 MR. : Yeah. 10 : -- it looks like someone 11 addressed it to you. It says, "Hi, 12 Unable to locate anything official. The basic 13 steps are as following: One, set the raid 14 level to none, and save. It will restart it 15 with all drives being J. Replace any faulty 16 drives. Two, set the raid level to five, and 17 save. It will restart and begin 18 initialization. The password is 1111. Four 19 ones. And if I recall correctly, once the raid 20 to is created, you will need to restart 21 Windows, and create the proper partitions. 22 I'll keep looking, but that should get you 23 going. Best regards, (Phonetic Sp. 24 *00:10:13), Senior Support Engineer." 25 MR. . Okay. I was EFTA00127639 15 1 wondering who that was. I was going to guess 2 Sharom (Phonetic Sp. *00:10:19), but 3 : Is that someone -- 4 MR. : Okay . 5 -- internally, or is that 6 from Qognify? 7 MR. : No. So, that -- yeah - 8 that's the Qognify technical support engineer. 9 : So, you reached out to 10 Qognify and to get assistance on this matter, 11 and they responded on these are the steps? 12 MR. : Mm-hmm. 13 : All right. And the next 14 step, the next comment I have is by 15 on August 14th, 2019. 8:02 p.m. So, 16 this is approximately six days after the 17 incident. 18 MR. : Okay. 19 -: called us on 20 Thursday, August 8th, stating that he had two 21 bad drives in his raid unit. Off the Nice 22 Vision Pro, Unit NVR (Phonetic Sp. *00:10:57). 23 We advised him to get replacement drives. Once 24 they are replaced, they should start to 25 initialize, to become available for the raid EFTA00127640 16 1 array. did not have drives 2 readily available. He checked with his local 3 CSM." What is CSM? 4 MR. : Should be computer 5 specialists manager -- 6 : That's 7 MR. : I believe. 8 : -- that's internal for the 9 BOP? 10 MR. : Yup. 11 : Okay. 12 MR. : That's what their IT 13 manager, and the IT department, I think. 14 : Thank you. "He checked with 15 his local CSM, to see if they had any spare 16 replacement drives. Once he located 17 replacement drives on Friday, August 9th, he 18 did not have access to the DVR room, to replace 19 them. He called SigNet for some phone support 20 on Saturday, August 10th, when he gained access 21 to the DVR room. He attempted to replace the 22 drives, and they started to rebuild. During 23 the rebuild process of the drives, the drives 24 were required to be taken out of raid, on DVR- 25 2. Once the drives were removed without proper EFTA00127641 17 1 shutdown of the recorder, the video database 2 becomes corrupted. Typically, any time the 3 raid is - raid on - raid five configuration 4 loses two drives, the raid needs to be rebuild, 5 and all data is wiped from the raid." Do you 6 recall making that comment? 7 MR. : Yeah. That sounds about 8 right. That sounds what I would have stated. 9 : Okay. So, I'm going to go 10 back. Can you explain to me the phone call 11 that you got from on August 8th, if you 12 recall what he stated to you on August 8th? 13 MR. : Yeah. I'm trying to think. 14 Well, yeah. I'm trying to -. So, August 8th, 15 well, that was a Was that a, like, a 16 Saturday, maybe? 17 : No. 18 MR. : Maybe it was -. 19 : That was a Thursday. 20 MR. : Thursday. Okay. 21 : It looks like, on Thursday, 22 he called - August 8th - he called you, he 23 reported the incident. You gave - possibly 24 gave - him instructions on what to do. August 25 9th, he got replacement drives, but he did not EFTA00127642 18 1 have access to the room. That would be on a 2 Friday. Then August 10th is when he called you 3 back, and it looks like you -. The incident 4 with Epstein happened, and he called you back. 5 MR. : Oh. Okay. Okay. Yeah, 6 because I was going to say -. Let's see. 7 Yeah. I have a different recollection than I 8 thought, because I thought, from what, and I 9 want to say, maybe that incident started 10 earlier, but maybe not. Because what I was, 11 what I was recalling on that was, me and my 12 wife were actually about, I think, let's see, 13 2019. So, that would have been -. Yeah. 14 Me and my wife and my son were out at a 15 cabin on a weekend get-away, and I remember an 16 email, I believe that was from , saying 17 something that he had gotten a call from 18 . Now, that could have been 19 after the initial reach out from him. That the 20 drives were down. I think that might have 21 been. So, I'm kind of questioning if 22 reached out to me initially, or if he reached 23 to , and then assigned that to me. 24 Because , I believe, was also out on 25 vacation, either that week or that weekend, as EFTA00127643 19 1 I was, but I was kind of local. So, he had 2 asked me to reach out or, you know, basically 3 work with him, work with Qognify. And so, 4 that's what I was remembering from that, 5 because I know, I remember specifically, I was 6 on vacation on the weekend. 