Page 1
1
2

IN THE UNITED STATES DISTRICT COURT

3

FOR THE NORTHERN DISTRICT OF ILLINOIS

4

EASTERN DIVISION

5

- - - - - - - - - - - - - - - - )

6

NATIONAL IMMIGRANT JUSTICE

) Case No.:

7

CENTER,

) 1:12-cv-5358

8
9

Plaintiff,

)

vs.

)

10

UNITED STATES DEPARTMENT OF

)

11

HOMELAND SECURITY, and UNITED

)

12

STATES IMMIGRATION AND CUSTOMS

)

13

ENFORCEMENT,

)

14
15

Defendants.

Vol. I

)

- - - - - - - - - - - - - - - - )

16
17
18

30(b)(6) DEPOSITION OF REGINALD SAKAMOTO

19

Washington, DC

20

Wednesday, January 29, 2014

21
22
23

Reported by:

24

Kim M. Brantley, CSR

25

Job No:

70294
TSG Reporting - Worldwide

877-702-9580

 Page 2
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

Page 3

SAKAMOTO

1
2
3
4
Wednesday, January 29, 2014
5
Time: 2:56 p.m.
6
7
8
30(b)(6) Deposition of REGINALD SAKAMOTO, 9
held at Dentons US, LLP, 1301 K Street, NW, 6th
10
Floor, Washington, DC, before Kim M. Brantley,
11
Court Reporter and Notary Public of the District
12
of Columbia.
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
APPEARANCES:
On behalf of the Plaintiff:
ERIC ANDALMAN, ESQUIRE
Dentons
233 South Wacker Drive
Chicago, Illinois 60606

On behalf of the Defendants:
CRAIG OSWALD, ESQUIRE
Assistant United States Attorney
Department of Homeland Security
219 Dearborn Street
Chicago, Illinois 60604

Page 4

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
ALSO PRESENT:
CLAUDIA VALENZUELA, ESQUIRE
National Immigrant Justice Center
DEBBIE W. SEQUIN, ESQUIRE
Chief - Government Information Law Division
U.S. Immigration & Customs Enforcement (ICE)
CHARLES OLEAN, ESQUIRE
U.S. Immigration & Customs Enforcement (ICE)

Page 5
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20

SAKAMOTO
P R O C E E D I N G S
R E G I N A L D S A K A M O T O,
called as a witness by Counsel for the Plaintiff,
and, after having first been duly sworn by the
Notary Public, was examined and testified as
follows:
EXAMINATION BY COUNSEL FOR THE PLAINTIFF:
BY MR. ANDALMAN:
Q. Please state your name for the record.
A. Reginald James Sakamoto.
Q. Where do you currently live?
A.
Q. Have you ever been deposed before?
A. Yes.
Q. When?
A. The last time I was deposed was 2000.
Q.
A.
Q.

22

A.

24
25

Q.
A.

.

2 (Pages 2 to 5)
TSG Reporting - Worldwide

877-702-9580

 Page 6

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
Q. Any other lawsuits in which you were
deposed?
A. No.
Q. It's fair to say you haven't been
deposed in your official capacity?
A. No.
Q. Correct. So to give you a little
refresher, since it's been now fourteen years or
so since your last deposition, let me give you a
little bit of the ground rules regarding the
deposition, okay?
A. Okay.
Q. I will ask questions, and this is a
question and answer format. Do you understand
that?
A. Yes.
Q. You should answer my questions
verbally. The court reporter can't record head
nods or head shakes.
Is that alright?
A. Yes.
Q. If your counsel objects to one of my
questions, please let your counsel state the
objection on the record.

Page 7

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
But, unless he instructs you otherwise
and you accept that instruction, please answer the
question, correct?
A. Okay.
Q. If you don't understand a question,
please tell me and I'll either restate or rephrase
it, okay?
A. Okay.
Q. If you don't hear a question, please
let me know, and I'll repeat it or have the court
reporter repeat it, alright?
A. I understand.
Q. If you find a question confusing,
please tell me and I'll rephrase, alright?
A. Yes.
Q. Is there anything interfering with your
ability to answer the questions that I'm about to
ask you candidly?
A. No.
Q. Are you under any medication or drugs?
A. No.
Q. I have to ask, I'm sorry.
If you need a break at any time for any
reason, just let me know, but please not while a

Page 8

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
question is pending, alright?
A. Yes.
Q. Mr. Sakamoto, did you prepare for your
deposition today?
A. Briefly.
Q. How did you prepare for your deposition
today?
A. I just went over some of our review
practices on our Internet site.
Q. Which Internet site is that?
A. Our internal, and share drive. Sorry,
let me clarify; share drive.
Q. What is the name of the share drive?
A. Custody and Management.
Q. Did you do this on your own or at the
direction of counsel?
A. I did this on my own.
Q. What documents did you look at on the
shared drive?
A. I just looked at, you know, previous
reviews going back to 2007, 2008. It was random.
I just picked out some.
MR. ANDALMAN: To the extent it's not
produced in the underlying FOIA request,

Page 9

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
we'll obviously ask for the production of it.
MR. OSWALD: I have no idea. I mean,
it's news to me. I have no idea. I don't
know how we can -MR. ANDALMAN: Fair enough.
THE WITNESS: I mean the honestly, I
can't even recall.
MR. OSWALD: I don't know what I can
do, Eric. I'm not trying -MR. ANDALMAN: Craig, I mean hopefully
it's produced in the underlying -MR. OSWALD: No, it will be produced.
MR. ANDALMAN: So it should be okay.
MR. OSWALD: It will all come out in
the wash.
MR. ANDALMAN: I just have to do that.
BY MR. ANDALMAN:
Q. Did you meet with Mr. Oswald in
preparation for this deposition?
A. Yes.
Q. Did you review documents with him?
A. Briefly.
Q. Do you know what documents you
reviewed?

3 (Pages 6 to 9)
TSG Reporting - Worldwide

877-702-9580

 Page 10

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
A. The documents that we reviewed, we
glanced at some of the information that was
provided to you, I believe.
Q. Is that in a letter form?
A. No, it was -Q. Oh.
A. It was on a C.D. disk.
Q. So you glanced at some of the documents
previously produced in this litigation?
A. Yes, but that's what it was, it was
just, you know...
Q. Is there anything else, any other
documents that you looked at?
A. I looked at -- I'm just trying to
remember. We've had so much stuff going on, so
I'm keeping things compartmentalized.
Q. No problem.
A. No, that's basically it. I looked at
who was inspecting when, due to course period, in
the course of 2007, 2012, because there was
changes in contracts.
I looked at an ODO E-mail, Office of
Detention and Oversight, an E-mail that was sent
to me from the Deputy Director, Nina Dozoretz.

Page 11

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
Q. Okay.
A. And that's pretty much it. I have seen
a list of the facilities. I have seen a list of
the one hundred facilities.
Q. Okay.
A. That's it. I didn't really -Q. Okay.
A. I didn't really pay attention to those
facilities or look at specifics as regards to
those facilities.
Q. So that E-mail from ODO Ms. Nina, what
was her last name, I'm sorry?
A. Dozoretz.
Q. Dozoretz, from Ms. Dozoretz to you,
what was the subject of that E-mail?
A. It was the subject of the creation of
ODO.
Q. Outlining the history of ODO, or -A. Yes, with when they were created in
2000. It was a clarification of what was the
creation of ODO as well as how they maintain their
records.
Q. Was this E-mail at the direction of
counsel?

Page 12

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
A. No.
MR. ANDALMAN: We're going to ask for
the production of that, obviously.
THE WITNESS: I mean, I don't know -well, let me rephrase. I don't know if it
was or not.
I wasn't present when -- I believe, was
it -MR. ANDALMAN: Fair enough. We'll deal
with it offline, not a problem.
BY MR. ANDALMAN:
Q. Fair enough. And that's the universe
of documents that you've looked at, plus or minus?
A. Yes.
Q. Fair enough.
I'm going to go through a couple of
background questions to get a sense of your
educational and job backgrounds.
This will lay a foundation for some of
the other questions we're going to ask.
Did you graduate high school?
A. Yes.
Q. Where did you attend high school?
A. Where did I graduate high school from

Page 13

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
or where did I attend high school?
Q. We'll just do graduate.
A. Big Ben, Washington.
Q. In Washington state, I imagine?
A. Yes.
Q. Did you attend college after graduating
high school?
A. No.
Q. Did you ever attend a college?
A. Yes, off and on, but I didn't graduate.
I went in the military.
Q. After graduating high school, did you
immediately enter the military?
A. No.
Q. So what did you do immediately after
graduating high school?
A. I played competitive rugby.
Q. That's pretty cool. And where did you
do that?
A. I played Alberta juniors. I played in
Alberta Canada, and then I played for the Alberta
junior team.
Q. Approximately what years did you play?
A. Yes, that would be 1981 to 1983.

4 (Pages 10 to 13)
TSG Reporting - Worldwide

877-702-9580

 Page 14

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
Q. Then in 1982 what did you do?
A. Went in the military.
Q. Which division?
A. Army.
Q. How long were you in that?
A. 'Till 1992.
Q. I assume an honorable discharge?
A. Yes.
Q. What position did you have in the army?
A. Sergeant.
Q. Sergeant?
A. Um-hmm.
Q. In 1992, what did you do, after leaving
the army?
A. After leaving the army I was married
overseas in Germany, so I worked for the federal
government, DOD.
Q. What position did you have there?
A. I was mail clerk.
Q. How long did you have that position?
A. About a year.
Q. So to about 1993?
A. No, from 1993 to 1994, almost 1995-ish.
Q. Okay.

Page 15

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
A. Came back to here actually.
Q. In 1995?
A. Yes.
Q. When you say came back here, came back
to Washington state -A. To the Washington area.
Q. Oh, Washington, D.C.?
A. Yes.
Q. What did you do in Washington, D.C.?
A. I ended up working for DOD, the Army
Research Labs in Adelphi, Maryland.
Q. What did you do there?
A. I was security.
Q. When you say security, physically a
security guard?
A. Yes, federal, armed.
Q. How long did you have that position?
A. 'Till 1997.
Q. What happened in 1997? Where did you
go?
A. INS.
Q. Which is the predecessor to -A. Yes.
Q. Department of Homeland Security and

Page 16

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
ICE?
A. Not Department of Homeland Security.
It is the predecessor to -- yes, to ICE.
Q. In 1997, what position did you hold at
the INS?
A. Deportation officer.
Q. Which facility was that at?
A. El Paso.
Q. In Colorado?
A. No.
Q. In Texas?
A. Yes.
Q. How long did you have that position?
A. At the facility or with the field
office?
Q. Let's just say the facility first.
A. 1997 to about 2000.
Q. Then in 2000 what happened?
A. I went to the field office.
Q. Where was the field office located?
A. El Paso.
Q. What did you do there?
A. I was non detained. My last job while
I was in El Paso was with the Southwest Fugitive

Page 17

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
Task Force.
Q. What did you specifically do for the
Southwest Fugitive Task Force?
A. Warrants.
Q. By warrants, that was catching folks
that -A. Yes. We went after fugitives, both
state and federal.
Q. How long did you do that for?
A. Almost a year.
Q. So, 2001?
A. Yes.
Q. In 2001 -A. Well, actually yeah, the end of 2001.
Q. Then at the end of 2001, what did you
do?
A. I went to federal Air Marshals Service.
Q. What did you do there?
A. I was a federal air marshal.
Q. Where were you based?
A. Las Vegas.
Q. Been a little bit of everywhere? How
long did you have that position?
A. 'Till January 2007.

5 (Pages 14 to 17)
TSG Reporting - Worldwide

877-702-9580

 Page 19

Page 18

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
Q. Then in January 2007, what did you do?
A. I came back to what is now ICE and
Enforcement Removal Operations.
Q. So ERO?
A. Um-hmm.
Q. What position did you have at ERO in
2007?
A. Detention deportation officer, staff
officer.
Q. How long did you have that position?
A. 'Till September 2009.
Q. As a deportation officer, what were
your primary roles and responsibilities?
A. As a deportation officer in El Paso
or -Q. No, at the ERO?
A. Headquarters?
Q. Yes.
A. I was a staff officer for Alternatives
to Detention, and then started the Juvenile Family
Residential Management Unit, and then went back to
ATD.
Q. What's ATD?
A. Alternatives to Detention.

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
Q. Oh, got it. When you say you started
at the Juvenile Family Residential Management
Unit, you were just one of the founding employees?
A. Um-hmm. Yes, I started in 2008 or
whatever.
Q. While we're at it, what is the role of
ERO, of the Enforcement Removal Operations unit or
office?
A. The program within ICE?
Q. Yes.
A. Our primary role is to safeguard our
borders and our national security and to remove
determined aliens from the United States.
Q. In September 2009 what did you do?
A. I transferred to Phoenix, Arizona.
Q. Were you still with the ERO?
A. Yes.
Q. Same position, deportation officer?
A. Supervisor, Detention Deportation
Officer.
Q. How did your role change there?
A. I mean, I was supervising non-detained
units to include fugitive operations. I worked
CAP.

Page 20
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
Q. You worked what?
A. Criminal Alien Program, Fugitive
Operations, Law Enforcement Agency Response Team.
Q. How long were you in this position?
A. Until September -- well, no, scratch
that. Until June 2012.
Q. In June 2012, where did you go?
A. I was acting chief for the Detention
Monitoring Unit which became permanent September
2012, to present.
Q. For Detention and Monitoring Unit, you
said?
A. That's correct.
Q. What were your roles there?
A. I supervised detention service
managers.
Q. In your supervision role, what sort of
day-to-day tasks do you do?
A. I deal with aspects of almost
everything that comes into the Custody and
Management Division.
So, anything that really revolves
around detention, I may be involved with it.
Q. When you say deal or be involved, you

Page 21

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
know, what specifically are you doing?
A. Well, I have onsite personnel at
fifty-four facilities.
Q. Um-hmm.
A. So, if there's an inspection that's
pending or if there's issues with standards or
those types of things, my unit would be involved
with that.
If there's things that come across with
regard to CRCL, my unit may be involved with that.
Q. What is CRCL?
A. Civil Rights Civil Liberties. Civil
Rights and Civil Liberties.
Q. Got it. When you say there's issues
with standards, what do you mean by that?
A. If there's questions with regards to
standards, or if there's, you know -- let me just
think of something.
Key and lock control, for example,
there's a question with, you know, how -- or
tools, let's say tools. There's a question with
how the tools are marked or what kind of shadow
board do they use, or something, we would, you
know, work with the service provider or the field

6 (Pages 18 to 21)
TSG Reporting - Worldwide

877-702-9580

 Page 22

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
office.
Or if the field office has concerns or
is -- or let's rephrase that.
If the service provider is having
concerns with maybe like interaction with the
field office, you know, we could facilitate maybe
some of that communication.
The whole gambit, I mean.
Q. Do you ever provide any written
opinions regarding the standards?
A. Can you -Q. If there is a question about standards,
do you personally write opinions as to how the
standards are to be implemented?
MR. OSWALD: Objection, vague.
You can answer the question.
THE WITNESS: How the standards are
being implemented? I mean, there's -BY MR. ANDALMAN:
Q. So, let me take a step back.
You stated that one of the roles that
you have is that you assist with questions
regarding standards, correct?
A. Did I use the word "assist"?

Page 23

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
Q. Perhaps not assist.
A. My unit, whether it's my employee that
I supervise that is on the ground, in my
day-to-day actions as a supervisor, I would have
potential knowledge of that.
DSCU, which is another unit, which is
the Detention Standards Compliance Unit, they're
the ones that make decisions with regard to the
standards.
Q. Okay.
A. My unit makes sure that the standards
are being adhered so.
So, you know, we have through our
day-to-day, you know, work, we have opinions of
how the standards should be performed, the service
provider would have opinions with how the
standards should be performed, and then
potentially the field office would have an
opinion.
So we would go to DSCU and ask DSCU for
clarification, and then we would ensure that all
the components, once that determination is made,
is complying with that.
Q. The written records that you have of

Page 24
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
whether or not the particular facilities are
adhering to DSCU's final opinion as to the
implementation of the standards?
A. As Custody and Management, we have
records of compliance with issues.
Q. What sort of records do you have?
A. We do responses. Like, for example,
let's say CRCL has a bunch of recommendations.
They go out and do a site visit and then they have
recommendations how they feel.
So, what Custody and Management would
do -- well, how it gets tasked. It gets tasked
through tasking, come down to Custody and
Management. Custody and Management would work
with the entities to formulate a response to those
recommendations.
It doesn't mean we agree. You know, we
could concur with some things. We could disagree
with some things.
Q. Right, and so my question is that, when
you formulate those responses, are they in written
form?
A. Those responses? Yes.
Q. Are they always in written form?

Page 25

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
A. No.
Q. So some of them were -A. I mean, I don't know how I can answer
that question.
Q. So, let's take the hypothetical that
you provided, which is Civil Rights and Civil
Liberties has an issue with how certain standards
are being implemented, perhaps.
They move the issue up the chain. Your
unit receives that -- let's call it an inquiry -A. Yes.
Q. Or recommendation or so forth, correct?
A. Yes, yes.
Q. You then formulate a response to that,
correct?
A. Yes. In conjunction with multiple
parties.
Q. Correct. But in part you put together
a response?
A. Yes.
Q. Is your formulated response then
delivered in writing or is it delivered orally or
does it vary?
A. Our responses back would be in writing.

7 (Pages 22 to 25)
TSG Reporting - Worldwide

877-702-9580

  

 

 

 

Page 26 page 27
1 SAKAMOTO 1 SAKAMOTO
2 Norv, ro come up wirli a final response. ii could 2 hc convcisaiions,
3 vary. 3 Fair enough, ls ir rhe rypical
4 Q, So whai's ihe difference beiween a 4 ro ineniorialize ihose conieisauons?
5 response and a final icSponSc" 5 A No
6 A, Well, a final lcspomc is our official 6 This posiuon is pcrmancm Chief of
7 response. "131 is where wc'lc lcsponding back ro 7 ihc Directing and Monitoring --
a CRCL in ihis insiance, A Dcienrion Momlonng Uml.
9 Q, So ihose nor necessarily wriuen. 9 Dcienrion Momlonng Uml. ls ihai
0 bul rhe -- 10 your cui-ieni posiuom
1 A, They are rvrinenfinal response. ii could vary. I mean. rheie 12 You siarcd rhar you oveisee fifry
3 could be several conveisauons, 12 pcisonnel ai fifiy-four faciliucSdidn'i say ihai
5 A, So "131 rhe biainslonnmg and 15 Okay. rhen niisniideisrood you
developmenr of rhis lcspomc isn'i necessarily a 16 A I manage fifiy--foui faciliries ivirh
7 wririen producr. bur |hal rhe final response is 17 pcisonnel. lhave ~onic peisonncl rhai have
8 always wnucn, 1e muluplc faciliues,
9 Am I you conscily" 19 Its mugth --
20 A Yes, For |hc niosi pan us even 20 Okay,
21 plcliminmy, lr goes lhlaugh several reviervs and 21 A Ycah. ii's mugth ihirry--fiie DSMs
2 2 edir,- 22 ocploycd naiionally. DSMS and DSCOs. ro clarify
23 Q, 001 ir, 23 ihai
24 A, Ii's wriucn, Bul rlieie can be. yusi 24 Whai aic DSMS and Dscov
2 5 io be clear, because you have me here. rheie could 25 A DSMS are Deicniion Service Managers.
Page 25 page 29
1 1 SAKAMDTL)
2 vvlneli are analysis. and uscos 2 A. Well. rhere's lwo So llusl wanl in
2 are ileporiniion officers |hA| are Derenuon 3 elari hecaiise ilie DSCOS are half of ihe roral
4 Compliance Officen 4 group
5 And iliose are ilie personnel responsible 5 Q. Righl,
faciliueo A. And DSMS are ihe oilier half. in
7 A Correer 7 essence ihey bolh do ihe same you and ihey do nor
a Where are iliose a do reviews and inspecuons
A Across ilie nnuon. 9 Q. We will gel inro ihai in a second ihen,
10 They're noi ilivnled by paniculizr iearns 10 A. Qka r,
11 in! field offices" 11
12 A lhnve iheni ilivnled by reglom. 12
1 2 vvesiem. cemml and easiern. 1 1
14 And yuu saiil yuu have iheni divided. 14
15 Does ihni meAn ihni you ereaied |hn divisionYeahyou repon io7 13
19 A lrepnri u. ilie Depniy Assisiani 19
2o Direcior for ilie Dereniion and Manngernern Division 20
21 vviilnri ciisrorly 21
22 These DSCD are ihey ilie ones 22
2 2 penuml revievvs. inspeeuons nudiumean. involved wilh" Whai does
25 Yuu saiil ilrni iliev ilenl vviili sinnilarilu 25 ihai mean" Yes. i mean. for ATD was involved in

 

 

 

  

 

 

TSG Repnrting WDIldwide

8 (Pages 26 to 29)

s77e7uzes5au

Page 30

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
litigation over a contract award. I was the
chairman of the committee.
And it was dual source. The agency
wanted to go to single source, so obviously there
was going to be a losing entity. So they sued.
Q. What is ATD?
A. Alternatives to Detention.
Q. Oh, right, right.
A. ankle bracelets, telephone, all that
stuff.
Q. Okay.
A. So I was chairman of the award
committee.
Q. Any other litigation?
A. Periphery, I mean peripherally, Hutto,
T. Don Hutto, the family unit back when the whole
unit was kind of wrapped up in that.
Q. Have you ever been named in a criminal
complaint?
A. No.
Q. Have you ever been charged criminally
with anything?
A. No.
Q. Are you familiar with the action of

Page 31
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
National Immigrant Justice Center vs. The
Department of Homeland Security, the instant
action here?
A. I mean, why I'm here now? Am I
familiar with it?
Q. Yes.
A. I'm familiar with it; not intimately.
Q. Are you familiar with the Freedom of
Information Act?
A. Yes.
Q. Have you handled Freedom of Information
Act requests before?
A. Yes, as they come down to my unit.
Q. How would they come to your unit?
A. An individual or an entity would file a
FOIA. The FOIA would, depending on which source I
imagine they filed it through, would wind up in
ERO FOIA, and once ERO FOIA gets it, then they
would look at the FOIA request and determine which
programs would be involved in that FOIA, and then
it would get tasked out to those programs.
Once it's tasked out to those programs,
each program would look for and acquire the
pertinent information with regards to that

Page 32

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
specific program.
Q. Based on your experience, how long does
this process typically take?
A. Five minutes to days, weeks.
Q. What's the longest one that you're
aware of?
A. The longest one that I'm aware of I
think might be this one.
Q. Have you been involved in any
litigation regarding FOIA requests?
A. No.
Q. Have you been involved with the
physical gathering and production of documents in
the FOIA, as it relates to a FOIA request?
A. Yes.
Q. Approximately how many have you done?
A. Three or four.
MR. ANDALMAN: Let's take a quick
break.
(Brief recess taken.)
BY MR. ANDALMAN:
Q. Do you understand what a 30(b)(6)
deposition is?
A. I believe I do.

Page 33

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
Q. Well, do you understand that you are
representing the knowledge and opinions of an
entity in your testimony?
It's not just based on your personal
knowledge, correct?
A. Yes.
Q. While your answer may incorporate your
experience, your answers will represent the
opinions -A. Wait, we have to have a caucus, hold
on. Seriously.
MR. ANDALMAN: Let's take a break. Do
you want to talk to your attorney?
THE WITNESS: Yes.
MS. VALENZUELA: We can leave.
(Brief recess taken.)
MR. ANDALMAN: We're back on the
record.
BY MR. ANDALMAN:
Q. I think when we last left off we were
discussing, you know, your knowledge of what a
30(b)(6) deposition is, correct?
A. Correct.
Q. I mentioned that your answer, while it

9 (Pages 30 to 33)
TSG Reporting - Worldwide

877-702-9580

 Page 34

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
may incorporate your own experiences, ultimately
represents the knowledge and opinions of the
entity on which you're responding, correct?
A. Yes.
Q. I'm going to show you what has
previously been marked I believe as Exhibit 1
Neveleff. Everyone has a copy.
Mr. Sakamoto -A. I have to say, I saw this, but I didn't
tell you about it earlier. Honestly, I can't
remember what you're talking about, seriously.
But I did see this.
Q. That was going to be my next question,
so we shortcut one.
So, given that you've seen this
document, it's labeled as Exhibit 1. It is the
Notice of 30(b)(6) Deposition, correct?
A. Yes, sir.
Q. If you turn to Page Five, you have been
designated to address certain topics, correct?
A. Yes.
Q. Topic Number Four, "The facts and
circumstances concerning or relating how records
of reviews, audits and inspections are retained in

Page 35
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
the ordinary course of business."
Are you prepared to address this on
behalf of the Department of Homeland Security?
A. Yes.
Q. Are you prepared to address this on
behalf of -A. Scratch that. How about ICE?
Q. Okay. So -A. I mean, it's ICE.
Q. I'll ask the question again.
Are you prepared to address this on
behalf of the Department of Homeland Security?
A. No.
Q. Are you prepared to address this on
behalf of the Immigration and Customs Enforcement?
A. Yes.
Q. Topic Number Five, "The facts and
circumstances concerning or relating to the
location of records, reviews, audits and
inspections."
Are you prepared to address this on
behalf of the Department of Homeland Security?
A. No.
Q. Are you prepared to address this topic

Page 36

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
on behalf of ICE?
A. Yes.
Q. Topic Number 6, "The facts and
circumstances concerning or relating to the level
of care exercised, including without limitation
security measures taken in connection with
retaining records of reviews, audits and
inspections in the ordinary course of business."
Are you prepared to address this on
behalf of DHS?
A. No.
Q. Are you prepared to address this on
behalf of ICE?
A. Yes.
Q. Topic Number 8, "The facts and
circumstances concerning or relating to the
persons and/or entities responsible for conducting
reviews, audits and inspections."
Are you prepared to address this on
behalf of DHS?
A. No.
Q. Are you prepared to address this on
behalf of ICE?
A. Yes.

Page 37

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
Q. Topic Number Nine, "The facts and
circumstances concerning or relating to the
persons and/or entities responsible for preparing
reviews, audits and inspections."
Are you prepared to address this on
behalf of DHS, Department of Homeland Security?
A. No.
Q. Are you prepared to address this on
behalf of ICE?
A. Yes.
Q. Topic Number 10, "The facts and
circumstances concerning or relating to the
preparation of reviews, audits and inspections."
Are you prepared to address this on
behalf of the Department of Homeland Security?
A. No.
Q. Are you prepared to address this on
behalf of ICE?
A. Yes.
Q. "The facts and circumstances concerning
or relating to how records relating to individual
detention ratings are maintained."
Are you prepared to address this on
behalf of the Department of Homeland Security?

10 (Pages 34 to 37)
TSG Reporting - Worldwide

877-702-9580

 Page 38

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
A. We moved to twelve?
Q. Thirteen.
A. Thirteen. Can you repeat it, please?
Q. Yes. "The facts and circumstances
concerning or relating to how records relating to
individual detention ratings are maintained."
A. Yes, according to ICE.
Q. But not according to DHS, correct?
A. Correct.
Q. Topic Number 15, "The facts and
circumstances concerning or relating to central
repositories, if any, that retain or store
government detention contracts and records of
reviews, audits and inspections."
Are you prepared to address this topic
to the extent it relates to reviews, audits and
inspections on behalf of DHS?
A. No.
Q. Same question on behalf of ICE.
A. And just for clarification, so you're
scratching the contract stuff, right?
Q. Mr. Oswald designated a different
designee to -A. Yes. So with regards to your question

Page 39

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
with that, yes.
Q. Are you prepared to address this topic
to the extent it relates to government detention
contracts?
MR. OSWALD: I object because it goes
beyond the scope of what I designated him
for.
So you can answer the question.
THE WITNESS: What I know.
BY MR. ANDALMAN:
Q. Number 16, "The facts and circumstances
concerning or relating to the media on which
government contracts, and the records of reviews
audits and inspections are stored."
Are you prepared to address this topic
to the extent it relates to reviews, audits and
inspections on behalf of the Department of
Homeland Security?
A. No.
Q. Same question with respect to ICE.
A. Again, same as fifteen, you know, as
far as I know about with regards to the contract.
Q. Got it. Number 20, "The facts and
circumstances concerning or relating to how

Page 40

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
government detention contracts and records of
reviews, audits and inspections are retrieved,
reviewed and produced, including without
limitation in connection with a Freedom of
Information Act request."
Are you prepared to address this topic
to the extent it relates to reviews, audits and
inspections on behalf of the Department of
Homeland Security?
A. No.
Q. Same question with respect to ICE.
A. Yes, the same as fifteen and sixteen.
Q. As part of your responsibilities do you
deal with certain reviews, audits and inspections
of detention facilities?
A. Yes.
Q. When I use the terms "reviews, audits
and inspections," are there distinctions between a
review, an audit and an inspection, according to
ICE?
A. Yes.
Q. What are the differences? What is a
review?
A. A review could be anything, ad hoc. We

Page 41

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
could see a spike in detainee grievances, for
example; we can order a review.
Q. Are reviews required to be in writing?
A. Yes. Official reviews would be in
writing.
Q. Are there unofficial reviews?
A. There's compliance monitoring through
several entities, which would be unofficial in
nature.
Q. What does it mean to be "unofficial in
nature"? I'm just trying to figure out what that
means.
A. Well, I mean, not so much in writing.
I mean, you have compliance teams.
Some field offices have compliance teams that go
out throughout the AOR's facilities.
I have my DSMs and DSCOs that are day
to day monitoring standards.
Those, you know, could be -- I mean, it
all depends on what your definition of a review
is, I guess.
Q. I'm concerned what the definition of a
review is to the Immigration and Customs
Enforcement, and that's what I'm trying to ask

11 (Pages 38 to 41)
TSG Reporting - Worldwide

877-702-9580

 Page 42

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
about.
A. ODO can conduct a review; CRCL could
conduct a review, and those would be in writing.
Q. No matter what, they're required to be
in writing?
A. They're external stakeholders that
would put it in writing. I mean, they're within
the department, but they're not part of ERO.
Q. What does it mean to be an external
stakeholder?
A. With regards to enforcement rules of
operations. They're not assigned to Enforcement
Removal Operations.
Office of Detention Oversight is part
of ICE and OPR. Civil Rights and Civil Liberties
is under the Department of Homeland Security.
Q. I'm sorry, what did you say that ODO is
under?
A. OPR.
Q. OPR, so that's Office of Professional
Review?
A. Responsibility.
Q. Responsibility?
You testified that DSCU performs

Page 43

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
certain reviews?
A. They are the ERO unit that manages the
Nakamoto contract that handles ERO's annual
reviews or inspections; reviews, inspections,
audits.
Q. Are those required to be put into
writing?
A. The Nakamoto?
Q. Yes.
A. Yes.
Q. Do the DSCU's conduct any reviews that
don't have to be in writing?
A. No.
Q. What is an audit from the perspective
of Immigration Customs Enforcement?
A. An audit would be a function that
happens with regards to performance.
Q. Performance of what?
A. Could be a contract. It could be
statistics. It could be any number of things.
Q. Let's go back to the reviews for one
second, my apologies.
Does DHS perform any reviews of the
detention facilities?

