EFTA00110002

1 2 3 4 DIGITALLY RECORDED 5 SWORN STATEMENT 6 OF 7 8 9 OIG CASE #: 10 2019-010614 11 12 13 14 15 16 17 18 DEPARTMENT OF JUSTICE 19 OFFICE OF THE INSPECTOR GENERAL 20 DECEMBER 2, 2021 21 22 23 24 25 RESOLUTE DOCUMENTATION SERVICES 28632 Roadside Drive, Suite 285 Agoura Hills, CA 91301 Phone: EFTA00110002 LIMITED OFFICIAL USE 1 APPEARANCES: 2 3 OFFICE OF THE INSPECTOR GENERAL 4 BY: 5 BY: 6 7 8 WITNESS: 9 10 11 12 OTHER APPEARANCES: 13 NONE 14 15 16 17 18 19 20 21 22 23 24 25 EFTA00110003 LIMITED OFFICIAL USE 3 1 MR. : All right. The recorder 2 is on. There is also going to be - I'm just 3 going to go over, like, a list of - it's kind 4 of, like, an introduction, and just kind of a 5 preamble into what we are going to be 6 discussing, and who you are. It's going to 7 sound very scripted, and that's because it 8 pretty much is. But you are there still. 9 Correct? 10 MS. : Yes. Mm-hmm. 11 MR. : Perfect. All right. So, 12 my name is and I am a Senior 13 Special Agent with the U.S. Department of 14 Justice, Office of the Inspector General. New 15 York Field Office. Boston Area Office. This 16 interview with Federal Bureau of Prisons 17 Associate Warden, - did I say 18 that correctly? 19 MS. : Yes. Correct. Mm-hmm. 20 MR. : Is being conducted as 21 part of an official U.S. Department of Justice, 22 Office of the Inspector General, or DOJ/OIG, 23 investigation. Today's date is December 2nd, 24 2021, and the time is 10:34 a.m. This 25 interview is being conducted by telephone. I EFTA00110004 LIMITED OFFICIAL USE 4 1 contacted you, Ms. by telephone number 2 . Also present 3 by telephone is DOJ/OIG Special Agent 4 This interview will be recorded by 5 me, SSA Could everyone 6 please identify themselves for the record, and 7 spell your last name? To start, again, I am 8 DOJ/OIG Senior Special Agent 9 And my last name is spelled 10 I. III, can you just state your name and spell 11 your name for the recorder? 12 MR. : Yes. I am DOJ/OIG Special 13 Agent Last name is spelled II ■ 15 MR. : And Ms. 16 MS. : My name is 17 Associate warden. Last name is spelled 18 19 MR. : Great. Thank you very 20 much. This is an official DOJ/OIG 21 investigation into the death of inmate Jeffrey 22 Epstein and the surrounding circumstances, and 23 you are being asked to voluntarily provide 24 answers to our questions. Will you agree to 25 the interview with the DOJ/OIG? EFTA00110005 LIMITED OFFICIAL USE 1 MS. : Yes. I do. 2 MR. : Perfect. And were you 3 able to review the voluntary interview form 4 that I sent to you via email, the DOJ/OIG form 5 11I-226/2? 6 MS. : Yes, I was. Yes, I did. 7 MR. : Perfect. And thank you 8 for sending it back to me a few minutes ago. I 9 see that you signed and dated it. 10 MS. : Mm-hmm. 11 MR. : And do you understand the 12 OIG form? 13 MS. : Yes, I do. 14 MR. : Perfect. And just, I'm 15 going to just going to read it for the record, 16 so that that's something that we have to do. 17 It says, United States Department of Justice, 18 Office of the Inspector General, Warnings and 19 Assurances to Employee Requested to Provide 20 Information on a Voluntary Basis. It says, 21 "You are being asked to provide information as 22 part of an investigation being conducted by the 23 Office of the Inspector General. This 24 investigation is being conducted pursuant to 25 the Inspector General Act of 1978, as amended. EFTA00110006 LIMITED OFFICIAL USE 6 1 This investigation pertains job performance 2 failure and security failure. This is a 3 voluntary interview. Accordingly, you do not 4 have to answer questions. No disciplinary 5 action will be taken against you if you choose 6 not to answer questions. Any statements you 7 furnish may be used as evidence in any future 8 criminal proceedings, or agency disciplinary 9 proceedings, or both." And there is a waiver 10 section. It says, "I understand the Warnings 11 and Assurances stated above, and I am willing 12 to make statements and answer questions. No 13 promises or threats have been made to me, and 14 no pressure or coercion of any kind has been 15 used against me." And I see that you signed 16 your signature. You printed your name, 17 And you dated and time 18 12/02/21, at 9:00 a.m. So, I assume that is 19 the time that you reviewed the form? 20 MS. : Yes. 21 MR. : Perfect. And that is 22 your signature on this form? 23 MS. : Yes, it is. 24 MR. : Awesome. And is there 25 any questions you have with regard to the EFTA00110007 LIMITED OFFICIAL USE 1 interview, or this form? 2 MS. : No. I don't. 3 MR. : Awesome. So, I will be 4 signing my name as the Special Agent. And 5 then, I will print my name under that as the 6 Special Agent. do you mind - since this 7 is a telephone interview, you're not present - 8 do you mind if I sign for you, and place that 9 it was me that signed for you, and print your 10 name as the witness? 11 MR. : I don't mind. 12 MR. : Perfect. All right. So, 13 I will sign for you, and then print your name, 14 and I will add the telephone number that we 15 are, as the place. Great. Let me get back to 16 this. Before starting the interview, I would 17 like to place you under oath. Ms. , can 18 you please raise your right hand? Do you swear 19 to tell the truth and nothing but the truth 20 during this interview? 21 MS. : Yes, I do. 22 MR. : Perfect. Thank you. And 23 then, because we are not in person, I'm just 24 going to have to ask you a couple questions to 25 verify your identity. What is your current EFTA00110008 LIMITED OFFICIAL USE 1 home address? 2 MS. . 38053. 4 MR. : Thank you. And what is 5 your date of birth? 6 MS. 7 MR. : And what is your social 8 security number? 9 MS. : Do I have to give it? 10 MR. : You can give me your last 11 four, if that's okay. 12 MS. : Okay. The last four. 13 MR. : Perfect. Thank you. And 14 how long have you worked for the BOP? 15 MS. : For 21 years. 16 MR. : Do you remember, 17 approximately, when your enter on duty date 18 was? 19 MS. : Yes. September 10 of 2000. 20 MR. : Perfect. And what is 21 your current position with the BOP? 22 MS. : I'm an Associate Warden. 23 MR. : And where is that? 24 MS. : I'm stationed at FCC Forrest 25 City in Forrest City, Arkansas. EFTA00110009 LIMITED OFFICIAL USE 1 MR. : And how long have you 2 held that position? 3 MS. : I've been - well, I've been at 4 this present duty station since officially 5 September, but physically here in October. Bu- 6 I've been an associate warden for, prior to 7 that. 8 MR. : Okay. So, you've been 9 basically you were remote in September, and 10 then physically present in October of this 11 current year, 2021? 12 MS. : Correct. 13 MR. : Perfect. And you - I'm 14 sorry - you said you've been an associate 15 warden since when? 16 MS. : I've been an associate warden 17 since - we're in 2021 - I think 2017. 18 MR. : Since 2017? 19 MS. : Uh-huh. 20 MR. : Okay. Great. And what 21 are your duties and responsibilities as an 22 associate warden? 23 MS. : As an associate warden, I 24 provide advice and counsel to the warden, and I 25 have oversight of specific disciplines as EFTA00110010 LIMITED OFFICIAL USE 1 decided by the warden. 2 MR. : Okay. 3 MS. : And I made decisions on policy, 4 and security (Indiscernible *00:06:34) concerns 5 of the institution. 6 MR. : Okay. And were you ever 7 interviewed by either the DOJ/OIG or FBI 8 regarding the Epstein matter? 9 MS. : No. I was not. 10 MR. : Okay. So, this is the 11 first time? 12 MS. : Yes. 13 MR. : Okay. Great. And are 14 you familiar with inmate Jeffrey Epstein, who 15 was housed within the MCC in July and August 16 2019, until his death on August 10th, 2019? 17 MS. : Yes. 18 MR. : And what was your 19 involvement with the matter? 20 MS. : Well, I have limited 21 involvement. I arrived at MCC New York July 22 4th, I believe, of 2019. And Epstein expired 23 August 10th, I believe. So, I actually, I saw 24 him, like, when he was in the visiting room. 25 And I was part of - there has been some EFTA00110011 LIMITED OFFICIAL USE 11 1 meetings, exec staff meetings. But as far as 2 extensive contact, or extensive involvement, 3 really nothing extensive due to my short time 4 being at the institution. 5 MR. : Okay. So, you didn't 6 arrive on July 4th? So, I guess you were 7 there, then, the entire time during his stay, 8 though. Correct? 9 MS. : Well, not the entire -. I 10 don't know when he arrived. So, I believe it 11 wasn't the entire time. But it was -. I think 12 he arrived some time in June, if I'm not 13 mistaken. I don't recall. 14 MR. : He arrived in July. 15 Right around the same time. So -- 16 MS. : In July? 17 MR. : -- there might be, like, 18 a day or two difference, but yeah, it was -- 19 MS. : Okay. 20 MR. : -- it was July and August 21 was when he was there. 22 MS. : Okay. Yeah. 23 MR. : Awesome. So, if you were 24 there in July, I'm just going to briefly touch 25 on the July 23rd, 2019 incident. Do you recall EFTA00110012 LIMITED OFFICIAL USE 1 an incident involving Jeffrey Epstein and 2 inmate Tartaglione on July 23rd, 2019? 3 MS. : When you say an incident, what 4 do you mean? 5 MR. : So, there was an incident 6 that happened in the SHU, where Tartaglione was 7 Epstein's celimate, and Epstein was removed 8 from the SHU and placed on suicide watch, and 9 then psychological observation. Are you 10 familiar with that? 11 MS. : Oh, yes. I'm familiar with it. 12 MR. : And what is your 13 understanding of what transpired? 14 MS. : My understanding is that 15 Tartaglione, I believe he requested, or he 16 called somehow for assistance because I believe 17 he indicated that Epstein was trying to commit 18 suicide. 19 MR. : Okay. And do you know by 20 what manner Epstein was attempting to commit 21 suicide? 22 MS. : I believe he was trying to, by 23 use of either strings, or some kind of 24 clothing, or something as a ligature. 25 MR. : Okay. And is it your EFTA00110013 LIMITED OFFICIAL USE 13 1 understanding that Epstein attempted to harm 2 himself? 3 MS. : Yes. That was my 4 understanding. 5 MR. : And did you hear anything 6 with regard to Tartaglione attempting to harm 7 Epstein? 8 MS. : I know there was, there was 9 speculation, not from Epstein, but there was 10 speculation that, perhaps, you know, there 11 could have been something involved, but 12 Epstein, I believe, made statements that his 13 cellmate did not try to harm him, as well as 14 Tartaglione himself indicated that he did not 15 try to harm him. 16 MR. : Okay. So, your belief is 17 that they are, they were not correct 18 statements, and then the fact it was Epstein 19 that attempted to harm himself, and not 20 Tartaglione? 21 MS. : That is correct. 22 MR. : Okay. And did you have 23 any involvement with selecting Tartaglione as 24 Epstein's cellmate? 25 MS. : No. I did not. EFTA00110014 LIMITED OFFICIAL USE 1 MR. : And do you know how 2 Tartaglione was selected to be Epstein's 3 cellmate? 4 MS. : I don't know. I don't, I don't 5 know exactly how he was selected. I do know, 6 after the fact, it was indicated that, because 7 he was former law enforcement, and he didn't 8 seem like he, I guess he didn't - he didn't 9 have anything that, it didn't appear that he 10 would hurt Epstein, that he was suitable to be 11 Epstein's cellmate. But I don't know exactly 12 what the vetting process was for that decision. 13 MR. : Okay. And do you believe 14 that Tartaglione was an appropriate choice for 15 a cellmate? 16 MS. : I'm not going to speculate 17 about that. I do know, at the time that he was 18 a cellmate, that he did not try to harm him. 19 Epstein never voiced any concerns about - that 20 I am aware of - about Tartaglione being his 21 cellmate. But as far as looking at 22 Tartaglione's charges, or anything to see if he 23 had any risk factors that would indicate that 24 he would harm Epstein, that would be 25 speculation after the fact. So, that, I don't EFTA00110015 LIMITED OFFICIAL USE 15 1 believe I'm in a position to make that decision 2 at this time. 3 MR. : Sure. Okay. And then, 4 what is your understanding of, after this 5 incident occurred, where was Epstein placed? 6 MS. : He was placed on suicide watch, 7 is my understanding. 8 MR. : Okay. Great. And that 9 was immediately following, or on July 23rd, 10 2019. Do you have any involvement with Epstein 11 while he was on suicide watch? And then, 12 psychological observation? 13 MS. : No. 14 MR. : And where is that 15 conducted? Or where was that conducted? 16 MS. : Where, in the suicide watch 17 cells, you mean? 18 MR. : Correct. Where would 19 have he been housed at the time? 20 MS. : Oh, yeah. The suicide watch 21 cells are on the, they are on the second -. 22 They are on the second floor. On the same 23 floor as the health services department. So, 24 around the corner, and it's down the hall from 25 psychology. From the psychology department EFTA00110016 LIMITED OFFICIAL USE 16 1 themselves. 2 MR. : Great. And where was the 3 SHU located in the MCC? 4 MS. : The Special Housing Unit is 5 located on the ninth floor. 6 MR. : Great. And while Epstein 7 was on suicide watch, and then psychological 8 observation, do you know if he was allowed any 9 visits, specifically any attorney visits, or 10 anything like that? 11 MS. : I do believe that he was 12 allowed to see his attorney. 13 MR. : And do you know if he did 14 see his attorney while he was on psychological 15 observation? 16 MS. : I don't know for certain if, 17 like, watch was - if it was the same day, but 18 am not for certain, 100 percent certain, but I 19 do believe that it did occur. It did occur. I 20 know he was He saw his attorneys very 21 often. Almost daily. And I don't believe that 22 there was any break in visits. So, I would, 23 would say that it probably did happen on the 24 same day that he was on suicide watch. 25 MR. : And how would that work? EFTA00110017 LIMITED OFFICIAL USE 17 1 If someone is on suicide watch, and then 2 psychological observation, how would they meet 3 with their attorneys? 4 MS. : Typically, if someone is on 5 suicide watch, they do not have visits, and 6 they don't - because they're on watch - they 7 would be under constant, whether it was an 8 inmate companion, or a staff watch. So, 9 typically, a person on suicide watch would not 10 have visits. So, if a visit did happen during 11 suicide watch, I would gather that that person 12 will still be under the same observation 13 protocol. Obviously, another inmate would not 14 be able to watch them because of the privacy 15 factor with the visit, but I would, I would 16 assume that a staff member would be present. 17 MR. : Okay. Now, would they be 18 present on that second floor suicide watch 19 area, psychological observation area? Or would 20 that be conducted in the attorney visit rooms 21 of the MCC? 22 MS. : So, again, typically, visits 23 don't happen when a person is on suicide watch. 24 And because of the placement where suicide 25 watch is, there is no visits that happen in EFTA00110018 LIMITED OFFICIAL USE 18 1 that area. So, all of the attorney conference 2 visits, they happen in the attorney conference 3 area, which is on the third floor. So, any 4 visit, attorney related, would happen on the 5 third floor, in the attorney conference area. 6 MR. : And to make sure I'm 7 understanding you correctly. So, that means 8 you believe that when Epstein was on 9 psychological observation or suicide watch, he 10 would have been, then, transported to that 11 third floor visiting area where he would 12 conduct his visits with his attorney? His 13 attorneys. 14 MS. : That is correct. 15 MR. : Okay. Now, were there 16 any specific - and oh, sorry, before I move on, 17 I guess I should say. So, that is not typical, 18 though? That would have been, like, a kind of 19 something that was a special circumstance for 20 Epstein? 21 MS. : Yeah. Yeah. That is not 22 typical. 23 MR. : Okay. And do you know if 24 there is any prohibition up against that, or 25 not? EFTA00110019 LIMITED OFFICIAL USE 19 1 MS. : I know There are 2 guidelines, I believe, that when a person is on 3 suicide watch, that is where they would remain 4 under constant supervision, and there would be 5 no visits. 6 MR. : Okay. So, I am assuming 7 that answer would be, then, yes, there are 8 prohibitions? 9 MS. : When you say prohibitions, you 10 mean that the agency has guidelines in place 11 that says absolutely not? 12 MR. : Yeah. So, I guess what 13 I'm asking is, should Epstein have been 14 visiting with his attorneys while he was on 15 suicide watch, or psychological observation? 16 MS. : If there was a determination, 17 which I am not aware of, that deemed that it 18 would be okay or appropriate, as far as a 19 psychologist, or someone from the psychology 20 department, indicating that it would be okay, 21 then that would be, you know, that would be a 22 consent. 23 MR. : Sure. 24 MS. : But other than that, I don't 25 believe anyone else would make that EFTA00110020 LIMITED OFFICIAL USE 1 determination to say that he would then be 2 taken off of suicide watch, and then placed in 3 the attorney conference area. 4 MR. : Okay. Great. So, I take 5 it, then, is it that MCC psychology department, 6 are they the ones who determined that Epstein 7 should be on suicide watch, and then 8 psychological observation? 9 MS. : Well, anyone can actually place 10 someone on suicide watch, if that person voices 11 - and when I say "anyone," for instance, if I 12 call a psychologist is not there after hours, 13 someone voices an intent to harm themselves, 14 the lieutenant can make that decision to place 15 the person on suicide watch. But psychology 16 typically is the one that would determine 17 whether someone is taken off of suicide watch 18 because they would have to do a suicide risk 19 assessment, and any other clinical assessment. 20 So, placing someone on suicide watch 21 again - depending on the time, it can be 22 psychology, or it can be a correctional 23 services staff member. And then, the removal 24 would be someone from psychology, to say that 25 this person is not deemed suicide, or, you EFTA00110021 LIMITED OFFICIAL USE 1 know, they are safe to be in general 2 population. 3 MR. : Okay. And then, but it 4 would also - and correct me if I'm wrong - but 5 it did sound like you said that it would have 6 been psychology's decision to allow Epstein to 7 visit with his attorneys while he was on 8 suicide watch or psychological observation? 9 MS. : No. I don't know if that was 10 what actually occurred. But to remove someone 11 from suicide watch, that would be a psychology 12 decision. 13 MR. : So, when you say "remove 14 someone," do you mean, like, just for those 15 hours that he was visiting, or are you talking 16 about when he was removed and placed back in 17 the SHU? 18 MS. : Typically, when you remove 19 someone, it's not for an hour or two. It's 20 typically, you are saying that that person 21 poses no more risk to themselves, so they are 22 off. Basically, they are going back to general 23 population. So, I am not aware of any 24 situation where you remove a person for an hour 25 or two, or for a short timeframe, and then EFTA00110022 LIMITED OFFICIAL USE 1 place them back. 2 MR. : Sure. So, that is kind 3 of I guess what I'm asking is, who makes the 4 determinations? Because you said that your 5 understanding was that he did conduct his 6 attorney visits during that time period that he 7 was on suicide watch. 8 MS. : Mm-hmm. 9 MR. : Or psychological 10 observation. So, who made the, you know, who 11 had the authority to allow him to conduct those 12 attorney visits? 13 MS. : Yes. I don't know. Again, I 14 don't know who made the ultimate decision for 15 that to happen. But I know the process for 16 removal of suicide watch ,and what that process 17 entails. And that is why I'm saying, to remove 18 someone off of suicide watch, it would have to 19 be someone in psychology, to say that that is 20 appropriate. But in this instance, I don't 21 know, I don't know if that was communicated. 22 If that actually occurred. So, I hope, 23 hopefully that answers the question. 24 MR. : Sure. Yeah. 25 MS. : But (Indiscernible *00:19:29). EFTA00110023 LIMITED OFFICIAL USE 23 1 MR. : We can move on to the 2 SHU, then, when he got removed. So, do you 3 know if there were any specific instructions, 4 by either you, the warden, or other MCC 5 executive staff, with regard to Epstein being 6 placed back in the SHU from psychological 7 observation? 8 MS. : When he was - you are saying 9 when he was removed? 10 MR. : So, when a determination 11 was made that he - for Epstein to be removed, 12 which was on or about July 30th, 2019. 13 MS. : Mm-hmm. 14 MR. : Were there any specific 15 instructions provided by you, the warden, or 16 other MCC executive staff, with regard to 17 Epstein being placed back in the SHU? 18 MS. : Well, I didn't, I didn't have 19 any specific direction, or instructions to a 20 particular staff member. But I do, I do know 21 that there was a determination made, and who 22 exactly made that determination, typically, 23 when you - high-profile individuals, and you 24 are saying to place them in Special Housing for 25 their care, it is typically the CEO, the EFTA00110024 LIMITED OFFICIAL USE 1 warden, in consultation with correctional 2 services, because it falls under custody care 3 and control. And so, that decision was made to 4 place him in Special Housing. 5 MR. : Okay. Do you know, did 6 you, MCC executive staff, or anyone, including 7 the warden, receive any calls, or was any 8 contacted by lawyers, or a judge, asking for 9 Epstein to be removed from suicide watch or 10 psychological observation? 11 MS. : That, I am not aware of any 12 communication about that. 13 MR. : Okay. And just to circle 14 back. Were you, or executive staff, involved 15 with any decisions to have Epstein removed from 16 suicide watch or psychological observation? 17 MS. : Say that one more time. Say 18 that one more time. 19 MR. : So, that actually having 20 him removed. So, back on July, you know, 30th, 21 when he was removed. Would yourself or 22 executive staff, would you have been a part of 23 the process of actually taking him off of 24 suicide watch or psychological observation? 