7 And trying to reach out, basically, to, I 8 want to say, like, our sales rep, 9 (Phonetic Sp. *00:14:27), who worked, you know, 10 for the Bureau, or worked with the Bureau of 11 Prisons. He sold all their equipment. 12 Reaching out to . But again, I could 13 be -. I could be wrong on the timeframe there. 14 But -- 15 : It's --. 16 MR. : -- either way, yes, I did 17 work directly with - at 18 one point, on the case, prior to visiting the 19 site. So, yeah. I was just trying to get that 20 timeline right, because I don't want to tell 21 you that it happened this specific way you're 22 saying it, and then it didn't. 23 : No problem. And you 24 mentioned that you were away with your wife on 25 a camping trip. Do you know how long the trip EFTA00127644 20 1 was for? 2 MR. : It was just a weekend. So, 3 I think we might have left out on a Friday, you 4 know, Friday afternoon, and then, probably came 5 back, like, Sunday night. 6 : So, it's possible that you 7 spoke to him on Thursday, August 8th, before 8 you headed out for the camping trip? 9 MR. : Possibly. Yeah. 10 : You don't recall? 11 MR. : Yeah. I don't - yeah - I 12 don't recall specifically. I do - and like I 13 said - I do know, I did talk to him, at one 14 point, about the drives, and that he couldn't 15 . Okay. So - yeah - that does clear it. 16 Okay. So, that's really -. Sorry. I'm just 17 trying to piece it together. 18 : No problem. 19 MR. : So, yeah. He did mention 20 something about that he would check with -. 21 So, that's why I'm trying to think that it may 22 have been the weekend prior to the 8th. Or not 23 the 8th. But it would have been the 10th, 24 would have been the Saturday. I want to say he 25 reached out before then. Because I want to say EFTA00127645 21 1 we were out on the weekend, before that. 2 : So, hold on. Let me just 3 clarify. 4 : Yeah. So, let me. So, 5 I'm looking at this now, This is 6 So, on August 8th -- 7 MR. : Uh-huh. 8 : -- that's when you 9 received, it looks like, a message from that 10 individual. Who is it? 11 MR. 12 13 MR. : Yes. 14 : -- saying, "Hi, 15 Unable to locate anything official. The basic 16 steps are as follows." So, it looks like, 17 maybe somebody would have reached out to you 18 before. So, in fact, that was the August 8th 19 comment. And then -- 20 MR. : Yeah. 21 : -- that was something 22 that says comment made by you. And then -- 23 MR. : Uh-huh. 24 : -- the next comment made 25 by you was actually on August 14th, 2019. EFTA00127646 22 1 MR. : Okay. 2 : And what you're stating 3 here is, it's saying, " called us 4 on Thursday, August 8th, stating that he had 5 two bad drives." So, it doesn't specifically 6 say he called you. Do you know if he would 7 have called you direct, or he would have called 8 someone else with SigNet? 9 MR. : That's why I was saying. I 10 think he may have called initially. And 11 then, had asked me to basically work on 12 that case because, like I said, I think 13 was out on vacation, and that's why he passed 14 the case to me, asking me to work with 15 and Qognify to try to see if we could get those 16 replaced. Let me look at the year here. I'm 17 just trying to pull it up. 18 : And you mentioned there is a 19 possibility you were away on a camping trip the 20 weekend prior to that. 21 MR. : So, the 10th. Yeah. I 22 mean, I could try to verify that, if that's, 23 like, an absolute 24 : No, no. 25 MR. : -- necessity. I could see. EFTA00127647 23 1 Yeah. I know it was basically right around 2 this case time. So, it could have been the 3 prior, or it could have been that weekend. But 4 yeah. That's really -. 