Page 44

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
A. We work for DHS, so, the answer would
be yes.
Q. DHS, apart from ERO, is there another
unit, or is there a -A. Yes.
Q. Okay, what is that?
A. CRCL.
Q. Any other ones?
A. Apart from ERO, ODO, OIG can, which is
Office of the Inspector General.
Q. Um-hmm. Any others?
A. Not that I can think of, off the top of
my head.
Q. ERO is a program within ICE you stated,
correct?
A. Yes.
Q. Is there another ICE unit or program
that conducts reviews?
A. It's potentially possible that it could
happen, but I can think of one, off the top of my
head, and that would be the Office of Detention
Planning and Policy, ODPP.
Q. Why do you think it's possible that
they would do a review?

Page 45

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
A. Because they're the Office of Detention
Planning and Policy, but the way it works now is
they would task that down to us in ERO.
Q. Okay.
A. So, you know, in theory, if they wanted
to go out then they could.
Q. Got it. Do the U.S. Marshals ever
perform reviews?
A. Yes.
Q. Do the U.S. Marshals perform reviews of
facilities that are managed or operated by ICE?
MR. OSWALD: I object on the grounds
that this witness is authorized to testify on
behalf of ICE in the 30(b)(6) context.
He is not speaking on behalf of
Marshals or anything in conjunction with
that.
To that extent, you can go ahead and
answer the question.
And anything that he says is going to
be based on his personal knowledge and not on
behalf of the organization.
MR. ANDALMAN: Well, to the extent that
he is a 30(b)(6) deponent on behalf of ICE,

12 (Pages 42 to 45)
TSG Reporting - Worldwide

877-702-9580

 Page 46

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
he should know what is going on with ICE
facilities.
BY MR. ANDALMAN:
Q. So, you can answer on that behalf?
A. Well, repeat the question.
Q. Let me repeat the question, yes.
Do the U.S. Marshals perform reviews of
facilities that ICE manages or operates?
A. No.
Q. To the extent you know, what reviews
did the U.S. Marshals perform with regards to
detention facilities?
MR. OSWALD: Same Objection. You may
answer the question.
THE WITNESS: Just go back to that
original one.
I mean, I do not know specifically,
however in the hypothetical there is one CDF
of ours, which is Contract Detention
Facility, that has U.S. Marshal detainees
within it.
Now, what the U.S. Marshals do and how
they review for their detainees, I don't
know. But they do not inspect to the ICE

Page 47

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
National Detention Standards.
BY MR. ANDALMAN:
Q. Do the U.S. Marshals perform reviews of
facilities in which detainees are in ICE custody?
MR. OSWALD: Same Objection. You can
answer the question.
THE WITNESS: Can I just paraphrase or
clarify?
BY MR. ANDALMAN:
Q. Yes.
A. So what you're asking me is do the U.S.
Marshals conduct their own inspections?
Q. Of facilities in which there are
detainees -A. ICE detainees?
Q. ICE detainees. And just state it to
the extent you know.
A. I think you're wording your question -okay, no.
Q. So -MS. VALENZUELA: Can we chat quickly?
MR. ANDALMAN: Yes, let us chat. Let's
go quickly off the record.
(Brief recess taken.)

Page 48

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
BY MR. ANDALMAN:
Q. Mr. Sakamoto, are there facilities,
U.S. Marshal facilities that house ICE detainees?
A. Yes.
Q. Does the U.S. Marshal's -A. Well, I mean, we're in a contract with
the U.S. Marshals. It might not be their
facility.
Q. Okay, fair enough, with that
understanding.
A. Okay.
Q. That the U.S. Marshal's contracts or
owned, for those facilities, do they perform
reviews of them?
A. Do the U.S. Marshals?
Q. Yes.
A. To the best of my knowledge, yes.
Q. Do you know if they are applying U.S.
Marshal or ICE standards of review?
A. They would apply their standard of
review.
Q. Do private entities perform reviews?
A. Yes.
Q. Is one of those the Nakamoto Group?

Page 49

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
A. Yes.
Q. Does the Nakamoto Group physically
perform inspections of these facilities, or is
that outsourced?
MR. OSWALD: Objection, vague.
MR. ANDALMAN: Strike that.
BY MR. ANDALMAN:
Q. Does the Nakamoto Group, itself,
perform the reviews of certain ICE facilities?
A. Yes.
Q. Contractors or employees of the
Nakamoto Group are conducting those reviews,
correct?
A. Yes.
Q. Are there other private entities that
perform reviews of ICE facilities?
A. Yes.
Q. What are those other private groups?
A. Capgemini.
Q. Are there any others?
A. Well, let's just go back. I mean,
because my understanding is the scope of is this
is 2007 to 2012.
Is that what we're talking about or are

13 (Pages 46 to 49)
TSG Reporting - Worldwide

877-702-9580

 Page 50

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
we talking about today?
Q. Today, too, I mean, potentially.
A. Okay, well going back to 2007 there
have been several contracts that have done our
inspections for us.
Q. Okay.
A. Creative Corrections.
Q. Okay.
A. MTG.
A. And then we have three experts that are
now with the Capgemini contract, but go back to
2007 and we're under another contract.
It's Capgemini now, but I can't
remember the name.
Q. Did these private entities apply the
ICE standards?
A. Yes.
Q. Who determines whether or not a review
is going to be performed by a private entity or
under a government entity?
A. Nakamoto handles all the ERO annual
reviews.
Q. Does ERO perform reviews in any other
time period, other than annually?

Page 51

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
A. There potentially could be an ad hoc
review, and then preoccupancy reviews that would
be handled by Nakamoto or potentially could be
handled by ERO.
Q. Itself?
A. Itself. Depends on, you know -- I
mean, Nakamoto could be out.
Q. What is a preoccupancy review?
A. Preoccupancy review would be an
assessment that would be done to determine whether
or not we were either going to go back into a
facility we were previously at, or potentially go
into a facility at a future date.
Q. Let's go through these very quickly.
Do you know if the CRCL reviews are
required to be in writing?
A. No.
Q. You don't know, or they don't need to
be?
A. I would assume that they are.
Q. Okay.
A. But I don't work for them, so. All the
ones I've seen are in writing.
Q. ODO, are those required to be in

Page 52

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
writing?
A. Yes.
Q. How often does ODO perform reviews?
A. ODO does theirs off a risk-based
matrix. I think that number would fluctuate. I
don't have a specific number.
Q. Does ODO use the ICE standards?
A. Yes.
Q. Does CRCL use the ICE standards?
A. Yes.
Q. OIG, when they perform it, are they
written reviews?
A. That's OIG. If OIG is doing a review,
that would be potential criminal. So, yes.
Q. Do they utilize the ICE standards?
A. I would think not.
Q. ODPP, to the extent that they do it, do
they perform their reviews in writing?
A. I don't know of one that they have
done, but in the hypothetical, yes, they would.
Q. The U.S. Marshals', are those in
writing?
MR. OSWALD: Objection. Beyond the
scope of his designation.

Page 53

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
MR. ANDALMAN: Fair enough.
MR. OSWALD: You can answer if you
know.
THE WITNESS: I have no idea.
BY MR. ANDALMAN:
Q. The private entity ones, the Nakamoto
ones, are those in writing?
A. Yes.
Q. Capgemini?
A. Yes.
Q. Creative Connects?
A. Creative Corrections.
Q. Creative Corrections, are those?
A. Yes.
Q. MTG?
A. Yes.
Q. The experts that had been previously
separate from Capgemini, are their reviews in
writing?
A. No. What I was saying is they now fall
under the Capgemini contract.
They were, I want to say it was the
STG -- it could be MTG, STG, I could have them
mixed up.

14 (Pages 50 to 53)
TSG Reporting - Worldwide

877-702-9580

 Page 54

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
Q. Got it.
A. But those three entities actually now
are under the scope of the Capgemini.
Q. By "individual" you mean those
entities, correct?
A. Yes.
Q. We started talking about audits, and
you said the audits may regard performance of
contracts or statistics.
Are there any others that audits may
refer to?
A. Alien removals. You know, we deal in
numbers, so, I mean, the whole spectrum.
Q. Would it be fair to say that all of
these entities that we just discussed performed
audits, as well?
A. Along the scope of doing a review
inspection.
Q. So I guess what I'm trying to figure
out is, from ICE's perspective, what is the
difference between a review and an audit?
MR. OSWALD: Objection. This was your
term, so you're asking him to use the term.
THE WITNESS: Yes.

Page 55

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
BY MR. ANDALMAN:
Q. Mr. Sakamoto, earlier you began
testifying that these terms do have specific
meanings and -A. I didn't say that.
Q. Okay, let me ask you that.
Does the term "review" have a specific
meaning for ICE?
A. A review would be an inspection.
Q. So there is no difference between a
review and an inspection?
A. Under the context of this, I mean,
somebody could say, "Hey, go out and review this
facility," but they mean to go out and do a
preoccupancy.
Q. So review -- the term of art might -A. I mean, I've never seen a statistic
that says, "We've done X amount of reviews".
Q. What statistics have you seen?
A. Inspections.
Q. So the term of art that ICE uses is
inspections, generally?
A. Generally.
Q. Does ICE use the term "audits" with

Page 56

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
regards to detention facilities?
A. With regards to inspections and such,
no.
Q. What do they use the term "audits" to
refer to?
A. I'm just really trying to think of an
example where -- there was a tasking for an audit.
Q. Well, let me help you maybe clarify it.
Earlier you testified that audits could
refer to performance of contracts, statistics,
numbers, and alien removals.
A. Right. I mean, under the basis of the
contract, there has to be an audit of the
performance of the contract.
Q. Do those differ from the inspections?
A. Yes, because a different entity would
do that. It would be outside the scope of the
standards.
Q. And what entity would perform these
functions?
A. I imagine it would be the contract
technical officer for -Q. Got it?
A. I mean, they do the billing. They make

Page 57

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
sure the man hours are correct.
Q. So audits, as a term of art, to the
extent it's used by ICE, it refers to contract
issues. Is that correct?
Typically it refers to contract issues?
A. Yes.
Q. So, for the purposes of the rest of
this, is it fair to assume that when we're
speaking of reviews or inspections, we're talking
about the same thing?
A. Yes.
Q. So I may use them interchangeably from
here on forward, but -- so that we're talking the
same language, we're stipulating that it's the
same thing?
MR. OSWALD: We will stipulate to the
same thing.
THE WITNESS: I mean, compartments -MR. OSWALD: It's stipulated to.
BY MR. ANDALMAN:
Q. Do detention facilities have ratings
associated with them?
A. Yes.
Q. Are those different from these reviews

15 (Pages 54 to 57)
TSG Reporting - Worldwide

877-702-9580

 Page 58

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
or inspections?
A. No.
Q. So, are you familiar with detention
ratings performed by entities such as the American
Bar Association?
A. No.
Q. So, no preparation -A. No, I didn't look at any of the
American Bar Association stuff.
Q. I'm going to present exhibit that's
been previously marked as Exhibit Number 3.
The first question I'm going to ask is
have you ever seen that Website?
A. Yes.
Q. Is this the Website you reviewed in
connection with your deposition today?
A. I didn't review it. I looked at it.
Q. If you would, would you turn to Page 12
of the exhibit.
A. Okay. Am I missing something?
Q. It's on the bottom.
A. I got one through thirty-seven -- oh, I
got you. Bear with me.
Q. No worries.

Page 59

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
A. Okay.
Q. Do you see in the middle of the page
where it says "Detention Facility Reviews Audits
American Bar Association Commission on
Immigration"?
A. No.
Q. It's maybe two-thirds down the page.
It's in bold?
A. Oh, yes. Okay, yes.
Q. Are you familiar with those reviews,
audits or perhaps rankings?
A. In the context of this document, no.
Q. If you could, would you turn to Exhibit
1 for a second.
A. Sure.
Q. You testified earlier that you were
prepared to testify on Topic Thirteen on behalf of
ICE.
Is that correct?
A. Yes.
Q. And you see where it says "Detention
Ratings"?
A. I see "Detention Facility Reviews and
Audits".

Page 60

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
Q. No, on top of Number 13.
A. Oh, yes.
Q. So, how are you prepared to testify on
detention ratings?
A. With regards to how ERO and ICE comes
up with a rating.
Q. So, I'm trying to figure out how the
reviews and inspections are the same or different
from ratings.
Is it your testimony that the reviews
and inspections are the same thing as ratings?
MR. OSWALD: Objection,
mischaracterizes the testimony, but you can
answer.
MR. ANDALMAN: Let me strike that
question.
BY MR. ANDALMAN:
Q. Is there any difference in the eyes of
ICE between reviews and inspections on the one
hand and ratings on the other hand?
Are those different documents?
A. In that context I guess -- I mean, I
feel like we're playing semantics. I mean, I
don't know --

Page 61

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
A rating is assigned to an inspection.
Q. Okay.
A. There could be a review that is done
that won't have a rating, because you could review
a single standard.
Q. Okay.
A. I mean, if you are asking, "Hey, did
you go and review use-of-force practices," so, I
mean, yeah -Q. And there would be a rating that's
associated with that inspection?
A. It wouldn't be a rating. A rating
would come from the total inspection.
Q. So it's akin, so to speak, to when a
restaurant is rated on several criteria -A. Pass or fail.
Q. And there is a grade of A, B, C or D,
or E, whatever, based on those criteria?
A. Yes.
Q. So, in other words, the ratings are
incorporated into the documents containing the
inspections; is that correct?
Or are there separate documents
containing ratings?

16 (Pages 58 to 61)
TSG Reporting - Worldwide

877-702-9580

 Page 62
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
A. Yeah. There's two ratings. There is
the Nakamoto rating and then it's memorialized
through the rating authority, which is the agency,
ERO, Custody and Management, that is assigning the
official rating.
Q. So is the Nakamoto rating a suggestion,
a recommendation to ERO?
A. Yes.
Q. Do they use the same scale? For
instance, is one numeric and one alpha, or are
they the same scales?
A. You've got to clarify that one with me.
Q. Well, let me strike that.
When Nakamoto provides a recommendation
as to a rating, is it in the same format that ERO
ultimately memorializes it?
For instance, if there is a letter
associated with it or a number associated with
it -A. Yes, yes. There may not be agreement,
but, yes.
MR. OSWALD: Could we really just go
off the record for a second?
(Discussion off the record.)

Page 63
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
BY MR. ANDALMAN:
Q. You stated that sometimes the Nakamoto
recommendation and the ERO's final memorialization
may not be the same, correct?
A. Yes.
Q. Are the disagreements documented in
some way?
A. Yes.
Q. How are they documented?
A. There would be a whole remedial
process.
Q. When you say "a whole remedial
process," what does that mean?
A. The way that Nakamoto would provide
their review to ERO, Custody and Management, in
turn to DSCU, who would go in and they would
review the document, at which time deficiencies
would be outlined to the service provider and the
field office.
And, you know, they would do a remedial
action, and there is the potential that when all
that is done there could be a change in the
rating.
And that could go both ways. I just

Page 64

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
want to be clear. Nakamoto could give a rating
and the agency could present a lower rating.
Q. Let me go back to the reviews and
inspections for one second.
A. Um-hmm.
Q. Are there any policies or procedures as
to when it is in written format how that format
must be presented?
So are there templates, so to speak?
A. You know, I don't know about a written
policy and what's in the contract. Because
basically it goes by what the contract is, what
the verbatim is.
Generally speaking, just generally
speaking, across the board with our contracts,
they're performance based, so we do allow leeway
to the contractors.
So, you know, we have a broad spectrum
of forms. They're basically the same, but the
template could be different.
If it's a CCA form, or sorry, a
Creative Corrections form, it can look different
in aspects than a Nakamoto form.
Q. Okay.

Page 65

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
A. The content is -Q. Okay.
A. Yeah.
Q. Now, is there -A. So a CIS, for example, CIS might look a
little bit different. When you look back at 2007
and look at a Creative Corrections CIS to today, a
Nakamoto CIS -Q. Is it possible -A. Or an MTG, for example.
Q. Got it.
Is it possible that more than one of
these entities, private or governmental, is
performing reviews at the same facility?
A. At the same time?
Q. Well, let's start with at the same
time, yes, or during the same period of time.
A. Yeah, I mean, during the same period,
it is. We don't like to do that, because it's
just so disruptive.
But, a Nakamoto could be doing an
inspection and ODO could be slated to go out. And
a lot of that has to do with, I mean, obviously
budget restraints, I mean, pre-planning, getting

17 (Pages 62 to 65)
TSG Reporting - Worldwide

877-702-9580

 Page 66
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
the travel, getting the people, getting the
subject matter experts together that things
sometimes are locked in.
And if the service provider is saying,
"Okay, we can handle it," because it's a
discussion that all the parties are involved.
I mean, there has been times when
there's been potential overlap where we said, "No,
you can't go out. One or the other".
The same with CRCL, for example. They
could be wanting to go out to a site and we could
have a Nakamoto out there and we will say, "Timing
is bad".
That's how I understood your question.
Q. No, that's exactly my question.
Is there a policy and procedure
determining which entity performs a review?
A. Yes. ERO/Nakamoto performs our
reviews. ODO, I think it was August 2009,
previously known as DEFIG, under ICE Secretary
John Morton, and the detention reform that
happened, yeah, it was August 2009, ODO then broke
off and became the DEFIG to the Office of
Detention and Oversight.

Page 67

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
So they handle they're stuff.
ERO/Nakamoto handles our annual inspections.
Q. So are there certain facilities that
are ERO facilities and certain facilities that are
ODO facilities?
A. No.
Q. So how is it determined at a given time
which of those is going to perform the review?
A. That's what I'm saying. That's where
there can be overlap and it's problematic.
Q. Okay.
A. And we have to work together between
the entities and say, "Hey, look. The service
provider can't handle this."
So there are instances though that it's
okay, and both entities could potentially -- we
don't like them to be on the site at the same
time. But they're doing they're thing and we're
doing our thing.
I mean, there have been times when
they've been on one half of the facility and we've
been on one half of the facility.
Q. Are you able to speak to how ODO
prepares its documents, memorializes its

Page 68

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO

1
2
inspections?
3
A. Generally I think I can.
4
Q. How about their ratings?
5
A. They don't provide ratings.
6
Q. Is ODO reviewing for something
7
different than ERO?
8
A. Yes.
9
Q. What are they -10
A. Well...
11
Q. Go ahead.
12
A. ERO is reviewing and inspecting the
13
standards in totality.
14
ODO on the other hand is an oversight
15
entity that is based on a risk-based matrix.
16
So, where we're looking -- when I say
"we're," I'm talking about Custody and Management 17
and ERO -- we're inspecting and reviewing through 18
19
the whole set of standards, which is, you know, a
20
Three Twenty-Four, eighty pages, every single
21
check box, you know, unless there's "N/As"...
22
Where ODO has, you know, environmental
23
health and safety, which is usually generally what
24
they cover, but then they could have, you know,
25
significant reports, whether it's through the JCNS

Page 69

SAKAMOTO
(phon) or wherever, where they're going to go out
and look at, you know, very specific things.
A. Got it. Are the ODO and ERO reviews
stored in the same location.
A. I don't know what that means with
regards to the public domain.
I mean, do you consider that to be the
same location?
I don't know if I'm even right. I
mean, they're under the FOIA. I think we got some
stuff under the FOIA.
MR. OSWALD: If you could ask the
question again, listen to the question.
BY MR. ANDALMAN:
Q. Yes, are the ODO reports stored in the
same location as the ERO reports?
A. No.
Q. So ODO maintains it separately than
ERO?
A. Yes.
Q. Are the CRCL reviews and inspections
sort of in the same place as ODO?
A. Okay, let's just go back and just -now you're talking about theirs, right?

18 (Pages 66 to 69)
TSG Reporting - Worldwide

877-702-9580

 Page 70

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
You're not talking about something that
was maybe given to ERO?
Q. I'm trying to understand.
A. I mean you're talking about the full,
complete package.
Q. Let me try to give you the framework.
We're trying to understand all the different types
of reviews.
A. So we're talking about their file.
Q. Yes. Is their file in the same
location as the ODO's file?
A. No, all three are separate.
Q. Are all of these separate, the CRCL,
the ODO, the OIG, to the extent that it exists,
the ODPP, I feel like I'm in alphabet soup, the
U.S. Marshals, to the extent they exist...
Are they all private entities in
separate locations?
A. I cannot speak to the U.S. Marshals.
Q. Any of the other ones?
A. ERO keeps ERO. ODO keeps ODO. CRCL
keeps CRCL. ODPP, they just call down to ERO.
Q. Got it.
A. If that helps.

Page 71

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
Q. Thank you. Is ERO provided copies of
the other entities' reviews?
A. That I know of as it pertains to us.
Q. When would it not pertain to you?
A. Well, you know, I mean, in the
hypothetical, CRCL might be doing something
criminal with OIG, so we wouldn't see it,
necessarily.
I wouldn't see it. I'm not saying that
the director wouldn't see it.
Q. Got it.
A. But with regards to us, for the most
part, yeah, we get a copy of their file. Well,
ODO, what goes on the FOIA site, we get a copy of
it.
Q. Is the FOIA listing a complete listing
of all the reviews and inspections?
A. I don't know.
Q. Is there a policy for putting reviews
and inspections on the FOIA site?
A. No, not that I'm aware of. Now with
regards to ODO, that's a whole separate animal.
Q. Fair enough.
A. And CRCL, to the best of my knowledge,

Page 72

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
they're not on there at all, period.
Q. Is there a formal written policy of
when ERO is provided with formal, written copies
of reviews?
A. No.
Q. So it happens on an ad hoc basis?
A. Yes, because they don't have a set
schedule.
Q. We spoke in Exhibit 3 about these
detention facility reviews, audits of the American
Bar Association Commission on Immigration.
A. Um-hmm.
Q. What's your understanding of what that
is?
A. Oh, I mean, my understanding is that
that's they're inspections and ratings that they
perform.
Q. Are they commissioned by ICE?
A. The ABA?
Q. Those inspections that they do.
A. I can't speak to this. I mean, this is
2001. All these dates right here go back to
2001.
Q. Well, if you go forward to --

Page 73

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
A. I have no knowledge of -Q. Well, if you go forward to Page 15,
there's at least a couple, you know. There's
several since 2007.
A. The ABA? I mean, they could be -Q. And it's fine if you don't know.
A. Yeah, I mean, they could be -- I don't
know. I don't know.
Q. Generally speaking, are you familiar
about the ABA audits and inspections?
A. No.
Q. On Page 15 there is something that
says, "Detention Facility Reviews, Audits,
Commission on Accreditation For Corrections".
A. ACA?
Q. Do you see that, the bold print on
fifteen?
A. Yes.
Q. Are you familiar with that review or
audit?
A. Is this referring to the ACA, the
American -- was it the CAC back then.
Again, no.
Q. Then if you turn the page to sixteen.

19 (Pages 70 to 73)
TSG Reporting - Worldwide

877-702-9580

 Page 74

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
A. Um-hmm.
Q. Do you see the Detention and Removal
Operations? That's what ERO is now today,
correct?
A. Yes.
Q. So, those are the ERO reviews that have
been made publicly available on this Website?
A. According to this document, yes.
Q. Does that appear to be every one or are
there other ones that you read?
A. Well, I mean, based on the parameters
of, you know, who was to be inspected, by looking
at this document I couldn't answer that question.
Q. Is every facility required every year
to have an inspection, annually?
A. No.
Q. How is that determined?
A. Alright, that's a monster.
Q. Okay.
A. No, it's not really. Like today,
roughly, we have two hundred and fifty-five
facilities. I think scheduled for an annual
review at some point this year, and then this is
just, I'm guessing, it's roughly a hundred and

Page 75

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
thirty-three of those facilities.
Q. Okay.
A. Then you have ORSA.
Q. Okay.
A. Facilities, which are self-assessment
facilities that the field office does.
And so this goes back to the original
questions, I guess. This will probably fall into
the original questions that you were asking about
who does them.
Q. Right.
A. You know, sorry.
Q. No problem.
A. I wasn't thinking about it. So the
ORSA is self-reviewed. There would be a portion
of those, and then another portion would be on the
biannual. Another portion would be on the
biannual.
And those, when you are talking about
under seventy-two hours, under seventy-two-hour
facilities, where we only hold for seventy-two
hours or less, and then, based upon average daily
population.
And so there is a whole gambit of

Page 76

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
reviews to get to be on the ORSA program.
Q. Okay, let's take a step back.
A. Okay.
Q. What is ORSA?
A. I always forget this acronym. It's
the -- Organizational Review Self-Assessment.
Don't quote me on that, but that's the gist of it.
MR. OSWALD: It's only a deposition.
BY MR. ANDALMAN:
Q. That's fine. I think you said, and I
just want to clarify, that the ORSA review is the
one where detainees can be there for over
seventy-two hours?
A. They can be. I didn't get to that
part. They can be, and again, you're asking me
stuff that is specific numbers that, you know, is
not in my day-to-day.
A. Fair enough.
Q. So how it works is for over seventy-two
hours I believe they have to be less than ten ADP?
Q. What is ten ADP?
A. Average daily population.
Q. Okay.
A. I mean, otherwise it would just cost us

Page 77

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
a fortune to go out and -Q. Got it.
A. And then there is the biannual group.
Q. And the biannual group is groups of
facilities that are reviewed once every two years?
A. Passed the criteria, and they are more
than ten, less than fifty, over seventy-two.
Q. More than ten, less than fifty.
A. Now you've got to remember, that's why
that number is always fluctuating, because need
and things can shift.
Q. Got it.
A. So any time you come outside of that
parameter, you would go into the annual.
Q. So, when you say more than ten, less
than fifty, that's average daily population?
A. Correct.
Q. And when you say passed the criteria,
those are facilities that -A. Previously passed, I believe for the
biannually it's two consecutive "meets standards".
Q. Okay.
A. So, that's why you'll never, ever see
all our facilities with an annual review.

20 (Pages 74 to 77)
TSG Reporting - Worldwide

877-702-9580

 Page 78

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
Q. So the hundred and thirty-three annual
review facilities, are those reviews required to
be in writing?
A. Yes.
Q. How ever many ORSA facilities, are
those reviews required to be in writing?
A. Yes.
Q. And the biannual ones, are those
required to be in writing?
A. Yes.
Q. So the hundred and thirty-three
facilities that have annual reviews, those have
greater than fifty ADP?
Is that the idea?
A. Yeah, well -- no, you could have
somebody come off the list. You could have
somebody go on the list. Depends upon need.
Let's say you had a Nakamoto setup, and
all of a sudden operationally they said they were
going to deviate from the loop flight or
something.
I'm just throwing something out there.
Q. Right.
A. And now all of a sudden X facility's

Page 79

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
ADP is now going to go down to less than fifty.
They could potentially, because last year they had
a pass, they could potentially go on the ORSA.
Or, I'm sorry -Q. Let me ask the question real quick.
So these self-assessments...
A. Um-hmm.
Q. First of all, with this whole
schematic, is there a written policy that exists
to discuss, these are the ones that are going to
get annual assessments, these are the ones that
are going to get biannual assessments, these are
the -A. I believe they're working on it.
Q. So there doesn't currently exist one,
to your knowledge?
A. Correct.
Q. The ORSA self-assessment, are there
protocols or templates that the ORSA people have,
or that facilities fill out?
A. Yes.
Q. Where are those templates stored?
A. ERO.
Q. ERO? In paper format or electronic

Page 80

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
format or both?
A. Within the guidelines of both.
Q. Okay.
MR. OSWALD: Can we take a break here?
MR. ANDALMAN: Yes, let's take a break?
(Brief recess taken.)
BY MR. ANDALMAN:
Q. So you mentioned earlier about these
biannual reviews, right?
A. Yes.
Q. The question that I have is, you said
if it fails, or if it has two consecutive meet
standards, it stays on the biannual -A. Within the parameters of the ADP.
Q. Within the parameters of the ADP,
exactly.
When you say meet standards, that means
meets standards on every item?
A. No. Overall and in totality, the
rating, the final rating.
Q. Do employees of ERO receive training
with regards to the storage and promulgation of
these reviews and inspections and ratings?
A. Yes.

Page 81

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
Q. Who provides that training?
A. Virtual University.
Q. Virtual University?
A. Yeah. It's the training Website. I
believe that they're a contract for them.
Q. So are they contracted by ICE?
A. It's the ERO training and development
division that handles Virtual University, and I
believe that Virtual University is a subcontractor
or a contract to them.
Q. As part of that training do you learn
specifically how to store these documents?
A. Not the specifics on how to store them.
Q. Okay.
A. Other than safeguarding.
Q. When you say "safeguarding," does that
mean encryption, or lock and keys, or what does
that mean?
A. No, it's -- I'm trying to remember.
It's the register; it's the length of service;
it's all those types of things.
And then, you know, other than
classified material, I don't believe that it gets
into, you know, specific lock and key.

21 (Pages 78 to 81)
TSG Reporting - Worldwide

877-702-9580

 Page 82

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
Q. Okay.
A. It just goes into how long you need to
maintain them.
Q. How long do these inspections need to
be maintained?
A. I think it's six years.
Q. Is that pursuant to the FAR
requirements?
A. No, no, I mean, I'm talking hard copy.
Q. What about electronic copies?
A. Electronic copies, we have them. I
take that back, scratch that.
It's six years, to include electronic
copies.
Q. Is there any protocol or standard
requiring that review and inspection documents are
scanned into some electronic format?
A. Well, I believe that the class does go
into the transfer of files into media. We do do
it, but with regards to a written policy.
Q. We'll take a step back. I'm sorry, I
didn't let you finish.
A. Yeah, I haven't read a written policy
with regards to scanning.

Page 83

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
Q. Is there any requirement, regardless if
it's written, that the reviews and inspections
must be put into electronic format?
A. I believe there is within the timeframe
parameters.
Q. When you say "timeframe parameters,"
does that mean -A. Given the, yeah, for whatever the
federal guidelines are with maintaining and
storing federal records.
Q. Okay. So -A. So, I mean, you know, the register, I'm
sure that the register is somewhere.
I mean, there's federal governing
policy on how the federal government maintains
records, which would include these.
Q. You're not certain whether or not every
review and inspection, in the relevant time
period, from 2007 onward, has been put in
electronic format?
A. Yes.
Q. Well, is that a no, you're not sure?
A. No.
Q. If it is put in electronic format, is

Page 84

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
it in searchable format?
A. Yes, yes.
Q. If it's in searchable -- when it's put
in electronic format, is it stored on a server?
A. Yes.
Q. Are the ERO ones stored in the same
server as the DOD ones?
A. I don't know about the ODO server.
Q. Let me restate that. Does ODO have a
different server than ERO?
A. They have a different share drive.
Q. Okay.
A. I don't know about the server.
Q. What types of documents are on this
shared drive?
A. All the inspection reviews and ratings.
Q. Can someone in ERO access ODO's share
drive?
A. No.
Q. Can someone in ERO -A. Well, let me go back and say, I could
if they gave me permissions to do so, or an access
and a link to that domain.
Q. How difficult is it to get permissions?