25 MS. : No. EFTA00110025 LIMITED OFFICIAL USE 1 MR. : So, that is solely a 2 psychology decision? 3 MS. : Yeah. Because they are the 4 subject matter experts, and again, and whether 5 someone is off of suicide, or displaying 6 suicide risk factors, typically, it is a 7 psychology thing, to remove the individual. 8 MR. : Okay. And that that's 9 not in consultation with MCC executive staff? 10 MS. : No. To remove someone from 11 suicide watch? No. 12 MR. : Okay. Now, it is our 13 understanding that, after Epstein was placed 14 back in the SHU, or the Special Housing Unit, 15 psychology recommended that Epstein be housed 16 with a cellmate. Do you know if that is 17 accurate? 18 MS. : That, I do know that is 19 accurate. 20 MR. : You do know that it is 21 accurate? 22 MS. : Yes. That, I do believe that 23 that was - Mm-hmm - that is accurate. That it 24 was indicated that he should have a cellmate. 25 MR. : Okay. And do you know EFTA00110026 LIMITED OFFICIAL USE 26 1 how that information was disseminated within 2 MCC? 3 MS. : And again, there was several, 4 you know, there was meetings, and I don't know 5 what particular meeting it occurred, but I do 6 recall, during one of the meetings, that it was 7 indicated. I don't know if it was during close 8 out, or open up, that it was important that he 9 did have a cellmate. 10 MR. : Okay. So, it was an 11 actual requirement that Epstein have a cellmate 12 while he was assigned to the SHU? 13 MS. : Yes. 14 MR. : Okay. And do you know 15 who made -? Do you know who he was celled 16 with? Do you know what the name of his 17 cellmate was when he came back off of suicide 18 watch, on July 30th, 2019? 19 MS. : Oh, who was his cellmate? i 20 don't know if it was -. I don't know what the 21 (Indiscernible *00:23:19). But I do know, at 22 one point, he had a cellmate named - the last 23 name was . And the first name was 24 I -F-R-A-I-N. But I don't recall if that was 25 his consistent cellmate. But I do recall, EFTA00110027 LIMITED OFFICIAL USE 1 besides Tartaglione, was another 2 cellmate. 3 MR. : And thank you. I have 4 actually been saying So, it's 5 MS. : That's what I think you 6 pronounce it as. It could be my New York 7 accent, but I'm saying 8 MR. : Okay. Hey. That's - _ 9 guess -. Yeah. I'm looking at it, and it's -. 10 I'm going to start saying now. 11 MS. : Mm-hmm. 12 MR. : Do you know who made the 13 decision that would be Epstein's 14 cellmate? 15 MS. : That, I am not aware of. I 16 don't know if it was an actual, like, meeting, 17 as far as a placement decision. So, I don't 18 know if it was actually a vetting process, to 19 determine who should be the cellmate. I know 20 itw as indicated that he should have a 21 cellmate. But what that process was, to get to 22 I am not aware of it. 23 MR. : Okay. So, that means 24 that you were not involved with that decision? 25 MS. : No. EFTA00110028 LIMITED OFFICIAL USE 28 1 MR. : Okay. And did you work 2 at the MCC on August 9th - which was a Friday - 3 or August 10th - which was a Saturday - that he 4 was found in 2019? 5 MS. : Well, I worked on Friday. My 6 work hours, because of my position, I work 7 Monday through Friday, 7:30 to 4:00. But I did 8 report to the institution the morning of, when 9 I received the call indicating that I needed to 10 report to the institution on that day that 11 Epstein was found. 12 MR. : Okay. So, on Friday, 13 August 9th, you worked from 7:30 a.m. to 4:00 14 p.m.? 15 MS. : Correct. 16 MR. : And then, on August 10th 17 - so, you did depart at 4:00 p.m. - and then 18 you returned after Epstein was found on August 19 10th? 20 MS. : And then, I returned back to 21 the institution -. Okay. I'm trying to 22 remember what -. I received a call around 23 maybe 8:00 or something. I received a call, 24 and then, I arrived at the institution maybe 25 around 9:00 or so. EFTA00110029 LIMITED OFFICIAL USE 1 MR. : Okay. 9:00 a.m.? 2 MS. : Mm-hmm. 3 MR. : Okay. So, since Epstein 4 was required to have a cellmate, who was 5 ultimately responsible to make sure that all 6 SHU staff were aware of his cellmate 7 requirement? 8 MS. : Oh. Okay. And because - I'm 9 just going to say this - because it's Special 10 Housing, Special Housing is governed under 11 correctional services. It would be the captain 12 is typically in charge of correctional 13 services. And there is a SHU lieutenant that 14 is assigned to the Special Housing on a daily 15 basis. That that is that person's daily 16 assignment. And they are responsible for 17 ensuring that everything is in compliance in 18 Special Housing. And so, there should be some 19 communication, if then, like I said, psychology 20 made a decision that he had to have a cellmate. 21 Everyone was aware of it, but that, like, 22 verbal communication, or insurance, it should 23 have happen in the correctional services. The 24 captain. The lieutenant. And then, that 25 information communicated down to the staff that EFTA00110030 LIMITED OFFICIAL USE 1 actually work in the Special Housing Unit. 2 MR. : Okay. And do you know, 3 at the time, in August 9th and 10th, who the 4 captain at the MCC was? 5 MS. : It was 6 MR. : Okay. And do you know 7 who the SHU lieutenant at the time was? 8 MS. : That, I am not aware of. That, 9 I am not aware of. 10 MR. : Does Lieutenant 11 sound familiar to you? 12 MS. : I know Lieutenant . But I 13 don't know if that was his post at that 14 quarter. 15 MR. : Okay. 16 MS. : I am not sure. 17 MR. : Okay. So, that was his 18 post for the quarter. So, ultimately, the 19 information should have come from Captain 20 and SHU Lieutenant They should 21 have provided to the SHU staff that Epstein was 22 required to have a cellmate at all times? 23 MS. : Mm-hmm. 24 MR. : Okay. And that is a yes? 25 MS. : Yes. That is a yes. EFTA00110031 LIMITED OFFICIAL USE 31 1 MR. : Okay. Great. And how 2 should have they communicated that? Should 3 have that been verbally, in writing? How 4 should have they made sure everyone knew? 5 MS. : Now, to ensure that, you could 6 have a record of it if you put it in an email. 7 That's blatant, and that can never be 8 contradicted. You could also have verbal 9 notification, in addition to written 10 notification. So, that it could be both. 11 Honestly. It could be both. But if you have 12 it in - you have something that, a bulletin or 13 some kind of an email that went out, that's 14 definitely, you know, something that - that's a 15 record. That's a permanent record. 16 MR. : So, it sounds -- 17 MS. (Indiscernible *00:28:24) 18 MR. : -- you're saying, it 19 really should have been both verbal and in 20 writing, but writing would basically make sure 21 that you are, it's documented/ 22 MS. : Correct. 23 MR. : Is that a correct 24 understanding? 25 MS. : That is a correct EFTA00110032 LIMITED OFFICIAL USE 1 understanding. 2 MR. : Okay. 3 MS. : And in addition to that, I do 4 know that the SHU staff did know that he should 5 have had a cellmate. 6 MR. : You do know that they 7 knew that? 8 MS. : I do know that the SHU staff 9 knew that. Mm-hmm. 10 MR. : And how do you know that? 11 MS. : Because the staff are required 12 to make weekly rounds, and I don't -. Now, 13 because of, after the - excuse me - after the 14 fact, you know, he was kind of, like, you are 15 playing a - I'm just trying to recall the facts 16 - but I do recall instances of making rounds in 17 the Special Housing, where staff, it was said, 18 make sure that he had a cellmate, and when we 19 make rounds, that that was - I can - I verbally 20 heard folks say it myself. 21 MR. : And do you remember who 22 was engaged in those conversations, or who you 23 know specifically that knew? 24 MS. : That, I can't recall, because 25 in Special Housing, there is, like, four -. EFTA00110033 LIMITED OFFICIAL USE 33 1 There is -. You have the SHU number one, SHU 2 number two, the three, and the four. So, you 3 at least have four staff, and you have staff 4 that are SHU (Indiscernible *00:29:46). So, 5 there is several staff assigned to the Special 6 Housing Unit. So, and at that -. So, I can' 7 say with certainty who was engaging in a 8 conversation. And then, like I said, and then 9 you have the SHU lieutenant. So, it was 10 several folks that were assigned to the Special 11 Housing. And again, I don't know specifically 12 who said what, but I do know that it was known 13 because I verbally, I heard it, it was audible. 14 I heard it. 15 MR. : While you were in the 16 SHU? 17 MS. : While I was in the SHU. 18 MR. : And do you know around 19 what time of day that would have been? 20 MS. : No. 21 MR. : No? 22 MS. : Hmm-mm. 23 MR. : And did you hear it more 24 than one time? 25 MS. : Yes. Mm-hmm. EFTA00110034 LIMITED OFFICIAL USE 34 1 MR. : So, it was something that 2 you had heard on multiple occasions? 3 MS. : Mm-hmm. 4 MR. : Okay. 5 MS. : Mm-hmm. 6 MR. : And is that something 7 that, because you were engaged in a 8 conversation, or you just overheard because 9 saying it? 10 MS. : I wasn't engaging in the 11 conversation about Epstein per se, but just in 12 a conversation about what was going on in SHU, 13 while making rounds. 14 MR. : Okay. 15 MS. : So, you discuss -. So, 16 typically, when you make SHU rounds, you can do 17 both. You can have, like, a SHU roster that 18 kind of lists all of the inmates that are 19 housed in the SHU. You can, like, look at the 20 board to see who has cellmates. So, sometimes, 21 the conversation is prompted from multiple 22 things, or sometimes inmates stop you at the 23 door, and ask questions, and then you talk 24 about who it is that asked you questions. So, 25 I'm just saying, because of all those EFTA00110035 LIMITED OFFICIAL USE 35 1 instances, I don't know why it was said about 2 that particular thing, but that was, that was 3 just one of some comments during that day. 4 MR. : But it was a comment 5 specific -- 6 MS. : Yeah. 7 MR. : -- to Epstein's cellmate. 8 Correct? 9 MS. : Yes. Exactly. 10 MR. : Okay. And do you know if 11 there were any plan -. Or sorry. Before I 12 move on, I guess I should specifically ask you. 13 So, you mentioned there was SHU one, two, 14 three, four, but Epstein was found when, you 15 know, during the overnight, I guess the morning 16 watch, which is, you know, I think midnight to 17 8:00 a.m. 18 MS. : Mm-hmm. 19 MR. : He was found at 20 approximately 6:33 a.m. on August 10th, and 21 then, at that time, there were only two SHU 22 staff in there. 23 MS. : Mm-hmm. 24 MR. : Specifically, a Tova Noel 25 and a Michael Thomas. Do you know those two EFTA00110036 LIMITED OFFICIAL USE 1 staff members? 2 MS. : I know of them. 3 MR. : Do you know if either of 4 those two specific staff members were aware of 5 Epstein's cellmate requirement? 6 MS. : No. I don't -. That, I don't 7 know because they are assigned to work other 8 departments, and they were working overtime. 9 But what I do know - because I also, when i 10 first started working in the Bureau, I was a 11 correctional officer - I do know that you 12 should engage in conversation with whomever it 13 is that you are relieving, to find out, is 14 there any special precautions, or you pass on 15 your equipment, you talk about what your base 16 count is. So, there, there should be some 17 communication between you and the staff member 18 that you are relieving. 19 MR. : Now, do you believe, if 20 the person is quarterly assignment was the SHU, 21 they would have known, and should have known? 22 MS. : Yeah. Yes. 23 MR. : Okay. So, fi you know 24 that Tova Nova was actually assigned to the SHU 25 for that quarterly post, does that change EFTA00110037 LIMITED OFFICIAL USE 37 1 anything for you? 2 MS. : Hmm. Well, you said Tova Noel. 3 Was she an officer, or she was -- 4 MR. : She was an officer. 5 MS. was she -? 6 MR. : But she was assigned -- 7 MS. : Okay. 8 MR. : -- as her quarterly -- 9 MS. : Mm-hmm. 10 MR. : -- post was in the SHU. 11 Michael Thomas -- 12 MS. : Okay. 13 MR. : -- was on overtime, 14 working in the SHU. He was a materials 15 handler. 16 MS. : Okay. 17 MR. : But Tova Noel was 18 actually -- 19 MS. : Okay. 20 MR. : -- assigned to the SHU. 21 MS. : Okay. Well then, she should 22 have known. And then, she - and again, I 23 didn't delve into that - she was on overtime, 24 but was she responding to what shift? Like, 25 evening watch? Was that her permanent EFTA00110038 LIMITED OFFICIAL USE 38 1 assignment? 2 MR. : I would have to check if 3 that was her -- 4 MS. : Okay. 5 MR. : -- she may have been, you 6 know, you might, you may be right. 7 MS. : Mm-hmm. 8 MR. : She may have been working 9 overtime in the SHU, but she was, in fact, 10 assigned to the SHU -- 11 MS. : Okay. 12 MR. : -- for that quarter. 13 MS. : Then she should have known. 14 MR. : And do you believe 15 MS. : She should have. 16 MR. : -- that there is any 17 excuse for her to say that she didn't know? 18 MS. : I can't see how, if that is 19 your post for the quarter, that you would not 20 know, because you have to make decisions based 21 on, like, recreation. You have to do rounds. 22 You have to actually physically walk down the 23 range. There are name tags on the door. There 24 is the hot list. There is information that 25 psychology, at times, even sends out to SHU EFTA00110039 LIMITED OFFICIAL USE 39 1 staff, indicating these inmates are on the hot 2 list, or these are some important factors about 3 specific inmates. 4 So, there is, there is information, and 5 there is things that you are required to do, as 6 part of your assignment in SHU, that you would 7 have to know who can even go in recreation, in 8 the recreation cage, with whom. It's because 9 of separation. So, there is information that 10 you have to be able to, you have to know, in 11 order for you to make safe decisions during 12 your eight hours of having oversight over the 13 inmates. 14 MR. : So - great - so, you 15 touched on the hot list. Can you just very 16 briefly explain what the hot list is? 17 MS. : Well, the hot list is, it's, 18 like a list that kind of, that psychology puts 19 together, and it has information about, at 20 times, who is on suicide alert, or of any kind 21 of risk factors, or something that requires 22 special care for just specific inmates. So, it 23 is, your base count, or the SHU can help maybe 24 have the capacity to hold maybe 80 inmates, 25 right? And if - not everyone is on the hot EFTA00110040 LIMITED OFFICIAL USE 1 list. 2 MR. : Okay. 3 MS. : So, again, the hot list is just 4 specifically designed to highlight specific 5 inmates, and what is needed, or something 6 special about that specific inmate. 7 MR. : So, if an inmate comes 8 off of suicide watch, or psychological 9 observation, and is placed in the SHU, would he 10 be - he or she, yeah - would he be listed on 11 the hot list? 12 MS. : I don't know if that would be 13 on the hot list, but I know that that should be 14 - that is something that would probably be on 15 the SHU roster, or the SHU report. 16 MR. : Okay. 17 MS. : The SHU report, it lists all of 18 the inmates. It has pictures of all of the 19 inmates. And it also sections for health 20 services, for psychology, for correctional 21 services, and for unit teams. And in those 22 comment sections, they typically will say this 23 inmate may need a cellmate. This inmate is on 24 the hot list. This inmate should be kept away 25 from inmate X, Y, and I. It provides specific EFTA00110041 LIMITED OFFICIAL USE 41 1 information. So, even if it was not on the hot 2 list, it probably would also be on the SHU 3 report, which is BOPWARE. That's an electronic 4 report that you can pull from a program, a BOP 5 program. 6 MR. : Okay. Now, do you know, 7 though, if Epstein specifically was on the hot 8 list in August of 2019? 9 MS. : You know what? I don't know 10 that. 11 MR. : Okay. So, if he was, 12 though, would it have listed that he was 13 required to have a cellmate? 14 MS. : I'm trying to think if that 15 information would be on the hot list. I'm not 16 sure if that information would be on the hot 17 list. 18 MR. : But it would be on this 19 other report that you were just speaking of, 20 that's in BOPWARE? 21 MS. : I was - mm-hmm - that should, 22 that is something that would be important, that 23 psychology would definitely put on there. 24 MR. : And would be - Tova Noel 25 would have, she had been required to review EFTA00110042 LIMITED OFFICIAL USE 42 1 that list, and see that Epstein was required to 2 have a cellmate? 3 MS. : Well, you are not required to 4 review the list, but in order to know what's 5 going on with the inmate, I mean, you have to 6 have a SHU roster. You would have to know 7 what's going on with the inmates. 8 MR. : So -- 9 MS. : So -. 10 MR. : -- so, she should have 11 reviewed the list, is what you are saying? 12 MS. : If you want to know what's 13 going on with the inmates, I would say that you 14 would review your SHU report. 15 MR. : Is there any other ways 16 that Tova Noel, being that it was her quarterly 17 post, would have and should have known that 18 Epstein was required to have a cellmate? 19 MS. : I do also know that we have 20 TruScope (Phonetic Sp. *00:38:23). So, there 21 is also an electronic program called TruScope, 22 and psychology lists things, and that psych, 23 it's called a psychology advisory list. And 24 so, again, there is multiple electronic 25 formats. And paper formats and things that EFTA00110043 LIMITED OFFICIAL USE 1 information is listed. 2 MR. : Okay. 3 MS. : So -. 4 MR. : And do you know, were 5 there any plans made on how to address the 6 situation if was removed as Epstein's 7 cellmate? 8 MS. : I do - hmm - I don't recall 9 there being a meeting to say specifically if 10 was removed, but -. So, I can't say that 11 there was a meeting that I am aware of, to talk 12 about. 13 MR. : So, being that Epstein 14 was -- 15 MS. : Actually, (Indiscernible 16 *00:39:13). 17 MR. : -- so, being that Epstein 18 was required to have a cellmate, and being that 19 MCC is, you know, a jail versus a prison, where 20 prisoners are constantly moved in and out. 21 MS. : Mm-hmm. 22 MR. : Was there anything in 23 place to address that situation, if Epstein is 24 required to have a cellmate, his cellmate is 25 then removed. What should have happened? EFTA00110044 LIMITED OFFICIAL USE 1 MS. : I don't recall of a 2 conversation specific to that. But I do know, 3 as part of, not just Epstein, but any inmate, 4 if they are required to have cellmates, if you 5 are doing your rounds, and the cellmate is not 6 in there, it could be because that cellmate is 7 inside of the recreation cage, but if it is a 8 prolonged thing -- 9 MR. : Mm-hmm. 10 MS. : -- that is something that 11 should be brought to the attention of, 12 obviously, your first line supervisor first, 13 and then that supervisor would then call, 14 depending on if it is after hours, they can 15 call the on-call psychologist, or if it during 16 duty hours, you call - then the lieutenant 17 would then contact someone in psychology. 18 MR. : Okay. So, the supervisor 19 20 MS. : Mm-hmm. 21 MR. : -- you're saying is the 22 SHU lieutenant. So, it's staff should have 23 notified the SHU lieutenant? 24 MS. : Yes. 25 MR. : Now, what -- EFTA00110045 LIMITED OFFICIAL USE 45 1 MS. : Mm-hmm. 2 MR. : -- what about if the SHU 3 lieutenant is off? So, on the 9th, Lieutenant 4 is off that day. There is no SHU 5 lieutenant. What should have happened with SHU 6 staff? Who should have they contacted? 7 MS. : There is always a lieutenant. 8 So, even if , who is the SHU lieutenant, is 9 not physically there, there is always a 10 lieutenant in the building, 24 hours. 11 MR. : Sure. 12 MS. : That person is -. So, there is 13 the management official, after hours. And so, 14 when there is any kind of emergency, or an 15 inmate situation that rises to the level of 16 contact, there is a management official there. 17 And they have received calls. And they then 18 call the captain, and then, the captain can 19 determine whether or not he wants some, you 20 know, to increase the level and call the AW, 21 but there is always a lieutenant in the 22 institution. 23 MR. : Okay. And so, they 24 should have contacted one of the lieutenants, 25 and you are referring to the two lieutenants EFTA00110046 LIMITED OFFICIAL USE 46 1 that are usually there during the day. Can you 2 refresh my memory of what the two are called? 3 MS. : One is the operations, and one 4 is the activities lieutenant. 5 MR. : Right. So, is there one 6 or the other that the SHU staff, during the 7 day, should have called? 8 MS. : Well, during the day, now, 9 okay, Monday through Friday, during the day, 10 there is the SHU lieutenant. 11 MR. : No. I'm saying on the 12 9th -- 13 MS. : After -. 14 MR. : -- with the fact that the 15 SHU lieutenant is not there. 16 MS. : That you can call, you can 17 either call the activities or operations. 18 MR. : So, it is either or. 19 There is not -- 20 MS. : But one -- 21 MR. : -- one or the other? 22 MS. : -- hey, you can call -. Hmm- 23 mm. You can call either or. 24 MR. : Okay. Great. And do you 25 know what happened to inmate on August EFTA00110047 LIMITED OFFICIAL USE 47 1 9th, 2019? 2 MS. : I know, I know because of after 3 the fact, that he was, I believe he was bonded, 4 or somehow, he was released from court. He was 5 at court, and he never came back because of 6 either a bond, receiving a bond or a bail. 7 MR. : Okay. So, your 8 understanding is that he actually went to 9 court, and then was released? 10 MS. : Yes. That is my understanding. 11 MR. : And where did you receive 12 that information? 13 MS. : That is after the fact. After, 14 you know, trying to gather what happened, and 15 to his cellmate. And so, if the information 16 was not, I was not aware of the information on 17 the day. It's because of this incident that 18 am aware of the information. 19 MR. : Okay. So, and that is 20 your belief to this day? 21 MS. : Yes. That is my belief to this 22 day. 23 MR. : Okay. And what does WAB 24 mean? 25 MS. : Oh, that means With All EFTA00110048 LIMITED OFFICIAL USE 1 Belongings. 2 MR. : So, if a person is 3 transported down to Receiving and Discharge, 4 with the status WAB next to their name -- 5 MS. : Mm-hmm. 6 MR. : -- what does that mean is 7 happening? 