5 : I know it's tough. It's been 6 a couple years. So, remembering the exact 7 details is kind of hard. 8 MR. : You know, it may have been 9 that Friday night. The 9th. So, you said I 10 was talking to Derek on the 8th? 11 : Yes. 12 MR. : Or I got a reply from him 13 on the 8th. Yeah. Because I want to say we 14 left out on the 9th, and we were at the cabin 15 on the 9th. And I want to say that me and 16 were maybe communicating back and forth 17 via email. And trying to kind of figure out, 18 you know, what drives he could get, or 19 whatever. So, maybe, maybe it all happened 20 right in that weekend. Because I do remember 21 something about hearing that, you know, the 22 incident happened there. 23 : Okay. Yeah, and I'm -- 24 MR. : Uh-huh. 25 : re-reading this. It EFTA00127648 24 1 doesn't specifically state in your comment, on 2 the 14th, that you actually ever spoke with 3 him. It just says 4 MR. : With 5 : -- it - yeah - with 6 It just says that he called us on the 7 8th. And then, it talks about, you talk about 8 how, on the 9th, he didn't have access to the 9 DVR room, to replace them. And then, it says, 10 he called SigNet for phone support on Saturday, 11 August 10th. So, do you know 12 MR. : Okay. 13 : -- if you were away, I'm 14 assuming this information was passed to you on 15 August 14th, when you made the comment? Would 16 that be accurate, since it sounds like you were 17 aware that weekend? 18 MR. : Well, I do -. So, I do 19 remember talking to him, at some point, and him 20 Well, I don't know if I talked to him or 21 emailed -- 22 : Okay. 23 MR. -- but basically, I 24 remember, I remember him saying that, like, he 25 was trying to find drives. He didn't have any, EFTA00127649 25 1 so he was going to check with the CSM, to see 2 if they had any on site. Then, I believe he 3 found them, and then, he said, and he called, 4 he either called me back, or emailed, and said, 5 hey, the room where the NVR is locked, and it's 6 our internal investigation office, and they 7 have the keys. I don't have access to that. 8 So, I'm going to have to wait until such and 9 such. It was probably Saturday. I think I 10 stated there that he could actually get access 11 into the room, to go try and replace the 12 drives. 13 : Okay. So -- 14 MR. : Sorry. 15 : You just 16 but 17 don't know if that's 18 August 8th or August 9th, the day you left for 19 your trip? 20 MR. : No. I was actually trying 21 to see if I could pull up a Outlook data file, 22 because I believe I saved some emails. 23 : Oh, that would be 24 awesome. And then, specifically -- 25 MR. : I'm just like that. EFTA00127650 26 1 : -- yeah. No. That would 2 be great. Specifically -. 3 MR. : I want to even say I saved 4 all of my tickets from SigNet, but I can't 5 promise that. 6 : Oh, that would be huge. 7 And I think going back, as far as, like, July 8 29th, if you don't mind, because that's when we 9 think that the drives may have actually gone 10 down. 11 MR. : July 29th? 12 : Yeah. I mean, I don't 13 know that they contacted you or not, but that 14 would be the follow up question, after we 15 figure out what happened on the 8th and 9th. 16 It would be, how far back did you know that 17 these drives, or (Indiscernible *00:20:50) 18 you've been working with , to 19 replace these things, because it looks like 20 they may have gone bad on 7/29/2019. 21 MR. : 29th. So, that would have 22 been about. That sounds about That sounds 23 about right. 24 : Why do you say that? 25 MR. : Well, because - again - EFTA00127651 27 1 like, I know that he initially contacted us 2 about the drives being out. And I want to say, 3 it took -. I remember it -. I thought it was 4 at least a couple of days of the process of 5 trying to go back and forth with him. And I 6 don't know if it was me or , basically 7 saying, hey, we've got to get drives. You 8 know, they don't sell them anymore at Qognify, 9 I don't think. Because they are basically non- 10 production drives, and we would have to get 11 refurbished drives. And I think was 12 looking on, like, eBay, and, you know, a couple 13 of our sources, to find some. So, I don't know 14 exactly, did that comment say that he had 15 drives on site? 16 : So -- 17 MR. : Or did he order them? 18 : -- that -- 19 MR. : Because that's the other 20 question 21 : -- it looks -- 22 MR. -- is, did he not have 23 them? 24 : -- he didn't have access to 25 them. EFTA00127652 28 1 MR. : Okay. So, that may have 2 been the gap, from the 29th. 3 : Well, it does say -- 4 : (Indiscernible *00:22:07). 