Page 85

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
A. Well, it's program driven. I mean,
it's need-to-know.
Q. Right.
A. So, I mean, that's why I don't have
access to ODO's.
Q. If someone were -A. I'm not saying it's impossible.
Q. Right. If someone were provided
permissions, how long does that typically take?
A. You know, it would have to go to
whatever, you know, the level of the approving
authority is.
Q. Okay.
A. Because ODO is an investigative OPR
authority. You know, it probably would take
several levels of approval.
Q. Is there someone high enough ranked at
ERO that would have the ability to have access to
this?
A. EAD Homeland could? I mean, I don't
know why he would want to. I mean, that's as high
level ERO you can go, the Executive Assistant
Director, who is under the assistant secretary.
Q. Is there anyone lower than him that

22 (Pages 82 to 85)
TSG Reporting - Worldwide

877-702-9580

 Page 86

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
might have access?
MR. OSWALD: Calls for speculation.
Objection, but you can answer if you want.
THE WITNESS: Nobody in Custody and
Management that I'm aware of it has it.
BY MR. ANDALMAN:
Q. ICE has a FOIA office, correct?
A. Yes.
Q. Can the FOIA office access the various
shared drives?
A. Again, if they were granted permissions
to do so, they would be able to do it.
Q. Are there classified documents on the
shared drives?
A. Within the parameters of classified
documents. Those would be clearly on, you know, a
classified server, and, you know, you'd have to
have the appropriate need-to-know and levels of
access for that stuff.
Q. Are any reviews or inspections
classified?
A. Not that I'm aware of.
Q. So, to your knowledge, and as the
deponent of ICE, there's not a document that would

Page 87

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
be so prohibitive to grant permissions to one
department of ICE or the other, one program of ICE
or the other?
MR. OSWALD: Objection,
mischaracterizes his testimony.
You can answer it.
THE WITNESS: Yes. I mean, there could
be documents that would permit ERO to go into
ODR servers, absolutely.
If they're doing a criminal
investigation...
BY MR. ANDALMAN:
Q. Fair enough.
Are there ways to prevent provide
limited access to the different drives, share
drives?
A. Not knowing the specific files and the
content of those specific files, I couldn't answer
that question.
Q. Let me restate it.
Is there a way to provide access to
some of the files on a particular shared drive and
not others?
For instance, if you have classified

Page 88

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
documents, just hypothetically, on ERO's shared
drive, is there a way to block those classified
documents from other people who don't have that
clearance?
A. Well, yeah, you have to safeguard
classified documents. That's a given.
But with regards to what measures need
to be put in place to potentially separate
classified documents from whatever might be
compartmentalized with those documents, I don't
know what that would take. That would be, you
know, an IT question.
Q. We spoke and we brushed up on it that
there are certain detention standards, correct?
A. Yes.
Q. When is the earliest known detention
standard that you're aware of?
A. 2000 National Detention Standards.
MR. ANDALMAN: Mark this as Exhibit 7.
Just continue it.
You have no objection to continuing the
exhibits, right?
MR. OSWALD: No.

Page 89

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
(2000 Detention Operations Manual was
marked Deposition Sakamoto Exhibit 7, for
identification.)
BY MR. ANDALMAN:
Q. You've been handed what's now been
marked as Exhibit 7, 2000 Detention Operations
Manual.
A. Um-hmm.
Q. Does that refer to that 2000 operations
standard?
A. Yes.
Q. I'm going to hand you what's marked as
Exhibit 8.
(2008 Performance-Based National
Detention Standards were marked Deposition
Sakamoto Exhibit 8, for identification.)
BY MR. ANDALMAN:
Q. You've been handed now what's marked as
Exhibit 8. Is this another one of the standards?
A. Yes.
Q. What standard is this?
A. The Performance-Based National
Detention Standards of 2008.
Q. Generally speaking, how did the 2000

23 (Pages 86 to 89)
TSG Reporting - Worldwide

877-702-9580

 Page 90

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
and 2008 standards differ?
A. The 2008 standards were created to
better enforce health and safety issues and expand
upon the National Detention Standards of 2000.
Q. Did they require assessment of
different and more items?
A. Yes.
(2011 Detention Operations Manual was
marked Deposition Sakamoto Exhibit 9, for
identification.)
BY MR. ANDALMAN:
Q. You've been handed what's marked as
Exhibit 9. Does this reflect or summarize the
2011 standard?
A. Yes.
Q. How does the 2011 standard differ from
the 2008 standard?
A. There were increases in, you know,
outcomes such as women's medical services that are
going to be provided, expanded recreation, you
know, mental health services, increased access to
legal services, visitation, those types of things.
Q. So between the 2000, Exhibit 7, 2008
and 2011, Exhibits 7 through 9, was there

Page 91

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
additional paperwork that needed to be filled out
as a result of the different standards?
A. What do you mean additional paperwork
that had to be filled out?
Q. Did these standards require additional
items, like a worksheet, for instance?
A. Do you mean changes to the Three
Twenty-Four?
Q. Correct.
A. Yes.
Q. Just for the record, what is the Three
Twenty-Four?
A. That's a standards checklist.
Q. Did the 2000 standard have a standards
checklist?
A. A Three Twenty-Four?
Q. Yes.
A. Yes.
Q. Did the 2008 have a Three Twenty-Four?
A. Yes.
Q. Did the 2011 have a Three Twenty-Four?
A. Yes.
Q. Are there any other standards that ICE
uses?

Page 92

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
A. Yes.
Q. What are those other standards?
A. The residential -- I'm glad I remember.
You see, I almost forgot. The Family Residential
Standards.
Q. Where is that memorialized?
A. What do you mean "where is it
memorialized"?
Q. Where is it publically? Is it
publically available on the ICE Website?
A. I believe it is, yes.
Q. Are there any other ones other than the
Family Residential Standards?
A. No.
Q. Are all facilities evaluated under the
Residential Family Standards?
A. No, there's only one.
Q. What is that one?
A. Burkes, Family Residential Center, to
be specific.
Q. Is there something called a 2013
Segregation Directive?
A. It's not a standard.
Q. Is that at all incorporated into any of

Page 93

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
the evaluations or audits -MR. OSWALD: I would object first on
the grounds that this case deals with things
that happened no later than 2012. So, that
is my first objection.
The second, he's already answered the
question.
MR. ANDALMAN: Well, he can answer it.
MR. OSWALD: You can answer it if you
wish.
THE WITNESS: Yeah, there is a
segregation directive that just came out.
BY MR. ANDALMAN:
Q. Okay.
A. That came out within the last few
months.
Q. I did have a follow-up question.
Is that incorporated into reviews going
forward, or it's unclear at this point?
A. Segregation is an ongoing priority for
ERO right now, that we are looking into those
avenues.
Q. So no decision has been determined?
A. The directive is specific -- well, the

24 (Pages 90 to 93)
TSG Reporting - Worldwide

877-702-9580

 Page 94

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
directive is not based on standards. It's based
on segregation operations.
Q. I'm glad we clarified that.
These form Three-Twenty-Fours, are they
in paper format when they're filled out?
A. Yeah, I mean, but today -- well, we're
not talking about today, so.
Q. Well, are they also in electronic
format?
A. They will become electronic format.
Q. Okay.
A. I mean, onsite, you know, the different
reviewers can have different mediums to, I
believe.
Q. So, there's -A. The final is in paper format.
Q. How about drafts?
A. So, to the best of my knowledge, the
reviewers will go out, and they will have a form.
You know, at least for sure 2007, they had a form.
They would go out and do the form.
And then they would come together to
the LCI, who is the Lead Compliance Investigator,
provide all of those, and a completed document

Page 95

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
would be generated by the LCI, or the RIC,
depending on the timeframe and the period we're
talking about.
Q. What is an LCI?
A. Lead Compliance Inspector.
Q. And then R-I-C, RIC?
A. Yes, Review Inspector in Charge.
Q. Is it fair to say that there is no
protocol as to the format in which drafts of the
Three Twenty-Four need to be recorded?
MR. OSWALD: Objection, one, vague,
two, it mischaracterizes the testimony. You
can feel free to answer.
THE WITNESS: Can you -BY MR. ANDALMAN:
Q. Let me restate. Is there a protocol
that requires drafts to be in a specific, drafts
of the Three Twenty-Four form, to be in a specific
format?
A. No.
Q. These standards form the basis for the
reviews and inspections that we spoke about,
correct?
A. Yes.

Page 96

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
Q. Is there any way of knowing when I pick
up a particular inspection report which standard
is being used?
A. Yes.
Q. How would that be determined?
A. It should state it. Then you can go
and, you know, obviously through the timeframe, I
mean, and the facility, you can determine.
Q. Is there any review or oversight to
ensure that the entity performing the review is
using the correct standard?
A. That would be DSCU.
Q. Does DSCU promulgate or create
documents saying whether or not the correct
standard is being utilized?
A. When the reviews are set up, it's set
up under which standards will be used.
Q. Are there still facilities using an
older standard?
A. Yes.
Q. Is there a policy or procedure to
determine which ones -MR. OSWALD: Objection. This
specifically relates to Item Number 11, which

Page 97

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
the protective order, it covers... "The facts
and circumstances concerning or relating to
which standards, whether Department of
Homeland Security standards or any other
corrections or performance-based standards,
reviews, audits and inspections are intended
to track."
MR. ANDALMAN: Okay, so I'm not -MR. OSWALD: It's specifically covered
by that.
MR. ANDALMAN: I won't go any further
than to ask whether or not a document exists.
MR. OSWALD: With the question being
whether a document exists, you may answer the
question.
THE WITNESS: Can you repeat the
question?
BY MR. ANDALMAN:
Q. Is there a document that exists saying
under what circumstances a given standard should
be utilized by an entity reviewing a facility?
A. Yes.
Q. What is that document?
A. It's a contract.

25 (Pages 94 to 97)
TSG Reporting - Worldwide

877-702-9580

 Page 98

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
Q. Do all contracts state this?
A. Yes.
Q. Let's talk a little bit more about the
form Three Twenty-Four.
Is the form Three Twenty-Four utilized
by all the various entities that do the reviewing?
A. No.
Q. Which entities use the Three
Twenty-Four?
A. Nakamoto.
Q. Any others?
A. I mean, that's today. So, all the
contractors that were doing our annual reviews
through your timeframe would use it.
Q. Does ODO use a Three Twenty-Four?
A. ODO can use a Three Twenty-Four if they
want to, but generally speaking they're looking at
aspects of specific items. So, they already know
going in to do their review, you know -The checklist, it's all the standards.
That's what our annual review is. It's from A to
Z.
ODO is primarily health, safety, those
issues, and then whatever else reason they're

Page 99

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
going in, you know, whether it's grievances,
allegations or whatever.
So they would delve a lot further into,
you know, a confined space than what we would
cover.
Q. Are there any worksheets that ODO uses
other than the Three Twenty-Four?
A. I'm not clear on what they use for
worksheets.
Q. How about CRCL? Did they use the Three
Twenty-Four?
A. Again, they can use the Three
Twenty-Four, but generally they don't.
Q. How about OIG?
A. Again, that would be principally a
criminal investigation.
Q. Got it. It's getting a little clearer
to me.
And you wouldn't know for the U.S.
Marshal, correct?
A. Correct.
Q. So after the form Three Twenty-Four is
created or filled out, let's say...
A. Um-hmm.

Page 100

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
Q. Is the requirement that it's provided
to a certain entity?
A. Yes.
Q. Which entity is it provided to?
A. It's provided to the Contract Technical
Representative.
Q. The contract -- sorry, go on.
A. I mean, it goes through their
hierarchy, and I believe it goes from the LCI to
the Nakamoto operations team, and from the
Nakamoto operations team it gets packaged and sent
to us, then to the Contract Technical Rep who
works for DSCU.
Q. When you say "their hierarchy," you
mean the inspecting entity's hierarchy?
A. Yeah, their operations.
Q. Are there any protocols with regards to
that?
A. What do you mean?
Q. What I'm trying to figure out is, is
there any paper trail that the government has
access to when it goes between the outsourced
entity?
MR. OSWALD: It's vague. You can

Page 101

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
answer it.
MR. ANDALMAN: Let me restate.
BY MR. ANDALMAN:
Q. Is there a paper trail that ICE has
access to when the form Three Twenty-Four goes
through the entity's hierarchy?
MR. OSWALD: Objection, vague. If you
want to answer...
THE WITNESS: I can only speculate.
BY MR. ANDALMAN:
Q. Okay.
MR. OSWALD: And the cause for
speculation is?
THE WITNESS: The cause for speculation
is, you know, it's a contract mechanism the
way we establish our contractor is basically
performance based, meaning that the
contractor has latitude to get to the final
result.
BY MR. ANDALMAN:
Q. Got it. So potentially a document
could be modified within the outsourced entity and
ICE would not have access to records of that?
A. Again, I'm speculating that

26 (Pages 98 to 101)
TSG Reporting - Worldwide

877-702-9580

 Page 102

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
potentially.
Q. And you mentioned an LCI? What is an
LCI?
A. That's a Lead Compliance Inspector.
Q. Okay.
A. That's why the likelihood of that
happening is not very likely, because, I mean
obviously it's the LCI whose signature is on that
final Three Twenty-Four.
Q. And is the LCI an ICE employee?
A. No, a Nakamoto employee.
Q. When is the first -A. I just want to say. I mean, this is
going back to 2007, correct? Right?
Q. Correct.
A. I mean, so, you know, it's not always
been Nakamoto.
Q. Fair enough.
A. So we all know that, right?
And at points in 2007, DRO was
conducting their own inspections simultaneously
along with Creative Corrections and MGT and these
types of groups.
Q. When DRO was doing these inspections,

Page 103
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
were they using the Three Twenty-Fours?
A. Yes. It would be the same -Q. Okay.
A. -- but the LCI, the reviewer in charge,
would be a DRO employee at the time. So you would
see a difference.
Q. Let's take the, I'll call them private
entity review inspections on the one hand.
A. Okay.
Q. And the government ones on another -the ERO or DRO ones -A. Right.
Q. That are done specifically in-house.
A. Okay.
Q. With regards to the private entity
reviews, when is the first instance when ICE
receives a form Three Twenty-Four?
A. There are time parameters that are set.
I mean, this is like in the weeds.
Q. I guess I'm not asking time,
necessarily the time.
A. So, basically -Q. I'm asking, where does the handoff
occur?

Page 104

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
A. There's time parameters that are set.
Q. Okay.
A. They have to have it to us sooner if
there's life-safety issues.
Q. Okay.
A. If there's no life-safety issues, they
have a little bit more leeway, so there is a time
requirement for them to get us the Three
Twenty-Four.
Q. Is that contractually based, the time
requirement?
A. I haven't seen the written contract,
but they do have time parameters.
Q. I guess what I'm asking is something
slightly different.
I'm asking, in the process -A. Um-hmm.
Q. It goes through the private entity's
hierarchy.
A. Um-hmm.
Q. There's a lead compliance officer that
signs off on it.
A. Um-hmm.
Q. Is it then delivered to ICE, or is

Page 105

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
there another step in between?
A. Yeah, that's what I'm saying. It
goes -- because they could be in, you know -because their subject matters experts, and
Nakamoto has their staff in different parts of the
country, and they have to Fed. Ex. obviously -Q. Okay.
A. So, if you are coming from Seattle, you
know, they have X amount of days.
Q. Okay. Got it. I get that. What I'm
trying to say is, is there another non-ICE hand
that touches -A. Yes, like I said, it goes to their
operational -- I believe it's -Q. Got it.
A. What's west of DC? Rockville. I
believe their operation center is in Rockville,
Maryland.
Q. And that's Nakamoto, still?
A. Yes.
Q. After it goes to the operation center,
does ICE get it next?
A. Yes.
Q. What format does ICE get it in at that

27 (Pages 102 to 105)
TSG Reporting - Worldwide

877-702-9580

 Page 106

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
point? Is it in a paper form or is it in an
electronic form?
A. You know, at some point we get both.
Q. So the electronic worksheet is
somehow -A. Yes, one might come a day before the
other, or vice versa.
Q. So Nakamoto is required to put it in
both electronic and paper formats?
A. We have a hard file.
Q. And an electronic file?
A. Yes, and at some point all hard files
will be transferred into an electronic file.
Q. During the time period of 2007 to the
present, at least for the time period there is a
paper file and an electronic file, that is of the
form Three Twenty-Four, that is delivered to ICE.
Is that correct?
A. That was the procedure, yes.
Q. When did that procedure end?
A. Well, I mean, going all the way back to
2007, like I said, we don't have a hard copy going
all the way back to 2007.
Q. Okay.

Page 107

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
A. We have media. We have an electronic
copy.
Q. Okay.
A. You know, I believe the requirement is
that we need to keep the hard copies for, you
know, however long it is, and then they're allowed
to be destroyed.
Q. I got it. I think we're kind of
confusing two different things.
A. Okay.
Q. Not currently what is in the
possession, custody and control of ICE.
When that delivery occurs, I think
you're saying that there is a hard copy and an
electronic copy that are provided to ICE.
Is that correct?
A. There's documents provided to ICE and
then ICE will create the hard copy.
Q. Create the hard copy -A. Create the file, the file.
Q. So I'm still a little bit confused and
I just want to be clear as to this.
A. Well, because -Q. Let's take your hypothetical of the one

Page 108

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
in Seattle, right?
THE WITNESS: I think I got to explain.
MR. OSWALD: Go ahead.
BY MR. ANDALMAN:
Q. Yes, go ahead and explain.
A. So I have last year's file for facility
X.
Q. Okay.
A. Now we're doing this year's. So the
Nakamoto paperwork for this inspection would go
into the file.
We're retaining the hard file for
whatever the time requirement is to maintain those
files.
Q. I think I'm asking a slightly different
question, and maybe I'm the one that has been
confused.
Let's use your hypothetical of Seattle,
of the facility in Seattle?
A. Was that my hypothetical?
Q. You said that there was a facility in
the west in Seattle. They have X number of days
to hand it off to Rockville?
A. Oh, that's right, Rockville.

Page 109

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
Q. Correct?
A. Yes.
Q. The Rockville facility is a Nakamoto
facility, correct?
A. Yes.
Q. After Nakamoto gets it, I think you
testified that it goes to ICE, the form Three
Twenty-Four.
Is that correct?
A. Yes.
Q. When that transfer occurs between
Rockville and ICE here in DC, I imagine, what
format or formats is the Three Twenty-Four
document in?
A. At some point we get the signed copy of
the Three Twenty-Four with the LCI.
Q. Okay.
A. At some point we get -- well, scratch
that. Scratch that.
We might create the electronic version.
Q. Okay, that's what I'm trying to get to.
A. Yes.
Q. So, it may come in paper form. It may
come in electronic form --

28 (Pages 106 to 109)
TSG Reporting - Worldwide

877-702-9580

 Page 110

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
A. We always get a paper form.
Q. You always get a paper form. It may or
may not come in electronic form, correct?
A. Correct.
Q. And if it doesn't come in electronic
form, it's the policy and procedure to make it
into -- make the paper copy into an electronic
form, correct?
A. Yes, based on the retention
requirement, the Federal Retention Requirements.
Q. Got you.
A. So, just to be specific, I mean, we
could get an electronic file in advance, like I
said if, for example, there's a life, health,
safety -Q. I got it.
A. And it will come through for immediate
action.
Q. And you might not get a paper file in
that -A. 'Till it catches up.
Q. That makes sense.
Let's take them one at a time. When
ICE gets Nakamoto's form Three Twenty-Four, in

Page 111

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
paper form -A. Yes.
Q. -- what does ICE do with it?
A. ICE will load it up into, now, today,
into SharePoint. We'll also turn it over to
Capgemini to put it into FPMS.
Q. What is FPMS?
A. Sorry, FMPS.
Q. What is that?
A. The Facility Management Program System.
Q. Is that a database?
A. No, it's not a database. It's just a
way that we can track, you know, Three
Twenty-Fours and deficiencies. Like I said, I'm
not a computer expert.
Q. Okay.
A. But it's more of a Three Twenty-Four
shell.
Well, I know that they had to go in and
basically, they just put the line items in. So
they could punch in numbers.
Q. I see.
A. It really doesn't have anything to do
with the actual inspection.

Page 112

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
Q. What is done with the paper document?
A. It goes into the file.
Q. And it's preserved, as you said, for
roughly six years?
A. No, I believe the whole preservation
requirement is six years.
Q. Okay.
A. So whatever the hard copy paper
document is required by the federal register to be
preserved, it is preserved.
Q. Where is that paper file physically
located?
A. ERO, PCN, the Potomac Center North, 500
12th Street.
Q. Do you know how it's organized?
A. I know where it is. I don't know how
it's specifically organized, whether it's
alphabetical or by year.
Q. And that's not information that you
looked at in preparation for this deposition?
A. No.
Q. Let's quickly talk about the electronic
ones, the electronic form of the Three Twenty-Four
form.

Page 113

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
A. Okay.
Q. When it's either created by ICE or
given to you by Nakamoto, is it in PDF format?
Is there a standard -A. No, I'm assuming it's PDF.
Q. Do you know if it's searchable?
A. Yes.
Q. When you get that format, other than
loading it into that -- I'll call it a computer
database -A. It's a shell.
Q. The shell, do you maintain the
document?
A. Yes. I believe it's 2007 to 2010 is on
our share drive. 2010 to present is on
SharePoint.
Q. What is SharePoint?
A. It's another new share drive type.
Q. Can the share drive be searched?
A. Yes.
Q. Can SharePoint be searched?
A. Yes.
MR. ANDALMAN: I think that's it for
now. I mean, I think we can call it a day at

29 (Pages 110 to 113)
TSG Reporting - Worldwide

877-702-9580

 Page 114

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

Page 115

SAKAMOTO
CERTIFICATE OF NOTARY PUBLIC
I, Kim M. Brantley, the officer before
whom the foregoing deposition was taken, do hereby
certify that the witness whose testimony appears
in the foregoing deposition was duly sworn by me;
that the testimony of said witness was taken by me
in stenotype and thereafter reduced to
computerized transcription under my direction;
that said deposition is a true record of the
testimony given by said witness; that I am neither
counsel for, related to, nor employed by any of
the parties to the action in which this deposition
was taken; and, further, that I am not a relative
or employee of any attorney or counsel employed by
the parties hereto, nor financially or otherwise
interested in the outcome of the action.
Date: 2/10/2014

1
SAKAMOTO
2
this point. I have a little bit tomorrow.
3
Probably like an hour and a half or so.
4
We'll do 9:30.
5
MR. OSWALD: 9:30 okay.
6
MR. ANDALMAN: I apologize. There's a
7
couple more things to get through.
8
(Whereupon at 5:59 p.m. the deposition
9
of Reginald Sakamoto adjourned until January 30,
10
2013, at 9:30 a.m.)

_______________________
Signature of Deponent

11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

____________________________
Notary Public in and for
The District of Columbia
My Commission Expires: October 14, 2014

Page 116

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
I N D E X
DEPOSITION OF REGINALD SAKAMOTO
EXAMINATION BY:
PAGE:
Mr. Andalman
5
INDEX OF DEPOSITION EXHIBITS:
SAKAMOTO EXHIBITS:
PAGE:
Exhibit 7. 2000 Detention Operations
Manual
89
Exhibit 8. 2008 Performance-Based
National Detention Standards
89
Exhibit 9. 2011 Detention Operations
Manual

Page 117
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23

SAKAMOTO
ERRATA SHEET FOR THE TRANSCRIPT OF:
Case Name: NATIONAL IMMIGRANT JUSTICE CENTER vs.
UNITED STATES DEPARTMENT OF HOMELAND SECURITY
Dep. Date: JANUARY 29, 2014
Deponent: REGINALD SAKAMOTO

Pg.
___
___
___
___
___
___
___
___
___

CORRECTIONS:
Ln. Now Reads Should Read Reason
___ ___________ _____________ ______________
___ ___________ _____________ ______________
___ ___________ _____________ ______________
___ ___________ _____________ ______________
___ ___________ _____________ ______________
___ ___________ _____________ ______________
___ ___________ _____________ ______________
___ ___________ _____________ ______________
___ ___________ _____________ ______________

_____________________
Signature of Deponent
SUBSCRIBED AND SWORN BEFORE ME
THIS____DAY OF_____________, 2014
_______________________
(Notary Public) MY COMMISSION EXPIRES:________

24
25

30 (Pages 114 to 117)
TSG Reporting - Worldwide

877-702-9580

 Page 1
A
ABA (3)
72:20 73:6,11
ability (2)
7:18 85:19
able (2)
67:24 86:13
absolutely (1)
87:10
ACA (2)
73:16,22
accept (1)
7:3
access (13)
84:18,23 85:6,19 86:2
86:10,20 87:16,22
90:22 100:23 101:6
101:24
Accreditation (1)
73:15
acquire (1)
31:24
acronym (1)
76:6
Act (3)
31:10,13 40:6
acting (1)
20:9
action (6)
30:25 31:4 63:22
110:19 115:13,17
actions (1)
23:5
actual (1)
111:25
ad (3)
40:25 51:2 72:7
additional (3)
91:2,4,6
address (20)
34:21 35:3,6,12,15,22
35:25 36:10,13,20
36:23 37:6,9,15,18
37:24 38:16 39:3,16
40:7
Adelphi (1)
15:12
adhered (1)
23:13
adhering (1)
24:3
adjourned (1)
114:9
ADP (6)
76:21,22 78:14 79:2
80:15,16

advance (1)
110:14
agency (4)
20:4 30:4 62:4 64:3
agree (1)
24:18
agreement (1)
62:21
ahead (5)
29:23 45:19 68:11
108:4,6
air (2)
17:18,20
akin (1)
61:15
Alberta (3)
13:21,22,22
alien (3)
20:3 54:13 56:12
aliens (1)
19:14
allegations (1)
99:3
allow (1)
64:17
allowed (1)
107:7
alpha (1)
62:11
alphabet (1)
70:16
alphabetical (1)
112:19
alright (5)
6:21 7:12,15 8:2
74:19
Alternatives (3)
18:20,25 30:8
American (5)
58:5,10 59:5 72:11
73:23
amount (2)
55:19 105:10
analysts (1)
28:2
Andalman (57)
3:6 5:9 8:24 9:6,11,14
9:17,18 12:3,10,12
22:20 32:19,22
33:13,18,20 39:11
45:24 46:4 47:3,10
47:23 48:2 49:7,8
53:2,6 55:2 57:21
60:16,18 63:2 69:15
76:10 80:6,8 86:7
87:13 88:20 89:5,18

90:12 93:9,14 95:16
97:9,12,19 101:3,4
101:11,21 108:5
113:24 114:6 116:5
and/or (2)
36:18 37:4
animal (1)
71:23
ankle (1)
30:10
annual (11)
43:4 50:22 67:3 74:23
77:15,25 78:2,13
79:12 98:14,22
annually (2)
50:25 74:16
answer (26)
6:15,18 7:3,18 22:17
25:4 33:8,25 39:9
44:2 45:20 46:5,15
47:7 53:3 60:15
74:14 86:4 87:7,19
93:9,10 95:14 97:15
101:2,9
answered (1)
93:7
answers (1)
33:9
AOR's (1)
41:17
apart (2)
44:4,10
apologies (1)
43:23
apologize (1)
114:6
appear (1)
74:10
APPEARANCES (1)
3:2
appears (1)
115:5
apply (2)
48:21 50:16
applying (1)
48:19
appropriate (1)
86:19
approval (1)
85:17
approving (1)
85:12
Approximately (2)
13:24 32:17
area (1)
15:7

TSG Reporting - Worldwide

Arizona (1)
19:16
Arlington (1)
5:13
armed (1)
15:17
army (5)
14:5,10,15,16 15:11
art (3)
55:17,22 57:3
asking (10)
47:12 54:24 61:8
75:10 76:16 103:21
103:24 104:15,17
108:16
aspects (3)
20:20 64:24 98:19
assessment (2)
51:11 90:6
assessments (2)
79:12,13
assigned (2)
42:13 61:2
assigning (1)
62:5
assist (3)
22:23,25 23:2
assistant (4)
3:16 28:19 85:23,24
assisted (1)
29:21
associated (4)
57:23 61:12 62:19,19
Association (4)
58:6,10 59:5 72:12
assume (3)
14:8 51:21 57:9
assuming (1)
113:6
ATD (4)
18:23,24 29:25 30:7
attend (4)
12:24 13:2,7,10
attention (1)
11:9
attorney (3)
3:16 33:14 115:15
audit (7)
40:20 43:15,17 54:22
56:8,14 73:21
audits (32)
28:23 34:25 35:20
36:8,19 37:5,14
38:15,17 39:15,17
40:3,8,15,18 43:6
54:8,9,11,17 55:25

877-702-9580

56:5,10 57:3 59:4
59:12,25 72:11
73:11,14 93:2 97:7
August (2)
66:20,23
authority (3)
62:4 85:13,16
authorized (1)
45:14
available (2)
74:8 92:11
avenues (1)
93:23
average (3)
75:23 76:23 77:17
award (2)
30:2,13
aware (6)
32:7,8 71:22 86:6,23
88:18
a.m (1)
114:10
B
B (1)
61:18
back (30)
8:22 15:2,5,5 18:3,22
22:21 25:25 26:7
30:17 33:18 43:22
46:16 49:22 50:4,12
51:12 64:4 65:7
69:24 72:23 73:23
75:8 76:3 82:13,22
84:22 102:15
106:22,24
background (1)
12:18
backgrounds (1)
12:19
bad (1)
66:14
Bar (4)
58:6,10 59:5 72:12
baseball (1)
5:22
based (14)
17:21 32:3 33:5 45:22
61:19 64:17 68:15
74:12 75:23 94:2,2
101:18 104:11
110:10
basically (6)
10:19 64:13,20
101:17 103:23
111:21

 Page 2
basis (3)
56:13 72:7 95:22
bat (1)
5:22
Bear (1)
58:24
began (1)
55:3
behalf (28)
3:5,14 29:12 35:4,7
35:13,16,23 36:2,11
36:14,21,24 37:7,10
37:16,19,25 38:18
38:20 39:18 40:9
45:15,16,23,25 46:5
59:18
believe (20)
10:4 12:8 32:25 34:7
76:21 77:21 79:15
81:6,10,24 82:19
83:5 92:12 94:15
100:10 105:15,18
107:5 112:6 113:15
Ben (1)
13:4
best (3)
48:18 71:25 94:19
better (1)
90:4
beyond (2)
39:7 52:24
biannual (8)
75:18,19 77:4,5 78:9
79:13 80:10,14
biannually (1)
77:22
Big (1)
13:4
billing (1)
56:25
bit (7)
6:11 17:23 65:7 98:4
104:8 107:22 114:2
block (1)
88:3
board (2)
21:24 64:16
bold (2)
59:9 73:17
borders (1)
19:13
bottom (1)
58:22
box (1)
68:21
bracelets (1)

30:10
brainstorming (1)
26:15
Brantley (3)
1:24 2:11 115:3
break (5)
7:24 32:20 33:13 80:5
80:6
Brief (4)
32:21 33:17 47:25
80:7
Briefly (2)
8:6 9:23
broad (1)
64:19
broke (1)
66:23
brushed (1)
88:14
budget (1)
65:25
bunch (1)
24:9
Burkes (1)
92:20
business (2)
35:2 36:9
C
C (2)
5:2 61:18
CAC (1)
73:23
call (5)
25:11 70:23 103:8
113:10,25
called (2)
5:4 92:22
Calls (1)
86:3
Canada (1)
13:22
candidly (1)
7:19
CAP (1)
19:25
capacity (1)
6:6
Capgemini (8)
49:20 50:12,14 53:10
53:19,22 54:4 111:7
care (1)
36:6
case (4)
1:6 5:18 93:4 117:3
catches (1)

110:22
catching (1)
17:6
caucus (1)
33:11
cause (2)
101:13,15
CCA (1)
64:22
CDF (1)
46:19
center (8)
1:7 4:5 31:2 92:20
105:18,22 112:14
117:3
central (2)
28:13 38:12
certain (10)
25:8 34:21 40:15 43:2
49:10 67:4,5 83:18
88:15 100:3
CERTIFICATE (1)
115:2
certify (1)
115:5
chain (1)
25:10
chairman (2)
30:3,13
change (2)
19:22 63:23
changes (2)
10:22 91:8
charge (2)
95:8 103:5
charged (1)
30:22
CHARLES (1)
4:11
chat (2)
47:22,23
check (1)
68:21
checklist (3)
91:14,16 98:21
Chicago (2)
3:9,19
chief (3)
4:8 20:9 27:6
circumstances (13)
34:24 35:19 36:5,17
37:3,13,21 38:5,12
39:12,25 97:3,21
CIS (4)
65:6,6,8,9
civil (11)