8 MS. : That means that the inmate is 9 leaving, and he's not coming back. 10 MR. : So, it does mean that 11 they are actually - that that is known as that 12 inmate is not coming back to the MCC? 13 MS. : Correct. 14 MR. : And what is 15 MS. : Mm-hmm. 16 MR. : -- what is the document 17 that would say WAS on it? 18 MS. : Normally, there is a court 19 roster that lets the unit officer know that the 20 inmate is leaving. So, you would know who to 21 send down to R&D. And typically, it has an 22 approximate time. And/or, sometimes R&D may 23 then call up to the specific location, or the 24 housing unit, to say, send inmate so and so 25 down with all belongings. EFTA00110049 LIMITED OFFICIAL USE 49 1 MR. : Okay. So, but there is 2 a, it sounds like a court list, or a 3 production, an inmate production list that is 4 created by R&D? 5 MS. : That is correct. 6 MR. : And that is what would 7 say -? That is how -? What staff members 8 would utilize in order to produce the inmates 9 to R&D? 10 MS. : That is - yeah - that is my 11 understanding. 12 MR. : And what happens with 13 that document? Like, so, the staff members 14 utilize it, then where does the document go? 15 Is it saved somewhere, like BOPWARE, or 16 TruScope, or is it something that they print 17 out, and then they destroy, or do they keep it? 18 MS. : Well, I know that R&D 19 definitely should have a cop of the court 20 roster. They should. Now, as far as what the 21 housing unit would do with it, I would believe 22 that they probably would shred it because it 23 serves no purpose to that specific housing 24 unit. But R&D would maintain copies of the 25 court roster. EFTA00110050 LIMITED OFFICIAL USE 50 1 MR. : Now, if R&D is saying 2 that they actually don't keep a copy, it's like 3 a template that they revise every day, based 4 upon what inmates need to be produced. So, 5 they actually don't have any records from past, 6 you know, production lists. Does that sound 7 accurate to you? 8 MS. : Hmm. From my understanding, I 9 would think that a copy would be maintained. 10 And that there would also possibly be a 11 logbook. Because I - again - at the time, I'm, 12 you know, an associate warden, but, and I never 13 specifically worked in Receiving and Discharge. 14 But from my understanding of being in Receiving 15 and Discharge, and from our early, my early 16 years of being a correctional officer, I am 17 aware of, like, if a receipt is being 18 maintained, because someone keys in inmates in, 19 and keys inmates out in Sentry. And there, at 20 times, control even annotates things in their 21 daily, their daily log. 22 MR. : Yeah. 23 MS. : So, of, like, of movement. 24 Depending on the control room officer, that 25 officer may even take the time to list the EFTA00110051 LIMITED OFFICIAL USE 51 1 names, to actually write out names and register 2 numbers. Or they just might write out the 3 numerical value of how many inmates departed 4 for court, versus how many departed, like, with 5 all belongings. Because that means that the 6 inmate is not returning, and he would 7 definitely have to be taken off your base 8 count, in order to get an accurate count. 9 MR. : Okay. So, and I know 10 we're not in person, so I'm going to have to 11 just explain to you what I'm looking at. I 12 have two emails that were sent to the MCC. One 13 was to - both from the U.S. Marshal Service - 14 one was to just Receiving and Discharge 15 personnel, and another one was sent, it looks 16 like to, like to a large amount of custody 17 personnel, including lieutenants, it looks like 18 Tijuana , who I believe was the SIS 19 lieutenant. It looks like , who was an AW, is on there. As well a: 21 a number of other people. Quite a large number 22 of people. I do not see your name on here. 23 But it does say the subject, "Prisoner 24 Production 8/9/2019," the date is Thursday, 25 August 8th, 2019, at 3:36 p.m. EFTA00110052 LIMITED OFFICIAL USE 1 MS. : Mm-hmm. 2 MR. : Now, within the 3 attachments, it shows NYM 8/9/2019. Do you 4 know what that would stand for? 5 MS. : You said NYM 8/9? 6 MR. : Yeah. So, N-Y-M. 7 MS. : Mm-hmm. 8 MR. : Yeah. And then, when you 9 open it up, it just says - it's the U.S. 10 Marshals report - and it says, "Prisoners 11 Schedule Report." It says -- 12 MS. : Mm-hmm. 13 MR. : -- MCC New York. 14 MS. : Mm-hmm. 15 MR. : Do you know if that would 16 be who was being produced to the U.S. Marshals 17 the following day? 18 MS. : Yeah. That is what it is. 19 It's a court list. 20 MR. : Okay. 21 MS. : Yeah. Basically, it's a court 22 list. 23 MR. : Okay. So, when I open 24 this up, on the first page there, it starts 25 with two inmates. The second inmate down, it EFTA00110053 LIMITED OFFICIAL USE 53 1 says, " ." Or I -F-R-A-I- 2 N. 3 MS. : Mm-hmm. 4 MR. -: It shows a date of birth. 5 A time. A time. The time says 8:53, and then, 6 it says, 8/9/2019. Underneath production 7 reason, it says, "TF," and the description 8 says, "Transfer within." And then 9 MS. : Mm-hmm. 10 MR. : -- it says, "MCC New 11 York." And then, it does say, next to that, 12 typed court. Now, under that, it says, "Judge. 13 MCC 202. 20T. GEO." Do you know what that 14 would stand for? 15 MS. : No. I'm not. Hmm-mm. 16 MR. : So, the MCC to GEO. You 17 wouldn't understand that that -- 18 MS. : Oh. 19 MR. -: -- meant -? 20 MS. : Oh. GEO. MCC to GEO. That 21 means that GEO is a private prison. 22 MR. : Correct. 23 MS. : So, I would think that GEO, 24 that's, like - yeah - that's a mnemonic for a 25 private prison. EFTA00110054 LIMITED OFFICIAL USE 54 1 MR. : Okay. And then, when it 2 says, "Destination description," it says, 3 "WAB/MED summary." Does that tell you 4 anything? 5 MS. : Yeah. Well, WAB. WAB means 6 With All Belongings. Now, /MED summary means 7 medical summary. So, when I'm first hearing 8 you say WAB, that lets me know that the person 9 is leaving. That means with all belongings. 10 So, typically, when someone is scheduled for 11 transfer, you have the time to pack them out, 12 and so, they would come down, you know, prior 13 to the date. But with WAB, that means that the 14 person is leaving that day, and then they 15 should come down with all of their belongings. 16 Everything that they have because for whatever 17 reason, they're not coming back, they're going 18 somewhere else. 19 MR. : Right. So -- 20 MS. And then -. 21 MR. : -- so, it looks like -- 22 MS. : Mm-hmm. 23 MR. : -- these first two 24 people, the first two people both say, 25 "Transfer within." Both of them say MCC to EFTA00110055 LIMITED OFFICIAL USE 1 GEO. And then 2 MS. : Mm-hmm. 3 MR. : -- they both say WAB, 4 with the destination in the description. Now, 5 the other inmates that are listed on here, they 6 have various things -- 7 MS. : Mm-hmm. 8 MR. from the reason being 9 status hearing, to sentencing, to a change of 10 plea, to all things that look like they are 11 court related, but would you believe that these 12 first two, since it would say, "Transfer Within 13 MCC to GEO," and NAB, that means that they are 14 actually being transferred and not going to 15 court? 16 MS. : Yeah. I would - if I had an 17 opportunity to see that - I would understand 18 that that means that, exactly what you said, 19 that they are transferring. 20 MR. : Okay. 21 MS. : Somewhere other than 22 MR. : So, being that the MCC 23 was sent, actually, the one that was sent to 24 Receiving and Discharge was much earlier in the 25 day. But the one that was sent to the custody EFTA00110056 LIMITED OFFICIAL USE 1 was on August 8th, 2019 at 3:36 p.m. What 2 should have been known from that information? 3 MS. : That those inmates listed for 4 departing and were not coming back. 5 MR. : Okay. 6 MS. : Yeah. 7 MR. : So then, it was known by 8 the MCC, at least, or at least should have been 9 known by the MCC, that on August 8th, 2019, 10 that , who happens to be Epstein's 11 cellmate, was actually transferring from the 12 MCC to another institution. And specifically, 13 to GEO. 14 MS. : That part is accurate. The 15 only thing that is not included in that is, if 16 it was sent to R&D, and R&D may not have known 17 that was Epstein's cellmate. So, it may 18 not have alerted them that was 19 (Indiscernible *00:52:03) for them to then have 20 to discuss, to say, oh, he's not, you know, it 21 wouldn't have rang alarms for whomever that R&D 22 staff member was. 23 MR. : Right. And that's why 24 focused on the email to custody, because all of 25 custody, including all the lieutenants -- EFTA00110057 LIMITED OFFICIAL USE 1 MS. : Yeah. 2 MR. : -- as well as or 3 AW , and Captain 4 were actually sent -- 5 MS. : Yeah. That -- 6 MR. : -- that email. 7 MS. : -- okay. Then that is - yeah - 8 that is different. That is different. 9 MR. : So, the fact that custody 10 received it, is there someone that should have 11 been alerted to the fact, or reviewed that 12 document, to know, huh, we got these two 13 inmates, one of them is Epstein's cellmate. 14 You know, we now know that is leaving 15 from the institution. Is there someone that 16 should have been responsible for catching that? 17 MS. : The one thing I will say is 18 that, unless you are actually looking at the 19 court production list, to vet it, a person may 20 have just seen that as another court production 21 list. If it wasn't actually read, to see, you 22 know, for - to determine, okay, this inmate is 23 leaving, and who is he associated with? 24 MR. : Absolutely. 25 MS. : So -- EFTA00110058 LIMITED OFFICIAL USE 58 1 MR. : And that's kind of - and 2 I apologize if I -- 3 MS. : -- no. 4 MR. : I apologize if I 5 wasn't clear. What I'm saying is -- 6 MS. : Mm-hmm. 7 MR. : -- should someone have 8 reviewed it? Is there someone that should have 9 - being that it was sent to all these people in 10 custody - is there someone that really should 11 have looked at it -- 12 MS. : Mm-hmm. 13 MR. : -- as opposed to could 14 have looked at it? 15 MS. : Yeah. No. That's not 16 necessarily the responsibility of custody to 17 view -. There is -. I will say this. There 18 is no procedures in place, or their 19 responsibility that exists, that would say that 20 custody had to review a court production list. 21 Typically, they don't -. They may have 22 received a list as a courtesy. But okay. It's 23 a courtesy. It wasn't necessarily something 24 that they may or may not have to have some, you 25 know, to do something with the list. It's not EFTA00110059 LIMITED OFFICIAL USE 1 2 MR. : Okay. 3 MS. : -- it's just a courtesy. It's 4 nothing more than that. 5 MR. : Okay. Now, I have an 6 email here, it's from you to Lamine N'Diaye. 7 Do you know who that is? 8 MS. : Lamine N'Diaye. Yes. He was 9 the former warden. 10 MR. : Okay. Great. And the 11 subject, it says, "Epstein, Jeffrey Edward," 12 and then it gives his reg number. It was sent 13 Saturday, August 10th, 2019, at 4:35 p.m., and 14 in the body of the message, it says, "So far, 15 this is the documentation I have in my 16 possession." And it's signed your name, 17 Associate Warden, MCC New York." 18 So, do you recall if you were tasked with 19 obtaining documentation on Warden N'Diaye's 20 behalf? 21 MS. : He didn't specifically task me 22 with anything. I just know that, when 23 something happens, that part of your 24 responsibility as an AW is to try to gather 25 documents. Now, I didn't have a specific EFTA00110060 LIMITED OFFICIAL USE 60 1 responsibility of securing the scenes. If 2 that's correctional services, and that is what 3 they do. But I, certain things, I just 4 inherently, or instinctively, knew that I 5 should try to assist with. But I wasn't given, 6 you know, the instruction that Warden N'Diaye 7 did, relayed to me was to report to the 8 institution because of, you know, the death. 9 And from that, I already knew, or in my head, 10 on the way there was planning of what I wanted 11 - one of the things that I needed to do to 12 assist with the matter. 13 MR. : Okay. So, you 14 independently took this task on, to collect all 15 these documents? 16 MS. : I did. 17 MR. : Okay. 18 MS. : I must admit I did. 19 MR. : Okay. Great. So, I have 20 the document opened that you provided to him. 21 It's an attachment to your email saying what it 22 was that you collected. 23 MS. : Mm-hmm. 24 MR. : It starts with, 25 "Documentation re: Epstein, Jeffrey -- EFTA00110061 LIMITED OFFICIAL USE 1 MS. : Mm-hmm. 2 MR. Jeffrey Edward, 3 Deceased." And then, it talks about Sentry 4 reports. Like, the PPE-44, or PPE-37, and all 5 the way down to a PR-15. And then, it talks 6 about BOPWARE, label, administrative detention 7 order. And then, a few down, which is directly 8 in the middle of the first page, or slightly 9 below the middle, it shows, "Court 10 documentation regarding WAB." And this is 11 under -- 12 MS. : Okay. 13 MS. : -- under the heading, 14 "Documentation -- 15 MS. : Okay. 16 MR. : -- re: 17 Reg number 85993-054." And then, it says, 18 "Cellmate." It says, "Court documentation 19 regarding WAB, 8/9/19." Do you know what court 20 documentation is you were referring to? 21 MS. : Well, it had to be the court 22 list, then. Is it the same thing that -? Are 23 you able to open the attachment? 24 MR. : That is the attachment. 25 So, it doesn't You didn't include in that EFTA00110062 LIMITED OFFICIAL USE 62 1 email the electronic versions of this. You 2 said, this is what I have collected. 3 MS. : Oh. 4 MR. : And within it, it says -- 5 MS. : Okay. 6 MR. : -- "Court documentation 7 regarding WAB, 8/9/19," and specific to 8 So, I am just wondering, what -- 9 MS. : Okay. 10 MR. what document were you 11 referring to? 12 MS. : What document? It had to 13 Hmm. I don't know. Unless I'm able to 14 actually look at my email. But if you are 15 saying WAB, that means I had to have seen 16 something -- 17 MR. : If you are actually -- 18 MS. : -- that says that -. 19 MR. : -- if you are in front of 20 your email, you can find this. Just go to your 21 sent emails. 22 MS. : Yeah. I have to go - hold on. 23 That's what I'm doing - but I have to go in my 24 archives. 25 MR. : Right. EFTA00110063 LIMITED OFFICIAL USE 1 MS. : You know? 2 MR. : Okay. So, yeah. 3 MS. : But when I open -- 4 MR. : This might help refresh 5 your memory, so we can actually, you can 6 actually look at what it is that I am talking 7 about. 8 MS. : Okay. 9 MR. : So -- 10 MS. : Yeah. 11 MR. : -- again, it would be, it 12 will probably take a little while -- 13 MS. : Okay. 14 MR. : -- because it was a long 15 time ago. 16 MS. : Yeah. 17 MR. : But August 10th, 2019 -- 18 MS. : Mm-hmm. 19 MR. : -- and again, the email 20 was sent at exactly 4:35 p.m. 21 MS. : Okay. Give me one second, 22 because like I said, I have to go in the 23 archives. 24 MR. : Sure. 25 MS. : Okay. Okay. To N'Diaye. EFTA00110064 LIMITED OFFICIAL USE 64 1 MR. : And did you happen to get 2 to that email yet? 3 MS. : No. Hmm-mm. 4 MR. : Okay. 5 MS. : But the way that this Okay. 6 Hold on. Just wait. I got this. Okay. You 7 said Hmm. Not -. I'm doing an advanced 8 search. And because it's the archives, it's a 9 little slow. It's not -. It's not on my 10 present Google Drive. 11 MR. : Yeah. No. I understand. 12 Same thing when I look for my own emails. If 13 it's, like, more than six months to a year old 14 15 MS. : No. 16 MR. : =- it takes a while. 17 MS. : Okay. Now - okay - I'm in old 18 stuff now. Okay. You said 8/9, 8/10/19. Oh. 19 MR. : 11. 20 MS. : Okay. I'm in nine. That's why 21 I had to do with it. Okay. Okay. Okay. 22 see. I see the Word attachment that is there. 23 Okay. 24 MR. : Okay. You did find the 25 email? EFTA00110065 LIMITED OFFICIAL USE 65 1 MS. : I - yes - I was able to find 2 the email. 3 MR. : Great. 4 MS. : Mm-hmm. 5 MR. : So then, yeah. So, you 6 see where the Word attachment. Do you see, 7 again, middle of the page, where it says, 8 "Documentation, Re: ." 9 MS. : Yeah. 10 MR. : And that - yeah - that 11 first document is the one I was wondering 12 about. This court documentation regarding WAB, 13 8/9/19. 14 MS. : Mm-hmm. 15 MR. : And I'm just trying to 16 refresh, see if you can remember what document 17 you would have -- 18 MS. : What -- 19 MR. : -- been talking about. 20 MS. : -- what I could do is, hold on, 21 because I'm trying to -. I'm trying to over 22 document that I have. Okay. So, what -. Let 23 me first forward this to my present email, so I 24 won't lose it. And then, I'm going to go, 25 because I had a folder of documents that I did EFTA00110066 LIMITED OFFICIAL USE 66 1 maintain because of that, I kept receiving, 2 like, inquiries after as to what documents I 3 had. And so, let me see what I -. See if I 4 have anything that shows that. Okay. Hold on. 5 I'm going to have go out -. Okay. So, I have 6 Okay. One thing I had, that I have a title 7 for was just, like, was his 8 (Indiscernible *01:04:43) and entry 9 information. Special Housing review. Okay. 10 That's not showing me the court date. R&D. 11 Okay. Hold on one second. Let me see which 12 drop file. No. The drop file. (Indiscernible 13 *01:05:16). Let me see. Man, I don't -. 14 That, as an attachment. I don't have that as 15 an attachment. I do -. I am able to look at 16 other things. But a court list. I don't have 17 that as a court list. I don't have the court 18 list. 19 MR. : Now, you're talking about 20 electronically, or are you referring to -- 21 MS. : Mm-hmm. 22 MR. : -- okay. 23 MS. : Yeah. Because I saw - there 24 were things that I saved. That's how I was 25 able to send them, you know, to other EFTA00110067 LIMITED OFFICIAL USE 67 1 individuals. Meaning, in the agency. When 2 there was a request. But that, I don't see, 3 for whatever reason. I don't see that file. I 4 mean, I don't see that. 5 MR. : Now, it sounds like this 6 specifically was, they were documents that you 7 obtained physically. 8 MS. : Mm-hmm. 9 MR. : Do you know, do you still 10 have any of those documents? When you say you 11 kept the file -- 12 MS. : No. 13 MR. : -- are they hard copy -- 14 MS. : No. 15 MR. : -- files? 16 MS. : No. It's not a hard copy file. 17 Any hard copy files, they were turned over. 18 Items that I have were turned over. And then, 19 there was some things that were still in my 20 possession. I have the emails where it shows 21 who it is that I turned them over. It was 22 myself and Lieutenant that was actually 23 working together. She was assigned to SIS. 24 Working together to gather the documents. And 25 then, there was some documents that were turned EFTA00110068 LIMITED OFFICIAL USE 68 1 over to the FBI. And that could, in fact, have 2 been one of the documents that was turned over 3 to the FBI. There should be a list of what was 4 turned over to them. 5 MR. : Okay. And do you know if 6 it was the FBI versus the OIG? 7 MS. : No. 8 MR. : You don't know who it 9 was? 10 MS. : I don't know because I - like I 11 said - any documents that Lieutenant 12 would have turned over, it should have been -. 13 There should be something, some kind of 14 document indicating what was turned over to 15 them. 16 MR. : And do you know -. So, 17 there should be some kind of a receipt with the 18 documents 19 MS. : There should be. 20 MR. : -- that were provided? 21 MS. : Yeah. Mm-hmm. 22 MR. : And that would be 23 something that Lieutenant would have? 24 MS. : If she, in fact, turned those 25 documents over, she worked in SIS. EFTA00110069 LIMITED OFFICIAL USE 69 1 MR. : Okay. So, it wouldn't -. 2 You didn't turn it over to the FBI. She -- 3 MS. : No. Yeah. I didn't have any 4 contact with the FBI agents directly. At all. 5 MR. : Okay. And then, as far 6 as - what is your understanding of what it 7 means, though, when it says, "Court 8 documentation regarding WAB." Do you know what 9 court -- 10 MS. : That was -- 11 MR. : -- documentation you 12 would be referring to? 13 MS. : -- that was (Indiscernible 14 *01:08:04). I don't know specifically, but 15 obviously, it would have to have been something 16 that said for, in order for me to write WAB, 17 without being able to look at it right now, it 18 obviously had to be something that said WAB on 19 it, and listed that inmate's name. Other than 20 that, I would not have wrote that. 21 MR. : And do you think that 22 that would have been that Receiving and 23 Discharge document that the SHU staff would 24 have utilized when they transported to 25 R&D? EFTA00110070 LIMITED OFFICIAL USE 70 1 MS. : It wouldn't have been his - 2 that document from SHU. Because I didn't even, 3 I didn't go to SHU that day. So 4 MR. : Sorry. But -- 5 MS. : -- (Indiscernible *01:08:42). 6 MR. : -- the court production 7 list that, I'm just saying that, because my 8 understanding is, R&D, you know, prints out all 9 the same court production lists, and they 10 provide it to the different housing units, and 11 to the ops lieutenant, and to, you know, the 12 different various people that need to be in the 13 know with who is being produced. So, that is 14 all -- 15 MS. : Mm-hmm. 16 MR. : -- all I'm saying, is, 17 like -- 18 MS. : Uh-huh. 19 MR. : -- would it be the -- 20 MS. : A copy of it. You're saying a 21 copy. It could have -. It had to be a copy of 22 something. But I don't know if it was, if it 23 was the court production list, or some kind of 24 Sentry roster. That, because you could print a 25 Sentry roster also, that shows, like you said, EFTA00110071 LIMITED OFFICIAL USE 71 1 everybody, you know, movement. So, it had to 2 be a copy of something listing information as 3 to who was going out of the institution on that 4 particular day. 5 MR. : Okay. 6 MS. : That is the only thing I could 7 have - that I could surmise why I would have 8 wrote WAB. 9 MR. : Okay. Can I ask you just 10 to see if, you know, after the interview, if 11 you can, if you can track that down by any 12 means? Or if you may -. I don't know if you 13 can coordinate with Lieutenant - can ask 14 Lieutenant , as well - but if you could 15 just see if you, in fact, did make a copy, or 16 you know what you did with this document, or 17 figure out what that document was. And I don't 18 know how you would do that. So, I don't, you 19 know -- 20 MS. : Yeah. 21 MR. : -- you might not be able 22 to, but just, if you could just check. 