5 : -- so, after the August 6 8th thing, it says, "He checked with his local 7 CSM to see if they had any spare replacement 8 drives. Once he located replacement drives, on 9 Friday, August 9th, he did not -- 10 MR. : Okay. 11 : -- have access to the DVR 12 room to replace them." 13 MR. : Okay. So then, he did have 14 them on site. Okay. 15 : At least that's -- 16 MR. : That's what it sounds like. 17 : -- that's what it sounds 18 like. Yeah. 19 MR. : Yeah. 20 : Okay. 21 : So, I'm assuming that 22 means that you wouldn't have sent them. Do you 23 know who the CSM was, by chance? 24 MR. : I can try to look here. 25 I'm looking at our database. I probably EFTA00127653 29 1 shouldn't have all this information, but -. 2 : It helps us a lot. We 3 appreciate it. 4 MR. : Okay. Maybe, yeah. I 5 don't pass it out to, you know, other 6 companies, but stuff like this, I do find it 7 useful, if it -. Hmm. Okay. I've got -. 8 Hey. There is a camera outage. Oh. I've got 9 a camera outage report. 10 : What is that? 11 MR. : But I don't -. That shows 12 from 8/16. These are all looking at August 13 16th. Which could have been the time that I 14 actually was on site. 15 : Okay. 16 : Yeah, we would be looking 17 specifically 8/10, and prior. 18 MR. : Okay. Let me see what I've 19 got. Do I have screenshots? 8/16. 8/11. 20 Okay. Let me go back and see. Let me look at 21 this report and see if it gives me, like, a 22 date of when this was exported to, because that 23 could be something, if you guys need it. 24 : Okay. 25 MR. : I don't know if you guys EFTA00127654 30 1 have all that or not. 2 : We don't have the -. This is 3 -. This is between SigNet employees. Right? 4 MR. : This is an Excel document, 5 but again, but I've got to see what date it 6 shows on here. Because they kind of hide it in 7 the columns. I'm trying to see if it has a 8 date. This is basically just a camera outage 9 report. So, I don't know if you guys need 10 that. And if that, again, I don't know if that 11 was ran from him, and we got that. 12 : But you said this was on the 13 16th? 14 MR. : That one shows that it was 15 edited on the 17th, but it - like I said - in 16 the outage report, I thought that they give you 17 a date when it was actually exported from the 18 system. 19 : Okay. 20 MR. : So, I would have to look at 21 the order. But yeah, let me go back to your 22 original. You're looking for the email traffic 23 and everything. So, let me see if I can find 24 that. Oh. Him. Oh, what's that? Sorry. I'm 25 looking through gigs and gigs of -- EFTA00127655 31 1 : No problem. 2 MR. : -- information here. 3 : No. We appreciate it. 4 Thank you. 5 MR. : Oh, no problem. Hopefully, 6 I can find something that helps a little more. 7 Okay. So, I've got -. All right. Let me see 8 if I can look (Indiscernible *00:25:28) Outlook 9 and see, if it will load. All right. So, 10 files. Open. And export. Let's do an import. 11 Oh, import from another program or file. Oh, 12 that is a ODF. Yup, right there. Let's see. 13 Allow duplicates to be created, replace to 14 (Indiscernible *00:26:04) items. Imported. I 15 have no idea. But I'll screw my work email up. 16 Crap. 17 : No problem. Can I - while 18 you're doing it, while you take a look - can I 19 ask you a question? 20 MR. : Yeah. 21 : This is, in here, it states, 22 "During the rebuild process of the drives, the 23 drives were required to be taken out of raid, 24 on DVR-2. Once the drives are removed without 25 proper shutdown of the recorder, the video EFTA00127656 32 1 database becomes corrupted." Is that your 2 understanding of what happened, from your 3 conversation with 4 MR. : I'm - so, yeah - I'm trying 5 to figure out when that was happening, because 6 I do know that, at some point, the FBI came 7 there on site, I think prior to us showing up. 8 And I want to say that the recorder was 9 rebuilding, and they said that they had to take 10 the equipment out. And that's what I'm -. 