TSG Reporting - Worldwide

5:19,20 21:13,13,13
21:14 25:7,7 29:12
42:16,16
clarification (3)
11:21 23:22 38:21
clarified (1)
94:4
clarify (7)
8:13 27:22 29:3 47:9
56:9 62:13 76:12
class (1)
82:19
classified (9)
81:24 86:14,16,18,22
87:25 88:3,7,10
CLAUDIA (1)
4:4
clear (4)
26:25 64:2 99:9
107:23
clearance (1)
88:5
clearer (1)
99:18
clearly (1)
86:17
clerk (1)
14:20
college (2)
13:7,10
Colorado (1)
16:10
Columbia (2)
2:13 115:24
come (16)
9:15 21:10 24:14 26:2
31:14,15 61:14
77:14 78:17 94:23
106:7 109:24,25
110:4,6,18
comes (2)
20:21 60:6
coming (1)
105:9
Commission (5)
59:5 72:12 73:15
115:25 117:23
commissioned (1)
72:19
committee (2)
30:3,14
communication (1)
22:8
compartmentalized...
10:17 88:11
compartments (1)

877-702-9580

57:19
competitive (1)
13:18
complaint (1)
30:20
complete (2)
70:6 71:17
completed (1)
94:25
compliance (10)
23:8 24:6 28:4 41:8
41:15,16 94:24 95:6
102:5 104:22
complying (1)
23:24
components (1)
23:23
computer (2)
111:16 113:10
computerized (1)
115:9
concerned (1)
41:23
concerning (12)
34:24 35:19 36:5,17
37:3,13,21 38:6,12
39:13,25 97:3
concerns (2)
22:3,6
concur (1)
24:19
conduct (4)
42:3,4 43:12 47:13
conducting (3)
36:18 49:13 102:22
conducts (1)
44:19
confined (1)
99:5
confused (2)
107:22 108:18
confusing (2)
7:14 107:10
conjunction (2)
25:17 45:17
connection (3)
36:7 40:5 58:17
Connects (1)
53:12
consecutive (2)
77:22 80:13
consider (1)
69:8
containing (2)
61:22,25
content (2)

 Page 3
65:2 87:19
context (4)
45:15 55:13 59:13
60:23
continue (1)
88:21
continuing (1)
88:22
contract (25)
30:2 38:22 39:23 43:4
43:20 46:20 48:7
50:12,13 53:22
56:14,15,22 57:4,6
64:12,13 81:6,11
97:25 100:6,8,13
101:16 104:13
contracted (1)
81:7
contractor (2)
101:17,19
contractors (3)
49:12 64:18 98:14
contracts (11)
10:22 38:14 39:5,14
40:2 48:13 50:5
54:10 56:11 64:16
98:2
contractually (1)
104:11
control (2)
21:20 107:13
conversations (3)
26:13 27:2,4
cool (1)
13:19
copies (6)
71:2 72:4 82:11,12,15
107:6
copy (13)
34:8 71:14,15 82:10
106:23 107:3,15,16
107:19,20 109:16
110:8 112:9
correct (45)
6:8 7:4 20:14 22:24
25:13,16,19 28:7
33:6,23,24 34:4,18
34:21 38:9,10 44:16
49:14 54:6 57:2,5
59:20 61:23 63:5
74:5 77:18 79:18
86:8 88:15 91:10
95:24 96:12,15
99:21,22 102:15,16
106:19 107:17
109:2,5,10 110:4,5

110:9
corrections (9)
50:8 53:13,14 64:23
65:8 73:15 97:6
102:23 117:8
correctly (1)
26:19
cost (1)
76:25
counsel (8)
5:4,8 6:23,24 8:17
11:25 115:12,15
country (1)
105:7
couple (3)
12:17 73:4 114:7
course (4)
10:20,21 35:2 36:9
court (4)
1:2 2:12 6:19 7:11
cover (2)
68:24 99:6
covered (1)
97:10
covers (1)
97:2
Craig (2)
3:15 9:11
CRCL (16)
21:11,12 24:9 26:8
42:3 44:8 51:16
52:10 66:11 69:22
70:14,22,23 71:7,25
99:11
create (5)
96:14 107:19,20,21
109:21
created (5)
11:20 28:15 90:3
99:24 113:3
creation (2)
11:17,22
Creative (7)
50:8 53:12,13,14
64:23 65:8 102:23
criminal (6)
20:3 30:19 52:15 71:8
87:11 99:17
criminally (1)
30:22
criteria (4)
61:16,19 77:7,19
CSR (1)
1:24
current (1)
27:10

currently (3)
5:12 79:16 107:12
custody (13)
8:15 20:21 24:5,12,14
24:15 28:21 47:5
62:5 63:16 68:17
86:5 107:13
Customs (6)
1:12 4:9,12 35:16
41:24 43:16
C.D (1)
10:8
D
D (4)
5:2,3 61:18 116:2
daily (3)
75:23 76:23 77:17
database (3)
111:12,13 113:11
date (3)
51:14 115:18 117:5
dates (1)
72:23
day (5)
41:18,19 106:7
113:25 117:22
days (3)
32:5 105:10 108:23
day-to-day (4)
20:19 23:5,15 76:18
DC (4)
1:19 2:11 105:17
109:13
deal (6)
12:10 20:20,25 28:25
40:15 54:13
deals (1)
93:4
Dearborn (1)
3:18
DEBBIE (1)
4:7
decision (1)
93:24
decisions (1)
23:9
Defendants (2)
1:14 3:14
deficiencies (2)
63:18 111:15
DEFIG (2)
66:21,24
definition (2)
41:21,23
delivered (4)

TSG Reporting - Worldwide

25:23,23 104:25
106:18
delivery (1)
107:14
delve (1)
99:4
Dentons (2)
2:10 3:7
Dep (1)
117:5
department (19)
1:10 3:17 5:23 15:25
16:3 31:3 35:4,13
35:23 37:7,16,25
39:18 40:9 42:9,17
87:3 97:4 117:4
depending (2)
31:17 95:3
depends (3)
41:21 51:7 78:18
deployed (1)
27:22
deponent (5)
45:25 86:25 114:18
117:6,21
deportation (7)
16:7 18:9,13,15 19:19
19:20 28:3
deposed (4)
5:14,17 6:3,6
deposition (23)
1:18 2:9 6:10,12 8:5,7
9:20 32:24 33:23
34:18 58:17 76:9
89:3,16 90:10
112:21 114:8 115:4
115:6,10,13 116:3,7
Deputy (2)
10:25 28:19
designated (3)
34:21 38:23 39:7
designation (1)
52:25
designee (1)
38:24
destroyed (1)
107:8
detained (1)
16:24
detainee (1)
41:2
detainees (8)
46:21,24 47:5,15,16
47:17 48:4 76:13
detention (53)
10:24 18:9,21,25

877-702-9580

19:20 20:9,12,16,24
23:8 27:8,9,25 28:3
28:20 30:8 37:23
38:7,14 39:4 40:2
40:16 42:15 43:25
44:22 45:2 46:13,20
47:2 56:2 57:22
58:4 59:4,22,24
60:5 66:22,25 72:11
73:14 74:3 88:15,17
88:19 89:2,7,16,24
90:5,9 116:9,12,13
determination (1)
23:23
determine (4)
31:20 51:11 96:9,23
determined (5)
19:14 67:8 74:18
93:24 96:6
determines (1)
50:19
determining (1)
66:18
development (2)
26:16 81:8
deviate (1)
78:21
DHS (8)
36:11,21 37:7 38:9,18
43:24 44:2,4
differ (3)
56:16 90:2,17
difference (5)
26:4 54:22 55:11
60:19 103:7
differences (1)
40:23
different (21)
38:23 56:17 57:25
60:9,22 64:21,23
65:7 68:7 70:8
84:11,12 87:16 90:7
91:3 94:13,14
104:16 105:6
107:10 108:16
difficult (1)
84:25
Directing (1)
27:7
direction (3)
8:17 11:24 115:9
directive (4)
92:23 93:13,25 94:2
director (4)
10:25 28:20 71:11
85:24

 Page 4
disagree (1)
24:19
disagreements (1)
63:7
discharge (1)
14:8
discuss (1)
79:11
discussed (1)
54:16
discussing (1)
33:22
discussion (2)
62:25 66:7
disk (1)
10:8
disruptive (1)
65:21
distinctions (1)
40:19
District (4)
1:2,3 2:12 115:24
divided (3)
28:10,12,14
division (7)
1:4 4:8 14:4 20:22
28:15,20 81:9
divorce (2)
29:15,18
document (16)
34:17 59:13 63:18
74:9,14 86:25 94:25
97:13,15,20,24
101:22 109:15
112:2,10 113:14
documented (2)
63:7,10
documents (25)
8:19 9:22,24 10:2,9
10:14 12:14 32:14
60:22 61:22,24
67:25 81:13 82:17
84:15 86:14,17 87:9
88:2,4,7,10,11
96:15 107:18
DOD (3)
14:18 15:11 84:8
doing (11)
21:2 52:14 54:18
65:22 67:19,20 71:7
87:11 98:14 102:25
108:10
domain (2)
69:7 84:24
Don (1)
30:17

Dozoretz (4)
10:25 11:14,15,15
drafts (4)
94:18 95:10,18,18
drive (13)
3:8 8:12,13,14,20
84:12,16,19 87:23
88:3 113:16,19,20
driven (1)
85:2
drives (4)
86:11,15 87:16,17
DRO (4)
102:21,25 103:6,12
drugs (1)
7:21
DSCOs (6)
27:22,24 28:2,22 29:3
41:18
DSCU (8)
23:7,21,21 42:25
63:17 96:13,14
100:14
DSCU's (2)
24:3 43:12
DSMs (6)
27:21,22,24,25 29:6
41:18
dual (1)
30:4
due (1)
10:20
duly (2)
5:5 115:6
D.C (2)
15:8,10
E
E (5)
5:2,2,3 61:19 116:2
EAD (1)
85:21
earlier (5)
34:11 55:3 56:10
59:17 80:9
earliest (1)
88:17
eastern (2)
1:4 28:13
edits (1)
26:22
educational (1)
12:19
eighty (1)
68:20
either (3)

7:7 51:12 113:3
El (4)
16:9,22,25 18:15
electronic (27)
79:25 82:11,12,14,18
83:4,21,25 84:5
94:9,11 106:3,5,10
106:12,14,17 107:2
107:16 109:21,25
110:4,6,8,14 112:23
112:24
employed (2)
115:12,15
employee (5)
23:3 102:11,12 103:6
115:15
employees (3)
19:4 49:12 80:22
encryption (1)
81:18
ended (1)
15:11
enforce (1)
90:4
enforcement (11)
1:13 4:9,12 18:4 19:8
20:4 35:16 41:25
42:12,13 43:16
ensure (2)
23:22 96:11
enter (1)
13:14
entities (18)
24:16 36:18 37:4 41:9
48:23 49:16 50:16
54:3,6,16 58:5
65:14 67:14,17
70:18 71:3 98:7,9
entity (19)
30:6 31:16 33:4 34:4
50:20,21 53:7 56:17
56:20 66:18 68:15
96:11 97:22 100:3,5
100:24 101:23
103:9,16
entity's (3)
100:16 101:7 104:19
environmental (1)
68:22
Eric (2)
3:6 9:10
ERO (50)
18:5,7,17 19:8,17
31:19,19 42:9 43:3
44:4,10,15 45:4
50:22,24 51:5 60:6

TSG Reporting - Worldwide

62:5,8,16 63:16
67:5 68:7,12,18
69:4,17,20 70:3,22
70:22,23 71:2 72:4
74:4,7 79:24,25
80:22 81:8 84:7,11
84:18,21 85:19,23
87:9 93:22 103:12
112:14
ERO's (3)
43:4 63:4 88:2
ERO/Nakamoto (2)
66:19 67:3
ERRATA (1)
117:2
ESQUIRE (5)
3:6,15 4:4,7,11
essence (1)
29:7
establish (1)
101:17
evaluated (1)
92:16
evaluations (1)
93:2
Ex (1)
105:7
exactly (2)
66:16 80:17
EXAMINATION (2)
5:8 116:4
examined (1)
5:6
example (8)
21:20 24:8 41:3 56:8
65:6,11 66:11
110:15
Executive (1)
85:23
exercised (1)
36:6
exhibit (19)
34:7,17 58:11,12,20
59:14 72:10 88:20
89:3,7,14,17,20
90:10,14,24 116:9
116:11,13
exhibits (4)
88:23 90:25 116:7,8
exist (2)
70:17 79:16
exists (5)
70:15 79:10 97:13,15
97:20
expand (1)
90:4

877-702-9580

expanded (1)
90:21
experience (2)
32:3 33:9
experiences (1)
34:2
expert (1)
111:16
experts (4)
50:11 53:18 66:3
105:5
Expires (2)
115:25 117:23
explain (2)
108:3,6
extent (13)
8:24 38:17 39:4,17
40:8 45:19,24 46:11
47:18 52:18 57:4
70:15,17
external (2)
42:7,10
eyes (1)
60:19
E-mail (5)
10:23,24 11:12,16,24
F
facilitate (1)
22:7
facilities (46)
11:4,5,10,11 21:4
24:2 27:13,16,18
28:6,8 40:16 41:17
43:25 45:12 46:3,9
46:13 47:5,14 48:3
48:4,14 49:4,10,17
56:2 57:22 67:4,5,5
67:6 74:23 75:2,6,7
75:22 77:6,20,25
78:3,6,13 79:21
92:16 96:19
facility (24)
16:8,15,17 46:21 48:9
51:13,14 55:15 59:4
59:24 65:15 67:22
67:23 72:11 73:14
74:15 96:9 97:22
108:7,20,22 109:4,5
111:11
facility's (1)
78:25
facts (12)
34:23 35:18 36:4,16
37:2,12,21 38:5,11
39:12,24 97:2

 Page 5
fail (1)
61:17
fails (1)
80:13
fair (15)
6:5 9:6 12:10,13,16
27:3 48:10 53:2
54:15 57:9 71:24
76:19 87:14 95:9
102:19
fall (2)
53:21 75:9
familiar (8)
30:25 31:6,8,9 58:4
59:11 73:10,20
family (7)
18:21 19:3 30:17 92:5
92:14,17,20
far (2)
39:23 82:8
Fed (1)
105:7
federal (11)
14:17 15:17 17:9,18
17:20 83:10,11,15
83:16 110:11
112:10
feel (5)
5:25 24:11 60:24
70:16 95:14
field (11)
16:15,20,21 21:25
22:3,7 23:19 28:11
41:16 63:20 75:7
fifteen (3)
39:22 40:13 73:18
fifty (6)
27:12 77:8,9,17 78:14
79:2
fifty-five (1)
74:22
fifty-four (4)
21:4 27:13,16 28:6
figure (4)
41:12 54:20 60:8
100:21
file (19)
31:16 70:10,11,12
71:14 106:11,12,14
106:17,17 107:21
107:21 108:7,12,13
110:14,20 112:3,12
filed (1)
31:18
files (6)
82:20 87:18,19,23

106:13 108:15
fill (1)
79:21
filled (4)
91:2,5 94:6 99:24
final (11)
24:3 26:2,5,6,12,17
63:4 80:21 94:17
101:19 102:10
financially (1)
115:16
find (1)
7:14
fine (3)
29:16 73:7 76:11
finish (1)
82:23
first (8)
5:5 16:17 58:13 79:9
93:3,6 102:13
103:17
Five (3)
32:5 34:20 35:18
flight (1)
78:21
Floor (1)
2:11
fluctuate (1)
52:6
fluctuating (1)
77:11
FMPS (1)
111:9
FOIA (17)
8:25 31:17,17,19,19
31:20,21 32:11,15
32:15 69:11,12
71:15,17,21 86:8,10
folks (1)
17:6
follows (1)
5:7
follow-up (1)
93:18
Force (2)
17:2,4
foregoing (2)
115:4,6
forget (1)
76:6
forgot (1)
92:5
form (32)
10:5 24:23,25 64:22
64:23,24 94:5,20,21
94:22 95:19,22 98:5

98:6 99:23 101:6
103:18 106:2,3,18
109:8,24,25 110:2,3
110:4,7,9,25 111:2
112:24,25
formal (2)
72:3,4
format (22)
6:15 62:16 64:8,8
79:25 80:2 82:18
83:4,21,25 84:2,5
94:6,10,11,17 95:10
95:20 105:25
109:14 113:4,9
formats (2)
106:10 109:14
forms (1)
64:20
formulate (3)
24:16,22 25:15
formulated (1)
25:22
forth (1)
25:13
fortune (1)
77:2
forward (4)
57:14 72:25 73:3
93:20
foundation (1)
12:20
founding (1)
19:4
four (2)
32:18 34:23
fourteen (1)
6:9
FPMS (2)
111:7,8
framework (1)
70:7
free (1)
95:14
Freedom (3)
31:9,12 40:5
fugitive (4)
16:25 17:4 19:24 20:3
fugitives (1)
17:8
full (1)
70:5
function (1)
43:17
functions (1)
56:21
further (3)

TSG Reporting - Worldwide

97:12 99:4 115:14
future (1)
51:14
G
G (2)
5:2,3
gambit (2)
22:9 75:25
gathering (1)
32:14
General (1)
44:11
generally (10)
55:23,24 64:15,15
68:3,23 73:10 89:25
98:18 99:14
generated (1)
95:2
Germany (1)
14:17
getting (4)
65:25 66:2,2 99:18
gist (1)
76:8
give (4)
6:8,10 64:2 70:7
given (8)
34:16 67:8 70:3 83:9
88:7 97:21 113:4
115:11
glad (2)
92:4 94:4
glanced (2)
10:3,9
go (54)
12:17 15:21 20:8
23:21 24:10 29:16
29:23 30:5 41:16
43:22 45:7,19 46:16
47:24 49:22 50:12
51:12,13,15 55:14
55:15 61:9 62:23
63:17,25 64:4 65:23
66:10,12 68:11 69:2
69:24 72:23,25 73:3
77:2,15 78:18 79:2
79:4 82:19 84:22
85:11,23 87:9 94:20
94:22 96:7 97:12
100:8 108:4,6,11
111:20
goes (16)
26:21 39:6 64:13
71:15 75:8 82:3
100:9,10,23 101:6

877-702-9580

104:19 105:4,14,22
109:8 112:3
going (29)
8:22 10:16 12:3,17,21
30:6 34:6,14 45:21
46:2 50:4,20 51:12
58:11,13 67:9 69:2
78:21 79:2,11,13
89:13 90:21 93:19
98:20 99:2 102:15
106:22,23
governing (1)
83:15
government (10)
4:8 14:18 38:14 39:4
39:14 40:2 50:21
83:16 100:22
103:11
governmental (1)
65:14
grade (1)
61:18
graduate (4)
12:22,25 13:3,11
graduating (3)
13:7,13,17
grant (1)
87:2
granted (1)
86:12
greater (1)
78:14
grievances (2)
41:2 99:2
ground (2)
6:11 23:4
grounds (2)
45:13 93:4
group (7)
29:4 48:25 49:3,9,13
77:4,5
groups (3)
49:19 77:5 102:24
guard (1)
15:16
guess (6)
41:22 54:20 60:23
75:9 103:21 104:15
guessing (1)
74:25
guidelines (2)
80:3 83:10
H
half (5)
29:3,6 67:22,23 114:3

 Page 6
hand (7)
60:21,21 68:14 89:13
103:9 105:12
108:24
handed (3)
89:6,19 90:13
handle (3)
66:6 67:2,15
handled (3)
31:12 51:4,5
handles (4)
43:4 50:22 67:3 81:9
handoff (1)
103:24
happen (1)
44:21
happened (4)
15:20 16:19 66:23
93:5
happening (1)
102:8
happens (2)
43:18 72:7
hard (10)
82:10 106:11,13,23
107:6,15,19,20
108:13 112:9
head (4)
6:19,20 44:14,22
Headquarters (1)
18:18
health (5)
68:23 90:4,22 98:24
110:15
hear (2)
5:24 7:10
held (1)
2:10
help (1)
56:9
helps (1)
70:25
hereto (1)
115:16
Hey (3)
55:14 61:8 67:14
hierarchy (5)
100:10,15,16 101:7
104:20
high (9)
12:22,24,25 13:2,8,13
13:17 85:18,22
history (1)
11:19
hoc (3)
40:25 51:2 72:7

hold (3)
16:5 33:11 75:22
Homeland (17)
1:11 3:17 15:25 16:3
31:3 35:4,13,23
37:7,16,25 39:19
40:10 42:17 85:21
97:5 117:4
honestly (2)
9:7 34:11
honorable (1)
14:8
hopefully (1)
9:11
hour (1)
114:3
hours (5)
57:2 75:21,23 76:14
76:21
house (1)
48:4
hundred (5)
11:5 74:22,25 78:2,12
Hutto (2)
30:16,17
hypothetical (7)
25:6 46:19 52:21 71:7
107:25 108:19,21
hypothetically (1)
88:2
I
ICE (72)
4:9,12 16:2,4 18:3
19:10 35:8,10 36:2
36:14,24 37:10,19
38:8,20 39:21 40:12
40:21 42:16 44:15
44:18 45:12,15,25
46:2,9,25 47:5,16
47:17 48:4,20 49:10
49:17 50:17 52:8,10
52:16 55:9,22,25
57:4 59:19 60:6,20
66:21 72:19 81:7
86:8,25 87:3,3
91:24 92:11 101:5
101:24 102:11
103:17 104:25
105:23,25 106:18
107:13,16,18,19
109:8,13 110:25
111:4,5 113:3
ICE's (1)
54:21
idea (4)

9:3,4 53:5 78:15
identification (3)
89:4,17 90:11
Illinois (3)
1:3 3:9,19
imagine (4)
13:5 31:18 56:22
109:13
immediate (1)
110:18
immediately (2)
13:14,16
Immigrant (4)
1:6 4:5 31:2 117:3
Immigration (8)
1:12 4:9,12 35:16
41:24 43:16 59:6
72:12
implementation (1)
24:4
implemented (3)
22:15,19 25:9
impossible (1)
85:8
include (3)
19:24 82:14 83:17
including (2)
36:6 40:4
incorporate (2)
33:8 34:2
incorporated (3)
61:22 92:25 93:19
increased (1)
90:22
increases (1)
90:19
INDEX (1)
116:7
individual (4)
31:16 37:22 38:7 54:5
information (7)
4:8 10:3 31:10,12,25
40:6 112:20
inquiry (1)
25:11
INS (2)
15:22 16:6
inspect (1)
46:25
inspected (1)
74:13
inspecting (4)
10:20 68:12,18
100:16
inspection (16)
21:6 40:20 54:19

TSG Reporting - Worldwide

55:10,12 61:2,12,14
65:23 74:16 82:17
83:19 84:17 96:3
108:11 111:25
inspections (49)
28:23 29:8 34:25
35:21 36:9,19 37:5
37:14 38:15,18
39:15,18 40:3,9,15
40:19 43:5,5 47:13
49:4 50:6 55:21,23
56:3,16 57:10 58:2
60:9,12,20 61:23
64:5 67:3 68:2
69:22 71:18,21
72:17,21 73:11
80:24 82:5 83:3
86:21 95:23 97:7
102:22,25 103:9
Inspector (4)
44:11 95:6,8 102:5
instance (6)
26:8 62:11,18 87:25
91:7 103:17
instances (1)
67:16
instant (1)
31:3
instruction (1)
7:3
instructs (1)
7:2
intended (1)
97:7
interaction (1)
22:6
interchangeably (1)
57:13
interested (1)
115:17
interfering (1)
7:17
internal (1)
8:12
Internet (2)
8:10,11
intimately (1)
31:8
investigation (2)
87:12 99:17
investigative (1)
85:15
Investigator (1)
94:24
involved (13)
20:24,25 21:8,11

877-702-9580

29:12,13,19,24,25
31:21 32:10,13 66:7
in-house (1)
103:14
issue (2)
25:8,10
issues (9)
21:7,15 24:6 57:5,6
90:4 98:25 104:5,7
item (2)
80:19 96:25
items (4)
90:7 91:7 98:19
111:21
J
James (1)
5:11
January (6)
1:20 2:5 17:25 18:2
114:9 117:5
JCNS (1)
68:25
job (4)
1:25 12:19 16:24 29:7
John (1)
66:22
June (2)
20:7,8
junior (1)
13:23
juniors (1)
13:21
Justice (4)
1:6 4:5 31:2 117:3
Juvenile (2)
18:21 19:3
K
K (2)
2:10 5:3
keep (1)
107:6
keeping (1)
10:17
keeps (3)
70:22,22,23
key (2)
21:20 81:25
keys (1)
81:18
Kim (3)
1:24 2:11 115:3
kind (3)
21:23 30:18 107:9
know (95)

 Page 7
7:11,25 8:21 9:5,9
9:24 10:12 12:5,6
21:2,18,21,25 22:7
23:14,15 24:18 25:4
33:22 39:10,22,23
41:20 45:6 46:2,11
46:18,25 47:18
48:19 51:7,16,19
52:20 53:4 54:13
60:25 63:21 64:11
64:11,19 68:19,21
68:22,24 69:3,6,10
71:4,6,19 73:4,7,9,9
74:13 75:13 76:17
81:23,25 83:13 84:9
84:14 85:11,12,16
85:22 86:17,18
88:12,13 90:19,22
94:13,21 96:8 98:19
98:20 99:2,5,20
101:16 102:17,20
105:4,10 106:4
107:5,7 111:14,20
112:16,17,17 113:7
knowing (2)
87:18 96:2
knowledge (12)
23:6 33:3,6,22 34:3
45:22 48:18 71:25
73:2 79:17 86:24
94:19
known (2)
66:21 88:17
L
L (1)
5:3
labeled (1)
34:17
Labs (1)
15:12
language (1)
57:15
Las (1)
17:22
latitude (1)
101:19
Law (2)
4:8 20:4
lawsuit (3)
5:19,21 29:12
lawsuits (1)
6:2
lay (1)
12:20
LCI (10)

94:24 95:2,5 100:10
102:3,4,9,11 103:5
109:17
lead (4)
94:24 95:6 102:5
104:22
learn (1)
81:12
leave (1)
33:16
leaving (2)
14:14,16
leeway (2)
64:17 104:8
left (1)
33:21
legal (1)
90:23
length (1)
81:21
letter (2)
10:5 62:18
let's (24)
16:17 21:22 22:4 24:9
25:6,11 32:19 33:13
43:22 47:23 49:22
51:15 65:17 69:24
76:3 78:19 80:6
98:4 99:24 103:8
107:25 108:19
110:24 112:23
level (3)
36:5 85:12,23
levels (2)
85:17 86:19
Liberties (4)
21:13,14 25:8 42:16
life (1)
110:15
life-safety (2)
104:5,7
likelihood (1)
102:7
limitation (2)
36:6 40:5
limited (1)
87:16
line (1)
111:21
link (1)
84:24
list (4)
11:4,4 78:17,18
listen (1)
69:14
listing (2)

71:17,17
litigation (6)
10:10 29:14,19 30:2
30:15 32:11
little (9)
6:8,11 17:23 65:7
98:4 99:18 104:8
107:22 114:2
live (1)
5:12
LLP (1)
2:10
Ln (1)
117:9
load (1)
111:5
loading (1)
113:10
located (3)
16:21 28:8 112:13
location (5)
35:20 69:5,9,17 70:12
locations (1)
70:19
lock (3)
21:20 81:18,25
locked (1)
66:4
long (13)
14:6,21 15:18 16:14
17:10,24 18:11 20:5
32:3 82:3,5 85:10
107:7
longest (2)
32:6,8
look (11)
8:19 11:10 31:20,24
58:9 64:23 65:6,7,8
67:14 69:3
looked (8)
8:21 10:14,15,19,23
12:14 58:18 112:21
looking (4)
68:16 74:13 93:22
98:18
loop (1)
78:21
losing (1)
30:6
lot (2)
65:24 99:4
lower (2)
64:3 85:25
M
M (4)

TSG Reporting - Worldwide

1:24 2:11 5:3 115:3
mail (1)
14:20
maintain (4)
11:22 82:4 108:14
113:13
maintained (3)
37:23 38:7 82:6
maintaining (1)
83:10
maintains (2)
69:19 83:16
man (1)
57:2
manage (1)
27:16
managed (1)
45:12
management (16)
8:15 18:22 19:3 20:22
24:5,12,15,15 28:2
28:20,21 62:5 63:16
68:17 86:6 111:11
managers (2)
20:17 27:25
manages (2)
43:3 46:9
Manual (5)
89:2,8 90:9 116:10,14
Mark (1)
88:20
marked (10)
21:23 34:7 58:12 89:3
89:7,13,16,19 90:10
90:13
married (1)
14:16
marshal (5)
17:20 46:21 48:4,20
99:21
Marshals (14)
17:18 45:8,11,17 46:8
46:12,23 47:4,13
48:8,16 52:22 70:17
70:20
Marshal's (2)
48:6,13
Maryland (2)
15:12 105:19
material (1)
81:24
matrix (2)
52:6 68:15
matter (2)
42:5 66:3
matters (1)

877-702-9580

105:5
mean (85)
9:3,7,11 12:5 19:23
21:16 22:9,19 24:18
25:4 26:12 28:15
29:24,25,25 30:16
31:5 35:10 41:11,14
41:15,20 42:8,10
46:18 48:7 49:22
50:3 51:8 54:5,14
55:13,15,18 56:13
56:25 57:19 60:23
60:24 61:8,10 63:14
65:19,24,25 66:8
67:21 69:8,11 70:5
71:6 72:16,22 73:6
73:8 74:12 76:25
81:18,19 82:10 83:8
83:13,15 85:2,5,21
85:22 87:8 91:4,8
92:8 94:7,13 96:9
98:13 100:9,16,20
102:8,14,17 103:20
106:22 110:13
113:25
meaning (2)
55:9 101:18
meanings (1)
55:5
means (3)
41:13 69:6 80:18
measures (2)
36:7 88:8
mechanism (1)
101:16
media (3)
39:13 82:20 107:2
medical (1)
90:20
medication (1)
7:21
mediums (1)
94:14
meet (3)
9:19 80:13,18
meets (2)
77:22 80:19
memorialization (1)
63:4
memorialize (1)
27:4
memorialized (3)
62:3 92:7,9
memorializes (2)
62:17 67:25
mental (1)

 Page 8
90:22
mentioned (4)
29:11 33:25 80:9
102:3
MGT (1)
102:23
middle (1)
59:3
military (3)
13:12,14 14:3
minus (1)
12:14
minutes (1)
32:5
mischaracterizes (3)
60:14 87:6 95:13
missing (1)
58:21
misunderstood (1)
27:15
mixed (1)
53:25
modified (2)
28:17 101:23
monitoring (7)
20:10,12 27:7,8,9
41:8,19
monster (1)
74:19
months (1)
93:17
Morton (1)
66:22
move (1)
25:10
moved (1)
38:2
MTG (4)
50:10 53:16,24 65:11
multiple (2)
25:17 27:18
N
N (3)
5:2,3 116:2
Nakamoto (33)
43:4,9 48:25 49:3,9
49:13 50:22 51:4,8
53:7 62:3,7,15 63:3
63:15 64:2,24 65:9
65:22 66:13 78:19
98:11 100:11,12
102:12,18 105:6,20
106:9 108:11 109:4
109:7 113:4
Nakamoto's (1)