23 MS. : Mm-hmm. That means all of 24 them, the documents that I listed, those things 25 were turned over. But okay. I will even look EFTA00110072 LIMITED OFFICIAL USE 1 at all of my emails I saved. Well, what I - 2 whom I turned things over to, or what I've 3 turned, what I turned over. 4 MR. : That would be great. 5 Specifically, we would be very interested in 6 that court documentation regarding, you know, 7 8 MS. : Mm-hmm. 9 MR. : And is it surprising to 10 you now, though, since again, like, you thought 11 that he was at court, and then released on, you 12 know, released from there, but now that you see 13 that you actually wrote, "Court documentation 14 regarding WAS," is that surprising? 15 MS. : Well, I won't say it's -. I 16 won't use the word "surprising." But it would 17 jog my memory to say, okay, you - like I Said - 18 if he left on WAB, I have something that says 19 WAB, that is what it was. WAB. But did I know 20 at the time, or was I in the know? No. This 21 is after the fact. 22 MR. : Right, right, right. No. 23 I'm just saying the, you know, it seems like a 24 lot of people seemed to think that he was, you 25 know, sent to court and released, whereas, you EFTA00110073 LIMITED OFFICIAL USE 73 1 know, as we just discussed, he was actually 2 transferred. So, I was just wondering if that 3 surprised you to find out that, oh, wow, I 4 actually did know he was WAB after the, you 5 know, on -- 6 MS. : Yeah, well -- 7 MR. : -- August 10th. 8 MS. : -- yeah, that part, because 9 that is, like you said, that has been, that has 10 been the discussion all along, that went 11 to court, and he was released from court. So, 12 I'm hoping that my information is accurate, but 13 typically, when you - because it's now, it 14 seems like, it conflicts, obviously, with what 15 everyone's recollection is - but typically, 16 when you see WAB, that means With All 17 Belongings, that the person is leaving, they 18 are transferring. Now, how the whole court got 19 into play, maybe, I don't know. And I don't 20 want to speculate, because it is just going to, 21 you know, further confuse everything. 22 MR. : Okay. Yeah. No. I 23 think we've definitely cleared up the fact that 24 he was WAB, and he transferred, just upon the 25 emails that we, you know, I talked to you about EFTA00110074 LIMITED OFFICIAL USE 74 1 with the U.S. Marshal Service, as well as this 2 one. But I was just, you know, for you being 3 that you are the one who gathered that 4 document, I'm just hoping that we can figure 5 out where that document went, because -- 6 MS. : Sure. 7 MR. : -- you know, it's really 8 the R&D document, and I'm hoping that that's 9 what it is, that we can track down, is whatever 10 they -- 11 MS. : Well -- 12 MR. : -- generated. 13 MS. : I want to clarify. It may 14 not be their specific document. If it's a 15 document that says WAB. 16 MR. : Absolutely. 17 MS. : It doesn't necessarily have to 18 be their, you know -- 19 MR. : No, no. Absolutely. I'm 20 just hoping that it is. And that we can track 21 it down 22 MS. : Okay. 23 MR. : -- is what I'm saying. 24 Like, I don't know what it is, because again, 25 it's not -- EFTA00110075 LIMITED OFFICIAL USE 1 MS. : Yeah. 2 MR. : -- specific. But yeah, I 3 was just hoping that you would be able to, you 4 know, provide some clarification on that 5 document. 6 MS. : Yeah. 7 MR. : Now, just to back up a 8 little bit. Now, what was your responsibility, 9 like, the AWs are kind of split. Right? 10 There's two AWs, and one is in charge of one 11 thing, and another is in charge of another. 12 What - when you were at the MCC - what were you 13 in charge of on August 9th and 10th? 14 MS. : What? I was in - I had 15 oversight of correctional services. 16 MR. : Okay. So, you actually 17 did have oversight over this incident? 18 MS. : Mm-hmm. 19 MR. : And is that -- 20 MS. : Well -- 21 MR. : -- is that why you would 22 have -- 23 MS. : I think what -- 24 MR. : -- gathered all those 25 documents? EFTA00110076 LIMITED OFFICIAL USE 76 1 MS. : -- not specifically only 2 because of that. But because I just know there 3 is an incident that happened, because I've been 4 an exec staff, and there is certain things that 5 you should gather. But it wasn't because I was 6 the AW of correctional services. Now, as an 7 AW, or someone in exec staff, you should just 8 know kind of what to gather anyway. 9 MR. : Okay. 10 MS. : What information to gather. 11 MR. : Okay. Great. And on 12 that note, would that have been something that 13 you would have gathered, specifically the R&D 14 court production list? 15 MS. : No. Hmm-mm. 16 MR. : No? 17 MS. : No. Mm-hmm. 18 MR. : But it's just something 19 that had -. Something that was court 20 production for with WAB, you just don't 21 know what it was. 22 MS. : I gathered all of the 23 information that I knew logically was 24 associated with Epstein. 25 MR. : Okay. EFTA00110077 LIMITED OFFICIAL USE 77 1 MS. : That was, it's just logical 2 connections, if you wanted - if you know you 3 have an incident, and you know something 4 happened, in the Special Housing, and there is 5 only two inmates that are in the cell, you know 6 you are not only going to focus on, quote 7 unquote, "The victim." You have to then also 8 turn your attention to who was in the cell at 9 the time. So, to me, anything that I gathered, 10 as far as Sentry information for Epstein, or 11 his Special Housing Unit record, I gathered the 12 same for his cellmate because that's just a 13 logical thing to do. 14 MR. : Sure. And that is what 15 I'm asking for my question. Being that you 16 logically gathered these documents, and you can 17 see that you wrote the document, I'm asking, 18 like, can you recall what would be - what would 19 have been the logical document that you would 20 have gathered, that would have showed that he 21 was -- 22 MS. : Oh, I understand what you mean. 23 MR. : WAB? 24 MS. : Mm-hmm. I don't, I don't know 25 if I would have gone in R&D to see, or if I ran EFTA00110078 LIMITED OFFICIAL USE 78 1 - or if it was a Sentry roster, like, a log, a 2 PP-37 log that showed something. But I don't - 3 thinking about it now - I honestly, I can't say 4 that, because I do have other R&D documents, 5 but I don't know if that was that R&D court 6 roster. 7 MR. : If you don't mind, and if 8 it's not too much trouble, can you just send me 9 an email with the documents that you do have, 10 and then I can go through them to figure out 11 what it is we have and don't have, and what we 12 need, and don't need? 13 MS. : Sure. 14 MR. : With regards to this 15 incident. 16 MS. : Okay. 17 MR. : You can just, like, and 18 not right now. After, after we're done. 19 MS. : Okay. Not right now. 20 MR. : Yeah, yeah. 21 MS. : Okay. 22 MR. : No, no, not right now. 23 MS. : Okay. Mm-hmm. 24 MR. : All right. So -- 25 MS. : And I will also look at other EFTA00110079 LIMITED OFFICIAL USE 79 1 emails that I sent out, because it's been, like 2 I said, it's been, it's been several requests 3 to show what I had and what I didn't have. So, 4 any other emails, I will be more than happy to 5 share with you. 6 MR. : Yeah. If you can just, 7 if that's possible, just to forward me those 8 emails that you have provided 9 MS. Mm-hmm. 10 MR. that had documents 11 with regarding, with regard to the matter. 12 MS. Mm-hmm. 13 MR. : That would be great. So, 14 being that you were the AW in charge of 15 custody, you would probably be perfect to 16 answer some of these questions. So, since 17 Epstein was required to have a cellmate, what 18 should have happened once the notification was 19 made that was being transferred? 20 MS. : He should have received another 21 cellmate. 22 MR. : And obviously, we 23 probably did just cover this, and just because 24 we got sidetracked, and you said that SHU 25 staff, once they found out that was EFTA00110080 LIMITED OFFICIAL USE 1 transferred, they should have notified, 2 Lieutenant wasn't there, so they should 3 have notified either the activities lieutenant, 4 or the operations lieutenant. Is that what you 5 said? 6 MS. : I'm saying that someone of a 7 supervisory nature, yeah, should have been 8 notified. 9 MR. : But who was it that 10 should have notified them? Would it be the OIC 11 of the SHU? Would it be the person that 12 transferred to R&D? You know it, when I 13 say transferred, I mean escorted him to R&D. 14 Should it have been R&D themselves? Who should 15 have made the notification to the lieutenant? 16 MS. : And without me spinning the 17 tale, and pointing a finger, because lack of, 18 it didn't, it all depends. For instance, if 19 the SHU staff knew that - and that's why 20 it's just kind of, I don't know, a question 21 mark - if the SHU staff knew that was not 22 coming back, then that would mean that they 23 would know that he wasn't, he was not going to 24 have a cellmate. So, without knowing what 25 everybody knew, I -- EFTA00110081 LIMITED OFFICIAL USE 1 MR. : Okay. So, I'll -- 2 MS. : -- (Indiscernible *01:17:59) 3 MR. fill you in on that. 4 MS. : Right. 5 MR. : So 6 MS. : Yeah. 7 MR. . Do you know 8 who Roberto is? 9 MS. : Yes. 10 MR. : So, he was the SHU OIC at 11 the time. He's the one who escorted Epstein to 12 attorney conference that morning. And -- 13 MS. : Mm-hmm. 14 MR. : -- at the same time, they 15 were jointly escorted with, I believe it was 16 Monge, but one of the, one of the SHU, one of 17 the internal staff who provided, produced 18 to R&D. They both did the 19 MS. : Mm-hmm. 20 MR. they both escorted 21 their inmates together. And during their 22 conversation, it was discussed that was, 23 in fact, WAB, and -- 24 MS. : Okay. 25 MR. : -- would be getting a new EFTA00110082 LIMITED OFFICIAL USE 1 cellmate. 2 MS. : Mm-hmm. 3 MR. : So, knowing that 4 was present, and there was an internal employee 5 that was present, and they both had this 6 discussion, and both said that they 7 MS. : Mm-hmm. 8 MR. : -- knew that he was WAB, 9 does that clue you in a little bit more of what 10 11 MS. : Yeah. 12 MR. : -- actions should have 13 taken at that time? 14 MS. : Yes. Either one of them should 15 Now, either one of them. So, you said 16 was was the OIC? 17 MR. -: was the OIC. He 18 was the one that was -- 19 MS. : Okay. 20 MR. : -- bringing Epstein, ana 21 the conversation was had with both Epstein and 22 , saying, , we know you're leaving, 23 you're WAB. Epstein, you'll get a new cellmate 24 by the end of the day. 25 MS. : Now, as the OIC, EFTA00110083 LIMITED OFFICIAL USE 1 should have then contacted the lieutenant. 2 MR. : Okay. So, being the AW 3 in charge of custody, do you believe that -- 4 MS. : Mm-hmm. 5 MR. : -- it was really 6 that should have made that notification? 7 MS. : Because as the OIC, that means 8 that you are, if you look at the post orders, 9 you are basically have oversight of SHU, for 10 lack of a better term. You should make sure 11 that the rounds are being conducted. If 12 inmates needs to be pulled out for whatever 13 reason. That the appropriate inmates are going 14 in their appropriate cages, so that, you know, 15 separate tees are adhered to. That inmates are 16 being fed. That sanitation is being conducted. 17 And if, and because you are now telling me 18 that this individual, whomever the individual 19 is, is saying that they were aware that Epstein 20 needed a cellmate, and that his cellmate was 21 leaving, they knew, so when you know something, 22 then you should, either you're going to - if 23 you didn't want to make the determination to 24 make another decision about who the cellmate 25 would be, then you need to contact your EFTA00110084 LIMITED OFFICIAL USE 1 supervisor. 2 If you, yourself, can't make a decision, 3 you contact your supervisor who is authorized 4 to make that decision. But you must make the 5 contact in order for your supervisor to know. 6 And as an OIC, you are aware of who you can 7 contact. 8 MR. : Yeah. 9 MS. : That's plainly known that you 10 can contact the lieutenant when something is 11 going on, especially for something that, it's 12 not, it's the Special Housing Unit, that you 13 must be able to get a decision maker. 14 MR. : Okay. So, he should have 15 notified a lieutenant, is basically the long 16 and short of it? 17 MS. : Yes. Yes. The long and short 18 of it, he should have notified a lieutenant. 19 MR. : Okay. And are you aware 20 if - we are going to just touch on counts and 21 rounds that were conducted in the SHU - are you 22 aware if the SHU counts and rounds were not 23 conducte by the SHU staff on August 9th and 24 10th of 2019? 25 MS. : I was aware after the fact that EFTA00110085 LIMITED OFFICIAL USE 85 1 the staff members indicated that they did not 2 make rounds. 3 MR. : And what did you become 4 aware of? Can you just give me a little bit 5 more clarity on that? 6 MS. : Well, I became aware of it just 7 like everybody else, you know, that the staff 8 member are saying that they didn't make rounds. 9 But was I aware of it on the day? No. 10 MR. : No, no, no. I'm sorry 11 MS. (Indiscernible *01:21:57). 12 MR. : -- so, what I mean is, 13 like, what did you became aware of? What staff 14 members, and what did you learn? 15 MS. : Oh. Oh, oh. Okay. The two 16 staff members that were assigned on the morning 17 watch shift, that they have said that they did 18 not make rounds. 19 MR. : And is that Tova Noel and 20 Michael Thomas? 21 MS. : Yes. Those were the two staff 22 members that worked that shift. 23 MR. : And do you remember who 24 you learned that information from? 25 MS. : No. Hmm-mm. EFTA00110086 LIMITED OFFICIAL USE 86 1 MR. : Okay. Did either Thomas 2 or Noel say that that, you know, tell you that 3 information directly? 4 MS. : No. I didn't -. I haven't 5 even, from the day of the incident, I have not 6 laid eyes on either one of them. 7 MR. : Okay. 8 MS. : Besides on TV. So, I have not 9 spoken to either one of them. Well, no, and 10 I'm not going to say I haven't spoken to either 11 one of them. I did call to make welfare checks 12 on staff members, to see if they were okay, and 13 that was weeks after, because they haven't been 14 at work, and that's what we were told to do, to 15 call the staff members, just to say, you know, 16 if you're okay. Because they physically were 17 not in the institution. But as far as 18 discussing the incident, and what they did and 19 did not do, I did not engage in that. 20 MR. : Okay. And did you learn 21 anything, you know, during your time on this, 22 did you learn anything about the accuracy of 23 the MCC SHU counts and rounds on August 9th and 24 10th of 2019? 25 MS. : You said did I run anything as EFTA00110087 LIMITED OFFICIAL USE 1 far as the -. 2 MR. : Did you learn if they 3 were accurate or not? Like, the counts that 4 they conducted, and the rounds they conducted. 5 Did you find out through your, you know, what 6 you were doing, did you learn if they were 7 accurate counts and accurate rounds? 8 MS. : The date, the date, you're 9 saying the date of when I was gathering the 10 information, or the documentation? 11 MR. : Or at any point. Did you 12 ever find out if the counts were either 13 accurate or not? And the rounds were accurate 14 or not. 15 MS. : Not specifically about the 16 counts and the rounds, but just like, like I 17 said, and like everybody else, of what has come 18 out, that they said that they did not do 19 counts. I mean, do rounds. 20 MR. : But had you heard 21 anything about, like, the counts being wrong? 22 Like, they're actually reporting the wrong 23 numbers, or anything like that? 24 MS. (Indiscernible *01:24:04). I'm 25 trying to remember. I know that there was, EFTA00110088 LIMITED OFFICIAL USE 88 1 there was discussion about whether or not the 2 count was done because, and I can't remember 3 exactly what happened to make that come up, but 4 I know there - we couldn't find certain count 5 slips. And I think somebody, and I can't 6 remember if it was Epstein, or r or 7 somebody was not keyed out. One of the inmates 8 was not keyed out, and if that, and my memory 9 is serving me properly, and the count should 10 have been affected by -- 11 MR. : Right. And did 12 MS. you know, inaccurate Sentry. 13 Inaccurate Sentry information. 14 MR. : -- okay. So, you are 15 aware of that then. Yeah. So, do you know, 16 it's, I think the inmate's name was Fernandes. 17 Does that ring a bell? Someone that -- 18 MS. : I -- 19 MR. : -- was found to have been 20 pass contraband, and then, they were removed 21 from the SHU and placed in R&D holding cell, 22 but they were not actually keyed out of the 23 SHU? 24 MS. : No. I don't - hmm-mm - I don't 25 remember that specific. Hmm-mm. EFTA00110089 LIMITED OFFICIAL USE 89 1 MR. : Okay. But you remember 2 someone wasn't keyed out, which messed up the 3 counts? 4 MS. : If you, it was something to 5 that effect. That there was somebody not keyed 6 out. I don't know if it was about SHU or about 7 the institution itself. But I know that there 8 was something about, there was some Sentry 9 inaccuracies that should have affected the 10 count. 11 MR. : Okay. And do you know if 12 that was documented anywhere, or you, you know, 13 provided information to anyone on that, that 14 you might be able to retrieve, to help, you 15 know, help us? 16 MS. : I'm going to try. 17 MR. : You know, you don't have 18 to do now. 19 MS. : Yeah. 20 MR. : But this is another one 21 of those -- 22 MS. : Okay. 23 MR. : -- things that if -- 24 MS. : All right. 25 MR. : -- you can put that to EFTA00110090 LIMITED OFFICIAL USE 1 your -- 2 MS. : Let me do Fernandes. 3 MR. : -- yeah. 4 MS. : Okay. 5 MR. : Yeah. So -- 6 MS. : Yeah. 7 MR. : -- if you can -- 8 MS. : Mm-hmm. 9 MR. : -- those two things. 10 One, whatever documents -- 11 MS. : What's his -? 12 MR. : -- (Indiscernible 13 *01:25:53). 14 MS. : What is Fernandes's register 15 number? 16 MR. : Let me pull that up. 17 That wasn't something I was going to touch on 18 with you, but since you brought it up, that's 19 the only reason I did. Let's see. All right. 20 And this one, I just have inmate Fernandes. 21 Let me -. Hold on. All right. So, it's 22 Leonardo. L-I-O-N-A-R-D-O. 23 MS. : Mm-hmm. 24 MR. : Fernandes. F-I-R-N-A-N- 25 D-I-S. EFTA00110091 LIMITED OFFICIAL USE 1 MS. : Mm-hmm. 2 MR. : Register number 86824- 3 054. 4 MS. : Okay. And you said he was -. 5 MR. : And there is, you 6 actually have an -. Actually, what I pulled up 7 was an email from to both you 8 and So, and it talks 9 MS. : And it said, it talks about 10 that? 11 MR. : No. It talks about the 12 incident, where it just talks about, the date 13 was Friday, August 9th, 2019, at 3:52 p.m., and 14 it just says, "On August 9th, 2019, at 15 approximately 1:37 p.m., while conducting 16 routine duties, the 9 South visiting officer 17 observed a female visitor produce an unknown 18 object from her waistband and hand it to inmate 19 Fernandez." And then, it just talks about, you 20 know, a little bit more of it. But this is the 21 individual -- 22 MS. : Okay. 23 MR. : -- that was not keyed out 24 of the SHU. And he was placed in R&D 25 MS. : Okay. EFTA00110092 LIMITED OFFICIAL USE 92 1 MR. : -- the R&D holding cell, 2 which caused the count numbers to be 3 inaccurately reported. Because the SHU staff 4 was still adding him on their count slips. 5 MS. : Yeah. Mm-hmm. Okay. Okay. 6 MR. : And does that -- 7 MS. : Okay. 8 MR. : -- does that -- 9 MS. : Okay. 10 MR. : -- does that refresh your 11 memory at all? 12 MS. : Hmm-mm. But you're saying, so, 13 but email doesn't talk about that. It 14 just talks about -- 15 MR. : No, no, no. 16 MS. : -- (Indiscernible *01:28:02). 17 MR. : It just talks about the 18 incident. 19 MS. : Okay. 20 MR. : It doesn't -- 21 MS. : Okay. 22 MR. : -- it doesn't talk about 23 the fact that it -. That's something that our 24 investigation has revealed. 25 MS. : Oh, okay. EFTA00110093 LIMITED OFFICIAL USE 93 1 MR. : Because we had to figure 2 out why are, you know, are the counts accurate 3 or not, how do we find out if they -- 4 MS. : Mm-hmm. 5 MR. : -- actually conducted the 6 counts, or didn't conduct the counts. 7 MS. : Okay. 8 MR. : So, when we went through 9 everything, we found that there was some 10 discrepancies based upon what was on the 11 lieutenant's log versus what was on 12 institutional count, which was on the, you 13 know, count slips. There are different things. 14 And then, you know, looking through the 15 lieutenant log, we see that, on August 10th, 16 during the night, at around 12:30 a.m., it has 17 a note in there, saying that they keyed 18 Fernandez out of the SHU, or out of the SHU, 19 and into wherever, R&D. And that's how we were 20 able to figure out, okay, these count slips are 21 actually all off. 22 MS. : Oh. 23 MR. : They are saying that they 24 were counting this many bodies, whereas, in 25 fact, there was one less because he wasn't EFTA00110094 LIMITED OFFICIAL USE 94 1 there. 2 MS. : Okay. Yeah. That doesn't jog, 3 that doesn't jog my memory for that, though. 4 MR. : Okay. 5 MS. : Yeah. 6 MR. : This is kind of the first 7 you're hearing of that, then? 8 MS. : Yeah. I don't, I don't -. If 9 for whatever reason, this is, I don't recall 10 anything about that. 11 MR. : There was something you 12 recalled about the counts being off, but it 13 wasn't that? 14 MS. : Yeah. But it wasn't that. 15 Hmm-mm. 16 MR. : But you did know that 17 someone wasn't keyed out? 18 MS. : I, perhaps out of the 19 institution, and again, if something came up 20 about the count, but I don't recall there being 21 - and because it's -- 22 MR. : Well, I think -- 23 MS. : -- (Indiscernible *01:29:35). 24 MR. : -- well, there was a 25 question that - and maybe this is something EFTA00110095 LIMITED OFFICIAL USE 95 1 that the warden asked you - but Ray Ormond, who 2 I'm assuming you know - correct? - the regional 3 director at the time. 4 MS. : Yeah. Mm-hmm. 5 MR. : He sent an email to 6 Warden N'Diaye, on the, I believe the 10th, 7 asking, "Why are the counts off? Why does one 8 say 72, and one say 73?" Maybe. 9 MS. : For Special Housing? 10 MR. : For Special Housing. 11 Correct. So, maybe -- 12 MS. : Mm-hmm. 13 MR. : -- that's where they 14 asked you. Do you recall? 