11 That's what I'm trying to piece together, if it 12 was then that they took it out. Or if it was - 13 . Yeah. Because I don't, I don't really make 14 any sense of him putting them in and then 15 pulling them out. 16 : Okay. 17 MR. : Yeah, because I would 18 think, once he puts them in, I mean, he would 19 leave them to rebuild. And I think I would 20 have probably made that comment, because he 21 said something the FBI coming in, they need to 22 confiscate the equipment. And then, and I'm 23 pretty sure I told him, I said, well, you don't 24 want to, you don't want to unplug those while 25 it's rebuilding because if it, you know, EFTA00127657 33 1 basically stops, you have no pick up point to 2 start rewriting. It's going to start all over, 3 and then, you're going to have gaps where 4 you're going to be missing recordings. 5 : Now, so, do you believe, 6 then, for whatever they did, that erased all 7 prior data, anything that was saved on there 8 would have been erased? 9 MR. : If - yeah - if they pulled, 10 if they pulled power, and pulled the units out, 11 then yeah. I mean, it would have wiped, wiped 12 the raid, I would think. 13 : So -. 14 : Now, if we have 15 information that the servers were already down, 16 since 7/29/2019 -- 17 MR. : Mm-hmm. 18 would have those 19 servers been recording up until the date that 20 they tried to rebuild them anyway? 21 MR. : That depends, because I 22 don't remember if the -. I think those 23 servers, the way, the older servers, I believe 24 they were set to a raid five. Let's see. 25 Those are the pros. So, I want to say that is EFTA00127658 34 1 a raid five, and they loaded, basically 2 everything was kind of compiled together, on 3 the same raid in those servers. So, that would 4 have put the OS, and the video storage on the 5 same raid array. 6 But they partition out for the OS. So, if 7 they lost one drive, then that would be okay. 8 With a raid five. If they lost two drives, 9 then -. So, if they would have lost two drives 10 simultaneously, they would lose everything. 11 The recorder would go down, and you wouldn't be 12 able to get into the OS. From what I 13 understood. So, it's possible that he lost one 14 drive and called us. Initially. Was trying to 15 replace that. And then, when, you know, 16 basically, another one went down while the 17 other one was rebuilding. That could have been 18 possible. And that could explain why the OS 19 didn't crash. 20 : So, on that note, so, our 21 understanding, there is, like, let's say there 22 is 150 cameras in the MCC. 23 MR. : Uh-huh. 24 : We were told about half 25 of them go to one drive, and half of them go to EFTA00127659 35 1 the other drive. If that one drive went down 2 on 7/29/2019, would those cameras that were on 3 that drive had continued to have recorded on 4 the other drive, or would have they stopped 5 recording, and only the other drive that was 6 good, that housed the other half of the 7 cameras, have recorded? 8 MR. : Well, sorry. So, it really 9 doesn't work like that. But yeah. I mean, 10 yeah, in theory, you would want it to work like 11 that. But essentially, the raid will spread 12 the data over all drives. 13 : Oh, I'm going to stop -. Can 14 you explain what a raid is? 15 MR. : So, a raid is a group of 16 drives. 17 : Is that, like, a DVR system? 18 MR. : What's that? 19 : Is that, like, a DVR system? 20 MR. : Yeah. I'm sorry. Yup. 21 Let's - yeah - let's go back. So, the DVR 22 system recorder. So, normally, their old set 23 up, I believe, had a - and that would be a PC 24 or a computer, like a server. A server. Like, 25 a rack PC server. That would contain the OS. EFTA00127660 36 1 Okay. So, yeah. Never mind. Let me take back 2 what I said about the OS. Because now, I'm 3 remembering their set up. 4 I believe they had -. The way the old 5 ones were, is they had a separate computer. 6 They called the Nice Vision Pro units. So, 7 that, I believe, had two drives in it. So, 8 that would be a raid one redundancy. So, that 9 So, again, the raid is a group of drives 10 for storage. 11 : Okay. 12 MR. : And what a raid allows is, 13 so, like, in your case, you were just talking 14 about if you had two drives, you had, you know, 15 half the cameras recording the one, half the 16 other, to the other one, if one went down, you 17 would technically still have all the other 18 cameras on that drive. So, what the raid does 19 is basically, it allows you to take - say you 20 don't have that scenario, of losing half your 21 cameras - the raid allows you to put, you know, 22 there is a number of drives that it requires to 23 have for certain raid levels. 