110:25
name (5)
5:10 8:14 11:13 50:15
117:3
named (1)
30:19
nation (1)
28:9
national (11)
1:6 4:5 19:13 31:2
47:2 88:19 89:15,23
90:5 116:12 117:3
nationally (1)
27:22
nature (3)
5:20 41:10,12
necessarily (4)
26:9,16 71:9 103:22
need (10)
7:24 29:16 51:19
77:11 78:18 82:3,5
88:8 95:11 107:6
needed (1)
91:2
need-to-know (2)
85:3 86:19
neither (1)
115:11
Neveleff (1)
34:8
never (2)
55:18 77:24
new (1)
113:19
news (1)
9:4
Nina (2)
10:25 11:12
Nine (1)
37:2
nods (1)
6:20
non (1)
16:24
non-detained (1)
19:23
non-ICE (1)
105:12
North (1)
112:14
NORTHERN (1)
1:3
Notary (5)
2:12 5:6 115:2,23
117:23
Notice (1)

34:18
number (18)
34:23 35:18 36:4,16
37:2,12 38:11 39:12
39:24 43:21 52:6,7
58:12 60:2 62:19
77:11 96:25 108:23
numbers (4)
54:14 56:12 76:17
111:22
numeric (1)
62:11
NW (1)
2:10
N/As (1)
68:21
O
O (3)
5:2,3,3
object (3)
39:6 45:13 93:3
objection (15)
6:25 22:16 46:14 47:6
49:6 52:24 54:23
60:13 86:4 87:5
88:22 93:6 95:12
96:24 101:8
objects (1)
6:23
obviously (7)
9:2 12:4 30:5 65:24
96:8 102:9 105:7
occur (1)
103:25
occurs (2)
107:14 109:12
October (1)
115:25
ODO (36)
10:23 11:12,18,19,22
42:3,18 44:10 51:25
52:4,5,8 65:23
66:20,23 67:6,24
68:6,14,22 69:4,16
69:19,23 70:15,22
70:22 71:15,23 84:9
84:10 85:15 98:16
98:17,24 99:7
ODO's (3)
70:12 84:18 85:6
ODPP (4)
44:23 52:18 70:16,23
ODR (1)
87:10
office (19)

TSG Reporting - Worldwide

10:23 16:16,20,21
19:9 22:2,3,7 23:19
42:15,21 44:11,22
45:2 63:20 66:24
75:7 86:8,10
officer (11)
16:7 18:9,10,13,15,20
19:19,21 56:23
104:22 115:3
officers (2)
28:3,4
offices (2)
28:11 41:16
official (4)
6:6 26:6 41:5 62:6
offline (1)
12:11
oh (9)
10:7 15:8 19:2 30:9
58:23 59:10 60:3
72:16 108:25
OIG (7)
44:10 52:12,14,14
70:15 71:8 99:15
okay (73)
6:12,13 7:5,8,9 9:14
11:2,6,8 14:25
23:11 27:15,20
29:10,16 30:12 35:9
44:7 45:5 47:20
48:10,12 50:4,7,9
51:22 55:7 58:21
59:2,10 61:3,7
64:25 65:3 66:6
67:12,17 69:24
74:20 75:3,5 76:3,4
76:24 77:23 80:4
81:15 82:2 83:12
84:13 85:14 93:15
94:12 97:9 101:12
102:6 103:4,10,15
104:3,6 105:8,11
106:25 107:4,11
108:9 109:18,22
111:17 112:8 113:2
114:5
older (1)
96:20
OLEAN (1)
4:11
once (4)
23:23 31:19,23 77:6
ones (18)
23:9 28:22 44:9 51:24
53:7,8 70:21 74:11
78:9 79:11,12 84:7

877-702-9580

84:8 92:13 96:23
103:11,12 112:24
ongoing (1)
93:21
onsite (2)
21:3 94:13
onward (1)
83:20
operated (1)
45:12
operates (1)
46:9
operation (2)
105:18,22
operational (1)
105:15
operationally (1)
78:20
operations (17)
18:4 19:8,24 20:4
42:13,14 74:4 89:2
89:7,10 90:9 94:3
100:11,12,17 116:9
116:13
opinion (2)
23:20 24:3
opinions (7)
22:11,14 23:15,17
33:3,10 34:3
OPR (4)
42:16,20,21 85:15
orally (1)
25:23
order (2)
41:3 97:2
ordinary (2)
35:2 36:9
organization (1)
45:23
Organizational (1)
76:7
organized (2)
112:16,18
original (3)
46:17 75:8,10
ORSA (9)
75:4,16 76:2,5,12
78:6 79:4,19,20
Oswald (37)
3:15 9:3,9,13,15,19
22:16 38:23 39:6
45:13 46:14 47:6
49:6 52:24 53:3
54:23 57:17,20
60:13 62:23 69:13
76:9 80:5 86:3 87:5

 Page 9
88:24 93:3,10 95:12
96:24 97:10,14
100:25 101:8,13
108:4 114:5
outcome (1)
115:17
outcomes (1)
90:20
outlined (1)
63:19
Outlining (1)
11:19
outside (2)
56:18 77:14
outsourced (3)
49:5 100:23 101:23
Overall (1)
80:20
overlap (2)
66:9 67:11
overseas (1)
14:17
oversee (1)
27:12
oversight (5)
10:24 42:15 66:25
68:14 96:10
owned (1)
48:14
P
P (1)
5:2
package (1)
70:6
packaged (1)
100:12
page (9)
34:20 58:19 59:3,8
73:3,13,25 116:4,8
pages (1)
68:20
paper (17)
79:25 94:6,17 100:22
101:5 106:2,10,17
109:24 110:2,3,8,20
111:2 112:2,9,12
paperwork (3)
91:2,4 108:11
parameter (1)
77:15
parameters (9)
74:12 80:15,16 83:6,7
86:16 103:19 104:2
104:14
paraphrase (1)

47:8
part (8)
25:19 26:20 40:14
42:9,15 71:14 76:16
81:12
particular (4)
24:2 28:10 87:23 96:3
parties (4)
25:18 66:7 115:13,16
parts (1)
105:6
party (1)
29:14
Paso (4)
16:9,22,25 18:15
pass (2)
61:17 79:4
passed (3)
77:7,19,21
pay (1)
11:9
PCN (1)
112:14
PDF (2)
113:4,6
pending (2)
8:2 21:7
people (3)
66:2 79:20 88:4
perform (19)
28:23 43:24 45:9,11
46:8,12 47:4 48:14
48:23 49:4,10,17
50:24 52:4,12,19
56:20 67:9 72:18
performance (7)
43:18,19 54:9 56:11
56:15 64:17 101:18
performance-based...
89:15,23 97:6 116:11
performed (5)
23:16,18 50:20 54:16
58:5
performing (2)
65:15 96:11
performs (3)
42:25 66:18,19
period (9)
10:20 50:25 65:18,19
72:2 83:20 95:3
106:15,16
peripherally (1)
30:16
Periphery (1)
30:16
permanent (2)

20:10 27:6
permissions (5)
84:23,25 85:10 86:12
87:2
permit (1)
87:9
personal (2)
33:5 45:22
personally (1)
22:14
personnel (5)
21:3 27:13,17,17 28:5
persons (2)
36:18 37:4
perspective (2)
43:15 54:21
pertain (1)
71:5
pertains (1)
71:4
pertinent (1)
31:25
Pg (1)
117:9
Phoenix (1)
19:16
phon (1)
69:2
physical (1)
32:14
physically (3)
15:15 49:3 112:12
pick (1)
96:2
picked (1)
8:23
place (2)
69:23 88:9
Plaintiff (4)
1:8 3:5 5:4,8
Planning (2)
44:23 45:3
play (1)
13:24
played (4)
13:18,21,21,22
playing (1)
60:24
please (8)
5:10 6:24 7:3,7,10,15
7:25 38:4
plus (1)
12:14
point (8)
74:24 93:20 106:2,4
106:13 109:16,19

TSG Reporting - Worldwide

114:2
points (1)
102:21
policies (1)
64:7
policy (12)
44:23 45:3 64:12
66:17 71:20 72:3
79:10 82:21,24
83:16 96:22 110:7
population (3)
75:24 76:23 77:17
portion (3)
75:16,17,18
position (13)
14:10,19,21 15:18
16:5,14 17:24 18:7
18:11 19:19 20:5
27:6,10
possession (1)
107:13
possible (4)
44:20,24 65:10,13
potential (4)
23:6 52:15 63:22 66:9
potentially (12)
23:19 44:20 50:3 51:2
51:4,13 67:17 79:3
79:4 88:9 101:22
102:2
Potomac (1)
112:14
practice (1)
27:4
practices (2)
8:10 61:9
predecessor (2)
15:23 16:4
preliminary (1)
26:21
preoccupancy (4)
51:3,9,10 55:16
preparation (4)
9:20 37:14 58:8
112:21
prepare (2)
8:4,7
prepared (21)
35:3,6,12,15,22,25
36:10,13,20,23 37:6
37:9,15,18,24 38:16
39:3,16 40:7 59:18
60:4
prepares (1)
67:25
preparing (1)

877-702-9580

37:4
present (7)
4:2 12:8 20:11 58:11
64:3 106:16 113:16
presented (1)
64:9
preservation (1)
112:6
preserved (3)
112:4,11,11
pretty (2)
11:3 13:19
prevent (1)
87:15
previous (1)
8:21
previously (7)
10:10 34:7 51:13
53:18 58:12 66:21
77:21
pre-planning (1)
65:25
primarily (1)
98:24
primary (2)
18:14 19:12
principally (1)
99:16
print (1)
73:17
priority (1)
93:21
private (11)
48:23 49:16,19 50:16
50:20 53:7 65:14
70:18 103:8,16
104:19
probably (3)
75:9 85:16 114:3
problem (3)
10:18 12:11 75:14
problematic (1)
67:11
procedure (5)
66:17 96:22 106:20
106:21 110:7
procedures (1)
64:7
process (4)
32:4 63:12,14 104:17
produced (5)
8:25 9:12,13 10:10
40:4
product (1)
26:17
production (3)

 Page 10
9:2 12:4 32:14
Professional (1)
42:21
program (11)
19:10 20:3 28:2 31:24
32:2 44:15,18 76:2
85:2 87:3 111:11
programs (3)
31:21,22,23
prohibitive (1)
87:2
promulgate (1)
96:14
promulgation (1)
80:23
protective (1)
97:2
protocol (3)
82:16 95:10,17
protocols (2)
79:20 100:18
provide (6)
22:10 63:15 68:5
87:15,22 94:25
provided (11)
10:4 25:7 71:2 72:4
85:9 90:21 100:2,5
100:6 107:16,18
provider (6)
21:25 22:5 23:17
63:19 66:5 67:15
provides (2)
62:15 81:2
public (6)
2:12 5:6 69:7 115:2
115:23 117:23
publically (2)
92:10,11
publicly (1)
74:8
punch (1)
111:22
purposes (1)
57:8
pursuant (1)
82:8
put (11)
25:19 42:8 43:7 83:4
83:20,25 84:4 88:9
106:9 111:7,21
putting (1)
71:20
p.m (2)
2:6 114:8
Q

question (42)
6:15 7:4,6,10,14 8:2
21:21,22 22:13,17
24:21 25:5 34:14
35:11 38:20,25 39:9
39:21 40:12 45:20
46:6,7,15 47:7,19
58:13 60:17 66:15
66:16 69:14,14
74:14 79:6 80:12
87:20 88:13 93:8,18
97:14,16,18 108:17
questions (10)
6:14,18,24 7:18 12:18
12:21 21:17 22:23
75:9,10
quick (2)
32:19 79:6
quickly (4)
47:22,24 51:15
112:23
quote (1)
76:8
R
R (2)
5:2,3
random (1)
8:22
ranked (1)
85:18
rankings (1)
59:12
rated (1)
61:16
rating (16)
60:7 61:2,5,11,13,13
62:3,4,6,7,16 63:24
64:2,3 80:21,21
ratings (17)
37:23 38:7 57:22 58:5
59:23 60:5,10,12,21
61:21,25 62:2 68:4
68:5 72:17 80:24
84:17
read (3)
74:11 82:24 117:9
Reads (1)
117:9
real (1)
79:6
really (7)
11:7,9 20:23 56:7
62:23 74:21 111:24
reason (3)
7:25 98:25 117:9

recall (1)
9:8
receive (1)
80:22
receives (2)
25:11 103:18
recess (4)
32:21 33:17 47:25
80:7
recommendation (4)
25:13 62:8,15 63:4
recommendations (3)
24:9,11,17
record (9)
5:10 6:19,25 33:19
47:24 62:24,25
91:12 115:10
recorded (1)
95:11
records (15)
11:23 23:25 24:6,7
34:24 35:20 36:8
37:22 38:6,14 39:14
40:2 83:11,17
101:24
recreation (1)
90:21
reduced (1)
115:8
refer (4)
54:12 56:6,11 89:10
referring (1)
73:22
refers (2)
57:4,6
reflect (1)
90:14
reform (1)
66:22
refresher (1)
6:9
regard (3)
21:11 23:9 54:9
regarding (4)
6:11 22:11,24 32:11
regardless (1)
83:2
regards (20)
11:10 21:17 31:25
38:25 39:23 42:12
43:18 46:12 56:2,3
60:6 69:7 71:13,23
80:23 82:21,25 88:8
100:18 103:16
Reginald (6)
1:18 2:9 5:11 114:9

TSG Reporting - Worldwide

116:3 117:6
regions (1)
28:12
register (4)
81:21 83:13,14
112:10
related (1)
115:12
relates (6)
32:15 38:17 39:4,17
40:8 96:25
relating (14)
34:24 35:19 36:5,17
37:3,13,22,22 38:6
38:6,12 39:13,25
97:3
relative (1)
115:14
relevant (1)
83:19
remedial (3)
63:11,13,21
remember (6)
10:16 34:12 50:15
77:10 81:20 92:4
Removal (4)
18:4 19:8 42:14 74:3
removals (2)
54:13 56:12
remove (1)
19:13
Rep (1)
100:13
repeat (6)
7:11,12 38:4 46:6,7
97:17
rephrase (4)
7:7,15 12:6 22:4
report (3)
28:18,19 96:3
Reported (1)
1:23
reporter (3)
2:12 6:19 7:12
reports (3)
68:25 69:16,17
repositories (1)
38:13
represent (1)
33:9
Representative (1)
100:7
representing (1)
33:3
represents (1)
34:3

877-702-9580

request (4)
8:25 31:20 32:15 40:6
requests (2)
31:13 32:11
require (2)
90:6 91:6
required (11)
41:4 42:5 43:7 51:17
51:25 74:15 78:3,7
78:10 106:9 112:10
requirement (8)
83:2 100:2 104:9,12
107:5 108:14
110:11 112:7
requirements (2)
82:9 110:11
requires (1)
95:18
requiring (1)
82:17
Research (1)
15:12
residential (7)
18:22 19:3 92:4,5,14
92:17,20
respect (2)
39:21 40:12
responding (2)
26:7 34:4
response (13)
20:4 24:16 25:15,20
25:22 26:2,5,5,6,7
26:12,16,17
responses (4)
24:8,22,24 25:25
responsibilities (2)
18:14 40:14
Responsibility (2)
42:23,24
responsible (3)
28:5 36:18 37:4
rest (1)
57:8
restate (5)
7:7 84:10 87:21 95:17
101:3
restaurant (1)
61:16
restraints (1)
65:25
result (2)
91:3 101:20
retain (1)
38:13
retained (1)
34:25

 Page 11
retaining (2)
36:8 108:13
retention (2)
110:10,11
retrieved (1)
40:3
review (49)
8:9 9:22 40:20,24,25
41:3,21,24 42:3,4
42:22 44:25 46:24
48:20,22 50:19 51:3
51:9,10 52:14 54:18
54:22 55:8,10,12,14
55:17 58:18 61:4,5
61:9 63:16,18 66:18
67:9 73:20 74:24
76:7,12 77:25 78:3
82:17 83:19 95:8
96:10,11 98:20,22
103:9
reviewed (5)
9:25 10:2 40:4 58:16
77:6
reviewer (1)
103:5
reviewers (2)
94:14,20
reviewing (5)
68:6,12,18 97:22 98:7
reviews (83)
8:22 26:21 28:23 29:8
34:25 35:20 36:8,19
37:5,14 38:15,17
39:14,17 40:3,8,15
40:18 41:4,5,7 43:2
43:5,5,12,22,24
44:19 45:9,11 46:8
46:11 47:4 48:15,23
49:10,13,17 50:23
50:24 51:3,16 52:4
52:13,19 53:19
55:19 57:10,25 59:4
59:11,24 60:9,11,20
64:4 65:15 66:20
69:4,22 70:9 71:3
71:18,20 72:5,11
73:14 74:7 76:2
78:3,7,13 80:10,24
83:3 84:17 86:21
93:19 95:23 96:17
97:7 98:14 103:17
revolves (1)
20:23
RIC (2)
95:2,7
right (21)

24:21 29:5 30:9,9
38:22 56:13 69:10
69:25 72:23 75:12
78:24 80:10 85:4,9
88:23 93:22 102:15
102:20 103:13
108:2,25
Rights (4)
21:13,14 25:7 42:16
risk-based (2)
52:5 68:15
Rockville (6)
105:17,18 108:24,25
109:4,13
role (4)
19:7,12,22 20:18
roles (3)
18:14 20:15 22:22
roughly (5)
27:19,21 74:22,25
112:5
rugby (1)
13:18
rules (2)
6:11 42:12
R-I-C (1)
95:7
S
S (2)
5:2,3
safeguard (2)
19:12 88:6
safeguarding (2)
81:16,17
safety (4)
68:23 90:4 98:24
110:16
Sakamoto (130)
1:18 2:1,9 3:1 4:1 5:1
5:11 6:1 7:1 8:1,4
9:1 10:1 11:1 12:1
13:1 14:1 15:1 16:1
17:1 18:1 19:1 20:1
21:1 22:1 23:1 24:1
25:1 26:1 27:1 28:1
29:1 30:1 31:1 32:1
33:1 34:1,9 35:1
36:1 37:1 38:1 39:1
40:1 41:1 42:1 43:1
44:1 45:1 46:1 47:1
48:1,3 49:1 50:1
51:1 52:1 53:1 54:1
55:1,3 56:1 57:1
58:1 59:1 60:1 61:1
62:1 63:1 64:1 65:1

66:1 67:1 68:1 69:1
70:1 71:1 72:1 73:1
74:1 75:1 76:1 77:1
78:1 79:1 80:1 81:1
82:1 83:1 84:1 85:1
86:1 87:1 88:1 89:1
89:3,17 90:1,10
91:1 92:1 93:1 94:1
95:1 96:1 97:1 98:1
99:1 100:1 101:1
102:1 103:1 104:1
105:1 106:1 107:1
108:1 109:1 110:1
111:1 112:1 113:1
114:1,9 115:1 116:1
116:3,8 117:1,6
saw (1)
34:10
saying (9)
53:21 66:5 67:10
71:10 85:8 96:15
97:20 105:3 107:15
says (5)
45:21 55:19 59:4,22
73:14
scale (1)
62:10
scales (1)
62:12
scanned (1)
82:18
scanning (1)
82:25
schedule (1)
72:9
scheduled (1)
74:23
schematic (1)
79:10
school (7)
12:22,24,25 13:2,8,13
13:17
scope (6)
39:7 49:23 52:25 54:4
54:18 56:18
scratch (5)
20:6 35:8 82:13
109:19,20
scratching (1)
38:22
searchable (3)
84:2,4 113:7
searched (2)
113:20,22
Seattle (5)
105:9 108:2,19,20,23

TSG Reporting - Worldwide

second (6)
29:9 43:23 59:15
62:24 64:5 93:7
secretary (2)
66:21 85:24
security (21)
1:11 3:17 15:14,15,16
15:25 16:3 19:13
31:3 35:4,13,23
36:7 37:7,16,25
39:19 40:10 42:17
97:5 117:4
see (14)
34:13 41:2 59:3,22,24
71:8,10,11 73:17
74:3 77:24 92:5
103:7 111:23
seen (8)
11:3,4 34:16 51:24
55:18,20 58:14
104:13
segregation (4)
92:23 93:13,21 94:3
self-assessment (3)
75:6 76:7 79:19
self-assessments (1)
79:7
self-reviewed (1)
75:16
semantics (1)
60:24
sense (2)
12:18 110:23
sent (2)
10:24 100:12
separate (7)
53:19 61:24 70:13,14
70:19 71:23 88:9
separately (1)
69:19
September (4)
18:12 19:15 20:6,10
SEQUIN (1)
4:7
Sergeant (2)
14:11,12
seriously (2)
33:12 34:12
server (6)
84:5,8,9,11,14 86:18
servers (1)
87:10
service (10)
17:18 20:16 21:25
22:5 23:16 27:25
63:19 66:5 67:14

877-702-9580

81:21
services (3)
90:20,22,23
set (6)
68:19 72:8 96:17,17
103:19 104:2
setup (1)
78:19
seventy-two (5)
75:21,22 76:14,20
77:8
seventy-two-hour (1)
75:21
shadow (1)
21:23
shakes (1)
6:20
share (9)
8:12,13,14 84:12,18
87:16 113:16,19,20
shared (6)
8:20 84:16 86:11,15
87:23 88:2
SharePoint (4)
111:6 113:17,18,22
SHEET (1)
117:2
shell (3)
111:19 113:12,13
shift (1)
77:12
shortcut (1)
34:15
show (1)
34:6
signature (3)
102:9 114:18 117:21
signed (1)
109:16
significant (1)
68:25
signs (1)
104:23
simultaneously (1)
102:22
single (3)
30:5 61:6 68:20
sir (1)
34:19
site (7)
8:10,11 24:10 66:12
67:18 71:15,21
six (4)
82:7,14 112:5,7
sixteen (2)
40:13 73:25

 Page 12
slated (1)
65:23
slightly (2)
104:16 108:16
smashed (1)
5:22
somebody (3)
55:14 78:17,18
sooner (1)
104:4
sorry (12)
5:24,25 7:23 8:12
11:13 42:18 64:22
75:13 79:5 82:22
100:8 111:9
sort (3)
20:18 24:7 69:23
soup (1)
70:16
source (3)
30:4,5 31:17
South (1)
3:8
Southwest (2)
16:25 17:4
space (1)
99:5
speak (5)
61:15 64:10 67:24
70:20 72:22
speaking (7)
45:16 57:10 64:15,16
73:10 89:25 98:18
specific (15)
32:2 52:7 55:4,8 69:3
76:17 81:25 87:18
87:19 92:21 93:25
95:18,19 98:19
110:13
specifically (8)
17:3 21:2 46:18 81:13
96:25 97:10 103:14
112:18
specifics (2)
11:10 81:14
spectrum (2)
54:14 64:19
speculate (1)
101:10
speculating (1)
101:25
speculation (3)
86:3 101:14,15
spike (1)
41:2
spoke (3)

72:10 88:14 95:23
staff (3)
18:9,20 105:6
stakeholder (1)
42:11
stakeholders (1)
42:7
standard (17)
48:21 61:6 82:16
88:18 89:11,22
90:15,17,18 91:15
92:24 96:3,12,16,20
97:21 113:5
standards (56)
21:7,16,18 22:11,13
22:15,18,24 23:8,10
23:12,16,18 24:4
25:8 28:4,25 41:19
47:2 48:20 50:17
52:8,10,16 56:19
68:13,19 77:22
80:14,18,19 88:15
88:19 89:16,20,24
90:2,3,5 91:3,6,14
91:15,24 92:3,6,14
92:17 94:2 95:22
96:18 97:4,5,6
98:21 116:12
start (1)
65:17
started (4)
18:21 19:2,5 54:8
state (8)
5:10 6:24 13:5 15:6
17:9 47:17 96:7
98:2
stated (4)
22:22 27:12 44:15
63:3
States (6)
1:2,10,12 3:16 19:14
117:4
statistic (1)
55:18
statistics (4)
43:21 54:10 55:20
56:11
stays (1)
80:14
stenotype (1)
115:8
step (4)
22:21 76:3 82:22
105:2
STG (2)
53:24,24

stipulate (1)
57:17
stipulated (1)
57:20
stipulating (1)
57:15
storage (1)
80:23
store (4)
5:23 38:13 81:13,14
stored (6)
39:15 69:5,16 79:23
84:5,7
storing (1)
83:11
Street (3)
2:10 3:18 112:15
strike (3)
49:7 60:16 62:14
stuff (8)
10:16 30:11 38:22
58:10 67:2 69:12
76:17 86:20
subcontractor (1)
81:10
subject (4)
11:16,17 66:3 105:5
SUBSCRIBED (1)
117:21
sudden (2)
78:20,25
sued (1)
30:6
suggestion (1)
62:7
summarize (1)
90:14
supervise (1)
23:4
supervised (1)
20:16
supervising (1)
19:23
supervision (1)
20:18
supervisor (2)
19:20 23:5
sure (6)
23:12 57:2 59:16
83:14,23 94:21
sworn (3)
5:5 115:6 117:21
System (1)
111:11
T

TSG Reporting - Worldwide

T (2)
5:3 30:17
take (16)
22:21 25:6 32:4,19
33:13 76:3 80:5,6
82:13,22 85:10,16
88:12 103:8 107:25
110:24
taken (8)
32:21 33:17 36:7
47:25 80:7 115:4,7
115:14
talk (3)
33:14 98:4 112:23
talking (15)
34:12 49:25 50:2 54:8
57:10,14 68:17
69:25 70:2,5,10
75:20 82:10 94:8
95:4
task (3)
17:2,4 45:4
tasked (4)
24:13,13 31:22,23
tasking (2)
24:14 56:8
tasks (1)
20:19
team (4)
13:23 20:4 100:11,12
teams (3)
28:10 41:15,16
technical (3)
56:23 100:6,13
telephone (1)
30:10
tell (3)
7:7,15 34:11
template (1)
64:21
templates (3)
64:10 79:20,23
ten (5)
76:21,22 77:8,9,16
term (8)
54:24,24 55:8,17,22
55:25 56:5 57:3
terms (2)
40:18 55:4
testified (5)
5:6 42:25 56:10 59:17
109:8
testify (3)
45:14 59:18 60:4
testifying (1)
55:4

877-702-9580

testimony (8)
33:4 60:11,14 87:6
95:13 115:5,7,11
Texas (1)
16:12
Thank (1)
71:2
theirs (2)
52:5 69:25
theory (1)
45:6
thing (6)
57:11,16,18 60:12
67:19,20
things (14)
10:17 21:8,10 24:19
24:20 43:21 66:3
69:3 77:12 81:22
90:23 93:4 107:10
114:7
think (23)
21:19 32:9 33:21
44:13,21,24 47:19
52:6,17 56:7 66:20
68:3 69:11 74:23
76:11 82:7 107:9,14
108:3,16 109:7
113:24,25
thinking (1)
75:15
Thirteen (3)
38:3,4 59:18
thirty-five (1)
27:21
thirty-seven (1)
58:23
thirty-three (3)
75:2 78:2,12
three (34)
32:18 50:11 54:3
68:20 70:13 91:8,12
91:17,20,22 95:11
95:19 98:5,6,9,16
98:17 99:8,11,13,23
101:6 102:10 103:2
103:18 104:9
106:18 109:8,14,17
110:25 111:14,18
112:24
Three-Twenty-Fou...
94:5
throwing (1)
78:23
Till (5)
14:7 15:19 17:25
18:12 110:22

 Page 13
time (24)
2:6 5:17 7:24 50:25
63:18 65:16,18,18
67:8,19 77:14 83:19
103:6,19,21,22
104:2,8,11,14
106:15,16 108:14
110:24
timeframe (5)
83:5,7 95:3 96:8
98:15
times (2)
66:8 67:21
Timing (1)
66:13
today (12)
8:5,8 50:2,3 58:17
65:8 74:4,21 94:7,8
98:13 111:5
tomorrow (1)
114:2
tools (3)
21:22,22,23
top (3)
44:13,21 60:2
topic (13)
34:23 35:18,25 36:4
36:16 37:2,12 38:11
38:16 39:3,16 40:7
59:18
topics (1)
34:21
total (2)
29:3 61:14
totality (2)
68:13 80:20
touches (1)
105:13
track (2)
97:8 111:14
trail (2)
100:22 101:5
training (5)
80:22 81:2,5,8,12
TRANSCRIPT (1)
117:2
transcription (1)
115:9
transfer (2)
82:20 109:12
transferred (2)
19:16 106:14
travel (1)
66:2
true (1)
115:10

try (1)
70:7
trying (13)
9:10 10:15 41:12,25
54:20 56:7 60:8
70:4,8 81:20 100:21
105:12 109:22
turn (6)
34:20 58:19 59:14
63:17 73:25 111:6
twelve (1)
38:2
Twenty-Four (28)
68:20 91:9,13,17,20
91:22 95:11,19 98:5
98:6,10,16,17 99:8
99:12,14,23 101:6
102:10 103:18
104:10 106:18
109:9,14,17 110:25
111:18 112:24
Twenty-Fours (2)
103:2 111:15
two (8)
29:2 62:2 74:22 77:6
77:22 80:13 95:13
107:10
two-thirds (1)
59:8
type (2)
5:18 113:19
types (6)
21:8 70:8 81:22 84:15
90:23 102:24
typical (1)
27:3
typically (3)
32:4 57:6 85:10
U
ultimately (2)
34:2 62:17
Um-hmm (14)
14:13 18:6 19:5 21:5
44:12 64:6 72:13
74:2 79:8 89:9
99:25 104:18,21,24
unclear (1)
93:20
underlying (2)
8:25 9:12
understand (7)
6:15 7:6,13 32:23
33:2 70:4,8
understanding (5)
26:19 48:11 49:23

72:14,16
understood (1)
66:15
unit (21)
18:22 19:4,8 20:10,12
21:8,11 23:3,7,8,12
25:11 27:8,9 30:17
30:18 31:14,15 43:3
44:5,18
United (6)
1:2,10,11 3:16 19:14
117:4
units (1)
19:24
universe (1)
12:13
University (4)
81:3,4,9,10
unofficial (3)
41:7,9,11
use (18)
21:24 22:25 40:18
52:8,10 54:24 55:25
56:5 57:13 62:10
98:9,15,16,17 99:9
99:11,13 108:19
uses (3)
55:22 91:25 99:7
use-of-force (1)
61:9
usually (1)
68:23
utilize (1)
52:16
utilized (3)
96:16 97:22 98:6
U.S (20)
4:9,12 45:8,11 46:8
46:12,21,23 47:4,12
48:4,6,8,13,16,19
52:22 70:17,20
99:20
V
vague (5)
22:16 49:6 95:12
100:25 101:8
VALENZUELA (3)
4:4 33:16 47:22
various (2)
86:10 98:7
vary (3)
25:24 26:3,12
Vegas (1)
17:22
verbally (1)