15 MS. : And you said, when did, that 16 happened on the day of 8/10? 17 MS. : Yeah. That would have been 18 Ray, Mr. Ormond asking N'Diaye on 8/10 because 19 20 MS. : Mm-hmm. 21 MR. : -- he was provided all 22 the count documentation, and asking him -- 23 MS. : Mm-hmm. 24 MR. : -- why are these counts - 25 ? Why did the count - oh, no. He said, "Why EFTA00110096 LIMITED OFFICIAL USE 1 did the count change?" That's what it was. 2 MS. : Okay. 3 MR. : He was, like, from the 4 10:00 p.m. 5 MS. : That's probably -- 6 MR. : -- count to midnight, it 7 changed from 73 down to 72 , and our 8 investigation has revealed it's because this 9 person was never keyed out of the SHU -- 10 MS. : Mm-hmm. 11 MR. : -- until -- 12 MS. : That is maybe that is what 13 prompted it, but like I said, I knew something 14 happened with the count, and from that, I - 15 myself and Lieutenant were trying to 16 gather the count slips, and it should be a 30- 17 day file maintained in control, and we were not 18 able to find the count slips. So, I didn't 19 know it. Well, now that you're telling me, I 20 didn't know it was because of that. And there 21 is some things that I was in the know about, 22 that I - or I wasn't - but I knew it had 23 something to do, like, is that with the counts, 24 and we were told to get some of the count 25 slips. EFTA00110097 LIMITED OFFICIAL USE 1 MR. : Okay. But just, you 2 don't have anything to add to that. This is 3 all kind of -- 4 MS. : Mm-hmm. 5 MR. : -- more new information 6 for you? 7 MS. : Yes. Mm-hmm. 8 MR. : Okay. We can move on, 9 then. 10 MS. : Okay. 11 MR. : What is a lieutenant - or 12 sorry - a SHU lieutenant round? So, sorry. 13 So, when a lieutenant conducts a round in the 14 SHU, what should that consist of? 15 MS. : So, when you're the SHU 16 lieutenant, you -- 17 MR. : And I don't mean 18 specifically the SHU lieutenant. I said that 19 wrong. 20 MS. : Okay. 21 MR. : In the first. 22 MS. : Okay. 23 MR. : Just when a lieutenant, 24 whether it's an activities, a SHU lieutenant -- 25 MS. : Okay. EFTA00110098 LIMITED OFFICIAL USE 1 MR. : -- an activities 2 lieutenant, an operation lieutenant. When a 3 lieutenant goes to the SHU and conducts a 4 round, what should they be doing when they 5 conduct a round? 6 MS. : They should be walking around 7 and talking to the inmates. 8 MR. : So, is there, is the SHU 9 -. Is a lieutenant round the same thing as a 10 staff round, where you are supposed to go up 11 and actually check on the inmates? 12 MS. : Hmm. I'm not going to say it's 13 the exact same thing because the staff in SHU, 14 they actually have to record that they have 15 done rounds. And by them recording that, they 16 are indicating that they recorded timely 17 rounds, and that they actually are able to say 18 with certainty that they looked, you know, that 19 they verified that all the inmates are there, 20 and that they are alive. Versus a lieutenant, 21 what your responsibility is, you are just 22 making, you are generally making sure that you 23 go around and ensure that everything is okay. 24 But are you specifically and stopping at every 25 single cell? I wouldn't say necessarily that EFTA00110099 LIMITED OFFICIAL USE 1 that is exactly, but it mimics the same 2 requirement as the staff. 3 MR. : Okay. So, if is 4 gone at 8:30, approximately 8:30 a.m. on August 5 9th -- 6 MS. : Mm-hmm. 7 MR. : -- and there is 8 obviously, I think there is supposed to be at 9 least, what? One lieutenant round conducted in 10 the SHU per shift? 11 MS. : Mm-hmm. 12 MR. : Is that -- 13 MS. : Mm-hmm. 14 MR. : -- is that correct? 15 MS. : Mm-hmm. 16 MR. : So, if there is an 17 activity, you know, the SHU lieutenant is out, 18 so there is an activities or an ops lieutenant 19 conducting a round, both the day shift and the 20 night shift, and then, the operations 21 lieutenant conducting one in the morning shift. 22 Should any of those lieutenants realized, when 23 they were doing their rounds, that Epstein, you 24 know, was gone, and/or Epstein was by 25 himself? EFTA00110100 LIMITED OFFICIAL USE 100 1 MS. : Yeah. If - now, that's a 2 would say yes. I would say yes. 3 MR. : And how should have they 4 known that? What should have the -. What 5 should have clued them in on the fact that 6 is gone, and Epstein is by himself? Or 7 if Epstein is in attorney conference, there is 8 just no one in the cell in general. 9 MS. : Well -- 10 MR. : Since they have names on 11 the door tags, like you said. 12 MS. : -- that's what I was going to - 13 yeah - that's what I was going to say. But the 14 names on the -. The names on the door tag. 15 When someone leaves, you should remove the door 16 tags, so then, in fact, there should have only 17 just been one tag on the door. You wouldn't 18 have, you wouldn't have two tags on the door if 19 there is only supposed to be one person in 20 there. So, the tag should have been removed. 21 And -. 22 MR. : Do you know if the tag 23 was removed for 24 MS. : That, I don't know if 25 tag was removed, because I didn't go in the EFTA00110101 LIMITED OFFICIAL USE 101 1 Special Housing Unit. So, I don't know if his 2 tag was removed. But you - by us talking - you 3 indicated that the SHU staff was aware that he 4 was leaving. So, they put the tags up, they 5 should remove the tags. And there would be no 6 reason to keep a tag on the door, indicating 7 that there is two inmates. One, when you are 8 aware that he is no longer going to be there. 9 MR. : But should -- 10 MS. : Yeah. 11 MR. : -- should those 12 lieutenants have conducted a round on basically 13 Epstein's cell? 14 MS. : I would -. You would conduct a 15 -. I would say yes. Because especially if you 16 have a highlighted inmate, or an inmate of 17 great concern. Or someone that you know you 18 need to check on. If you are not going to look 19 at anybody else's cell, you would definitely 20 look at, or check on, the inmates that are of 21 concern, to even say, hey, you okay? Or, you 22 know, just to talk with them, or physically see 23 them. So, I would say that you would - yeah - 24 that you would have looked in his cell to see 25 something, that something is going on. EFTA00110102 LIMITED OFFICIAL USE 102 1 MR. : Now, what about -- 2 MS. : And then -. 3 MR. : -- if Epstein -. So, if 4 they are conducting their rounds when Epstein 5 is in attorney visits, should they still be 6 checking in on his cell itself, like, to make 7 sure everything is okay with his cellmate, or 8 anything like that? 9 MS. : Well, if he was, if he was 10 physically inside of his, he physically was not 11 inside the cell at the time, but the only way 12 for you to know, because why would the 13 lieutenant automatically know that he's in 14 attorney conference? So, you still would have 15 looked in his cell. 16 MR. : So, they - regardless, in 17 this specific, you know, Epstein is your 18 highest profile inmate at the time 19 MS. : Mm-hmm. 20 MR. : -- any time a lieutenant 21 basically goes into that SHU, they should 22 really check on him? And check on that cell? 23 MS. : I would say so. 24 MR. : Okay. But that is more 25 of a, you know, it sounds like it's not EFTA00110103 LIMITED OFFICIAL USE 103 1 necessarily a policy, but just, that's good 2 practice. Is that what you are saying? 3 MS. : Yeah. Yeah. That's what I'm 4 saying. And because it was known, as you and I 5 discussed, that he should have a cellmate. So, 6 there's certain things that you would be 7 checking for, you would be checking for his 8 welfare, and you would also be checking to make 9 sure that those recommendations were adhered to 10 because you want to make sure, with certainty, 11 if you are saying that you made the round, you 12 are annotating it in the book that you made the 13 round. And you would want to say that you 14 actually went around to them, and you checked 15 on these things. 16 MR. : But is there any kind of 17 BOP or MCC policy or directive that, you know, 18 they would have violated, if they didn't in 19 fact check on Epstein's cell? 20 MS. : I can't say that it would be a 21 I don't know about the lieutenant, that 22 they would say that, because they didn't look 23 in one cell or two cells. But I do know, if 24 you are indicating, and then, that's another 25 thing. If you are, when you come inside of the EFTA00110104 LIMITED OFFICIAL USE 104 1 Special Housing Unit, there is a logbook. If 2 you are annotating in the logbook that you are 3 visiting, or if you are indicating in the 4 logbook that you are doing a round, you -. So, 5 I'm going to backtrack what I said before. 6 MR. : Well, there is an actual 7 log sheet that they sign. So, the lieutenants 8 actually have to sign that they conducted their 9 round. 10 MS. : So then, that's why I'm going 11 to backtrack then. If you are saying that you 12 did rounds, that means that you should have 13 looked in all of the cells. 14 MR. : Okay. And so, for a 15 lieutenant, that - and that, so, this is where 16 we've been getting kind of different 17 information - some lieutenants are saying, 18 absolutely, you need to go down each range, 19 check on every cell door. Other lieutenants 20 are saying, no, no, no, no, we're just supposed 21 to check in with the staff member that are in 22 there, and make sure that they don't have any 23 problems. Our rounds are really conducted on 24 the staff members, not on the inmates. So, 25 that is where I am - and there is nothing that EFTA00110105 LIMITED OFFICIAL USE 105 1 I can find, specifically in policy, that really 2 specifies that information. 3 MS. : Yeah. So, I - and that's where 4 I was kind of weaving back and forth. A 5 lieutenants' purpose, let's just say in the 6 general housing, like, general, you know, GP. 7 You are making rounds on the unit, you're 8 checking on, generally, you're checking on the 9 unit itself. And you don't, you would not go 10 down, and checking every cell, because that's 11 general population. You don't anticipate being 12 in SHU. And you are making yourself available 13 in the event that the staff member needs 14 something. So, you are physically supposed to 15 go. But if it's the Special Housing Unit, and 16 then, also 10 South, which MCC also has. 17 MR. : Correct. 18 MS. : Your responsibility level, 19 because of the practices, or just you knowing, 20 inherently, what you should be doing, it's a 21 little different than the just making yourself 22 available to the staff. You are not just there 23 for the staff. You are also there for the 24 inmates because they can't come to you. You 25 have to go to them. EFTA00110106 LIMITED OFFICIAL USE 106 1 MR. : Okay. So -- 2 MS. : So -. 3 MR. : -- so, basically, I'm 4 understanding that general population, no, a 5 SHU - or a lieutenant wouldn't have to - with 6 their rounds - don't have to be with the 7 specific inmates, but in the SHU, because they 8 have limited movement, and they are only in 9 their cells, a lieutenant really should be 10 checking on each cell, during their rounds? 11 MS. : For - like you said - for good 12 correctional judgment, sound correctional 13 practices, you - yeah - you would. 14 MR. : But to your knowledge, 15 there is no requirement. It's just sound 16 judgment and sound practice? 17 MS. : Yeah. And because that, but 18 that's why I was going back, because I don't 19 think there is anything written that says when 20 a lieutenant makes his rounds, they should go 21 to every single cell. I know their requirement 22 is, like you said, for you to, for a lieutenant 23 to be present, and to, on every shift, as well 24 as if there is also, also different departments 25 that are required to make rounds. Weekly. And EFTA00110107 LIMITED OFFICIAL USE 107 1 with that in mind, you typically know that that 2 means that you are stopping at every door, and 3 you are talking to the inmates, because again, 4 your purpose in SHU is to provide information, 5 and again, it's not like they can come out to 6 you. So, you have to go to them. 7 MR. : So, just to wrap this 8 thing up, if a lieutenant is saying that they 9 did not conduct any rounds of cells, they just 10 stopped in and talked to staff members. Do you 11 believe that they did something wrong? 12 MS. : I would say that I don't think 13 that they acted responsibly. I don't want to 14 say it's wrong or right because, you know, then 15 that person could say this, it's not written, 16 but I would say that that's not a responsible 17 decision. 18 MR. : So, when they certify 19 their round sheets that they conducted a round, 20 what do you believe that they are certifying? 21 MS. : That they have visited SHU, and 22 that they visited the inmates. 23 MR. : Okay. So, you do believe 24 that certification that they are signing, that 25 they conducted a round in the SHU, is that they EFTA00110108 LIMITED OFFICIAL USE 108 1 actually did conduct a round with the inmates? 2 MS. : That is what I believe. 3 MR. : Okay. But that is more 4 of a belief and opinion versus a knowledge. 5 Correct? 6 MS. : Yes. 7 MR. : Okay. Great. We can 8 move on. Next thing we are going to talk 9 about, and I apologize this has taken a little 10 long, is the cameras. Do you know if the SHU 11 cameras were recording on August 9th and 10th 12 of 2019? 13 MS. : I know there was some -. And 14 again, this is information that has become 15 available after the fact. I know it has become 16 known after the fact that there was some 17 cameras that were not working. And that were 18 not recorded. But did I know the day of the 19 incident? No. I did not know on the day of 20 the incident. 21 MR. : Did you know why they 22 weren't recording? Do you know what happened 23 with the cameras? 24 MS. : I know that, I don't know why 25 they were not working on that day, but I know EFTA00110109 LIMITED OFFICIAL USE 109 1 that, following Epstein, that there have been 2 issues with MCC's cameras. The recorder, that 3 there was supposed to be a backup camera, and 4 that, when the primary camera failed to record, 5 that there was supposed to be another camera 6 that kind of acts, or kind of, you know, 7 interfaces, so that there is always some 8 recording going on. That has been going on, 9 and again, that was after the fact, but as far 10 as the day of, I don't know. 11 MR. : So, you don't know what 12 caused the cameras to stop recording? 13 MS. : No. I don't know. 14 MR. : Okay. And do you 15 remember the - so, on August 8th, which would 16 have been a Thursday - do you remember, if on 17 August 8th, if you and SIS Lieutenant 18 were attempting to review video footage, and 19 you learned that you were not able to rewind 20 the cameras, and review the footage that you 21 were looking for? 22 MS. : You said on August 8th? 23 MR. : Right. And to help 24 further jog your memory. So, the information 25 we received from Lieutenant was that the EFTA00110110 LIMITED OFFICIAL USE 110 1 two of you were attempting to review video 2 footage, you weren't able to, so you called the 3 comtech, Hughwon Daniel, and asked him to 4 review the matter, and fix the issue. Does 5 that ring a bell to you? 6 MS. : If she's saying that that's 7 happened, and I know, Lieutenant and I 8 have had conversations, and about that, I would 9 say that that's - that if she is saying that 10 she and I had a conversation, I would say that 11 that probably did occur. 12 MR. : But you don't recall it? 13 MS. : I don't know if it was August 14 8th, or if it happened prior to. But I do 15 recall. I, again, I recall her and I trying to 16 look at something, but I don't recall the date 17 or the timeframe. 18 MR. : So, I guess, when you 19 arrived on the 10th, and learned that the 20 cameras weren't recording, which is, I'm 21 assuming, you would have learned on that day, 22 the 10th, that Epstein was found. Is that -- 23 MS. : Mm-hmm. 24 MR. : -- is that accurate? 25 MS. : No. No. That is not accurate. EFTA00110111 LIMITED OFFICIAL USE 111 1 MR. : Okay. When did you learn 2 that the cameras actually weren't, or didn't 3 record, or weren't recording? 4 MS. : I don't recall exactly when I 5 learned that -- 6 MR. : Oh, okay. 7 MS. but mm-hmm. 8 MR. : Okay. So, when we spoke 9 with Lieutenant , she said, when she 10 found out on the 10th that the cameras weren't 11 recording, she went to Daniel and said, hey, 12 what happened? You were to supposed fix this. 13 So, I didn't know if you 14 MS. : Oh. 15 MR. : -- you would have, you 16 know, had a similar reaction, or a similar take 17 on the matter. 18 MS. : Mm-hmm. And she is saying that 19 it was the SHU cameras that were not recording? 20 That -- 21 MR. : Well, she -- 22 MS. (Indiscernible *01:45:44). 23 MR. : -- well, she just said 24 that she knows that there were problems with 25 the cameras. I would have to look back at her EFTA00110112 LIMITED OFFICIAL USE 1 transcript to find out exactly if we were 2 talking about the SHU, but she says that -- 3 MS. : Mm-hmm. 4 MR. : -- the two of you were 5 trying, were attempting to review video, and 6 you were unable to review it because there was, 7 you couldn't find the recording, or you 8 couldn't rewind. So, the, you know, the 9 determination was made between the two of you, 10 and I can actually, let me pull up the actually 11 specific part of what she, of what she said 12 here. To see if you think it's accurate. So, 13 it says, "I remember stepping into his office." 14 Oh, okay. 15 So, "I remember stepping into his office, 16 which was right next door to mine, and 17 notifying him that the camera was down, and I'm 18 trying to get back to look at footage, and I 19 can't. Actually, I had one of the associate 20 wardens with me, as well, who happens to be his 21 supervisor." "So," I said, "Who was that?" 22 "Associate Warden ." " was there?" 23 "Yes." "Okay." "It was me and her together, 24 looking at the camera." 25 "Okay. So, it wasn't ? It EFTA00110113 LIMITED OFFICIAL USE 113 1 was actually ?" "No. It was me and AW 2 • " "And that was with Captain ?" 3 "Yes." "Okay. So then, the two of them knew 4 that the cameras were down?" "Yes." "All 5 right. And do you know if they had any 6 conversation with Daniel about a need to get 7 them back up?" 8 She says, "I don't know if they had a 9 separate conversation, but when I called Mr. 10 Daniel over to radio, Ms. was still 11 standing there with me in the office, and she 12 was there with me when he came up to check, 13 because we thought it was something that maybe 14 he could just go in, and it allow us to go to 15 look at the camera, and look for what we were 16 looking for." So, does that ring a bell to you 17 at all? 18 MS. : Yeah. That does. Mm-hmm. 19 MR. : Does that sound accurate? 20 MS. : It does. Mm-hmm. 21 MR. : Okay. So, and this was 22 what she was saying, was on August 8th, that 23 she went in. So, do you know if, were you 24 there and present when Daniel was brought into 25 the office and told to fix the issue? EFTA00110114 LIMITED OFFICIAL USE 114 1 MS. : I don't recall. I don't recall 2 - hmm-mm - I don't recall having that 3 conversation. And then, and I could have had 4 that conversation, but I don't recall having a 5 conversation with Daniel. 6 MR. : Okay. So, you don't 7 recall -. But you do recall 8 MS. : Mm-hmm. 9 MR. : -- this interaction 10 MS. : I remember -- 11 MR. : -- with both you, 12 Lieutenant , and -- 13 MS. : Yeah. 14 MR. : -- Captain 15 MS. : Mm-hmm. I do remember that. 16 And speaking of, I don't remember if it was, if 17 it was, because I'm trying to understand if it 18 was because you were saying we just couldn't 19 rewind, or if it was known that it was not, or 20 if it was that the cameras were not recording. 21 I'm hoping that you understand what I'm saying. 22 MR. : Yeah. So, the way that - 23 all right - the question was asked, so I said, 24 "Okay. So then, the two of them knew the 25 cameras were down?" She said, "Yes." And I EFTA00110115 LIMITED OFFICIAL USE 115 1 said, "Oh, all right. And do you know if they 2 had any conversations with Daniel about a need 3 to get them back up?" She said, "I don't know 4 if they had a separate conversation, but when I 5 called Mr. Daniel over to radio, Ms. was 6 still standing there with me in the office, and 7 she was there with me when he came up to check 8 because we thought it was something that may be 9 he could just go in and it allow us to go to 10 the camera, and look for what we were looking 11 for." 12 I then said, "And when he mentioned the 13 whole -". So then, we started talking about 14 overtime, and when he couldn't fix it, I said, 15 "And when he mentioned the whole, I'll stay 16 overtime, was she there when - was there - 17 when he mentioned that he would stay to work 18 overtime?" And she said, "I can't remember." 19 MS. : Well, and I know that, if I had 20 a conversation with Daniel, or anybody, about 21 the cameras not recording, versus you not being 22 able to rewind on your, on the Nice Vision. 23 That that would have been something that would, 24 that I would have known that was important. 25 And I'm trying to differentiate because there EFTA00110116 LIMITED OFFICIAL USE 116 1 are there, and I have had the experience that I 2 have access to Nice. And I was not able to 3 actually rewind on one of the cameras. 4 But it's not because the camera was not 5 recording. It's because it was, the camera was 6 not programmed correctly or something. I don't 7 even know if I'm using the proper word. But 8 it's not that the camera was not recording. It 9 had something to do more with you're not being 10 able to pull it up and rewind it on the Nice 11 Vision application. But it's not the same as 12 it not being recorded. So, that's why I was 13 asking you, is she saying that we knew that it 14 was not recording? Because that's not my 15 knowledge, or my understanding, that the 16 cameras were not recording. 17 MR. : Okay. Yeah. No. Her 18 specific words were, "I remember stepping into 19 his office, which was right next door to mine, 20 and notifying him that the camera was down. 21 And I'm trying to go back and look at the 22 footage, and I can't. Actually, I had one of 23 the associate wardens with me -- 24 MS. : Yeah. 25 MR. : -- as well." EFTA00110117 LIMITED OFFICIAL USE 117 1 MS. : That - I wouldn't say that that 2 means that the camera is not recording. Hmm- 3 mm. 4 MR. : So -- 5 MS. : And that -. 