24 But basically, it allows you to, like, 25 let's say four to six hard drives. It groups EFTA00127661 37 1 those together. So now, you - then the 2 recorder takes the video, the video recording, 3 and starts to spread it out over all those 4 drives, and it basically makes a mirrored copy. 5 So, if one did fail, it still can go back on 6 the other drives, and access the copied files, 7 or the mirrored files. 8 : Now -. 9 MR. : So, how -. It's for the 10 purpose of redundancy, in case you did lose a 11 drive, you're not losing, you know, certain 12 data that was just written on that drive. 13 Because then, you have gaps in the recording. 14 : So, a raid can also be 15 referred to as DVR system. Right? Now, if a 16 DVR system, they have two DVRs. If DRV-2 went 17 down completely, right? It stopped recording. 18 Should it have 19 MR. : Mm-hmm. 20 : -- stopped recording on DVR- 21 1? 22 MR. : No, because they are two 23 separate -. They are two separate 24 : Systems. 25 MR. : -- machines. EFTA00127662 38 1 : Okay. And how would they 2 have known that the DVR system went down? Was 3 there any alerts that come up in Nice Vision, 4 anything that comes up to them? 5 MR. : Yeah. So, it would. It 6 would normally come up on the -. It's called 7 the AMS, or the Application Management Server. 8 And that's, like, the primary unit that 9 controls the whole video system. And then, you 10 add recorders underneath that AMS. Depending 11 on how many cameras you have. That's how they 12 kind of allocate recorders. So, if you have 13 100 cameras, okay, let's put 100 cameras on 14 this recorder. Let's put 100 more on the 15 second one. So on and so forth. 16 And then, Application Management Server 17 basically allows the users to authenticate and 18 log into that system, from any client in the 19 facility. Or outside if you, you know, if 20 they've managed to network that way. But yeah, 21 the Application Management Server is kind of, 22 like, the gateway to let people in, to view the 23 video. And then, that also manages the traffic 24 of, okay, you want to see this video and this 25 recorder. Okay, you've got, you know, you've EFTA00127663 39 1 got correct credentials. Okay, you're allowed 2 to view that camera. And then, it sends the 3 feed -- 4 : Okay. 5 MR. : -- to their client station. 6 So, yeah. In short, the AMS would normally 7 have alerts, in an application, I believe it's 8 - it's not Investigator - it's called 9 Supervision. 10 : Mm-hmm. 11 MR. : There was five different 12 applications for Nice Vision. Supervision 13 would keep all of the, like, the hardware, and 14 I think most software events, in that 15 application. And I think you could control, 16 basically, if you had pop-ups messages or 17 anything. But as far as if you didn't go to 18 that server physically, and check, from what I 19 know from the Bureau, they did not allow those 20 servers to send email notifications out. 21 : So -. 22 MR. : Because that would have 23 required them to load with an email client, on 24 the server, and then, you know, basically act 25 like it's, you know, someone's account on that EFTA00127664 40 1 server, to send those email notifications out 2 to other people in the facility there. And as 3 far as I know, up until I left, they didn't 4 allowed that. 5 : So -- 6 MR. : So, you had, you would have 7 to go the physical server, to see those 8 notifications. Or you would -. Well, I take 9 that back, because you could go on the client 10 and log into Nice Vision. And then, check the 11 Supervision. But it's not going to send you, 12 like, an email notification. 13 : So, I want to clarify this 14 for this. If you log into Nice Vision, let's 15 say you're reviewing the video footage -- 16 MR. : Mm-hmm. 17 -- if you log in, there would 18 have been an alert, saying that these cameras 19 are not recording? 20 MR. : Yes. If you -. Yeah. 21 : Now -- 22 MR. : Normally. I don't -. Now, 23 I don't know
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