TSG Reporting - Worldwide

6:19
verbatim (1)
64:14
versa (1)
106:8
version (1)
109:21
vice (1)
106:8
Virginia (1)
5:13
Virtual (4)
81:3,4,9,10
visit (1)
24:10
visitation (1)
90:23
Vol (1)
1:9
vs (3)
1:9 31:2 117:3
W
W (1)
4:7
Wacker (1)
3:8
Wait (1)
33:11
want (11)
29:2 33:14 53:23 64:2
76:12 85:22 86:4
98:18 101:9 102:14
107:23
wanted (2)
30:5 45:6
wanting (1)
66:12
warrants (2)
17:5,6
wash (1)
9:16
Washington (8)
1:19 2:11 13:4,5 15:6
15:7,8,10
wasn't (2)
12:8 75:15
way (10)
45:3 63:8,15 87:22
88:3 96:2 101:17
106:22,24 111:14
ways (2)
63:25 87:15
Website (5)
58:14,16 74:8 81:5
92:11

877-702-9580

Wednesday (2)
1:20 2:5
weeds (1)
103:20
weeks (1)
32:5
went (7)
8:9 13:12 14:3 16:20
17:8,18 18:22
west (2)
105:17 108:23
western (1)
28:13
we'll (6)
9:2 12:10 13:3 82:22
111:6 114:4
we're (24)
12:3,21 19:7 26:7
33:18 48:7 49:25
50:13 57:9,10,14,15
60:24 67:19 68:16
68:17,18 70:8,10
94:7 95:3 107:9
108:10,13
we've (3)
10:16 55:19 67:22
wind (1)
31:18
wish (1)
93:11
witness (23)
5:4 9:7 12:5 22:18
33:15 39:10 45:14
46:16 47:8 53:5
54:25 57:19 86:5
87:8 93:12 95:15
97:17 101:10,15
108:3 115:5,7,11
women's (1)
90:20
word (1)
22:25
wording (1)
47:19
words (1)
61:21
work (6)
21:25 23:15 24:15
44:2 51:23 67:13
worked (3)
14:17 19:24 20:2
working (2)
15:11 79:15
works (3)
45:3 76:20 100:14
worksheet (2)

 Page 14
91:7 106:5
worksheets (2)
99:7,10
worries (1)
58:25
wouldn't (5)
61:13 71:8,10,11
99:20
wrapped (1)
30:18
write (1)
22:14
writing (20)
25:23,25 41:4,6,14
42:4,6,8 43:8,13
51:17,24 52:2,19,23
53:8,20 78:4,7,10
written (19)
22:10 23:25 24:22,25
26:9,11,17,18,24
52:13 64:8,11 72:3
72:4 79:10 82:21,24
83:3 104:13
X
X (6)
55:19 78:25 105:10
108:8,23 116:2
Y
yeah (19)
17:15 27:21 28:17
61:10 62:2 65:4,19
66:23 71:14 73:8
78:16 81:5 82:24
83:9 88:6 93:12
94:7 100:17 105:3
year (6)
14:22 17:11 74:15,24
79:3 112:19
years (7)
6:9 13:24 77:6 82:7
82:14 112:5,7
year's (2)
108:7,10
Z
Z (1)
98:23
1
1 (3)
34:7,17 59:15
1:12-cv-5358 (1)
1:7
10 (1)

37:12
11 (1)
96:25
12 (1)
58:19
12th (1)
112:15
13 (1)
60:2
1301 (1)
2:10
14 (1)
115:25
15 (3)
38:11 73:3,13
16 (1)
39:12
1981 (1)
13:25
1982 (1)
14:2
1983 (1)
13:25
1992 (2)
14:7,14
1993 (2)
14:23,24
1994 (1)
14:24
1995 (1)
15:3
1995-ish (1)
14:24
1997 (4)
15:19,20 16:5,18
2
2/10/2014 (1)
115:18
2:56 (1)
2:6
20 (1)
39:24
2000 (13)
5:17 11:21 16:18,19
88:19 89:2,7,10,25
90:5,24 91:15 116:9
2001 (6)
17:12,14,15,16 72:23
72:24
2007 (18)
8:22 10:21 17:25 18:2
18:8 49:24 50:4,13
65:7 73:5 83:20
94:21 102:15,21
106:15,23,24

113:15
2008 (10)
8:22 19:5 89:15,24
90:2,3,18,24 91:20
116:11
2009 (4)
18:12 19:15 66:20,23
2010 (2)
113:15,16
2011 (6)
90:9,15,17,25 91:22
116:13
2012 (6)
10:21 20:7,8,11 49:24
93:5
2013 (2)
92:22 114:10
2014 (5)
1:20 2:5 115:25 117:5
117:22
219 (1)
3:18
233 (1)
3:8
29 (3)
1:20 2:5 117:5

88:20 89:3,7 90:24,25
116:9
70294 (1)
1:25
8
8 (5)
36:16 89:14,17,20
116:11
89 (2)
116:10,12
9
9 (4)
90:10,14,25 116:13
9:30 (3)
114:4,5,10

3
3 (2)
58:12 72:10
30 (1)
114:9
30(b)(6) (7)
1:18 2:9 32:23 33:23
34:18 45:15,25
5
5 (1)
116:5
5:59 (1)
114:8
500 (1)
112:14
6
6 (1)
36:4
6th (1)
2:10
60604 (1)
3:19
60606 (1)
3:9
7
7 (6)

TSG Reporting - Worldwide

877-702-9580

 Page 118
1
2

IN THE UNITED STATES DISTRICT COURT

3

FOR THE NORTHERN DISTRICT OF ILLINOIS

4

EASTERN DIVISION

5

- - - - - - - - - - - - - - - - )

6

NATIONAL IMMIGRANT JUSTICE

) Case No.:

7

CENTER,

) 1:12-cv-5358

8
9

Plaintiff,

)

vs.

) Vol. II

10

UNITED STATES DEPARTMENT OF

)

11

HOMELAND SECURITY, and UNITED

)

12

STATES IMMIGRATION AND CUSTOMS

)

13

ENFORCEMENT,

)

14
15

Defendants.

)

- - - - - - - - - - - - - - - - )

16
17
18

CONTINUED 30(b)(6) DEPOSITION OF REGINALD SAKAMOTO

19

Washington, DC

20

Thursday, January 30, 2014

21
22
23

Reported by:

24

Kim M. Brantley, CSR

25

Job No:

70293
TSG Reporting - Worldwide

877-702-9580

 Page 119
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

Page 120

SAKAMOTO

1
2
3
Thursday, January 30, 2014
4
Time: 9:39 a.m.
5
6
7
Continued 30(b)(6) Deposition of REGINALD
8
SAKAMOTO, held at Dentons US, LLP, 1301 K Street, 9
NW, Suite 600, Washington, DC, before Kim M.
10
Brantley, Court Reporter and Notary Public of the
11
District of Columbia.
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
APPEARANCES:
On behalf of the Plaintiff:
ERIC ANDALMAN, ESQUIRE
Dentons
233 South Wacker Drive
Chicago, Illinois 60606

On behalf of the Defendants:
CRAIG OSWALD, ESQUIRE
United States Department
of Homeland Security
219 Dearborn Street
Chicago, Illinois 60604

Page 121

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
ALSO PRESENT:
ROYCE MURRAY, ESQUIRE
National Immigrant Justice Center
CHARLES OLEAN, ESQUIRE
U.S. Immigration & Customs Enforcement (ICE)

Page 122
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
P R O C E E D I N G S
R E G I N A L D S A K A M O T O,
called as a witness by Counsel for the Plaintiff,
and, after having first been duly sworn by the
Notary Public, was examined and further testified
as follows:
EXAMINATION BY COUNSEL FOR THE PLAINTIFF:
BY MR. ANDALMAN:
Q. Your counsel stated prior to the
deposition that you had an issue that you'd like
to clarify based on your testimony yesterday. Mr.
Sakamoto, feel free to do that.
A. Yes, I just wanted to clarify with
respect to ODO and their records maintenance, they
only keep electric -- electric -MS. MURRAY: Electronic?
MR. OSWALD: Electronic.
THE WITNESS: Electronic documentation.
They have only kept electronic documentation
since 2010.
BY MR. ANDALMAN:
Q. And since 2010 -MR. ANDALMAN: Let's go off the record.
(Brief interruption.)

2 (Pages 119 to 122)
TSG Reporting - Worldwide

877-702-9580

 Page 123

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
BY MR. ANDALMAN:
Q. Going along that line, I presume that
prior to 2010 it was only in paper form. Is that
correct?
A. It was -Q. Was there a mix between electronic and
paper?
A. I mean, obviously, ODO, I don't work
for ODO. What I believe is it was both.
Q. But you do not know?
A. I do not know, no, for sure. But I do
know as of 2010 to present, it's only electronic.
Q. And you said those would be on a
different share drive, to the extent that they're
electronic, than the ones that are EROs that are
on a share drive, for instance -A. Yes.
Q. -- perhaps on the same server?
A. Yes. I'm not sure where the servers
break off.
Q. A couple of things from yesterday that
we wanted to clarify...
I'm trying to figure out, we talked a
little bit about the generation of the

Page 124

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
inspections, and, correct me if I am wrong, I
believe those were the Nakamoto Group's
inspections with annual, biannual and ORSA ones.
Is that correct? Those are mainly -A. Three Twenty-Four inspections?
Q. Correct. Three Twenty-Four inspections
were mainly for the Nakamoto Group?
A. Yes.
Q. Right.
A. They are for the Nakamoto Group.
Q. Right.
A. Now, what you had asked yesterday with
regards to the other entities, could they use a
Three Twenty-Four, my answer is yes, they could
use a Three Twenty-Four.
Do they primarily use a Three
Twenty-Four? No. Their format is usually in
executive summary type.
Q. Got it.
A. And the ORSA is not Nakamoto, just to
clarify that.
Q. Okay.
A. The ORSA is internal ERO,
self-inspection.

Page 125

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
Q. Let me just clarify this so that I
understand this. The status of being annual,
biannual or ORSA is assigned to each facility. Is
that correct?
A. Yes, but it's living, so it can always
change based on ADP.
Q. Which is the average -A. Daily population.
Q. Daily population.
A. Correct.
Q. So, ODO could go to a facility and
review it, that is annual or biannual, correct?
A. Well, ODO doesn't do annuals or
biannuals.
Q. So this is only -A. It's only Nakamoto, ODO.
Q. Got it. Does ODO have a timetable in
which it reviews facilities?
A. Like I said yesterday, they set their
facilities up based on a risk-based matrix.
Q. Okay.
A. And obviously budget restraints and all
those other things. So, I mean, they try to set
their facilities up and give us as much advanced

Page 126

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
notice as possible. But that's always changing,
as well.
Q. When you say a risk-based matrix, is
there a document that states certain criteria on
which a facility will be up for review?
A. Again, not working for ODO, but my
understanding is that in working with ODPP, there
was a risk-based matrix developed.
Q. Is that a document or is that a
computer program?
A. I haven't seen it.
Q. You're not otherwise familiar with it?
A. No.
Q. As you said, OIG is a criminal-based
system, so there is no timetable on them either.
Is that correct?
A. Correct.
Q. It's an as-needed?
A. Correct. Any time there's a complaint,
potential criminal or allegation, first tier is
OIG; they will defer down to ODR, and then from
there...
Q. And then CRCL, is that again an
as-needed, or is it a timetable-based review?

3 (Pages 123 to 126)
TSG Reporting - Worldwide

877-702-9580

 Page 127

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
A. It's as needed, as well.
Q. So, is it fair to say that the only
timetable-based reviews, regular reviews, are ones
that are either ERO or the Nakamoto Group?
A. The Nakamoto Group is ERO.
Q. Correct.
A. And as you stated earlier, through the
biannual, the annual -Q. Got it.
A. And ORSA is set up on a schedule, yes.
Q. So I had a question about ORSA.
You said that ORSA is not performed by
the Nakamoto Group. Does ORSA use the Three
Twenty-Four form?
A. Yes, they use the Three Twenty-Four
form.
Q. Is there any auditing of the ORSA,
random auditing or regular auditing of the
facilities that do the ORSA reviews?
A. The procedures are the same with the
Nakamoto.
Q. Okay.
A. So, it would come to DSCU.
Q. Just to clarify, DSCU comes in and

Page 128

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
ensures that the reviews are being done properly?
Is that correct?
A. Yes, the detention standards
compliance.
Q. Are they reviewing the physical
documents, or are they going in and performing a
separate investigation on themselves?
Let me clarify. It seems that the ORSA
facilities will do a self-assessment, correct?
A. Correct.
Q. And they will fill out a form Three
Twenty-Four -A. Not the facilities, the field office.
Q. The field office. The ORSA field
office will perform a -A. ORSA.
Q. An ORSA. A self-assessment?
A. The field office will conduct the ORSA.
Q. The field office will conduct a
self-assessment and fill out a form Three
Twenty-Four, correct?
A. Correct.
Q. Does DSCU then come in and review the
form Three Twenty-Four, or do they do their own

Page 129

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
separate investigation or inspection or, you know,
what have you of the facility?
A. It's done the same way that the
Nakamoto is done. The Three Twenty-Four and the
documents will come up to DSCU, which they will
then review.
Q. Okay.
A. And then at some point an RA will be
issued.
Q. What is an RA?
A. That's the final agency rating.
Q. When they review it, are they reviewing
for completeness, or what are they reviewing for?
A. They're reviewing the inspection.
Q. When they are reviewing the inspection,
are they reviewing for completeness or are they
reviewing for accuracy?
A. All the above. And I mean, if there
are any discrepancies or a need for clarification
or further understanding, then they would perform
that.
Q. Is there a document that they create if
they send it back to the field office saying that
this is incomplete or inaccurate?

Page 130

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
A. Yes.
Q. What is that document called?
A. UCAP.
Q. U-C-A-P?
A. Um-hmm.
Q. What does that stand for?
A. You know, we have all these acronyms.
That is the Corrective Action Plan. That's the
uniform -- it's the Corrective Action Plan.
Q. And this -A. Now, just to be clear...
Q. Go ahead.
A. Previously, I mean in years past, just
because the timeframe we're talking about, 2007,
it used to be called a POA at some point. But I
don't know if it's all on what you have seen.
But just to clarify, in case you have
seen that and there was some confusion. It's now
called the UCAP. Before it was called a POA.
Q. The POA, is that standard Plan of
Action?
A. Yes.
Q. But a UCAP and the POA, they don't
differ in any way except for their being acronyms?

4 (Pages 127 to 130)
TSG Reporting - Worldwide

877-702-9580

 Page 131

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
Is that correct? Or is there any distinction
between the two?
A. No, they're the same.
Q. Is a Plan of Action a document which
outlines the ways to improve the inspection, or is
it a way to improve the facility?
A. The Plan of Action or UCAP would be a
way to clarify an issue, whether it's a deficiency
or something else.
Q. Is that a substantive deficiency, or a
deficiency in the actual reviews?
A. It would be with regards to the
facility.
Q. Now I guess I'm asking a slightly
different question, which is, if there's a problem
with the document, with the form Three
Twenty-Four, not substantive...
A. Um-hmm.
Q. That it's incomplete...
A. Um-hmm.
Q. Or they have reason to believe that
there is an improper process that is going on in
reviewing and inspecting these...
A. Um-hmm.

Page 132

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
Q. In a particular facility, is there then
a document that is created?
Or what happens to that form Three
Twenty-Four when the DSCU is reviewing it?
A. My understanding is the DSCU at that
point, the officer, the docket officer would then
need to go back for clarification or if there is
something that needs to be corrected within the
document.
Q. Okay.
A. Can you give me the question again.
Q. I can restate it if that's helpful?
A. Yes.
Q. So, the question is, when the DSCU
determines that there is something missing or that
they have questions as to the process or accuracy
of the form Three Twenty-Four.
A. Um-hmm.
Q. Do they generate a separate document
memorializing those thoughts, or is there a
standard operating procedure for sending it back
to the field office, or is there some other -A. Well, for ORSA that would be done
through the course-of-day business.

Page 133
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
You know, I don't believe that there's
a correction document.
Q. Okay.
A. I mean, it would be more like an
E-mail. Now Nakamoto's a little bit different in
the fact that there is a COTR that's involved.
The office is the headquarters to the field
office, which is government federal staff.
Nakamoto is a contract of that.
So there is the middle person being the
contract technical representative. So the DSCU
officer with would go to the COTR. The COTR could
go to the -- it's just a formality.
Q. What is a COTR?
A. Contract Officer's Technical
Representative.
Q. When DSCU is reviewing the accuracy or
precision of the report, are they physically
onsite at the facility, or are they reviewing them
separately?
MR. OSWALD: I'm going to object at
this point, because we're now asking just a
series of questions that are all covered by
nineteen, which is struck from the Notice of

Page 134

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
Deposition, which is "The facts and
circumstances concerning the development and
implementation of a Plan of Action to remedy
any deficiencies identified in reviews,
audits, inspections and how these are
incorporated into the reviews, audits and
inspections."
These questions are all covered by
that, in my view, and if we're going to
continue on...
I mean, I'm trying to give you some
leeway so you understand, you know, some
parts of the process in terms of what the
documents are, but I think we're going into,
you know, an entire area that's specifically
covered by the protective order.
MR. ANDALMAN: Well, and that's a good
point. I'm not discussing the Plan of
Action. I'm discussing these corrections and
what documents are generated and how they're
generated.
So I'm asking specifically, and I
appreciate that, Craig, because I'm not
talking about the Plan of Action in this

5 (Pages 131 to 134)
TSG Reporting - Worldwide

877-702-9580

 Page 135

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

Page 136

SAKAMOTO

1
2
instance.
3
BY MR. ANDALMAN:
4
Q. Let me restate the question.
5
When the DSCU is reviewing the
6
underlying form Three Twenty-Four, are they onsite
7
or are they elsewhere?
8
A. Well, through the time period 2007,
9
2012, I mean, it could have been both. At, you
know, 2007, DSCU officers from headquarters may 10
11
have been the lead reviewer. That wouldn't be the
12
case today.
13
Q. Okay, what would it be today?
14
A. Today they would be reviewing from
15
here.
16
Q. So they may never even see the
17
facility?
18
A. Today, correct.
19
Q. When you say lead reviewer, does that
20
mean the -- ***
21
A. The LCI, I'm sorry. Like we said
22
yesterday, the LCI or the RIC. Generally it would
23
be the LCI. So the LCI would be the Lead
24
Compliance Inspector, which should be the
25
contractor.

SAKAMOTO
The RIC, Review Inspector in Charge,
would be an ERO employee.
Q. And the LCI, maybe or maybe not at ERO,
could be Nakamoto?
A. I don't know. I don't believe that
I've seen a document with an LCI that was an ERO
employee.
Q. So most likely they would be Nakamoto?
A. Or Creative Corrections or MGT.
Q. Or one of those parties?
A. Yes.
Q. That's very helpful. Is it fair to say
that there is no standard operating procedure or
protocol for the DSCU to formalize comments on the
Three Twenty-Four document?
MR. OSWALD: Again, I would object,
again, citing Paragraph 19, "The facts and
circumstances concerning the development and
implementation of a Plan of Action to remedy
any deficiencies identified in reviews,
audits, inspections and how these are
incorporated into the reviews, audits and
inspections."
MR. ANDALMAN: And I'll tell you --

Page 137

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
MR. OSWALD: I don't understand why
we're in a group, a series of questions
within this context, which is all follow-up
action to the reviews.
So, if we're going to go much further,
I don't -MR. ANDALMAN: We're close to the end
of the road. I'm trying to figure out,
Craig, what documents are created and knowing
what, you know, modifications are made and
whether or not that is memorialized in any
sort of meaningful way.
I'm trying to understand from the
witness' perspective, and that's the type of
question.
MR. OSWALD: I understand it, but then
you're saying "documents," which I would
agree to, you know, within the spirit here,
to try to go to documents, so -MR. ANDALMAN: Let me try to narrow it.
Let me try to narrow it.
MR. OSWALD: Okay.
BY MR. ANDALMAN:
Q. Is there any protocol discussing what

Page 138

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
sorts of documents or how the comments on the
Three Twenty-Four need to be memorialized with
regards to, we'll start with ORSA?
A. No.
Q. Is there a protocol or standard
operating procedure with regards to how comments
on the Three Twenty-Four need to be memorialized
for annual reviews?
A. No.
Q. Is there a standard operating procedure
or protocol for how comments or modifications -A. I'm going back. I'm not speaking for
Nakamoto. I don't know if they have guidance down
to their subject matter expert, if they want
comments on that.
I don't know if that's what you are
asking.
Q. No, it's not what I'm asking, and just
let me finish the question, because it gets kind
of difficult to read in the transcript. So let me
restate that question.
I'm asking specifically documents that
would ultimately be in the possession, custody and
control of ICE, eventually of ICE.

6 (Pages 135 to 138)
TSG Reporting - Worldwide

877-702-9580

 Page 139
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
So the question becomes, is there a
standard operating procedure or protocol for how
comments or modifications would be memorialized
for biannual reviews?
A. Modifications to the Three Twenty-Four
or comments to the Three Twenty-Four would be done
through the UCAP or the POA.
Q. I thought you testified earlier that -A. I understand that, but I didn't
understand -- I mean, I thought you were talking
about with regards to the actual Three Twenty-Four
and making changes to the Three Twenty-Four
(indicating).
Q. That is what I'm asking.
A. Oh, okay. I mean, we don't have policy
that says "changes to Three Twenty-Four".
Q. Let me take a step back.
We were discussing earlier that the
DSCU's are kind of a second-level review of the
underlying inspection.
Am I understanding that correctly?
A. Yes.
Q. If they approve it, I assume it goes on
to the next step of the process. Is that correct?

Page 140

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
A. Yes.
Q. If they say that there is a problem
with it...
A. Yes.
Q. You said that they send it back to the
field office, right?
A. Correct.
Q. My question is -A. For the -Q. For the ORSA -A. For the ORSA.
Q. For the ORSA, annual and biannual
reviews...
A. Yes.
Q. When DSCU notices a deficiency, a
problem, a need to modify...
A. Yes.
Q. Something on the worksheet, is there a
standard operating procedure on how those
comments, those recommendations, et cetera, need
to be memorialized?
A. Yes.
Q. There is one?
A. Yes.

Page 141

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
Q. What is the procedure?
A. It would be done through the POA and
the UCAP.
Q. Even if it's not substantive to the
facility, it's just a matter of -A. No, if it's not substantive to the
facility, it could be an E-mail for clarification.
Q. So that's what I'm asking.
A. Okay.
Q. Nonsubstantive changes, not to say "we
need to have better beds," or "we need to have
better medical," et cetera -A. Okay. That would be -Q. Let me finish real quickly.
When DSCU discovers a problem in the
worksheet, is it my understanding, am I correct
that there is no protocol or standard operating
procedure to articulate those changes or those
modifications to the field office?
A. Nonsubstantive, yes.
Q. Got it. Let's hopefully move past the
form Three Twenty-Four at this point.
So the Three Twenty-Four, in all of
these reviews, we'll forget the other ones that

Page 142
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
perhaps use different procedures, like the ODO,
the CRCO, et cetera, just for the ERO ones for the
time being...
When the Three Twenty-Four document has
been approved by DSCU, where does it go next?
A. To the review authority.
Q. Is that different from an ORSA
facility, an annual facility or a biannual
facility?
A. No.
Q. So who is the review authority?
A. The Assistant Director for Custody and
Management, which could be delegated to the Deputy
Assistant Director, or used in his acting
capacity.
Q. When the acting director or the deputy
director receive -A. It would be the assistant director or
the DAD, if the DAD is acting for the assistant
director.
Q. DAD being Deputy Assistant Director?
A. Yes.
Q. Thank you for the clarification.
When the assistant director or the

7 (Pages 139 to 142)
TSG Reporting - Worldwide

877-702-9580

 Page 143

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
deputy assistant director receives the Three
Twenty-Four, what form is the document in? Is it
in paper format or electronic format?
A. It's the file.
Q. When you say "the file," what do you
mean?
A. It's the facility file. As we
discussed yesterday, if there's previous reviews,
for as long as we're maintaining the physical file
as per the federal regulations, it would be that
file, with the Three Twenty-Four in there. If
there is any UCAP or POA, that would be in there.
Q. Now, does the file include previous
years' reviews or just the current year's review?
A. It could.
Q. Is there a standard operating procedure
or protocol as to what needs to be in the file?
A. I don't know if there's a file set up.
Q. After it goes to these, let's call
them, as you said, DAD, or assistant directors,
after it goes to them, where do they hand it off
to?
A. Well, just let me clarify. There's a
whole other level that comes in, and that's the

Page 144

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
DSCU chief.
Q. Okay.
A. So the DSCU chief would obviously see
the whole thing, and then it would go from the
chief to the deputy.
Q. So, it goes from the DSCU -A. Chief.
Q. Officer originally?
A. Yes.
Q. To the DSCU chief, to the ADs, or the
DADs, correct?
A. Correct. So the chief would make sure
that it's prepared and it's ready.
Q. Is the file kept intact through each
process?
A. To the best of my knowledge.
Q. And it's in paper, or is it in
electronic format?
A. I've only seen paper.
Q. After it goes to the ADs...
A. Um-hmm.
Q. Or the DADs, which is the acting
assistant director and the Deputy Assistant
Director --

Page 145

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
A. The assistant director or the Deputy
Assistant Director.
Q. After they get it, where does the file
go?
A. It goes back to DSCU for filing.
Q. When you say "filing," what does that
mean?
A. To be stored in -Q. Okay.
A. A PCA.
Q. And it's stored in paper format?
A. Yes.
Q. You spoke earlier that the documents
are also in electronic format, correct?
A. Correct.
Q. Why don't you take me through the
transmission and creation of those electronic
documents.
A. Well, we're talking about the end of
the file, and yesterday we were talking about the
beginning of the file.
Q. Okay.
A. So, I mean, I'm not clear on what you
want now.

Page 146

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
Q. Well, I'm trying to figure out when it
becomes electronic and when it is paper.
A. That would be during the whole process.
That would be from the beginning through the
process. That's with the DSCU officer.
Q. I'm a little unclear. Could you
explain on that?
A. So, as I said yesterday, if there was a
previous annual inspection, there was an
inspection last year, we would have the file.
The DSCU officer would go pull that
file with last year's inspection. They would have
the inspection that maybe happened last week, so
now they have the new documents.
The new documents will be scanned and
put onto the share drive. They will go into that
file, and they would review the Three Twenty-Four,
line by line, if a UCAP or POA is required.
If there needs to be further
communication from the headquarters element to
whoever did the review, then that would be
performed.
When DSCU is satisfied with the rating,
it will then go and be packaged to go to the chief

8 (Pages 143 to 146)
TSG Reporting - Worldwide

877-702-9580

 Page 147

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
as prepared. The chief will generate the RA memo,
which will go to the AD, or the deputy. The RA
memo will be signed off as a review authority,
with the final agency rating.
Q. Got it.
A. And then once that's signed, then that
would get scanned and put in the electronic file.
Q. So, all of -A. The files are maintained, paper files
are maintained as according to the federal
register and the requirements we have to maintain
files, paper files.
Q. Okay.
A. When that timeframe expires, then -Q. I understand that. But throughout the
process, and correct me if I am wrong, there is no
protocol or standard operating procedure that the
file needs to be kept together all along the way.
Is that correct?
MR. OSWALD: Objection,
mischaracterizes the testimony. You can feel
free to answer.
THE WITNESS: The operating procedure
is a unit. I'm sure the unit has SOPs in

Page 148

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
place on how they conduct their day-to-day
business, but with regards to agency policy
on that, no.
BY MR. ANDALMAN:
Q. SOP means standard operating procedure,
right?
A. Yes.
Q. It's possible that, for instance, a
form Three Twenty-Four could be separate from a
POA?
A. Yes.
Q. Are you aware of a situation where a
POA may have been misplaced?
A. No.
Q. Let's talk about how the Three
Twenty-Four gets turned into a final inspection
report. I.
Think you said the DSCU chief takes the
final report and puts it into some sort of -So how does that work? I just want you
to explain that.
MR. OSWALD: I just want to object,
because he just ran through the entire
procedure, I believe.

Page 149

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
MR. ANDALMAN: Well, I want to
understand a little bit better about how the
Three Twenty-Four goes from a worksheet to a
final report.
MR. OSWALD: And I object because it's
asked and answered, because he just ran
through the entire procedure.
MR. ANDALMAN: Fair enough.
MR. OSWALD: You can go ahead and do it
again.
BY MR. ANDALMAN:
Q. Once you have a finalized Three
Twenty-Four that is approved by DSCU, take me
through the steps that gets it into a final
report, or as you said, a rating at the end.
A. The Three Twenty-Four, to include the
SIS, the S-I-S, the S-I-S, the last page of the
S-I-S has the Lead Compliance Instructor's
recommended rating, along with the Three
Twenty-Four.
It goes to DSCU. The DSCU officer goes
through the Three Twenty-Four, line by line, and
if there are no deficiencies, it gets packaged and
it goes to the chief, as concurrence based on that

Page 150

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
officer's recommendation, to the chief for another
review.
Once the DSCU chief is satisfied with
that review, the RA is created.
Now, I mean, I don't know who actually
prints out the RA. I'm assuming that the unit
chief prints out the RA to go to the AD level. It
goes up to the AD level. It gets signed off on,
it's done.
(Glades County Detention Center Quality
Assurance Review was marked Deposition
Sakamoto Exhibit 10, for identification.)
BY MR. ANDALMAN:
Q. You've been handed what has been marked
as Exhibit 10. Does this appear to be a true and
correct copy of the Management Inspection Unit's
Detention Facility and Inspection Report Group
Quality Assurance Review for Glades County
Detention Center
A. Yes.
MR. OSWALD: Can I just clarify. Did
you pull this off the Internet, or is this
something that we produced?
MR. ANDALMAN: This was a document

9 (Pages 147 to 150)
TSG Reporting - Worldwide

877-702-9580

 Page 151

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
produced in this action.
MR. OSWALD: Okay.
MR. ANDALMAN: Yes.
MR. OSWALD: I know we produced it from
this when I was going through the disk. I
just want to make sure.
It's from the stuff we gave you as
opposed to the stuff that's posted on the
Internet?
MR. ANDALMAN: Yes. This was not from
the FOIA Website.
MR. OSWALD: Okay.
MR. ANDALMAN: This was from a document
transmitted -MR. OSWALD: Right, when we were making
the disclosures.
MR. ANDALMAN: Yes, correct.
THE WITNESS: Can we have a break for a
second.
MR. ANDALMAN: We will start again in a
couple minutes. Let's take a five-minute
break.
(Brief recess taken.)

Page 152

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
BY MR. ANDALMAN:
Q. Before we move to this exhibit, I want
to just close two other things with regards to the
Three Twenty-Four.
How long is the Three Twenty-Four
generally, the form, how many pages?
A. Right around eighty pages. PBN desk,
eleven -- hold on. Now I've got to clarify.
It depends on the format that it's
saved in.
Q. Okay.
A. So a PDF, obviously because of the
formatting, it changes, so it could be more pages,
whereas a template document it could be less, or
in the file.
Q. And -A. So, the media document could be much
larger because of megabytes and all those things,
as opposed to the file.
Q. Let me try to figure this out. Are
additional pages added to the media -A. No, it's just the way it's saved.
Q. Okay.
A. Because you're asking.

Page 153
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
Q. So, let me clarify. Is it initially
put into a document, like a Word document, and
then saved as a PDF?
A. I don't know.
Q. You wouldn't know if metadata or
anything were saved when that transition occurred?
A. Right.
Q. So the actual Three Twenty-Four
document, it's a worksheet, correct?
A. Yes.
Q. Does the worksheet have a rating system
on it, or that, you know, a certain box is checked
off, "yes or no," or is there another way that -A. You have the standard, then you have
the components, and then you have the
subcomponents, and then you have check boxes along
the right-hand column.
Q. So it's a "yes or no," check "yes or
no"?
A. Or "N/A," I believe.
Q. So that's that it doesn't apply, or
"not applicable"?
A. Yes, yes.
Q. That's very helpful.