6 MR. : -- so, saying the camera 7 was down, that would, what would you think that 8 that was saying? 9 MS. : And that's not -. When you say 10 that a camera is down, that's different than 11 the whole system not recording. That's not the 12 same thing. That might be that one particular 13 camera, and whatever area that she was talking 14 about, that I believe they had to be a fight, 15 or something happening for her and I to look at 16 a camera. That particular camera may, again, 17 something might have not been programmed 18 correctly, that we were not able to rewind. 19 But that is not the same thing as a whole 20 system not being operational. 21 MR. : Okay. 22 MS. : It's two totally different 23 things. 24 MR. : Okay. So, my question on 25 this really is -- EFTA00110118 LIMITED OFFICIAL USE 118 1 MS. : And it's still fine. 2 MR. : -- my question on this is 3 really is 4 MS. : Mm-hmm. 5 MR. : -- regarding Daniel, 6 because it sounds like Daniel was told to fix 7 the issue, and that's really why I'm asking 8 this question. Do you know if Daniel was 9 instructed that you need to fix this issue? 10 MS. : You said in SHU? 11 MR. : Well, no. This is just 12 the cameras in general. 13 MS. (Indiscernible *01:52:06). 14 MR. : Well, we learned that the 15 cameras in SHU weren't recording. 16 MS. : Okay. 17 MR. : Through the 18 investigation. And to find 19 MS. : Mm-hmm. 20 MR. : -- and determining, well, 21 when was this first found out? This is 22 MS. : Okay. 23 MR. : -- you know, that there 24 was a problem with the cameras. You know, we 25 obviously had to talk to a lot of people, EFTA00110119 LIMITED OFFICIAL USE 119 1 including, you know, Daniel, and , a 2 you know -- 3 MS. : Now, that, now, I would like to 4 ask you to, did Daniel ever say that he knew 5 that the whole camera system was not working, 6 and when he knew, and who he had a conversation 7 with? 8 MR. : No, no, no. 9 MS. : About it. 10 MR. : So, that -- 11 MS. : Oh. 12 MR. : -- so, the understanding 13 that I am of is that - and again, I know at 14 least spoke with Daniel, and she 15 believed that you were with her when the 16 conversation took place. So, that is where I 17 was asking if you recall having a conversation 18 with and Daniel? 19 MS. : I recall that, but not about 20 the camera system. The whole Nice system. And 21 all of the cameras in SHU not recording. 22 MR. : Yeah. Right. And I'm 23 not saying that that would have been the 24 conversation. I would think that the 25 conversation would more be along the lines of, EFTA00110120 LIMITED OFFICIAL USE 120 1 hey, we are trying to review this video. We 2 are not able to do it. Can you figure out 3 what's going on with the cameras? 4 MS. : If that, if we had a 5 conversation about that, then I could see, 6 logically, that, yeah, I would say, Daniel, 7 hey, why we can't rewind? 8 MR. : Sure. 9 MS. : Can you fix a camera, X, Y, and 10 I, or see why it's not focused, or something to 11 that effect. 12 MR. : Right. And so, my 13 question -- 14 MS. : Yeah. Yeah. 15 MR. : -- is to you 16 MS. : Yeah. 17 MR. : -- do you remember what 18 the conversation entailed? 19 MS. : I can't remember the 20 conversation, but I know, if we were talking 21 about a particular image, or a particular 22 camera, and again, I'm not saying that it's not 23 recording, we are saying that we can't rewind, 24 that is what it would have been about. Daniel, 25 why can't we rewind? Why can't we pull up EFTA00110121 LIMITED OFFICIAL USE 121 1 camera X, Y, and I? But not about the whole 2 system. Especially if the whole system was not 3 in question. Or there was no talk about the 4 system not recording, or even SHU not 5 recording. There was never any conversation 6 about SHU, or anything. So, that's the 7 conversation would have been limited to that 8 particular camera, and why we can't rewind. 9 MR. : Absolutely. And then 10 MS. : And -. 11 MR. : -- that is kind of my 12 understanding -- 13 MS. : Yeah. 14 MR. is what your part of 15 this conversation was, is we are having an 16 issue trying to recording, can you figure it 17 out? And my question to isn't, like, you know, 18 this isn't an I gotcha type of question, even 19 in the slightest. It's just, if you can 20 MS. : Yeah. 21 MR. : -- recall what 22 conversation you had with Daniel. 23 MS. : I can only recall about that, 24 like you said, about the interaction with 25 and I talking about why we were not able EFTA00110122 LIMITED OFFICIAL USE 122 1 to rewind to see what happened. Because we 2 were able to pull the image up. We were just 3 not able to rewind. So, that is what I'm 4 saying. There is, and it might sound like I'm 5 trying to be very specific and deliberate, 6 because I am, because there is a difference 7 with you accessing the Nice system, and I'm not 8 an electronic - an electrician - or, you know, 9 an electronic person, and I could physically 10 see it, I could see it, but I am not able to 11 rewind. That doesn't let me know that, oh, the 12 system is not recording. So, that would not 13 have ever been part of the conversation. The 14 conversation would have been limited to, why is 15 it that I am able to look at it, but I can't 16 rewind? 17 MR. : Sure. Now, do you know 18 anything about 19 MS. : So, figure that out. 20 MR. : -- and do you know if, do 21 you know if Lieutenant created a memo, 22 and provided it to , regarding the camera 23 issue on the 8th? 24 MS. : No. Now, if she included me in 25 it, then I would say, oh, okay -- EFTA00110123 LIMITED OFFICIAL USE 123 1 MR. : But you -- 2 MS. : -- but I don't -- 3 MR. : -- yeah. And I don't 4 know that she would have included. She said 5 that she wrote a memo, based upon the issue 6 with the camera, and provided it to Captain 7 8 MS. : No. 9 MR. : But -- 10 MS. : Hmm-mm. 11 MR. : -- but when you -. But 12 you do remember when, you know, in her, like I 13 just read to you, she said that the 14 conversation with the problem with rewinding 15 actually was with you and , though? Do 16 you remember being present for that, you 17 know -? 18 MS. : Now, I don't know if was 19 present for that. But I do, I know, because of 20 you reciting about the conversation, I do know, 21 definitely, that was there, and if she 22 is saying that was there, it is 23 Gosh, I don't know see why she would say he was 24 or he wasn't. It didn't have great importance 25 to me, that conversation, because it wasn't -. EFTA00110124 LIMITED OFFICIAL USE 124 1 So, that is why I am not, I am not - I can't 2 recall this (Indiscernible *01:56:39), oh, this 3 person was there, that person was there, 4 because it wasn't, it wasn't, in my mind, 5 highlighted that the camera system was down. 6 So -- 7 MR. : Okay. So, what we have 8 learned is that, that is when Daniel checked on 9 the system, and he realized that - and this, 10 there is nothing that we learned that, you 11 know, have any knowledge of this, so I will 12 just, you know, put that out front - -s that 13 Daniel said he checked on the system, and he 14 realized that two of the drives were down, and 15 when two drives go down, it stops the system 16 from recording. So, half of the cameras in the 17 institution stopped, were not recording at the 18 time. And this was basically learned on August 19 8th and August 9th, when he was trying to fix 20 the system. Were you ever made aware of that 21 information? 22 MS. : No. I was not. 23 MR. : Okay. Is this the first 24 time you are even hearing of that information? 25 MS. : Absolutely. EFTA00110125 LIMITED OFFICIAL USE 125 1 MR. : And is there someone that 2 he should have told about that information, the 3 fact that -- 4 MS. : Yeah. 5 MR. : -- no, no, no, that half 6 the cameras in the institution are actually 7 down and not recording? I mean, there is 8 live feed, but there is no recording. 9 MS. : Yeah. So, he should have 10 definitely told his first line supervisor, who 11 would have known to then tell his supervisor, 12 and if I am the common denominator, because I 13 am, I was the AW, and I probably was 14 supervising facilities at the time, that 15 information, at some point, would have made it 16 to me. 17 MR. : All right. So, this is 18 another one of those everyone seemed to be out 19 on the 9th, at least. Mr. Nobile was the 20 facilities manager, and he was actually out 21 that entire week. So, he wasn't in the know 22 that the cameras were down. So, it was just 23 MS. : There is a, there is a -. 24 Okay. So, there is his -. So, Daniel's first 25 line supervisor is not actually Nobile. Nobile EFTA00110126 LIMITED OFFICIAL USE 126 1 was his second line supervisor. 2 MR. : Okay. 3 MS. : His first line supervisor was 4 another person. Linton (Phonetic Sp. 5 *01:58:34). I don't know if Linton was working 6 at the institution at the time, but Nobile, who 7 is the facility manager, is the second line 8 supervisor. 9 MR. : Would -- 10 MS. : So, I don't -. 11 MR. : -- would Linton be, you 12 are talking about the general foreman? 13 MS. : Yeah. The general foreman. 14 MR. : If there was no one -- 15 MS. : Yeah. 16 MR. : -- filing the general 17 foreman at the time -- 18 MS. : No. 19 MR. : -- is our understanding. 20 MS. : So, there was not even an 21 acting in place? 22 MR. : Yeah. From Nobile's out 23 of office response, to the people that acted in 24 his stead, where Ryan McNamara (Phonetic Sp. 25 *01:58:57), and I think her name was Geise EFTA00110127 LIMITED OFFICIAL USE 1 (Phonetic Sp. *01:59:02). 2 MS. : Oh. Oh. 3 MR. : But -- 4 MS. : Acting in his place. 5 MR. : -- right. So, but that 6 wasn't an acting for the general foreman. From 7 our understanding is that there was just no one 8 in the general foreman role at the time, and 9 that's, unfortunately, on the 9th, there is a 10 lot of people that were out of the institution, 11 and a lot of people that were not there, that 12 would have -- 13 MS. : Then -- 14 MR. : -- potentially been in 15 the know in these situations. 16 MS. : -- then he could have 17 contacted, he should have contacted somebody. 18 I mean, if you are all - and I'm just going to 19 say line staff, but they are all peers, they 20 are all subordinates, and no one is a 21 supervisor. If there is something that, that's 22 a security issue, you would raise it to 23 someone, of a supervisory nature. And if your 24 supervisor is not there, you would raise that 25 to the next level, who was, in the absence of EFTA00110128 LIMITED OFFICIAL USE 128 1 your supervisor, your supervisor's supervisor. 2 MR. : And do you know, so, 3 according to Daniel, this is something that 4 happened quite regularly. 5 MS. : Mm-hmm. 6 MR. : That these things would 7 go down, he would have to rebuild the system, 8 and then the cameras would be down for, you 9 know, a period of 24 hours, while the system 10 rebuilt. Were you aware of that? 11 MS. : Hmm. No. I know, after the 12 fact, there have been issues that we were aware 13 of with the camera. But prior to, and again, 14 arrived at the institution in July -- 15 MR. : Sure. 16 MS. so, this is one-month in. 17 So, if there were historical issues with the 18 camera, I have no way of knowing what existed 19 because I was not present then. But at the 20 time that I was present, there is no mention of 21 those cameras being down. And again, because 22 of that incident, there was obviously 23 heightened attention to the cameras, and who 24 you should notify when you are aware that a 25 camera is down. But at the time ,when I was, EFTA00110129 LIMITED OFFICIAL USE 129 1 you know, like I said, a recent arrival, there 2 was no mention or a discussion that I was aware 3 of about any issues with the camera. 4 MR. : Okay. So, leading up to 5 this issue, you didn't know that the cameras, 6 they are a big problem at the institution? 7 MS. : You said leading up, or 8 following the incident? 9 MR. : No. Leading up to the 10 incident. 11 MS. : You said, did I have any 12 knowledge of it? 13 MR. : Right. 14 MS. : Yes. Leading up to the 15 incident, there was no knowledge that there was 16 issues with the cameras recording. 17 MR. : Okay. And do you know if 18 - when you and Lieutenant were speaking 19 with Daniel - do you know if he was told to fix 20 the camera situation immediately? Or to just 21 look into it and figure out what's going on. 22 Do you recall? 23 MS. : I don't -. I don't want to -. 24 I don't want to -. I don't recall my exact 25 words to him. But again, if there was no EFTA00110130 LIMITED OFFICIAL USE 130 1 mention that the camera was not recording, 2 there is a difference when instruction, based 3 on knowledge that the cameras are not working, 4 versus knowledge that the camera that I can see 5 it, but I can't rewind it: 6 MR. : Sure. 7 MS. : And not -- 8 MR. : So, you 9 MS. : -- knowing -- 10 MR. : -- so, you knew that 11 there was an issue with the camera. You just 12 didn't know what the issue was. 13 MS. : I knew that we could not 14 rewind. Yes. 15 MR. : Okay. 16 MS. : Yes. 17 MR. : And do you remember if 18 you ever followed up, after that conversation, 19 with anyone, to say, hey, did that ever get 20 resolved? 21 MS. : I don't. I don't recall. 22 MR. : Okay. Is there a reason 23 why you should have, or did you believe someone 24 else was on top of it, and that was fixing it, 25 and looking into it? EFTA00110131 LIMITED OFFICIAL USE 1 MS. : I don't (Indiscernible 2 *02:02:48). I don't -. I actually, I don't 3 recall because, again, at the time, when we 4 were looking at the camera, you can see it. 5 So, there was, there was never any discussion, 6 or there was never even no information to say 7 that the camera was not working. There was 8 never any discussion about that. So, to follow 9 up on an issue that you don't know is present, 10 I would say that that's, if I didn't have a 11 further discussion about it, it's because of 12 that, that there was no discussion that the 13 camera was not recording. 14 MR. : Okay. So, from the 15 knowledge that you do have, that, you know, you 16 know, according to , she was saying she 17 knew that the cameras weren't recording, and 18 they were down. And then, Daniel saying that 19 he was going to fix them, and he clearly knew 20 the cameras weren't recording. What should 21 have happened? 22 MS. : Well, first, I want to clarify, 23 you are saying that said that she knew 24 the cameras were not recording. 25 MR. : She - yeah - her -. That EFTA00110132 LIMITED OFFICIAL USE 132 1 is what I read you before - that she said, her 2 words, "Notifying him that the camera was down, 3 and trying to go back and look at the footage, 4 and I can't." And then, later on 5 MS. : But that's not saying that 6 MR. : -- saying, you know, 7 saying -- 8 MS. : -- (Indiscernible *02:04:10). 9 MR. : -- so, okay -- 10 MS. : Yeah. 11 MR. : -- the two of them knew 12 the cameras were down. Yes. And then, she 13 said that she actually wrote a memo to the 14 captain, saying that, you know, the cameras 15 were down, and that Daniel was fixing the 16 issue. And then, when he came in on the 10th, 17 to find out the cameras still hadn't recorded, 18 she had a conversation with Daniel and said, 19 hey, you told me you were going to fix the 20 cameras. Why didn't you fix them? So, I'm not 21 saying that you have any part of this. What 22 I'm saying -- 23 MS. : Oh. 24 MR. : -- you, is -- 25 MS. : No. I know -- EFTA00110133 LIMITED OFFICIAL USE 133 1 MR. : -- being that Lieutenant 2 seems to have known that the cameras 3 were down, and Daniel definitely knew the 4 cameras were down, what should have happened? 5 MS. : Then no one should have 6 followed up to say were the cameras, if saying 7 down means not recording. 8 MR. : Right. And that's what 9 they -- 10 MS. : That's (Indiscernible 11 *02:04:57). 12 MR. : -- and that was clear. 13 Daniel went into, you know, great detail of, 14 the cameras, you could watch live, it's only 15 when you try to rewind, because they weren't 16 recording. And he said -- 17 MS. : That's -- 18 MR. : -- this is what happened 19 20 MS. : -- (Indiscernible *02:05:11). 21 MR. : -- and he -- 22 MS. (Indiscernible *02:05:11). 23 MR. sorry. Go ahead. 24 MS. : I don't know if knew 25 that what, the explanation that you said, EFTA00110134 LIMITED OFFICIAL USE 134 1 Daniel provided, that, I have never had a 2 conversation to say that the reason why you 3 can't rewind is because the cameras are not 4 recording. I don't know. I can't say what 5 knew. If she understood that that's 6 what that meant. I know that I know that 7 that's -. I did not know that that's what that 8 meant. So, if Daniel never came back, and 9 said, oh, the cameras are not recording, that 10 is a difference with then just saying that, oh, 11 you could see the camera, you are thinking that 12 the camera is working. If you pull up a camera 13 on the Nice Vision (Phonetic Sp. *02:05:52), 14 and you could actually see the image and 15 everything, you are thinking that the camera is 16 recording. So, how else would -? Why else 17 would you think that it's not recording? 18 MR. : Well, that's why -- 19 MS. (Indiscernible *02:06:02) 20 MR. : -- that's why I'm trying 21 to explain to you -- 22 MS. (Indiscernible *02:06:04). 23 MR. : -- like, said that 24 she knew that they weren't. That's why she 25 wrote the memo to the captain, and that's why - EFTA00110135 LIMITED OFFICIAL USE 135 1 2 MS. : Yeah. 3 MR. : -- on the 10th, when she 4 found out that the cameras were still down, she 5 confronted Daniel and said, you were supposed 6 to fix this, why didn't you fix the cameras? 7 MS. : Hmm. 8 MR. : So, those two things is 9 what I'm trying to I've been trying to 10 explain to you 11 MS. : Oh. 12 MR. : -- is that she did know, 13 is because that is why she wrote the memo to 14 the captain, and that is why she confronted 15 Daniel on the 10th, saying why didn't you fix 16 this? 17 MS. : And my response then would be: 18 maybe she thought - and I'm not, I don't even 19 want to -. I don't know. Maybe -- 20 MR. : And she didn't point the 21 22 MS. : -- (Indiscernible *02:06:42). 23 MR. : -- she didn't point the 24 finger at you in the slightest. I'm not even 25 trying to insinuate that. EFTA00110136 LIMITED OFFICIAL USE 136 1 MS. : Mm-hmm. 2 MR. : I'm saying, because you 3 are the AW in charge of -- 4 MS. : Yeah. 5 MR. : -- you know, this 6 situation, what should have happened? And this 7 8 MS. : Mm-hmm. 9 MR. : -- and again, isn't 10 gotcha. I'm asking you -- 11 MS. : Mm-hmm. 12 MR. : -- as a genuine question. 13 Like, you're the boss. What should have they 14 done? 15 MS. : Yeah. Someone should have 16 specifically said the cameras are not 17 recording. And I'm not going to say it's 18 responsibility, but she reported it. 19 If she reported it to her supervisor, she did 20 what she was supposed to do. So, I'm going to 21 kind of -. Like you said, I'm going to try to 22 come back and be, like, really assess it. If 23 she reported it to her supervisor, that's her 24 responsibility. 25 That's what she did. But from there, it - EFTA00110137 LIMITED OFFICIAL USE 137 1 . I wish had said to me, hey, I 2 received this memo from , saying that the 3 cameras are not working. And that I spoke with 4 Daniel, and the cameras are not working, they 5 are not recording. And that is something that 6 I could have definitely said, okay, Daniel, you 7 have to do overtime, in the absence of your 8 supervisor, I am authorizing you to do 9 overtime, to then fix the cameras, and then, 10 when something like that happens, obviously, 11 you know you have to make security related 12 decisions. 13 Then you could have recalled all the 14 inmates, so that if there is any incidents that 15 happened, at least the inmates are confined to 16 their cells. And then, you say, well, there is 17 no cameras inside of the cells. But you make 18 rounds. You have to make rounds in Special 19 Housing anyway. You know? So, you wouldn't be 20 able to capture what's happening inside of the 21 cell itself. But you would have a general idea 22 about, you know, with the cameras, what's going 23 on. 24 But there would have been decisions that 25 would have been made, to ensure security. But EFTA00110138 LIMITED OFFICIAL USE 138 1 there should have been notification, and 2 clarification, and specificity about - 3 specificity - about actually what was the 4 issue. 5 MR. : Okay. So, in your 6 opinion, though, it's should have 7 reported it to should have made 8 the appropriate - like, this is, I'm not saying 9 that this did or didn't happen. I'm just 10 saying, under, from what you know -- 11 MS. : Mm-hmm. 12 MR. should have 13 told should have made whatever 14 appropriate, you know 15 MS. : He should have told -- 16 MR. : -- taken whatever actions 17 needed to be taken. 18 MS. : -- he should have -. Yeah. 19 Then, if I was his supervisor, then he should 20 have told me. 21 MR. : Okay. And again, it 22 sounds like this is how - you already answered, 23 but to be clear - you knew there was a problem 24 with that one specific incident, trying to 25 rewind, but you had no idea what the problem EFTA00110139 LIMITED OFFICIAL USE 139 1 was. You just knew you weren't able to rewind. 2 MS. : And - yeah - if you simplify 3 it. Yeah. 4 MR. : Right. So, you didn't 5 know that the -- 6 MS. : Mm-hmm. 7 MR. : -- point being, you 8 didn't know the cameras were down. 9 MS. : Yeah. 10 MR. : You didn't know that they 11 were not recording. 12 MS. : Exactly. 13 MR. : Great. So, were you 14 aware that MCC cameras were scheduled to be 15 replaced? 16 MS. : Him. No. I didn't know that 17 they were scheduled to be replaced. I know 18 again - there is information that you -. I 19 don't know if they were scheduled to be 20 replaced. I know that they have been, they 21 were upgraded after. And then, I know there 22 was certain projects. But I don't -. I, 23 again, I don't know what I -. That, if they 24 were scheduled to be replaced at the time of 25 the incident. EFTA00110140 LIMITED OFFICIAL USE 140 1 MR. : So, I guess what I'm 2 saying is, do you know if they were, you had 3 new cameras on site at the MCC, and there was 4 currently a camera project underway, of 5 replacing the old cameras? Did you know that? 6 MS. : No. Not at the time. 7 MR. : Okay. 8 MS. : Not -. Not at the time. 9 MR. : So, based on the work 10 orders and email communications that we 11 received -- 12 MS. : Mm-hmm. 13 MR. : -- the MCC ordered new 14 cameras, DVRs, and other system parts, and had 15 them delivered to the MCC in approximately 16 October of 2018. 