Page 154
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
We spoke about the movement of this
physical or electronic Three Twenty-Four document,
and we mentioned that at some point it goes from
the worksheet into, as an example, what you see in
Exhibit 10, correct?
A. No. I mean, this is not ours.
Q. Mr. Sakamoto, you've been handed
Exhibit Number 10, correct?
A. Yes.
Q. If you would turn to the third page, it
says that, "The Office of Detention and Removal
Operations Miami's field office are authorized to
use this facility to detain and process aliens."
A. Um-hmm.
Q. In the first paragraph, do you see
that?
A. Yes, I see the first paragraph.
Q. Then what does that say? Does that say
that it's a DRO facility?
A. It's a DRO facility, but this document
is not a DRO document.
Q. Well, how do you know it's not a DRO?
A. Because it's OPR. This is Office of
Professional Responsibility. This is a DFEG

10 (Pages 151 to 154)
TSG Reporting - Worldwide

877-702-9580

 Page 155

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
document, which is the predecessor to ODO.
Q. It says on the bottom of this document,
in the background it says "DRO Detention Standards
Compliance Units conducted National Detention
Unit's annual reviews of DCGC in July of 2008."
A. Um-hmm.
Q. That's not incorporated?
A. I don't know, because I don't know what
they use to gather this information. It looks
like -MR. OSWALD: I would object. We're
getting into specific questions of a 30(b)(6)
witness about specifically what goes on in
these documents.
You know, these are clearly things that
are in his individual knowledge and not what
he's speaking of on behalf of the agency.
It is not fair to ask the 30(b)(6)
witness for reports he's never even seen to
find out what specifically was applied in
this review.
And also you're mixing and matching
entities that are doing reviews.

Page 156

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
BY MR. ANDALMAN:
Q. When the eighty-page Three Twenty-Four
document is received by, I think you said the DSCU
chief, it is then formulated into a report,
correct?
A. No.
Q. It's not?
A. No. The Three Twenty-Four goes to the
DSCU staff officer.
Q. Right.
A. What goes to the chief is the file,
completed.
Q. Is that the complete -A. In preparation for a final rating.
Q. Is there ever a narrative report like
the one that you see in front of you that is
drafted?
A. You'll see the LCI, which is the SIS,
from the review team, the lead, whether it's the
RIC or the LCI, then you will have all the
remedial information, the UCAP, POA, those types
of things.
Q. So you're not going to see necessarily
a narrative like you see in this ODO review before

Page 157
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO

1
2
you?
3
A. This is an executive summary.
4
Q. Do you -5
A. We do Three Twenty-Four annual reviews.
6
ODO, CRCL and those types, and we said this
7
yesterday, they do executive summaries.
8
Q. Got it.
9
A. Now, what I said yesterday was they
10
could use a Three Twenty-Four. They could use a
11
type of checklist. I mean, they're free to take
our Three Twenty-Four and however they go, line by 12
13
line, but at the end of the day their final is an
14
executive summary.
15
Q. Is that dictated by policy and
procedure, that the EROs use a Three Twenty-Four? 16
17
A. Yes, your inspection annual process is
18
dictated by policy. Yes.
19
Q. There is a policy manual for that,
20
that's written down?
21
A. It's an SOP, not a policy.
22
Q. So the standard operating procedure is
23
written down saying how it needs to be formed?
24
A. The DSCU should have a standard
25
operating plan. I have not seen it, but with

Page 158

SAKAMOTO
regards to a policy, no.
Q. When the final rating comes out, what
form is that in? Is that in numeric form, or is
that a qualitative form?
A. The RA is roughly two paragraphs, and
this says "meets standards," "does not meet
standards".
Q. If it doesn't meat standards, is that
when the POA is issued?
A. No. We're going back to -MR. OSWALD: It's asked and answered.
BY MR. ANDALMAN:.
Q. So what remedial steps are taken?
A. That's when the UCAP and the POA is all
conducted, from the point the staff officer
receives the Three Twenty-Four from the inspection
group, all the remedial action goes through when
headquarters, DSCU is prepared to issue a final
rating, that's when the RA is prepared.
MR. OSWALD: You know what, let's go
off the record for just one second.
(Discussion off the record.)
BY MR. ANDALMAN:
Q. We may have covered this, but I just

11 (Pages 155 to 158)
TSG Reporting - Worldwide

877-702-9580

 Page 159

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
want to close the knot on it.
With regards to changes to the Three
Twenty-Four, if there's let's say an E-mail,
saying there is a deficiency in the way that the
Three Twenty-Four was filled out, is that kept
with the file?
A. You need to clarify "deficiency,"
because before we were talking about like
editorial things. I can't read the line, or a
deficiency to the facility.
Q. Yes.
A. I mean, what are you talking about?
Q. And thank you. I mean a nonsubstantive
deficiency, that they did not fill out on Line
112, for instance, whatever it is...
You said that at times someone would
write an E-mail back to perhaps the field office
saying that "You need to go back and fill this
out".
Is that correct?
A. No. It would go back to the review
team.
Q. The review team?
A. It would go back to the lead, actually.

Page 160

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
The DSCU officer, staff officer, would send it
back to the team lead for clarification, or
correction. It could be clarification, because it
can't make out a word.
Q. Let's take it one at a time. If that
is written in E-mail form, is that included in the
file?
A. If the officer prints out the E-mail
and puts it in the file, I can't say -- I don't -Q. Is there any requirement that it be put
in the file?
A. I don't believe so.
Q. Are these forms ever track-changed or
redlined?
A. I have not seen an official Three
Twenty-Four that has had track changes on it,
after inspection.
Q. Are there ever handwritten comments on
maybe a paper form sent back to the review team?
MR. OSWALD: Just for the record, I'm
going to object on the grounds that this is
beyond the scope of the 30(b)(6) witness.
All of these questions today are based
upon his individual knowledge, that he speak

Page 161

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
about it on his own personal knowledge and
are not binding on behalf of the agency.
These questions are so specific that,
you know, I understand and am giving you
leeway, but I do want to make it clear that
these are really specific questions that are
talking about him within his personal
knowledge and not as a 30(b)(6) witness.
MR. ANDALMAN: So noted.
Can you reread the question.
THE COURT REPORTER: "Question: Are
these forms ever track-changed or redlined?
"Answer: I have not seen an official
Three Twenty-Four that has had track changes
on it, after inspection.
"Question: Are there ever handwritten
comments on maybe a paper form sent back to
the review team?"
THE WITNESS: You mean handwritten
comments from a DSCU officer?
BY MR. ANDALMAN:
Q. Correct.
A. No, I have not seen that. I'm not
saying it won't happen, but I mean, they would

Page 162

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
have to then scan the document. It doesn't make
sense.
Q. Okay.
A. Now there could be DSCU officer notes
that they put on that didn't go back.
Q. What do you mean it "didn't go back"?
A. Well, while they're reviewing it, to
ask this or clarify this -MS. MURRAY: Notes to the file.
THE WITNESS: Yes, notes to the file.
BY MR. ANDALMAN:
Q. So those may or may not make it into
the file?
A. No, if they wrote on the Three
Twenty-Four, obviously that would be in the file.
Q. Just so that I'm clear, this entire
file is then ultimately sent to that location in
Maryland you discussed yesterday?
A. No.
Q. Where is it ultimately stored?
A. PCN is there.
Q. What is PCN?
A. That's the Potomac Center North, ICE
building.

12 (Pages 159 to 162)
TSG Reporting - Worldwide

877-702-9580

 Page 163

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
Is that in Maryland?
No.
Where is Potomac Center North?
Washington, D.C.
My apologies.
So the entire file is ultimately placed
in the Potomac facility, correct?
A. Correct.
Q. The paper file is filed in a building
on Floor Nine, correct?
A. Eight.
Q. Eight. And it's secured?
A. Yes.
Q. And it's in file cabinets?
A. Yes.
Q. So in the context of a FOIA, let's say,
and I wanted to get a review for a certain year in
a certain facility, I could go to the Potomac
facility on Floor Eight, if I had to access it,
and pull that file, correct?
A. Yes.
Q. And if I wanted -A. Well, as long as it's within the
retention period.
Q.
A.
Q.
A.
Q.

Page 164

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
Q. So long as it's within the required -A. Yes.
Q. I appreciate that.
As long as it's within the retention
period, if I wanted to go and get an electronic
copy of that review, and I had such access, I
could go onto the shared drive and get that
document, correct?
A. The share drive or SharePoint.
Q. The share drive or SharePoint,
depending on the time period, as we discussed
yesterday?
A. Correct.
Q. I think you said that the SharePoint or
share drive were both searchable, correct?
A. Yes.
Q. And I think you said also that some of
the documents that are past the retention period
may go to a different storage site.
Am I incorrect in that?
A. No.
Q. What happens to the documents after the
six-year retention period? Are they destroyed?
A. Yes.

Page 165
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
Q. Has there ever been an audit that
you're familiar with of the Potomac facility's
maintenance of the files?
A. No, I do not know one that happened
with Custody and Management. There probably has
been one that I'm just not aware of.
Q. Do you know of any audit that's been
done of the electronic document management system?
A. Again, same answer.
Q. Is the storage system, the electronic
one, password protected, the shared drive?
A. It's need-to-know access. So, what you
have is you have the computer folks, and, so, if
an individual employee, federal employee, needs to
have access, they will be granted permissions into
whatever portion.
Q. And the computer recognizes that based
on credentials -A. I don't know if the computer recognizes
it. I just know you've got to have access. You
can access the share drive, and you click on a
file, and it won't let you have access.
Q. You're not sure how that works, whether
or not it's based on your credentials or so forth?

Page 166

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
MR. OSWALD: Again, I object on
incorrectly specific questions that are
relying on his personal knowledge, the
personal knowledge of a 30(b)(6) witness.
You can feel free to answer, if you
know.
THE WITNESS: Yes. I mean, you either
have access or you don't have access to the
share drive. Once you have access to the
share drive, you have access to the
components within the shared drive that you
need to have access to. And then within the
components you have access to whatever files
you need.
At any level you can be denied or you
can be granted.
BY MR. ANDALMAN:
Q. One last question about the actual
reports that are generated. Where on the document
would it say which standard is being used, when
you said the 2000, 2008 or 2011 standard?
Is there a specific location on the
document that it would say that?
A. You have to re --

13 (Pages 163 to 166)
TSG Reporting - Worldwide

877-702-9580

 Page 167

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
Q. Let me restate.
We discussed yesterday about the three
different, the primarily three different standards
that are used for the reports.
A. Yes.
Q. Where on the document would it say
which standard is being used for that particular
facility's review?
A. Are you talking about the Three
Twenty-Four?
Q. Let's start with the Three Twenty-Four.
Where would it say it?
A. The PTS 2011 is so new, actually. I
don't know if they have the actual -I mean, you would know, I would know by
looking at the form which standard, because it's
an NDS and the PBOS -- 2000 and 2008 are
different, not in template, but in content.
Off the top of my head, I can't
remember in the header if it says national
detention centers or PBNOS.
Q. Where would it be reflected in the
final report?
A. I don't know if it's in the RA memo. I

Page 168

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
mean, obviously, in advance with the SIS, the
notification that the facility is going to be
reviewed, everybody knows which standards are
going to be reviewed.
Q. But in the final report it may not
be -A. The final report, I don't specifically
recall exactly in which form it outlines.
Q. So let me just clarify.
In the final report it may not be
articulated which standard is being used to
assess -MR. OSWALD: Objection,
mischaracterizes the testimony.
You can feel free to answer.
THE WITNESS: No, it should. I mean,
yeah.
Well, from up until 2008 it would be
all NDS. So there would be no need to say.
Everybody would know, it would be all NDS.
BY MR. ANDALMAN:
Q. Let's take after 2008. After 2008,
after all these rules got in place, how would we
know looking at the report that it's the 2000

Page 169

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
standard or the 2008 standard that's being
applied?
A. It would be in the facility
notification, for sure.
Q. In the report?
A. Yes. It would be in the -- well, no.
The facility notification is the notification that
gets sent out to the facility.
Q. But in the final -A. Yes, so that notification would be part
of the file.
Q. But in the final report it may not be
on the actual document?
MR. OSWALD: Objection,
mischaracterizes the testimony.
THE WITNESS: I haven't looked at all,
you know.
BY MR. ANDALMAN:
Q. You're not aware of a policy stating
that it has to be in the final report?
MR. OSWALD: Objection.
THE WITNESS: No.
MR. ANDALMAN: Let's take a quick
break. I may be able to finish pretty

Page 170

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
quickly.
MR. OSWALD: Okay.
(Brief recess taken.)
BY MR. ANDALMAN:
Q. One piece of housekeeping.
We discussed yesterday, if you recall,
that the U.S. Marshal's has certain facilities
that house ICE detainees, right?
A. Yes.
Q. Does ICE inspect those facilities ever?
A. Yes.
Q. When they inspect it, is it according
to the Three Twenty-Four form?
A. Yes.
Q. Are those stored in the same location,
in the Potomac facility, in the same Potomac
facility as EROs?
A. On the eighth floor, yes.
Q. On the eighth floor, okay.
Is there any meaningful difference
between when ICE inspects a U.S. Marshal facility
and when ERO does for instance, or the Nakamoto
Group does?
Is there any differences between the

14 (Pages 167 to 170)
TSG Reporting - Worldwide

877-702-9580

 Page 171

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
paper form between those used -A. No. Strictly based on the standards.
Q. When CRCL performs a review of the
facility, is the paper file stored in the Potomac
facility?
A. No, that's CRCL.
Q. Where are those -A. I don't even know what their address
is. They work for the department. As a matter of
fact, they just moved. I believe they're at L
Street somewhere.
Q. But presumably they would have a
storage facility?
A. You're asking me to presume.
Q. Okay.
A. I would presume so.
Q. When ODO performs a review of the
facility, are those paper files stored in the
Potomac facility?
A. Within the guidelines of the federal
register, and with regards to management of files,
and as I understand, after 2010 it's electronic
only.
Q. Prior to 2010?

Page 172

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
A. Yes, I mean, I couldn't tell you if
it's within the requirements to maintain.
Q. OIG, when they perform a review, are
those in the same location?
A. Well, again, I have no knowledge of how
they -Q. You said that ODPP may do reviews, but
you weren't familiar with one?
A. No. What I said was ODPP could
potentially do a review, but I don't know of any.
Q. Got it.
A. Or to clarify even further, know of any
that they've done.
Q. When a third-party private entity, like
the Nakamoto Group, performs a review, would the
file be put in the Potomac facility?
A. Yes.
Q. When OPR performs a review, would that
be put into the Potomac facility?
A. No, that would be with OPR.
Q. So essentially it could be with OPR,
with CRCL, or in the Potomac facility, correct?
A. Yes.
MR. ANDALMAN: Let's go off the record.

Page 173
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
(Discussion off the record.)
BY MR. ANDALMAN:
Q. And I think you said that, to the best
of your knowledge, each of these has a shared
drive or a SharePoint to the extent documents are
available, correct?
A. "Each" being who?
Q. CRCL, ODO, OIG, ODPP, and ERO?
A. I can't speak for U.S. Marshals; I
can't speak for OIG, but everybody else within the
department -The Department of Homeland Security
means CRCL, ODPP, ERO, ODO. To the best of my
knowledge, they all have a shared drive.
Now, SharePoint, I don't know.
Q. But to the extent that these reviews,
audits and inspections are in electronic form,
they could be accessed, to the best of your
knowledge, on these shared drivers or on
SharePoint?
A. With regards to ERO and ODO, yes.
Q. We spoke briefly about in response to a
FOIA request how documents are collected and
produced.

Page 174

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
A. Um-hmm.
Q. Once a document request is received by
the FOIA office, how is it communicated by the
ERO?
A. Depending on how the FOIA request comes
in, whether it comes in through ICE FOIA or
department FOIA, those have different tiers of
dissemination.
Once it gets down to ERO FOIA, ERO FOIA
reviews the request, will make a determination on
which programs are involved with the FOIA, or may
have pertinent information with regards to the
FOIA. That will then get tasked out to those
programs.
Q. Once it's tasked out to those programs,
as you said, is there any obstacle in collecting a
document, like a review, audit and inspection?
A. "Obstacle" you mean?
Q. Let me clarify.
If I want to get a document that is at
the Potomac facility, is there any obstacle in
going to the Potomac facility in a number of days
or number of weeks, as you mentioned, and getting
it?

15 (Pages 171 to 174)
TSG Reporting - Worldwide

877-702-9580

 Page 175

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
A. It depends. It depends on who has
access to retrieve that document. There's factors
that come into play there.
Q. Let me restate.
Presuming someone has access to it, are
there any obstacles of physically going and
getting the documents and making appropriate
copies?
A. No.
Q. And my last question is, do you know if
the standard FOIA process was followed in this
FOIA request?
MR. OSWALD: Objection. That's calling
upon personal knowledge and not as a 30(b)(6)
witness.
You can answer, if you know.
THE WITNESS: Yes, I do not know what
the standard practice is.
MR. ANDALMAN: Pass the witness.
MR. OSWALD: I have nothing. We would
reserve signature.
(Whereupon the deposition of Reginald
Nakamoto concluded at 11:14 a.m.)

Page 176

SAKAMOTO
CERTIFICATE OF NOTARY PUBLIC
I, Kim M. Brantley, the officer before
whom the foregoing deposition was taken, do hereby
certify that the witness whose testimony appears
in the foregoing deposition was duly sworn by me;
that the testimony of said witness was taken by me
in stenotype and thereafter reduced to
computerized transcription under my direction;
that said deposition is a true record of the
testimony given by said witness; that I am neither
counsel for, related to, nor employed by any of
the parties to the action in which this deposition
was taken; and, further, that I am not a relative
or employee of any attorney or counsel employed by
the parties hereto, nor financially or otherwise
interested in the outcome of the action.
Notary Public in and for
The District of Columbia
My Commission Expires:
October 14, 2014

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

____________________________
Kim M. Brantley
Date: 2/11/2014

Page 177
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

SAKAMOTO
I N D E X
CONTINUED DEPOSITION OF REGINALD SAKAMOTO
EXAMINATION BY:
PAGE:
Mr. Andalman
122
INDEX OF DEPOSITION EXHIBITS:
SAKAMOTO EXHIBITS:
PAGE:
Exhibit 10.
150

Page 178
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20

SAKAMOTO
ERRATA SHEET FOR THE TRANSCRIPT OF:
Case Name: NATIONAL IMMIGRANT JUSTICE CENTER vs.
UNITED STATES DEPARTMENT OF HOMELAND SECURITY
Dep. Date: JANUARY 30, 2014
Deponent: REGINALD SAKAMOTO

Pg.
___
___
___
___
___
___
___
___
___
___

_____________________
Signature of Deponent

21
22
23
24
25

CORRECTIONS:
Ln. Now Reads Should Read Reason
___ ___________ _____________ ______________
___ ___________ _____________ ______________
___ ___________ _____________ ______________
___ ___________ _____________ ______________
___ ___________ _____________ ______________
___ ___________ _____________ ______________
___ ___________ _____________ ______________
___ ___________ _____________ ______________
___ ___________ _____________ ______________
___ ___________ _____________ ______________

SUBSCRIBED AND SWORN BEFORE ME
THIS____DAY OF_____________, 2014
_______________________
(Notary Public) MY COMMISSION EXPIRES:________

16 (Pages 175 to 178)
TSG Reporting - Worldwide

877-702-9580

 Page 1
A
able (1)
169:25
access (15)
163:20 164:7 165:13
165:16,21,22,23
166:9,9,10,11,13,14
175:3,6
accessed (1)
173:19
accuracy (3)
129:18 132:17 133:18
acronyms (2)
130:8,25
acting (4)
142:15,17,20 144:23
action (14)
130:9,10,22 131:5,8
134:4,20,25 136:20
137:5 151:2 158:18
176:13,17
actual (6)
131:12 139:12 153:9
166:19 167:15
169:14
AD (3)
147:3 150:8,9
added (1)
152:22
additional (1)
152:22
address (1)
171:9
ADP (1)
125:7
ADs (2)
144:11,21
advance (1)
168:2
advanced (1)
125:25
agency (5)
129:12 147:5 148:3
155:18 161:3
agree (1)
137:19
ahead (2)
130:13 149:10
aliens (1)
154:14
allegation (1)
126:21
Andalman (38)
120:6 122:9,22,24
123:2 134:18 135:3
136:25 137:8,21,24

148:5 149:2,9,12
150:14,25 151:4,11
151:14,18,21 152:2
156:2 158:13,24
161:10,22 162:12
166:18 168:22
169:19,24 170:5
172:25 173:3
175:20 177:5
annual (11)
124:4 125:3,13 127:9
138:9 140:13 142:9
146:10 155:6 157:5
157:17
annuals (1)
125:14
answer (7)
124:15 147:23 161:14
165:10 166:6
168:16 175:17
answered (2)
149:7 158:12
apologies (1)
163:6
appear (1)
150:16
APPEARANCES (1)
120:2
appears (1)
176:5
applicable (1)
153:23
applied (2)
155:21 169:3
apply (1)
153:22
appreciate (2)
134:24 164:4
appropriate (1)
175:8
approve (1)
139:24
approved (2)
142:6 149:14
area (1)
134:16
articulate (1)
141:19
articulated (1)
168:12
asked (3)
124:13 149:7 158:12
asking (10)
131:15 133:23 134:23
138:18,19,23
139:15 141:9

152:25 171:15
assess (1)
168:13
assigned (1)
125:4
assistant (12)
142:13,15,19,20,22
142:25 143:2,21
144:24,24 145:2,3
assume (1)
139:24
assuming (1)
150:7
Assurance (2)
150:12,19
as-needed (2)
126:19,25
attorney (1)
176:15
audit (3)
165:2,8 174:18
auditing (3)
127:18,19,19
audits (5)
134:6,7 136:22,23
173:18
authority (3)
142:7,12 147:4
authorized (1)
154:13
available (1)
173:7
average (1)
125:8
aware (3)
148:13 165:7 169:20
a.m (2)
119:5 175:24
B
back (17)
129:24 132:8,22
138:13 139:18
140:6 145:6 158:11
159:18,19,22,25
160:3,20 161:18
162:6,7
background (1)
155:4
based (8)
122:12 125:7,21
149:25 160:24
165:18,25 171:3
beds (1)
141:12
beginning (2)

TSG Reporting - Worldwide

145:22 146:5
behalf (4)
120:5,14 155:18
161:3
believe (9)
123:10 124:3 131:22
133:2 136:6 148:25
153:21 160:13
171:11
best (4)
144:17 173:4,14,19
better (3)
141:12,13 149:3
beyond (1)
160:23
biannual (7)
124:4 125:4,13 127:9
139:5 140:13 142:9
biannuals (1)
125:15
binding (1)
161:3
bit (3)
123:25 133:6 149:3
bottom (1)
155:3
box (1)
153:13
boxes (1)
153:17
Brantley (4)
118:24 119:11 176:3
176:24
break (4)
123:21 151:19,23
169:25
Brief (3)
122:25 151:24 170:4
briefly (1)
173:23
budget (1)
125:23
building (2)
162:25 163:10
business (2)
132:25 148:3
C
C (1)
122:2
cabinets (1)
163:15
call (1)
143:20
called (5)
122:4 130:3,16,20,20

877-702-9580

calling (1)
175:14
capacity (1)
142:16
case (4)
118:6 130:18 135:12
178:3
Center (7)
118:7 121:5 150:11
150:20 162:24
163:4 178:3
centers (1)
167:22
certain (5)
126:5 153:13 163:18
163:19 170:8
CERTIFICATE (1)
176:2
certify (1)
176:5
cetera (3)
140:21 141:13 142:3
change (1)
125:7
changes (8)
139:13,17 141:11,19
152:14 159:3
160:17 161:15
changing (1)
126:2
Charge (1)
136:2
CHARLES (1)
121:7
check (2)
153:17,19
checked (1)
153:13
checklist (1)
157:11
Chicago (2)
120:9,19
chief (15)
144:2,4,6,8,11,13
146:25 147:2
148:19 149:25
150:2,4,8 156:5,12
circumstances (2)
134:3 136:19
citing (1)
136:18
clarification (6)
129:20 132:8 141:8
142:24 160:3,4
clarify (18)
122:12,14 123:23

 Page 2
124:22 125:2
127:25 128:9
130:18 131:9
143:24 150:22
152:9 153:2 159:8
162:9 168:10
172:13 174:20
clear (4)
130:12 145:24 161:6
162:17
clearly (1)
155:16
click (1)
165:22
close (3)
137:8 152:4 159:2
collected (1)
173:24
collecting (1)
174:17
Columbia (2)
119:12 176:19
column (1)
153:18
come (4)
127:24 128:24 129:6
175:4
comes (5)
127:25 143:25 158:3
174:6,7
comments (11)
136:15 138:2,7,12,16
139:4,7 140:21
160:19 161:18,21
Commission (2)
176:20 178:25
communicated (1)
174:4
communication (1)
146:21
complaint (1)
126:20
complete (1)
156:14
completed (1)
156:13
completeness (2)
129:14,17
compliance (4)
128:5 135:24 149:19
155:5
components (3)
153:16 166:12,14
computer (4)
126:11 165:14,18,20
computerized (1)

176:9
concerning (2)
134:3 136:19
concluded (1)
175:24
concurrence (1)
149:25
conduct (3)
128:19,20 148:2
conducted (2)
155:5 158:16
confusion (1)
130:19
content (1)
167:19
context (2)
137:4 163:17
continue (1)
134:11
Continued (3)
118:18 119:8 177:3
contract (3)
133:10,12,16
contractor (1)
135:25
control (1)
138:25
copies (1)
175:9
copy (2)
150:17 164:7
correct (44)
123:5 124:2,5,7 125:5
125:11,13 126:17
126:18,20 127:7
128:3,10,11,22,23
131:2 135:18
139:25 140:8
141:17 144:12,13
145:15,16 147:17
147:20 150:17
151:18 153:10
154:6,9 156:6
159:21 161:23
163:8,9,11,21 164:9
164:14,16 172:23
173:7
corrected (1)
132:9
correction (2)
133:3 160:4
corrections (3)
134:20 136:10 178:8
Corrective (2)
130:9,10
correctly (1)

139:22
COTR (4)
133:7,13,13,15
counsel (5)
122:4,8,10 176:12,15
County (2)
150:11,19
couple (2)
123:22 151:22
course-of-day (1)
132:25
Court (3)
118:2 119:11 161:12
covered (4)
133:24 134:9,17
158:25
Craig (3)
120:15 134:24 137:10
CRCL (7)
126:24 157:6 171:4,7
172:23 173:9,14
CRCO (1)
142:3
create (1)
129:23
created (3)
132:3 137:10 150:5
creation (1)
145:18
Creative (1)
136:10
credentials (2)
165:19,25
criminal (1)
126:21
criminal-based (1)
126:15
criteria (1)
126:5
CSR (1)
118:24
current (1)
143:15
custody (3)
138:24 142:13 165:6
Customs (2)
118:12 121:8
D
D (3)
122:2,3 177:2
DAD (4)
142:20,20,22 143:21
DADs (2)
144:12,23
Daily (2)

TSG Reporting - Worldwide

125:9,10
Date (2)
176:25 178:5
day (2)
157:13 178:23
days (1)
174:23
day-to-day (1)
148:2
DC (2)
118:19 119:10
DCGC (1)
155:6
Dearborn (1)
120:18
Defendants (2)
118:14 120:14
defer (1)
126:22
deficiencies (3)
134:5 136:21 149:24
deficiency (8)
131:9,11,12 140:16
159:5,8,11,15
delegated (1)
142:14
denied (1)
166:16
Dentons (2)
119:9 120:7
Dep (1)
178:5
department (7)
118:10 120:16 171:10
173:12,13 174:8
178:4
depending (2)
164:12 174:6
depends (3)
152:10 175:2,2
Deponent (2)
178:6,21
deposition (12)
118:18 119:8 122:11
134:2 150:12
175:23 176:4,6,10
176:13 177:3,7
deputy (8)
142:14,17,22 143:2
144:6,24 145:2
147:3
desk (1)
152:8
destroyed (1)
164:24
detain (1)

877-702-9580

154:14
detainees (1)
170:9
detention (8)
128:4 150:11,18,20
154:12 155:4,5
167:22
determination (1)
174:11
determines (1)
132:16
developed (1)
126:9
development (2)
134:3 136:19
DFEG (1)
154:25
dictated (2)
157:15,18
differ (1)
130:25
difference (1)
170:21
differences (1)
170:25
different (10)
123:15 131:16 133:6
142:2,8 164:20
167:4,4,19 174:8
difficult (1)
138:21
direction (1)
176:9
director (13)
142:13,15,17,18,19
142:21,22,25 143:2
144:24,25 145:2,3
directors (1)
143:21
disclosures (1)
151:17
discovers (1)
141:16
discrepancies (1)
129:20
discussed (5)
143:9 162:19 164:12
167:3 170:7
discussing (4)
134:19,20 137:25
139:19
Discussion (2)
158:23 173:2
disk (1)
151:6
dissemination (1)

 Page 3
174:9
distinction (1)
131:2
District (4)
118:2,3 119:12
176:19
DIVISION (1)
118:4
docket (1)
132:7
document (38)
126:5,10 129:23
130:3 131:5,17
132:3,10,20 133:3
136:7,16 142:5
143:3 150:25
151:14 152:15,18
153:3,3,10 154:3,21
154:22 155:2,3
156:4 162:2 164:9
165:9 166:20,24
167:7 169:14 174:3
174:18,21 175:3
documentation (2)
122:19,20
documents (19)
128:7 129:6 134:15
134:21 137:10,18
137:20 138:2,23
145:14,19 146:15
146:16 155:15
164:19,23 173:6,24
175:8
doing (1)
155:24
drafted (1)
156:18
drive (15)
120:8 123:15,17
146:17 164:8,10,11
164:16 165:12,22
166:10,11,12 173:6
173:15
drivers (1)
173:20
DRO (5)
154:20,21,22,23
155:4
DSCU (35)
127:24,25 128:24
129:6 132:5,6,15
133:12,18 135:5,10
136:15 140:16
141:16 142:6 144:2
144:4,7,11 145:6
146:6,12,24 148:19

149:14,22,22 150:4
156:4,10 157:24
158:19 160:2
161:21 162:5
DSCU's (1)
139:20
duly (2)
122:5 176:6
D.C (1)
163:5
E
E (4)
122:2,2,3 177:2
earlier (4)
127:8 139:9,19
145:14
EASTERN (1)
118:4
editorial (1)
159:10
Eight (3)
163:12,13,20
eighth (2)
170:19,20
eighty (1)
152:8
eighty-page (1)
156:3
either (3)
126:16 127:5 166:8
electric (2)
122:16,16
electronic (19)
122:17,18,19,20
123:7,13,16 143:4
144:19 145:15,18
146:3 147:8 154:3
164:6 165:9,11
171:23 173:18
element (1)
146:21
eleven (1)
152:9
employed (2)
176:12,15
employee (5)
136:3,8 165:15,15
176:15
Enforcement (2)
118:13 121:8
ensures (1)
128:2
entire (5)
134:16 148:24 149:8
162:17 163:7

entities (2)
124:14 155:24
entity (1)
172:15
ERIC (1)
120:6
ERO (14)
124:24 127:5,6 136:3
136:4,7 142:3
170:23 173:9,14,22
174:5,10,10
EROs (3)
123:16 157:16 170:18
ERRATA (1)
178:2
ESQUIRE (4)
120:6,15 121:4,7
essentially (1)
172:22
et (3)
140:21 141:13 142:3
eventually (1)
138:25
everybody (3)
168:4,21 173:11
exactly (1)
168:9
EXAMINATION (2)
122:8 177:4
examined (1)
122:6
example (1)
154:5
executive (4)
124:19 157:3,7,14
exhibit (6)
150:13,16 152:3
154:6,9 177:9
EXHIBITS (2)
177:7,8
expert (1)
138:15
expires (3)
147:15 176:20 178:25
explain (2)
146:8 148:22
extent (3)
123:15 173:6,17
E-mail (6)
133:6 141:8 159:4,18
160:7,9
F
facilities (8)
125:19,21,25 127:20
128:10,14 170:8,11

TSG Reporting - Worldwide

facility (40)
125:4,12 126:6 129:3
131:7,14 132:2
133:20 135:17
141:6,8 142:9,9,10
143:8 150:18
154:14,20,21
159:11 163:8,19,20
168:3 169:4,8,9
170:17,18,22 171:5
171:6,14,19,20
172:17,20,23
174:22,23
facility's (2)
165:3 167:9
fact (2)
133:7 171:11
factors (1)
175:3
facts (2)
134:2 136:18
fair (4)
127:3 136:13 149:9
155:19
familiar (3)
126:13 165:3 172:9
federal (5)
133:9 143:11 147:11
165:15 171:21
feel (4)
122:13 147:22 166:6
168:16
field (12)
128:14,15,15,19,20
129:24 132:23
133:8 140:7 141:20
154:13 159:18
figure (4)
123:24 137:9 146:2
152:21
file (37)
143:5,6,8,10,12,14,18
143:19 144:15
145:4,21,22 146:11
146:13,18 147:8,19
152:16,20 156:12
159:7 160:8,10,12
162:10,11,14,16,18
163:7,10,15,21
165:23 169:12
171:5 172:17
filed (1)
163:10
files (8)
147:10,10,13,13
165:4 166:14

877-702-9580

171:19,22
filing (2)
145:6,7
fill (4)
128:12,21 159:15,19
filled (1)
159:6
final (17)
129:12 147:5 148:17
148:20 149:5,15
156:15 157:13
158:3,19 167:24
168:6,8,11 169:10
169:13,21
finalized (1)
149:13
financially (1)
176:16
find (1)
155:21
finish (3)
138:20 141:15 169:25
first (4)
122:5 126:21 154:16
154:18
five-minute (1)
151:22
floor (4)
163:11,20 170:19,20
FOIA (13)
151:12 163:17 173:24
174:4,6,7,8,10,10
174:12,14 175:12
175:13
folks (1)
165:14
followed (1)
175:12
follows (1)
122:7
follow-up (1)
137:4
foregoing (2)
176:4,6
forget (1)
141:25
form (25)
123:4 127:15,17
128:12,21,25
131:17 132:4,18
135:6 141:23 143:3
148:10 152:7 158:4
158:4,5 160:7,20
161:18 167:17
168:9 170:14 171:2
173:18

 Page 4
formality (1)
133:14
formalize (1)
136:15
format (7)
124:18 143:4,4
144:19 145:12,15
152:10
formatting (1)
152:14
formed (1)
157:23
forms (2)
160:14 161:13
formulated (1)
156:5
forth (1)
165:25
free (5)
122:13 147:23 157:11
166:6 168:16
front (1)
156:17
further (6)
122:6 129:21 137:6
146:20 172:13
176:14
G
G (2)
122:2,3
gather (1)
155:10
generally (2)
135:22 152:7
generate (2)
132:20 147:2
generated (3)
134:21,22 166:20
generation (1)
123:25
getting (3)
155:13 174:24 175:8
give (3)
125:25 132:12 134:12
given (1)
176:11
giving (1)
161:5
Glades (2)
150:11,19
go (30)
122:24 125:12 130:13
132:8 133:13,14
137:6,20 142:6
144:5 145:5 146:12

146:17,25,25 147:3
149:10 150:8
157:12 158:21
159:19,22,25 162:6
162:7 163:19 164:6
164:8,20 172:25
goes (16)
139:24 143:20,22
144:7,21 145:6
149:4,22,22,25
150:9 154:4 155:14
156:9,12 158:18
going (16)
123:3 128:7 131:23
133:22 134:10,15
137:6 138:13 151:6
156:24 158:11
160:22 168:3,5
174:23 175:7
good (1)
134:18
government (1)
133:9
granted (2)
165:16 166:17
grounds (1)
160:22
group (10)
124:8,11 127:5,6,14
137:3 150:18
158:18 170:24
172:16
Group's (1)
124:3
guess (1)
131:15
guidance (1)
138:14
guidelines (1)
171:21
H
hand (1)
143:22
handed (2)
150:15 154:8
handwritten (3)
160:19 161:17,20
happen (1)
161:25
happened (2)
146:14 165:5
happens (2)
132:4 164:23
head (1)
167:20

header (1)
167:21
headquarters (4)
133:8 135:10 146:21
158:19
held (1)
119:9
helpful (3)
132:13 136:13 153:25
hereto (1)
176:16
hold (1)
152:9
Homeland (4)
118:11 120:17 173:13
178:4
hopefully (1)
141:22
house (1)
170:9
housekeeping (1)
170:6
I
ICE (8)
121:8 138:25,25
162:24 170:9,11,22
174:7
identification (1)
150:13
identified (2)
134:5 136:21
II (1)
118:9
Illinois (3)
118:3 120:9,19
Immigrant (3)
118:6 121:5 178:3
Immigration (2)
118:12 121:8
implementation (2)
134:4 136:20
improper (1)
131:23
improve (2)
131:6,7
inaccurate (1)
129:25
include (2)
143:14 149:17
included (1)
160:7
incomplete (2)
129:25 131:20
incorporated (3)
134:7 136:23 155:8

TSG Reporting - Worldwide

incorrect (1)
164:21
incorrectly (1)
166:3
INDEX (1)
177:7
indicating (1)
139:14
individual (3)
155:17 160:25 165:15
information (3)
155:10 156:22 174:13
initially (1)
153:2
inspect (2)
170:11,13
inspecting (1)
131:24
inspection (17)
129:2,15,16 131:6
139:21 146:10,11
146:13,14 148:17
150:17,18 157:17
158:17 160:18
161:16 174:18
inspections (9)
124:2,4,6,7 134:6,8
136:22,24 173:18
Inspector (2)
135:24 136:2
inspects (1)
170:22
instance (5)
123:17 135:2 148:9
159:16 170:23
Instructor's (1)
149:19
intact (1)
144:15
interested (1)
176:17
internal (1)
124:24
Internet (2)
150:23 151:10
interruption (1)
122:25
investigation (2)
128:8 129:2
involved (2)
133:7 174:12
issue (3)
122:11 131:9 158:19
issued (2)
129:10 158:10

877-702-9580

J
January (3)
118:20 119:4 178:5
Job (1)
118:25
July (1)
155:6
Justice (3)
118:6 121:5 178:3
K
K (2)
119:9 122:3
keep (1)
122:16
kept (4)
122:20 144:15 147:19
159:6
Kim (4)
118:24 119:10 176:3
176:24
kind (2)
138:20 139:20
knot (1)
159:2
know (46)
123:11,12,13 129:2
130:8,17 133:2
134:13,16 135:10
136:6 137:11,19
138:14,17 143:19
150:6 151:5 153:5,6
153:13 154:23
155:9,9,16 158:21
161:5 165:5,8,20,21
166:7 167:15,16,16
167:25 168:21,25
169:18 171:9
172:11,13 173:16
175:11,17,18
knowing (1)
137:10
knowledge (12)
144:17 155:17 160:25
161:2,9 166:4,5
172:6 173:5,15,20
175:15
knows (1)
168:4
L
L (2)
122:3 171:11
larger (1)
152:19
LCI (8)

 Page 5
135:21,22,23,23
136:4,7 156:19,21
lead (7)
135:11,19,23 149:19
156:20 159:25
160:3
leeway (2)
134:13 161:6
let's (13)
122:24 141:22 143:20
148:16 151:22
158:21 159:4 160:6
163:17 167:12
168:23 169:24
172:25
level (4)
143:25 150:8,9
166:16
line (9)
123:3 146:19,19
149:23,23 157:12
157:13 159:10,15
little (4)
123:25 133:6 146:7
149:3
living (1)
125:6
LLP (1)
119:9
Ln (1)
178:9
location (4)
162:18 166:23 170:16
172:5
long (5)
143:10 152:6 163:24
164:2,5
looked (1)
169:17
looking (2)
167:17 168:25
looks (1)
155:10
M
M (5)
118:24 119:10 122:3
176:3,24
maintain (2)
147:12 172:3
maintained (2)
147:10,11
maintaining (1)
143:10
maintenance (2)
122:15 165:4

making (3)
139:13 151:16 175:8
management (5)
142:14 150:17 165:6
165:9 171:22
manual (1)
157:19
marked (2)
150:12,15
Marshal (1)
170:22
Marshals (1)
173:10
Marshal's (1)
170:8
Maryland (2)
162:19 163:2
matching (1)
155:23
matrix (3)
125:21 126:4,9
matter (3)
138:15 141:6 171:10
mean (27)
123:9 125:24 129:19
130:14 133:5
134:12 135:9,20
139:11,16 143:7
145:8,24 150:6
154:7 157:11
159:13,14 161:20
161:25 162:7 166:8
167:16 168:2,17
172:2 174:19
meaningful (2)
137:13 170:21
means (2)
148:6 173:14
meat (1)
158:9
media (2)
152:18,22
medical (1)
141:13
meet (1)
158:7
meets (1)
158:7
megabytes (1)
152:19
memo (3)
147:2,4 167:25
memorialized (5)
137:12 138:3,8 139:4
140:22
memorializing (1)

132:21
mentioned (2)
154:4 174:24
metadata (1)
153:6
MGT (1)
136:10
Miami's (1)
154:13
middle (1)
133:11
minutes (1)
151:22
mischaracterizes (3)
147:22 168:15 169:16
misplaced (1)
148:14
missing (1)
132:16
mix (1)
123:7
mixing (1)
155:23
modifications (5)
137:11 138:12 139:4
139:6 141:20
modify (1)
140:17
move (2)
141:22 152:3
moved (1)
171:11
movement (1)
154:2
MURRAY (3)
121:4 122:17 162:10
N
N (3)
122:2,3 177:2
Nakamoto (17)
124:3,8,11,21 125:17
127:5,6,14,22 129:5
133:10 136:5,9
138:14 170:23
172:16 175:24
Nakamoto's (1)
133:6
Name (1)
178:3
narrative (2)
156:16,25
narrow (2)
137:21,22
national (5)
118:6 121:5 155:5

TSG Reporting - Worldwide

167:21 178:3
NDS (3)
167:18 168:20,21
necessarily (1)
156:24
need (13)
129:20 132:8 138:3,8
140:17,21 141:12
141:12 159:8,19
166:13,15 168:20
needed (1)
127:2
needs (6)
132:9 143:18 146:20
147:19 157:23
165:15
need-to-know (1)
165:13
neither (1)
176:11
never (2)
135:16 155:20
new (3)
146:15,16 167:14
Nine (1)
163:11
nineteen (1)
133:25
nonsubstantive (3)
141:11,21 159:14
North (2)
162:24 163:4
NORTHERN (1)
118:3
Notary (5)
119:11 122:6 176:2
176:18 178:25
noted (1)
161:10
notes (3)
162:5,10,11
notice (2)
126:2 133:25
notices (1)
140:16
notification (5)
168:3 169:5,8,8,11
number (3)
154:9 174:23,24
numeric (1)
158:4
NW (1)
119:10
N/A (1)
153:21

877-702-9580

O
O (3)
122:2,3,3
object (7)
133:22 136:17 148:23
149:6 155:12
160:22 166:2
Objection (5)
147:21 168:14 169:15
169:22 175:14
obstacle (3)
174:17,19,22
obstacles (1)
175:7
obviously (6)
123:9 125:23 144:4
152:13 162:16
168:2
occurred (1)
153:7
October (1)
176:21
ODO (16)
122:15 123:9,10
125:12,14,17,18
126:7 142:2 155:2
156:25 157:6
171:18 173:9,14,22
ODPP (5)
126:8 172:8,10 173:9
173:14
ODR (1)
126:22
office (16)
128:14,15,16,19,20
129:24 132:23
133:8,9 140:7
141:20 154:12,13
154:24 159:18
174:4
officer (15)
132:7,7 133:13 144:9
146:6,12 149:22
156:10 158:16
160:2,2,9 161:21
162:5 176:3
officers (1)
135:10
officer's (2)
133:16 150:2
official (2)
160:16 161:14
Oh (1)
139:16
OIG (5)
126:15,22 172:4

 Page 6
173:9,11
okay (23)
124:23 125:22 127:23
129:8 132:11 133:4
135:13 137:23
139:16 141:10,14
144:3 145:10,23
147:14 151:3,13
152:12,24 162:4
170:3,20 171:16
OLEAN (1)
121:7
once (7)
147:7 149:13 150:4
166:10 174:3,10,16
ones (5)
123:16 124:4 127:4
141:25 142:3
onsite (2)
133:20 135:6
operating (13)
132:22 136:14 138:7
138:11 139:3
140:20 141:18
143:17 147:18,24
148:6 157:22,25
Operations (1)
154:13
opposed (2)
151:9 152:20
OPR (4)
154:24 172:19,21,22
order (1)
134:17
originally (1)
144:9
ORSA (21)
124:4,21,24 125:4
127:11,12,13,14,18
127:20 128:9,15,17
128:18,19 132:24
138:4 140:11,12,13
142:8
OSWALD (27)
120:15 122:18 133:22
136:17 137:2,17,23
147:21 148:23
149:6,10 150:22
151:3,5,13,16
155:12 158:12,21
160:21 166:2
168:14 169:15,22
170:3 175:14,21
outcome (1)
176:17
outlines (2)

131:6 168:9
P
P (1)
122:2
packaged (2)
146:25 149:24
page (4)
149:18 154:11 177:4
177:8
pages (4)
152:7,8,14,22
paper (15)
123:4,8 143:4 144:18
144:20 145:12
146:3 147:10,13
160:20 161:18
163:10 171:2,5,19
paragraph (3)
136:18 154:16,18
paragraphs (1)
158:6
part (1)
169:11
particular (2)
132:2 167:8
parties (3)
136:11 176:13,16
parts (1)
134:14
Pass (1)
175:20
password (1)
165:12
PBN (1)
152:8
PBNOS (1)
167:22
PBOS (1)
167:18
PCA (1)
145:11
PCN (2)
162:22,23
PDF (2)
152:13 153:4
perform (3)
128:16 129:21 172:4
performed (2)
127:13 146:23
performing (1)
128:7
performs (4)
171:4,18 172:16,19
period (6)
135:8 163:25 164:6

164:12,19,24
permissions (1)
165:16
person (1)
133:11
personal (5)
161:2,8 166:4,5
175:15
perspective (1)
137:15
pertinent (1)
174:13
Pg (1)
178:9
physical (3)
128:6 143:10 154:3
physically (2)
133:19 175:7
piece (1)
170:6
place (2)
148:2 168:24
placed (1)
163:7
Plaintiff (4)
118:8 120:5 122:4,8
plan (10)
130:9,10,21 131:5,8
134:4,19,25 136:20
157:25
play (1)
175:4
POA (13)
130:16,20,21,24
139:8 141:3 143:13
146:19 148:11,14
156:22 158:10,15
point (8)
129:9 130:16 132:7
133:23 134:19
141:23 154:4
158:16
policy (8)
139:16 148:3 157:15
157:18,19,21 158:2
169:20
population (2)
125:9,10
portion (1)
165:17
possession (1)
138:24
possible (2)
126:2 148:9
posted (1)
151:9

TSG Reporting - Worldwide

potential (1)
126:21
potentially (1)
172:11
Potomac (14)
162:24 163:4,8,19
165:3 170:17,17
171:5,20 172:17,20
172:23 174:22,23
practice (1)
175:19
precision (1)
133:19
predecessor (1)
155:2
preparation (1)
156:15
prepared (4)
144:14 147:2 158:19
158:20
present (2)
121:2 123:13
presumably (1)
171:13
presume (3)
123:3 171:15,17
Presuming (1)
175:6
pretty (1)
169:25
previous (3)
143:9,14 146:10
Previously (1)
130:14
primarily (2)
124:17 167:4
prints (3)
150:7,8 160:9
prior (3)
122:10 123:4 171:25
private (1)
172:15
probably (1)
165:6
problem (4)
131:16 140:3,17
141:16
procedure (16)
132:22 136:14 138:7
138:11 139:3
140:20 141:2,19
143:17 147:18,24
148:6,25 149:8
157:16,22
procedures (2)
127:21 142:2

877-702-9580

process (11)
131:23 132:17 134:14
139:25 144:16
146:4,6 147:17
154:14 157:17
175:12
produced (4)
150:24 151:2,5
173:25
Professional (1)
154:25
program (1)
126:11
programs (3)
174:12,15,16
properly (1)
128:2
protected (1)
165:12
protective (1)
134:17
protocol (8)
136:15 137:25 138:6
138:12 139:3
141:18 143:18
147:18
PTS (1)
167:14
Public (5)
119:11 122:6 176:2
176:18 178:25
pull (3)
146:12 150:23 163:21
put (7)
146:17 147:8 153:3
160:11 162:6
172:17,20
puts (2)
148:20 160:10
Q
qualitative (1)
158:5
Quality (2)
150:11,19
question (15)
127:12 131:16 132:12
132:15 135:4
137:16 138:20,22
139:2 140:9 161:11
161:12,17 166:19
175:11
questions (9)
132:17 133:24 134:9
137:3 155:13
160:24 161:4,7

 Page 7
166:3
quick (1)
169:24
quickly (2)
141:15 170:2
R
R (2)
122:2,3
RA (10)
129:9,11 147:2,3
150:5,7,8 158:6,20
167:25
ran (2)
148:24 149:7
random (1)
127:19
rating (9)
129:12 146:24 147:5
149:16,20 153:12
156:15 158:3,20
read (3)
138:21 159:10 178:9
Reads (1)
178:9
ready (1)
144:14
real (1)
141:15
really (1)
161:7
reason (2)
131:22 178:9
recall (2)
168:9 170:7
receive (1)
142:18
received (2)
156:4 174:3
receives (2)
143:2 158:17
recess (2)
151:24 170:4
recognizes (2)
165:18,20
recommendation (1)
150:2
recommendations (1)
140:21
recommended (1)
149:20
record (7)
122:24 158:22,23
160:21 172:25
173:2 176:10
records (1)

122:15
redlined (2)
160:15 161:13
reduced (1)
176:8
reflected (1)
167:23
regards (12)
124:14 131:13 138:4
138:7 139:12 148:3
152:4 158:2 159:3
171:22 173:22
174:13
Reginald (5)
118:18 119:8 175:23
177:3 178:6
register (2)
147:12 171:22
regular (2)
127:4,19
regulations (1)
143:11
related (1)
176:12
relative (1)
176:14
relying (1)
166:4
remedial (3)
156:22 158:14,18
remedy (2)
134:4 136:20
remember (1)
167:21
Removal (1)
154:12
report (16)
133:19 148:18,20
149:5,16 150:18
156:5,16 167:24
168:6,8,11,25 169:6
169:13,21
Reported (1)
118:23
Reporter (2)
119:11 161:12
reports (3)
155:20 166:20 167:5
representative (2)
133:12,17
request (5)
173:24 174:3,6,11
175:13
required (2)
146:19 164:2
requirement (1)

160:11
requirements (2)
147:12 172:3
reread (1)
161:11
reserve (1)
175:22
respect (1)
122:15
response (1)
173:23
Responsibility (1)
154:25
restate (5)
132:13 135:4 138:22
167:2 175:5
restraints (1)
125:23
retention (4)
163:25 164:5,19,24
retrieve (1)
175:3
review (35)
125:13 126:6,25
128:24 129:7,13
136:2 139:20 142:7
142:12 143:15
146:18,22 147:4
150:3,5,12,19
155:22 156:20,25
159:22,24 160:20
161:19 163:18
164:7 167:9 171:4
171:18 172:4,11,16
172:19 174:18
reviewed (2)
168:4,5
reviewer (2)
135:11,19
reviewing (14)
128:6 129:13,14,15
129:16,17,18
131:24 132:5
133:18,20 135:5,14
162:8
reviews (23)
125:19 127:4,4,20
128:2 131:12 134:5
134:7 136:21,23
137:5 138:9 139:5
140:14 141:25
143:9,15 155:6,24
157:5 172:8 173:17
174:11
RIC (3)
135:22 136:2 156:21

TSG Reporting - Worldwide

right (9)
124:10,12 140:7
148:7 151:16 152:8
153:8 156:11 170:9
right-hand (1)
153:18
risk-based (3)
125:21 126:4,9
road (1)
137:9
roughly (1)
158:6
ROYCE (1)
121:4
rules (1)
168:24
S
S (2)
122:2,3
Sakamoto (68)
118:18 119:1,9 120:1
121:1 122:1,13
123:1 124:1 125:1
126:1 127:1 128:1
129:1 130:1 131:1
132:1 133:1 134:1
135:1 136:1 137:1
138:1 139:1 140:1
141:1 142:1 143:1
144:1 145:1 146:1
147:1 148:1 149:1
150:1,13 151:1
152:1 153:1 154:1,8
155:1 156:1 157:1
158:1 159:1 160:1
161:1 162:1 163:1
164:1 165:1 166:1
167:1 168:1 169:1
170:1 171:1 172:1
173:1 174:1 175:1
176:1 177:1,3,8
178:1,6
satisfied (2)
146:24 150:4
saved (4)
152:11,23 153:4,7
saying (6)
129:24 137:18 157:23
159:5,19 161:25
says (6)
139:17 154:12 155:3
155:4 158:7 167:21
scan (1)
162:2
scanned (2)

877-702-9580

146:16 147:8
schedule (1)
127:11
scope (1)
160:23
searchable (1)
164:16
second (2)
151:20 158:22
second-level (1)
139:20
secured (1)
163:13
Security (4)
118:11 120:17 173:13
178:4
see (9)
135:16 144:4 154:5
154:16,18 156:17
156:19,24,25
seen (10)
126:12 130:17,19
136:7 144:20
155:20 157:25
160:16 161:14,24
self-assessment (3)
128:10,18,21
self-inspection (1)
124:25
send (3)
129:24 140:6 160:2
sending (1)
132:22
sense (1)
162:3
sent (4)
160:20 161:18 162:18
169:9
separate (4)
128:8 129:2 132:20
148:10
separately (1)
133:21
series (2)
133:24 137:3
server (1)
123:19
servers (1)
123:20
set (4)
125:20,24 127:11
143:19
share (9)
123:15,17 146:17
164:10,11,16
165:22 166:10,11

 Page 8
shared (6)
164:8 165:12 166:12
173:5,15,20
SharePoint (6)
164:10,11,15 173:6
173:16,21
SHEET (1)
178:2
signature (2)
175:22 178:21
signed (3)
147:4,7 150:9
SIS (3)
149:18 156:19 168:2
site (1)
164:20
situation (1)
148:13
six-year (1)
164:24
slightly (1)
131:15
SOP (2)
148:6 157:21
SOPs (1)
147:25
sorry (1)
135:21
sort (2)
137:13 148:20
sorts (1)
138:2
South (1)
120:8
speak (3)
160:25 173:10,11
speaking (2)
138:13 155:18
specific (5)
155:13 161:4,7 166:3
166:23
specifically (6)
134:16,23 138:23
155:14,21 168:8
spirit (1)
137:19
spoke (3)
145:14 154:2 173:23
staff (4)
133:9 156:10 158:16
160:2
stand (1)
130:7
standard (23)
130:21 132:22 136:14
138:6,11 139:3

140:20 141:18
143:17 147:18
148:6 153:15
157:22,24 166:21
166:22 167:8,17
168:12 169:2,2
175:12,19
standards (8)
128:4 155:4 158:7,8,9
167:4 168:4 171:3
start (3)
138:4 151:21 167:12
stated (2)
122:10 127:8
states (6)
118:2,10,12 120:16
126:5 178:4
stating (1)
169:20
status (1)
125:3
stenotype (1)
176:8
step (2)
139:18,25
steps (2)
149:15 158:14
storage (3)
164:20 165:11 171:14
stored (6)
145:9,12 162:21
170:16 171:5,19
Street (3)
119:9 120:18 171:12
Strictly (1)
171:3
struck (1)
133:25
stuff (2)
151:8,9
subcomponents (1)
153:17
subject (1)
138:15
SUBSCRIBED (1)
178:22
substantive (4)
131:11,18 141:5,7
Suite (1)
119:10
summaries (1)
157:7
summary (3)
124:19 157:3,14
sure (7)
123:12,20 144:13

147:25 151:7
165:24 169:5
sworn (3)
122:5 176:6 178:22
system (4)
126:16 153:12 165:9
165:11
S-I-S (3)
149:18,18,19
T
T (1)
122:3
take (8)
139:18 145:17 149:14
151:22 157:11
160:6 168:23
169:24
taken (6)
151:24 158:14 170:4
176:4,7,14
takes (1)
148:19
talk (1)
148:16
talked (1)
123:24
talking (9)
130:15 134:25 139:11
145:20,21 159:9,13
161:8 167:10
tasked (2)
174:14,16
team (6)
156:20 159:23,24
160:3,20 161:19
technical (2)
133:12,16
tell (2)
136:25 172:2
template (2)
152:15 167:19
terms (1)
134:14
testified (2)
122:6 139:9
testimony (7)
122:12 147:22 168:15
169:16 176:5,7,11
thank (2)
142:24 159:14
thing (1)
144:5
things (7)
123:22 125:24 152:4
152:19 155:16

TSG Reporting - Worldwide

156:23 159:10
think (6)
134:15 148:19 156:4
164:15,18 173:4
third (1)
154:11
third-party (1)
172:15
thought (2)
139:9,11
thoughts (1)
132:21
three (57)
124:6,7,15,16,17
127:14,16 128:12
128:21,25 129:5
131:17 132:4,18
135:6 136:16 138:3
138:8 139:6,7,12,13
139:17 141:23,24
142:5 143:2,12
146:18 148:10,16
149:4,13,17,20,23
152:5,6 153:9 154:3
156:3,9 157:5,10,12
157:16 158:17
159:3,6 160:16
161:15 162:15
167:3,4,10,12
170:14
Thursday (2)
118:20 119:4
tier (1)
126:21
tiers (1)
174:8
time (6)
119:5 126:20 135:8
142:4 160:6 164:12
timeframe (2)
130:15 147:15
times (1)
159:17
timetable (2)
125:18 126:16
timetable-based (2)
126:25 127:4
today (5)
135:12,13,14,18
160:24
top (1)
167:20
track (2)
160:17 161:15
track-changed (2)
160:14 161:13

877-702-9580

transcript (2)
138:21 178:2
transcription (1)
176:9
transition (1)
153:7
transmission (1)
145:18
transmitted (1)
151:15
true (2)
150:16 176:10
try (5)
125:24 137:20,21,22
152:21
trying (5)
123:24 134:12 137:9
137:14 146:2
turn (1)
154:11
turned (1)
148:17
Twenty-Four (55)
124:6,7,15,16,18
127:15,16 128:13
128:22,25 129:5
131:18 132:5,18
135:6 136:16 138:3
138:8 139:6,7,12,13
139:17 141:23,24
142:5 143:3,12
146:18 148:10,17
149:4,14,17,21,23
152:5,6 153:9 154:3
156:3,9 157:5,10,12
157:16 158:17
159:4,6 160:17
161:15 162:16
167:11,12 170:14
two (3)
131:3 152:4 158:6
type (3)
124:19 137:15 157:11
types (2)
156:22 157:6
U
UCAP (10)
130:4,20,24 131:8
139:8 141:4 143:13
146:19 156:22
158:15
ultimately (4)
138:24 162:18,21
163:7
Um-hmm (9)

 Page 9
130:6 131:19,21,25
132:19 144:22
154:15 155:7 174:2
unclear (1)
146:7
underlying (2)
135:6 139:21
understand (11)
125:3 134:13 137:2
137:14,17 139:10
139:11 147:16
149:3 161:5 171:23
understanding (5)
126:8 129:21 132:6
139:22 141:17
uniform (1)
130:10
unit (3)
147:25,25 150:7
United (5)
118:2,10,11 120:16
178:4
Units (1)
155:5
Unit's (2)
150:17 155:6
use (11)
124:14,16,17 127:14
127:16 142:2
154:14 155:10
157:10,10,16
usually (1)
124:18
U-C-A-P (1)
130:5
U.S (4)
121:8 170:8,22
173:10
V
view (1)
134:10
Vol (1)
118:9
vs (2)
118:9 178:3
W
Wacker (1)
120:8
want (10)
138:15 145:25 148:21
148:23 149:2 151:7
152:3 159:2 161:6
174:21
wanted (5)

122:14 123:23 163:18
163:23 164:6
Washington (3)
118:19 119:10 163:5
way (9)
129:4 130:25 131:7,9
137:13 147:19
152:23 153:14
159:5
ways (1)
131:6
Website (1)
151:12
week (1)
146:14
weeks (1)
174:24
weren't (1)
172:9
we'll (2)
138:4 141:25
we're (11)
130:15 133:23 134:10
134:15 137:3,6,8
143:10 145:20
155:12 158:11
witness (22)
122:4,19 137:15
147:24 151:19
155:14,20 160:23
161:9,20 162:11
166:5,8 168:17
169:17,23 175:16
175:18,20 176:5,7
176:11
word (2)
153:3 160:5
work (3)
123:9 148:21 171:10
working (2)
126:7,8
works (1)
165:24
worksheet (6)
140:19 141:17 149:4
153:10,12 154:5
wouldn't (2)
135:11 153:6
write (1)
159:18
written (3)
157:20,23 160:7
wrong (2)
124:2 147:17
wrote (1)
162:15

X
X (1)
177:2
Y
yeah (1)
168:18
year (2)
146:11 163:18
years (2)
130:14 143:15
year's (2)
143:15 146:13
yesterday (14)
122:12 123:22 124:13
125:20 135:22
143:9 145:21 146:9
157:7,9 162:19
164:13 167:3 170:7
1
1:12-cv-5358 (1)
118:7
10 (5)
150:13,16 154:6,9
177:9
11:14 (1)
175:24
112 (1)
159:16
122 (1)
177:5
1301 (1)
119:9
14 (1)
176:21
150 (1)
177:9
19 (1)
136:18

2012 (1)
135:9
2014 (5)
118:20 119:4 176:21
178:5,23
219 (1)
120:18
233 (1)
120:8
3
30 (3)
118:20 119:4 178:5
30(b)(6) (8)
118:18 119:8 155:13
155:19 160:23
161:9 166:5 175:15
6
600 (1)
119:10
60604 (1)
120:19
60606 (1)
120:9
7
70293 (1)
118:25
9
9:39 (1)
119:5

2
2/11/2014 (1)
176:25
2000 (3)
166:22 167:18 168:25
2007 (3)
130:15 135:8,10
2008 (7)
155:6 166:22 167:18
168:19,23,23 169:2
2010 (6)
122:21,23 123:4,13
171:23,25
2011 (2)
166:22 167:14

TSG Reporting - Worldwide

877-702-9580