17 MS. : Mm-hmm. 18 MR. : These were the cameras 19 that were installed immediately after Epstein's 20 death in August of 2019. 21 MS. : Hmm. 22 MR. : Did you know that to be 23 accurate? 24 MS. : I know that there were cameras 25 that were installed after, and afterward, but EFTA00110141 LIMITED OFFICIAL USE 141 1 again, I don't know when those cameras arrived 2 because I didn't work there in 2018. 3 MR. : Sure. Sure. 4 MS. : No. 5 MR. : But I guess what I'm 6 saying, though, is -- 7 MS. : Oh. 8 MR. : -- did you know that 9 those cameras were on site, and they were, you 10 know -- 11 MS. : No. 12 MR. : -- you didn't even know 13 that? 14 MS. : No. There's a lot of things 15 that have, obviously that folks have knowledge 16 of after the fact because of the incident, and 17 there have been actions after, but there was 18 no, I was not knowledgeable about cameras being 19 on site, and about the installation prior to. 20 MR. : And just to be clear. 21 So, Nobile, you know, the facilities manager -- 22 MS. : Mm-hmm. 23 MR. : -- you know, Warden 24 N'Diaye, and, you know, Daniel, they have all 25 said, yup, this is accurate. So, the follow up EFTA00110142 LIMITED OFFICIAL USE 142 1 on that is, when should the new camera system, 2 that was already on site at the MCC, have been 3 installed? Do you have even a -? Or do you 4 just not have knowledge on that because you 5 weren't there at the time? 6 MS. : Yeah. So, I don't have 7 knowledge of that. 8 MR. : Okay. Do you know who 9 would have been ultimately responsible for 10 ensuring -? Because it sounds - and again, you 11 weren't there at the time, but there was a lot 12 of problems, the same problem happened time and 13 time again, at the MCC, where these cameras 14 would -. Two hard drives would crash, and then 15 take out the system. And then, Daniel would 16 have to go and rebuild the system, and it was, 17 like, a 24 hour process to rebuild it. 18 MS. : Mm-hmm. 19 MR. : Who should have made sure 20 that new camera system was installed? That was 21 on site. Who should have, like, said, like, 22 this is an urgent matter? And I am assuming it 23 was. Was that an urgent matter, if the cameras 24 are down? 25 MS. : Mm-hmm. Yeah. EFTA00110143 LIMITED OFFICIAL USE 143 1 MR. : And they are not 2 recording? I would think that that's a pretty 3 big deal. Correct? 4 MS. : Mm-hmm. Correct. 5 MR. : So, who should have made 6 sure that that new system was installed? That 7 had been on site, all the way back to October 8 2018. 9 MS. : It's multi-layered. And when 10 it's a multi -. This is multi-layered. Because 11 if you are saying that, who actually does the 12 work for the installation, or who the primary 13 person is the electronics technician. But 14 ultimately, they have a supervisor, and that 15 supervisor tracks the completion of projects. 16 The progress of projects. So, it's - that's 17 what I'm saying - it's multi-layered. That, 18 and if the cameras were present, I don't know 19 what would have happened to make them not be 20 installed. 21 MR. : And just for more -- 22 MS. (Indiscernible *02:13:50) 23 MR. : -- information, the 24 reason why they were on site, the reason why 25 you guys were able to get your cameras EFTA00110144 LIMITED OFFICIAL USE 144 1 immediately back up and running, with a whole 2 new system, was because they were already on 3 site. So, knowing that information, what is 4 your thought on the matter? Like, the fact, 5 now that you are hearing, and again, this is, 6 I'm looking at you as a subject matter expert. 7 I am not looking for any type -. 8 I'm not accusing you of anything. I'm 9 just looking at you as you are a boss there. 10 You are in charge of custody. So, I am just 11 kind of giving you this information, so you can 12 give me your professional feedback. So, the 13 fact that they were able to immediately install 14 this, have SigNet come in, who was the 15 contracted company, and install these new 16 cameras that had been on site since October of 17 2018 -- 18 MS. : Mm-hmm. 19 MR. : -- what is your opinion 20 on that? 21 MS. : Hmm. 22 MR. : Do you think that they 23 were, you know, the MCC, or, you know, really 24 dropped the ball with having this faulty camera 25 system, and actually having the parts that they EFTA00110145 LIMITED OFFICIAL USE 145 1 needed on site, to be able to be replaced? 2 MS. : I'm careful with saying about 3 this, who dropped the ball. I know if you know 4 that there is cameras present. And there is no 5 logical reason why the cameras can't be 6 installed. And if it is your department that 7 is responsible for installing the cameras, then 8 you should ultimately ensure that the cameras 9 are installed. And -. 10 MR. : Now, should - would it 11 fall on the facilities manager to make sure 12 that that's happening? 13 MS. : The Comtech works for the 14 facility manager. So, the facility manager is 15 responsible for the department that that staff 16 member works in. 17 MR. : So -- 18 MS. : You know? 19 MR. : -- according to Daniel, 20 he said that his job was basically to fix it. 21 His job, you know, fix things when they're 22 broken. And he had been screaming that there 23 was a problem with these camera systems for a 24 long time, and he's basically the reason why 25 they got the new cameras, but he said, you EFTA00110146 LIMITED OFFICIAL USE 146 1 know, it wasn't his job to get SigNet there, to 2 be able to actually get these installed. 3 You know, so, that is where, to me, 4 hearing that explanation, it sounds like oh, 5 well, it's really probably the facilities 6 manager that is, you know, supposed to manage 7 that task, and make sure that they get in 8 there. But I don't -. I want to make sure 9 that that would be an accurate, you know, 10 assessment, or if I'm off. 11 MS. : Now, would have I don't know 12 if, like you said, if it's the facility manager 13 that actually calls SigNet, or if it is the 14 Comtech that would call and coordinate SigNet's 15 visit. It's between the two. 16 MR. : So, you believe they 17 have, both have part responsible --- 18 MS. : Mm-hmm. 19 MR. : -- you know -- 20 MS. : Mm-hmm. 21 MR. : -- their part exposure to 22 this thing? 23 MS. : Yeah. 24 MR. : And anything -- 25 MS. : Yeah. EFTA00110147 LIMITED OFFICIAL USE 147 1 MR. anyone outside of the 2 facilities manager? I mean, did this go up to 3 the executive, you know, level, to the captain, 4 AWs, or warden? 5 MS. : If they were aware that the 6 cameras were there, and that the cameras should 7 have been installed. Now, and that's what I'm 8 saying, I don't know if, who knew that the 9 cameras were there. 10 MR. : Yeah. I mean, certainly, 11 the warden did. 12 MS. : Or that -- 13 MR. : But -. 14 MS. : -- that it shipped. Mm-hmm. 15 MR. : So, if the -- 16 MS. : Mm-hmm, 17 MR. : -- warden knew that, is 18 that something you think that he has exposure 19 to, then, as well? 20 MS. : Hmm. Oh my gosh. If - again, 21 without knowing who knew what, I don't, I don't 22 know who -. This is -. Yeah. 23 MR. : Sure. 24 MS. : No. 25 MR. : No. And that's fine. EFTA00110148 LIMITED OFFICIAL USE 148 1 And point being, though, you didn't know that 2 the cameras were even there. It sounds like 3 you are saying? 4 MS. : I would have no knowledge to 5 know about the cameras were there, because this 6 all happened prior to me. 7 MR. : Right. No. I'm just 8 saying -- 9 MS. (Indiscernible *02:17:39). 10 MR. : -- like, you know, you 11 were -- 12 MS. : Yeah. No. 13 MR. : -- you were -- 14 MS. : No. 15 MR. : -- you were, I know it 16 was only a month and a half, but you were 17 there, leading up to this point. I just didn't 18 know if that was a conversation that would be 19 happening within executive staff meetings, 20 that, hey, this is where we are on the camera 21 project. You know, and -- 22 MS. : Well, now -- 23 MR. : -- we'll be -. 24 MS. : -- conversations about the 25 camera project, and again, I'm going to EFTA00110149 LIMITED OFFICIAL USE 149 1 reiterate what I've kind of said before, 2 because of this incident, there have been 3 discussions about things that happened within 4 this incident, but that's after the fact. 5 MR. : And so, prior 6 MS. you're asking -- 7 MR. : -- prior to August 10th, 8 that you weren't involved in the conversations 9 at all with the camera project? 10 MS. : I do not recall anything 11 specifically about discussing about camera 12 project. 13 MR. : Great. 14 MS. : Now, if you can, if you can 15 show me something, or anything to that effect, 16 then I can say, okay, yes. 17 MR. : No, no, no, and again, 18 this is not an I gotcha interview. This is 19 just to ask -- 20 MS. : No. I know. 21 MR. : -- you know -. 22 MS. : I know. But I'm being 23 forthcoming, so that's why I'm trying to tell 24 you. In your investigation, I know you are 25 aware, you've had conversations with folks that EFTA00110150 LIMITED OFFICIAL USE 150 1 are giving you information, but this is 2 information after the fact. 3 MR. : Right. And then -- 4 MS. : So -. 5 MR. : -- and point being is you 6 don't recall anything prior to, about -- 7 MS. : No. 8 MR. : -- a camera project. You 9 are not -. You weren't aware that there was a 10 - at least at this moment in time - you don't 11 recall there ever being a camera project 12 leading up to the incident? 13 MS. : I do not recall. Hmm-mm. 14 MR. : Okay. 15 MS. : I did -. Yeah. I don't 16 recall. Mm-hmm. 17 MR. : Okay. So, now, we are 18 going to touch on cell assignments. Then we're 19 going to just try to fly through the rest, 20 because that was the primary things I wanted to 21 talk to you about, were the cameras and 22 MS. : Mm-hmm. 23 MR. : So, these are more just 24 to touch on some things. 25 MS. : Mm-hmm. EFTA00110151 LIMITED OFFICIAL USE 151 1 MR. : Now, are you aware that, 2 on August 9th and 10th, 2019, Epstein was not 3 in his assigned cell, as documented within the 4 BOP cell assignment history, and the BOP 5 database? 6 MS. : Can you say that one more time? 7 I'm sorry. 8 MR. : So, were you aware, are 9 you aware of anything with a cell discrepancy, 10 with Epstein, that he was, he was physically in 11 a cell that didn't correspond with the BOP 12 system? 13 MS. : Yes. And this information 14 after, after the fact. 15 MR. : And do you know why 16 Epstein wasn't in his assigned cell, according 17 to the BOP database? 18 MS. : Sheer error. 19 MR. : And do you know who made 20 that error? 21 MS. : Not - no - not specifically. 22 don't know who made the error. 23 MR. : So, what do you know 24 about it? 25 MS. : I know that there were keying EFTA00110152 LIMITED OFFICIAL USE 152 1 errors. And so, Sentry reflected one cell 2 assignment, but he was physically in another 3 cell. 4 MR. : And do you -? So, he was 5 in that cell from the time he, you know, 6 assigned to that cell in Sentry, from July 7 30th, all the way to August 10th. 8 MS. : Mm-hmm. 9 MR. : So, being that he was 10 there for, you know, ten or 11 days -- 11 MS. : Mm-hmm. 12 MR. : -- should that have been 13 caught in that period of time? 14 MS. : Yes. 15 MR. : And who should have 16 caught that? 17 MS. : The folks that are doing the 18 rounds. 19 MR. : So, is that, that falls 20 onto the SHU staff? 21 MS. : If - yeah - if it happened in 22 GP, it would have fallen on the person that is 23 actually doing the rounds in GP. So, yes. Mm- 24 hmm 25 MR. : Okay. And then, would EFTA00110153 LIMITED OFFICIAL USE lr 1 any lieutenants, whether it be the SHU 2 lieutenant, or the captain, or, you know, ops, 3 activities lieutenant, should any of them 4 caught this? 5 MS. : Well, they would have only know 6 that if they actually looked at a roster, and 7 physically walked with a roster, to know which 8 cell he was in. But I'm thinking about the 9 292s, whether or not it would have the cell on 10 it. I'm not sure if the 292 -. Do you know 11 what I'm talking about when I say 292? 12 MR. : Yeah. His file that is 13 kept in the housing unit. 14 MS. : Does it have this -? I'm not 15 even sure if it has the cell number on it. But 16 the long and short of it, you are making 17 rounds, you're pulling the inmate in and out of 18 his cell, you're keying, because -- 19 MR. : Now, are you talking 20 about bed book count, or are you talking about, 21 like, actual rounds? 22 MS. : No. You're making rounds. Not 23 a bed count. If you actually did it, if a bed 24 book was done, between those days, then whoever 25 did the bed book would most definitely know EFTA00110154 LIMITED OFFICIAL USE 154 1 that there was an error. Because you have to 2 have the roster with you. But without, if a -. 3 I don't know if a bed book was count during 4 that time. I know that the counts were done 5 after the fact. 6 MR. : And is there a -- 7 MS. : (Indiscernible *02:22:36). 8 MR. : -- requirement to do, 9 like, a bed book count, like once a week, or 10 any certain amount of days, or -? 11 MS. : There is no, there is no 12 requirement that says a bed book count has to 13 be done once a week. That was -. There was 14 some procedures put in place after the fact. 15 MR. : Okay. And is, and how do 16 we determine if a bed book count was in fact 17 conducted? 18 MS. : Without there being some 19 documentation, or to say, or, because I know 20 after the fact, like I said, when that was a 21 procedure put in place, it was indicated that 22 that should be documented in the log. 23 MR. : But that was an after the 24 fact thing? So, it wasn't -- 25 MS. : After. EFTA00110155 LIMITED OFFICIAL USE 155 1 MR. : -- being documented prior 2 to? 3 MS. : No. It wasn't. It wasn't done 4 prior to. Now, if you are making, TruScope, 5 the officers have a log that they do. Any 6 activity is part of whatever is going on in 7 your unit. That should have That could 8 have been logged. But is there a requirement 9 that said that you have to log that, that you 10 did the bed book count? You would be doing it, 11 you know, for documentation purposes. But a 12 lieutenant or a staff member can do a bed book 13 count, just to make sure that things are done 14 accurate. So, that's not -. It's not 15 something that was a requirement prior to. 16 MR. : Okay. So -- 17 MS. : Mm-hmm. 18 MR. : -- aside from the bed 19 book count, though, is there any other way, 20 though, and you said when they were conducting 21 rounds. I mean, when a staff member is 22 conducting rounds, are they supposed to be 23 walking around with the, you know, Sentry 24 report, or BOP roster, or whatever it is, the 25 housing roster that indicates what cell he is EFTA00110156 LIMITED OFFICIAL USE 156 1 assigned to in the system? 2 MS. : No. They don't have to have 3 the roster. However, once the inmate is 4 introduced into SHU, typically, the OIC does a 5 lot of the data entry. So, someone, even if 6 it's not the OIC, if someone in SHU, if someone 7 is doing the data entry, they are the ones that 8 is physically recording where the inmates is. 9 No one else would know where that inmate was 10 assigned unless they actually go in the system 11 and do the Sentry assignment. So -- 12 MR. : Okay. 13 MS. : -- the person that is saying, 14 okay, if I am saying put inmate X, Y, and I in 15 cell ten, I have to change him from wherever he 16 was before, and make sure that I update, I 17 update it. And not only that, there is a 18 physical board in SHU that you have the cards. 19 You have name tags or whatever. And it shows 20 where everyone is. 21 MR. : And does it say where 22 they are based upon them writing it down from 23 knowing that they are in there, or is that 24 showing where they are based upon what the BOP 25 system says? EFTA00110157 LIMITED OFFICIAL USE lr 1 MS. : From knowing where - from 2 knowing where they are. 3 MR. : Okay. 4 MS. : So, the system, and everything 5 should be the same. So, if I'm changing, if 6 I'm changing an inmate's Sentry assignment, 7 then I know I - I automatically know there is 8 not just one thing I have to do, there is a 9 couple of things I have to do. 10 MR. : Mm-hmm. 11 MS. : I have to physically move the 12 body from one place to another. 13 MR. : Okay. 14 MS. : I have to put the card, you 15 know, the card off of one door, put it on the 16 new door, and I know I have to update Sentry 17 because Sentry should be accurate. I 18 physically have to do a PP - I can't remember - 19 34, and then update the Sentry assignment. And 20 then, I should physically update the board, so, 21 the door and the board would have cards on 22 them, or, you know -- 23 MR. : And this is where, so, _ 24 know what happened. I know what happened when 25 this all happened on the 30th. On the - I know EFTA00110158 LIMITED OFFICIAL USE 158 1 what happened, how it was done, where the 2 discrepancy came in place. So, I guess my 3 question, though, is: between - and so, I know 4 that the person who dropped, you know, 5 basically dropped the ball by not making the 6 correct entry on the 30th, but the fact that 7 from the 30th all the way to the 10th -- 8 MS. : Mm-hmm. 9 MR. : -- this, you know, 10 discrepancy continued, my question to you is, 11 is there any point, aside from when he was 12 physically placed in the wrong cell, and the 13 key entry wasn't, you know, updated, or not in 14 the wrong cell, but they key entry wasn't 15 updated. Was there any way that that would 16 have been caught in those approximately ten 17 days? After that initial mistake happened. 18 So, like, an audit of the system -- 19 MR. : Yeah. 20 MS. : -- or, like, hey, let's, you 21 know, aside from a bed book count, how do we 22 know that these inmates are actually in the 23 cells that they are supposed to be assigned, 24 you know, or they are in the cells that they 25 are assigned in, in the system? Is there a EFTA00110159 LIMITED OFFICIAL USE 159 1 checks and balance to that? Are they -? Is 2 there -? Is the staff supposed to be checking 3 those sheets, or is it -? Is there an audit 4 that is done by the lieutenant or the OIC? 5 MS. : I wouldn't say that there is an 6 audit done, but you -. That's (Indiscernible 7 *02:27:56). That's the 30 (Indiscernible 8 *02:27:58), ten. That -. There is not a 9 specific audit that is done on a daily basis. 10 There is not an audit that is done besides, 11 like I said, you making rounds 12 MR. : Mm-hmm. 13 MS. : -- and you -. Yeah. I can't 14 think of a specific, like you said, a procedure 15 in place that you would check, where you would 16 audit on a daily basis, besides if you were 17 actually required to do a bed book count. 18 Which, she was not required to do a bed book 19 count daily. 20 MR. : Right. And at the time, 21 they weren't required to do them at all? 22 MS. : There was no procedure - and 23 when you say they were not required - there is 24 times when -- 25 MR. : I mean, based upon a time EFTA00110160 LIMITED OFFICIAL USE 160 1 period. 2 MS. : -- yeah. 3 MR. : versus, like, a, you 4 know, an incorrect count. 5 MS. : Yeah. Not that I am - not that 6 I am aware of. 7 MR. : Okay. Now, just to touch 8 on cell searches. On August 9th and 10th, 9 2019, do you know how often the SHU staff were 10 supposed to conduct cell searches? 11 MS. : Oh, you are supposed to do cell 12 searches daily. 13 MR. : Okay. And is it, like, 14 supposed to be at least five per shift -- 15 MS. : Mm-hmm. 16 MR. : -- aside from the 17 morning? 18 MS. : It's five. 19 MR. : Five. 20 MS. : Yeah. Yeah. And then, you 21 annotate it in, I believe it's TruScope, so 22 that you are ensuring, and that kind of, it 23 tracks, so that there is a, so that you can 24 ensure that all of the cells have been done. 25 MR. : Okay. So, is it EFTA00110161 LIMITED OFFICIAL USE 161 1 acceptable that only one cell was entered as 2 being searched in TruScope, on August 9th, 3 2019? 4 MS. : No. You should do at least 5 five. 6 MR. : Now, do you believe that 7 if only one was entered, does that mean only 8 one was actually conducted? 9 MS. : Hmm. I wouldn't say that. But 10 because I don't -. Hmm. That would be -. I 11 would question why one was only entered. But 12 you should do five. And you should recall, 13 record all five. 14 MR. : Now, being, you know, day 15 and night watch -- 16 MS. : Mm-hmm. 17 MR. : -- are required to do 18 five, who is responsible for, one) conducting 19 them; and two) entering them into TruScope? Is 20 it the OIC that is ultimately responsible to 21 make sure that they are done, and then enter 22 them, or is it, there is no rhyme or reason to 23 who is actually responsible? Everybody is -- 24 MS. : I wouldn't -- 25 MR. : -- responsible. EFTA00110162 LIMITED OFFICIAL USE 162 1 MS. : -- no. I wouldn't say who, 2 because the folks that actually do the, that do 3 the rounds, they are physically, you know, 4 doing the manual labor. And typically, the SHU 5 OIC, because there is not, like, five computers 6 up in SHU. There may be one or two computers 7 in SHU. And typically, the OIC is the one that 8 is logged in. And that person is doing all the 9 administrative work. So, they would ensure 10 that, okay, rounds are done. And if there were 11 bar taps, or like you said, if there were cell 12 searches done, that information is then 13 communicated from one officer to the OIC, and 14 then that person goes in and records that it's 15 done. 16 MR. : Okay. Do you know 17 anything about Epstein placing a telephone call 18 on August 9th, 2019, from the SHU? 19 MS. : You said from August 9th? 20 MR. : August 9th, 2019. Do you 21 know anything about Epstein placing -- 22 MS. : I -- 23 MR. : -- a telephone call from 24 25 MS. : -- again -- EFTA00110163 LIMITED OFFICIAL USE 1, 1 MR. : -- the SHU? 2 MS. : I know, I know information 3 after the fact. Just like everybody else. But 4 the day that it happened, no, I wasn't aware of 5 the phone call the day that it happened. I 6 know information after the fact. 7 MR. : Okay. And what did you 8 learn after the fact? And just briefly. 9 MS. : Mm-hmm. That there was a staff 10 member that allowed him to place a phone call. 11 MR. : Did you learn that it was 12 a phone call on an unrecorded line? 13 MS. : Mm-hmm. 14 MR. : Is that a yes? 15 MS. : Yes. That is a yes. 16 MR. : Okay. And then, do you - 17 is that standard practice, to allow inmates to 18 make personal calls, as had been done, from an 19 unrecorded line? 20 MS. : No. That is not standard 21 practice, and the phone call should be on the 22 ITS - the Inmate Telephone System - line. 23 MR. : Now, if he didn't have 24 his pack and PIN set up -- 25 MS. : Oh, yeah. EFTA00110164 LIMITED OFFICIAL USE 164 1 MR. : -- or PIN and pack, or 2 however, which way you say it, what, what could 3 have or should have happened, if you wanted to 4 allow someone to take a - make a telephone 5 call? 6 MS. : They don't make a phone call. 7 MR. : They just don't make one? 8 MS. : They don't make one. There is 9 allowances for, like, the (Indiscernible 10 *02:32:44) phone calls. That would be done by 11 the Chaplin, but that, too, is on a recorded 12 line. And that is in the Chaplin area. The 13 other thing is a legal phone call, and that 14 would be on an unmonitored line. But that 15 would only be for legal purposes. 16 MR. : Now, is it true, though, 17 if it was allowed to be done on a legal line, 18 if it was authorized by, you know, the captain 19 or whomever, or the case manager, unit manager, 20 should it be put on speaker phone, and 21 monitored by a staff member? 22 MS. : Policy says - I don't know - 23 but policy says that the inmates should make 24 phone calls, and it should be through the ITS 25 system. EFTA00110165 LIMITED OFFICIAL USE 165 1 MR. : And do you -- 2 MS. : But you -- 3 MR. : -- is that -? 4 MS. : -- but there is social calls 5 and legal calls. 6 MR. : Phone calls and legal 7 calls -. 8 MS. : Oh, no. I said there is social 9 calls and there is legal calls. 10 MR. : Okay. 11 MS. : And the only phone call that 12 should be on an unmonitored line would be the 13 legal call. 14 MR. : Okay. So, you don't, you 15 don't believe there is any circumstance where, 16 if it is not a legal call, that a social call 17 should be made? 18 MS. : I know policy, what I know of 19 policy, it indicates social calls, which should 20 be via ITS. 21 MR. : And do you know if there 22 was any kind of recorded line in the SHU, that 23 could have been utilized if an inmate did not 24 have a pack and PIN? 25 MS. : No. EFTA00110166 LIMITED OFFICIAL USE 166 1 MR. : No. 2 MS. : Hmm-mm. 3 MR. : There was no line. There 4 was no such line. Just a legal line? 5 MS. : No. I'm saying, there is an 6 ITS system in SHU. 7 MR. : No, no, no. What I'm 8 saying is 9 MS. (Indiscernible *02:34:31). 10 MR. : -- if someone doesn't 11 have a pack and PIN, to be able to record it, 12 do you know if there was another type of a 13 line, like you said, I think you said the 14 Chaplin has a line that people can use, that 15 for bereavement purposes, but it's still 16 recorded. 17 MS. : Mm-hmm. 18 MR. : Is there a line that is 19 still recorded, that a staff member can provide 20 to an inmate that doesn't have the ability to 21 make a call from his pack and PIN? 22 MS. : No. 23 MR. : Or -? 24 MS. : No. 25 MR. : And is that no, there is EFTA00110167 LIMITED OFFICIAL USE 1 no line, or no, you are not aware? 2 MS. : No, there is no line that you 3 can make a phone call from, that is recorded, 4 that is not hooked up to the ITS. 5 MR. : Okay. And when you say 6 7 MS. : -- (Indiscernible *02:35:09). 8 MR. : -- the ITS, what does 9 that mean? 10 MS. : Inmate Telephone System. 11 MR. : And is that -- 12 MS. : Yeah. 13 MR. : -- with reference to the 14 pack and PIN that they receive to be able to 15 put money on their cards and use -- 16 MS. : Mm-hmm. 17 MR. : -- or -? Yes? 18 MS. : Yeah. 19 MR. : Okay. 20 MS. : Yeah. That is a yes. 21 MR. : Okay. And what is your 22 understanding of what occurred in Epstein's 23 cell on August 9th or 10th, 2019? 24 MS. : Well, what I am aware of, 25 again, after the fact, is that he committed EFTA00110168 LIMITED OFFICIAL USE 168 1 suicide. 2 MR. : Okay. So, you believe 3 that Epstein took his own life? 4 MS. : Yes. He was the only one in 5 the cell. 6 MR. : And do you have any 7 information, with regard to anyone else taking 8 Epstein's life? 9 MS. : No. 10 MR. : Had you heard anything 11 about Epstein's cell door being left open the 12 night of August 9th, 2019, or 10th, or the 13 morning of August 10th -- 14 MS. : No. 15 MR. : -- 2019? 16 MS. : This is the first If that 17 happened, this would be the first time that I 18 have, of me even hearing that. I have never 19 heard that. 20 MR. : And have you heard of any 21 other cell mates in the SHU, in the SHU, with 22 their doors being left open the night of August 23 9th, 2019, or the morning of August 10th -- 24 MS. : No. 25 MR. : -- 2019? EFTA00110169 LIMITED OFFICIAL USE 169 1 MS. : No. I have never heard that. 2 MR. : No? And do you know if - 3 4 MS. : Never heard that. 5 MR. : -- do you know any 6 information, with regard to anyone harming 7 Epstein on August 9th or 10th, 2019? 8 MS. : No. 9 MR. : Okay. Do you know 10 anything about Epstein changing his will just 11 prior to his death? 12 MS. : Again, that's just in the news, 13 but no, I don't have any knowledge of that. 14 MR. : So, only from what you've 15 heard in the news? 16 MS. : Yeah. I don't have any 17 knowledge of that. We don't -. The BOP has 18 nothing to do with inmates' wills. 19 MR. : Okay. So, and we're just 20 going to now wrap up. It's just specific to 21 the timeline. There was an after action report 22 that was created by the BOP. So, this is 23 specifically where I am getting this 24 information, but -- 25 MS. : Mm-hmm. EFTA00110170 LIMITED OFFICIAL USE 170 1 MR. : I'm just going to ask 2 you just a couple more questions, then we will 3 be done. 4 MS. : Okay. 5 MR. : It says, "6:33 a.m., on 6 August 10th, 2019, a body alarm is activated in 7 the Special Housing Unit. SHU staff reported 8 inmate Epstein was unresponsive in cell," and 9 it says the cell, but it says Sentry does not 10 reflect this accurately. "Staff entered the 11 cell and attempted to wake inmate Epstein. 12 Control center announced a medical emergency, 13 and CPR was initiated." So, the information 14 that we have is that 6:33, Thomas told Noel, 15 call in the emergency, and Thomas went straight 16 into the cell. Did Thomas act appropriately by 17 going straight into the cell, or should he have 18 waited for someone to arrive? 19 MS. : No. There is Well, it 20 depends if you feel like you - that is an 21 emergency, and it is a life or death situation. 22 I don't know if he had the -. He could have 23 gone into -. He could have gone into the cell. 24 MR. : Okay. So, policy doesn't 25 dictate that you are supposed to wait for other EFTA00110171 LIMITED OFFICIAL USE 1 people to arrive, so that if it was a 2 MS. : Yeah. 3 MR. : -- a ruse, that someone 4 could have overpowered him, and then taken -? 5 MS. : There is no When you say 6 policy, policy does state that you have to be 7 safe, and that you should wait for another 8 staff to arrive. Policy does say that. If 9 Thomas felt that he had enough staff on hand, 10 don't know if he felt that, but policy does say 11 to ensure. And especially if you have more 12 than one inmate in a cell. So, with, I guess 13 Thomas realized there was only one inmate in 14 the cell, and if he saw the inmate hanging, he 15 would probably want to act immediately. But 16 policy protects you either way. If you feel 17 that you have enough, because - and that's your 18 - that's what I said - that's your discernment. 19 If you feel that you have enough people on, you 20 know, available, maybe he felt that way. 21 MR. : Okay. And then, it says, 22 "At 7:36 a.m., inmate Epstein pronounced dead 23 by the emergency room physician." Do you know 24 of anything about -? Do you know if Epstein 25 ever shown signs of life, prior to leaving the EFTA00110172 LIMITED OFFICIAL USE 172 1 MCC, or specifically from 6:33 a.m. to 7:36 2 a.m., do you know if he showed any kind of 3 signs of movement or life? 4 MS. : No. I don't. I arrived after. 5 And I have never heard of anything to the 6 contrary that he exhibited life. 7 MR. : Okay. And here is 8 another thing that was written in there, in the 9 BOP, and again, this is the BOP after-action 10 report. It says, "SHU has multiple cells 11 equipped with video recording capability. 12 Inmate Epstein was not housed in one of these 13 cells, and there appears to be no set guidance 14 on when to utilize these cells." So 15 specifically, I am assuming he is, they are 16 either talking about 10 South or possibly G- 17 tier. I'm not sure. I can't remember if G- 18 tier has cameras or not. But 10 South 19 certainly does. 20 MS. : Mm-hmm. 21 MR. : Do you believe that 22 Epstein should have been placed in one of those 23 cells that were, that had cameras in them? 24 MS. : I'm not going to say that. I'm 25 not going to say that he should have been EFTA00110173 LIMITED OFFICIAL USE 173 1 placed in a cell with a camera. He was an -. 2 He is an inmate, just like another inmate. So, 3 I can't, I can't say that, that he should have 4 definitely been placed in a cell. There 5 obviously was a reason that they felt that he 6 was safe, since he didn't say that he was going 7 to -. I don't -. Yeah. I can't say that he 8 should have definitely been placed in a cell 9 with a camera. 10 MR. : Okay. 11 MS. : Because those cells are for the 12 SAMs inmates. Those inmates that can't, you 13 know, their communication has to be monitored. 14 So, that is a different vetting process. 15 MR. : Okay. 16 MS. : Mm-hmm. 17 MR. : And do you These are 18 going to be the last, like, three or four 19 questions. Oh. What do you believe allowed 20 Epstein to be able to - if he took his own life 21 - what do you believe allowed Epstein to take 22 his own life? 23 MS. : Well, there were, I think his, 24 if that's what he wanted to do, without - 25 because the -. Now, we do know that staff EFTA00110174 LIMITED OFFICIAL USE 174 1 members have to make rounds. They're going 2 to, every, I don't know, 30 minutes, a regular 3 round. But he could have done it right before, 4 or right after the round. So, it doesn't mean 5 that he still - at the end - still wouldn't 6 have happened. So, I can't say for certain 7 that, we still would not have had the same 8 outcome. 9 So, I can't -. I know there was some 10 things that staff did not do that they were 11 supposed to do. Had they still made their 12 rounds, there is a possibility that a death 13 could have still have occurred, because there 14 are instances where staff make their rounds, 15 and inmates still are able to successfully 16 complete suicide, unfortunately. So, in this 17 instance, staff - we all, again, know - staff 18 did not do what they were, you know, supposed 19 to do by policy, but I can't say with certainty 20 that he still would not have been able to 21 successfully complete suicide. 22 MR. : So, it sounds like rounds 23 would have helped. What about having a 24 cellmate? Do you think that would have helped? 25 MS. : Yes. A cellmate would have EFTA00110175 LIMITED OFFICIAL USE 175 1 been able to alert a staff member, that is, if 2 they were alert and oriented themselves. 3 MR. : Yeah. I would think, 4 though, if a cellmate was in there, and they 5 saw someone hanging themselves, you know, 6 obviously, there would be no requirement, I 7 guess, for them to do it, but that would 8 certainly indicate to that person that they 9 probably, there was an issue. Right? 10 MS. : Yeah. But when you say that, 11 when you say that, it depends on, see, if the 12 manner in which he committed suicide, he did it 13 because he was in there by himself. Yes. 14 MR. : Right. 15 MS. : But there is instances where 16 you have cellmates, if you are on, you could 17 have - an inmate could have tied a ligature 18 around his neck, if he was in his bed, and just 19 hung himself that way. So, again, there are 20 things that were not done on line with policy, 21 but I can't say for certain because we have, we 22 do have successful suicides, where staff do 23 follow procedure and follow policy. 24 MR. : But in this case, I 25 guess, you know, you know, correct me if I'm EFTA00110176 LIMITED OFFICIAL USE 176 1 wrong, but I would think that the two most 2 glaring things were the fact that he was 3 required to have a cellmate, and he didn't; and 4 that, also, staff were not conducting rounds as 5 they were required. Would you agree with that 6 assessment? 7 MS. : Yeah. We know that those 8 things did not happen. 9 MR. : And do you believe 10 anything else, you know, basically, if we are 11 looking at what all, you know, what could have 12 helped prevent this from happening in the 13 future? If we are looking at it as, you know, 14 like, well, what can we do better next time? 15 Aside from making sure, you know, cellmates 16 that are required to have cellmates have them, 17 and then, aside from making sure that staff are 18 actually conducting their rounds and counts, is 19 there anything else that should have been done? 20 MS. : Just -- 21 MR. : It sounds like you didn't 22 agree with putting him in a cell with a camera. 23 So, I'm just wondering if there is anything 24 else that -- 25 MS. : No. I'm not saying necessarily EFTA00110177 LIMITED OFFICIAL USE 177 1 I agree or disagree. I'm saying that there is 2 inmates that are in cells without cameras, and 3 they don't necessarily commit suicide. So, 4 what was the difference? Why did Epstein have 5 to be in a cell with a camera? So, I'm saying, 6 we don't -. That's not part of our policy, 7 that cameras have to be present. So, that is 8 not the That does -. That in and of itself 9 doesn't determine or make a difference whether 10 someone commits suicide or doesn't. 11 MR. : Sure. 12 MS. : Like, that's not a requirement. 13 MR. : So, I guess the - and I 14 probably got you off on track, on the camera 15 thing - I'm just saying, is there anything else 16 we are missing here, aside from, you know, what 17 we just discussed, as far as reasons that 18 allowed for Epstein to be able to take his 19 life? 20 MS. : No. 21 MR. : No. 22 MS. : I don't know. 23 MR. : Okay. What do you 24 believe the failures of the BOP - if you 25 believe there are any - that allowed for EFTA00110178 LIMITED OFFICIAL USE 178 1 Epstein to die? 2 MS. : I don't believe that the BOP is 3 responsible for him committing suicide. I 4 believe that, as you investigate, that there 5 are things that - no, none with the policy, but 6 I don't believe that that contributed to the 7 suicide itself. Because, like I said, I know 8 we are looking at it after, like, Monday 9 morning quarterbacking, but there are, there 10 are some instances where there is a successful 11 suicide, where does not follow protocol from 12 top to bottom. And it happens, unfortunately. 13 And in this instance, they didn't do everything 14 that they were supposed to do, or they didn't 15 do a lot, but I don't believe that it 16 contributed to him committing suicide. I 17 don't. I don't really believe that. 18 MR. : So, you don't believe - 19 and we didn't get into staff members sleeping 20 but you don't believe that a staff member not 21 conducting rounds, a staff member sleeping on 22 the job, a staff members not, you know, making 23 proper notifications and getting a new cellmate 24 into them, you don't believe that that is 25 contributed to him taking his own life? EFTA00110179 LIMITED OFFICIAL USE 179 1 MS. : I'm -- 2 MR. : The ability to do that? 3 MS. : hmm. Because when you are 4 saying staff members sleeping, yeah, if, even 5 if a staff member is awake, and that I'm saying 6 that because I'm aware of a successful suicide, 7 staff members can make their rounds every 30 8 minutes. And when they go by, unfortunately, 9 if someone actually is intent on committing 10 suicide, they can wait for you to make your 11 round, and they know that you don't have to 12 come back until another 30 minutes. 13 MR. : Sure. And I didn't say 14 that staff members -- 15 MS. (Indiscernible *02:47:32). 16 MR. -: -- caused him to die. 17 What I said is, helped contribute, and allowed 18 for him -- 19 MS. : Yeah. 20 MR. : -- to take his life. So, 21 what I'm saying is, like, the job -- 22 MS. : Okay. 23 MR. : -- performance that 24 wasn't done, and that's why this investigation 25 pertains to security failure and job EFTA00110180 LIMITED OFFICIAL USE 180 1 performance failure, because it seems to me 2 that there was a lot of job performance failure 3 here, at the very least, in the sense that 4 people weren't doing their jobs. 5 MS. : Mm-hmm. 6 MR. : And that, that helped 7 cause, you know, and again, I think you 8 mentioned it, if a person wants to kill 9 themselves, they're probably going to be able 10 to find a way. But there is also things that, 11 when an inmate is in our custody, it is our job 12 to try to do everything we can to keep them 13 alive, and prevent that from happening. 14 MS. : Mm-hmm. 15 MR. : So, my question to you 16 is, you don't believe that, by though, you 17 know, them not doing those things, that that 18 helped contribute? 19 MS. : And I know this might sound - 20 but you sound bewildered by my response, but 1 21 believe that it contributed to some failures, 22 but I don't really believe that the failure 23 equals the contribution of the suicide. I 24 really don't believe that. 25 MR. : Okay. Yeah. I don't EFTA00110181 LIMITED OFFICIAL USE 181 1 know that I look at it as a contribution. I'm 2 just saying, the failures that allowed for him 3 to be able to take his own life. And so, 4 again, I'm not saying that they helped assist 5 him with taking his life, but by not doing -- 6 MS. : Mm-hmm. 7 MR. their job, that, you 8 know, provided him ample opportunity to do so. 9 Would you agree with that? 10 MS. : Again, I'm going to - my thing 11 is going to be the same. 12 MR. : Okay. No. You're just 13 the first person I've talked to that said that. 14 MS. : Yeah. 15 MR. : Okay. That's totally 16 fine. Okay. Well, is there anything else that 17 I missed, or that you would like to add to 18 this? 19 MS. : Hmm-mm. No. 20 MR. : And are you still 21 there? Is there any follow up questions that 22 you have, before we end this thing? 23 MR. : No follow up questions. 24 MR. : All right. Great. Well, 25 you have my information. My cell phone. My EFTA00110182 LIMITED OFFICIAL USE 182 1 email. 2 MS. : Mm-hmm. 3 MR. : If there is anything you 4 need, please feel free to contact me. But 5 otherwise, I would very much greatly appreciate 6 if you get me that stuff we talked about, 7 specific with regard to the documents that you 8 9 MS. : Okay. 10 MR. : -- that you kept on file, 11 and I think you took - there was something else 12 that we discussed. What was the other thing? 13 Was it -? 14 MS. : You said it was about the bad 15 (Indiscernible *02:49:59). I made some notes 16 about the bad count. And then, about the court 17 document. 18 MR. : Perfect. Yeah. So, 19 there would be those specific things. But 20 again, anything -? I think you said you made 21 records of things that you produced, that would 22 be very much appreciated, as well. 23 MS. : Yeah. 24 MR. : It is 1:24 p.m. on 25 December 2nd, 2021. This is Senior Special EFTA00110183 LIMITED OFFICIAL USE 183 1 Agent and I am going to turn 2 off this recorder. 3 MS. : Okay. 4 (Whereupon, the above-entitled matter went 5 off the record and back on the record). 6 MR. : This is Senior Special 7 Agent It is currently 1:26 8 p.m., 12/02/2021. Prior to hanging up the 9 call, Associate Warden asked if I could 10 turn back on the recorder so she could make a 11 clarifying statement. So, Ms. , go ahead. 12 I'll just remind you, you are under oath, and 13 this is a voluntary interview. 14 MS. : I wanted to clarify whether I 15 filled that, some of the things helped, I guess 16 helped to, or contributed to, Epstein's ability 17 to commit suicide. While I understand that 18 this is something that no one wanted, there 19 were things that were not done, that were in 20 line with policy. That were required to be 21 done, and had those things been done, maybe we 22 would not be questioning the liability aspect. 23 But I just want to ensure that it's understood 24 that I have - I believe that that's should 25 follow policy, to ensure with certainty that no EFTA00110184 LIMITED OFFICIAL USE 184 1 inmate is able to hurt themselves, or that no 2 other inmate is able to hurt them. 3 So, with that knowledge, again, I really 4 hope that staff would have done everything 5 within their power to follow policy, so that 6 there would be no question as to what should or 7 should not have been done. And with 8 acknowledgement that there were not things done 9 that should have been done, as it relates to 10 following policy. 11 MR. : All right. Thank you 12 very much. Is there anything else you wanted 13 to add before I turn off the recorder and we 14 end this interview? 15 MS. : No. I think that's it. I just 16 wanted to add that as a sentiment, that I 17 understand that this is a serious matter, and 18 that it required care and attention, and that 19 it requires me to clarify what I believe 20 actually, you know, the staff did or did not 21 do. 22 MR. : Perfect. Thank you so 23 much. Again, if there is anything you need 24 from me, you have my email, and I will greatly 25 look forward to the information you can provide EFTA00110185 LIMITED OFFICIAL USE 185 1 following this interview. It is 1:28 p.m., 2 12/02/2021. This is Senior Special Agent 3 and I am turning off the 4 recorder. 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 EFTA00110186 LIMITED OFFICIAL USE 186 1 CERTIFICATE 2 I hereby certify that the foregoing pages 3 represent an accurate transcript of the 4 electronic sound recording of the proceedings 5 before the Department of Justice, Office of the 6 Inspector General in the matter of: 7 8 Interview of 9 10 /St 11 12 Brianna Rose Burton, Transcriber 13 14 15 16 17 18 19 20 21 22 23 24 25 EFTA00110187