EFTA00117643

1 2 APPEARANCES: OFFICE OF THE INSPECTOR GENERAL BY: BY: WITNESS: DIGITALLY RECORDED SWORN STATEMENT OF OTHER APPEARANCES: JASON FOY, ESQ. OIG CASE #: ERIC SARRAGA, ESQ. 2019-010614 SERINE GREG DEPARTMENT OF JUSTICE OFFICE OF THE INSPECTOR GENERAL JUNE 21, 2021 RESOLUTE DOCUMENTATION SERVICES 28632 Roadside Drive, Suite 285 Agoura Hills, CA 91301 Phone: (818) 431-5800 3 4 1 MR. The recorder is on. My 1 Seplowitz, LLC; as well as union representative 2 name is . I am a Senior 2 Serine Greg of the Local 3149 with the BOP. 3 Special Agent with the U.S. Department of 3 This interview will be recorded by me, Senior 4 Justice Office of the Inspector General New 4 Special Agent . Could S York Field Office and these are my credentials. 5 everyone please identify themselves for the 6 This interview with Federal Bureau of Prisons 6 record and spell your last name. To starti_ 7 correctional officer is being 7 again, I am DO) OIG Senior Special Agent 8 conducted as part of an official U.S. 8 9 Department of Justice Office of the Inspector 9 DOJ OIG Special Agent 10 General investigation. Today's date is June 10 11 22, 2021 and the time is 10:09 a.m. This 11 MS. : I'm 12 interview is being conducted at - what is the 12 MR. FOY: Jason Foy, F-O-Y, attorney for 13 location - 15 -? 13 14 MR. FOY: 15 Bergen Street, Hackensack, 14 MR. SARRAGA: Eric Sarraga, S-A-R-R-A-G-A, 15 New JerseiiIIIIIIII 15 attorney for 16 MR. : Thank you, sir. 16 MS. GREGG: Serine Gregg, G-R-E-G-G, Local 17 MR. FOY: Bergen County Bar Association, 17 3148. 18 second floor conference room. 18 MR. : Thank you everyone. Ms. 19 MR. : Okay. 19 IIII, you are here today as a subject in this 20 MR. FOY: By the way, that was Jason Foy 20 DOJ OIG investigation. This DO) OIG 21 speaking. 21 investigation concerns your alleged misconduct 22 MR. Yes. Also present are 22 to include allegations of false statements, job 23 DO) OIG Special Agent 23 performance failure, security failure, and 24 Correctional officer ; 24 reporting false information. This is an 25 attorneys, Jason Foy, and Eric Sarraga of Foy & 25 official DOJ OIG investigation and you are EFTA00117643 S 6 1 being asked to voluntarily provide answers to 1 questions. Any statement you furnish may be 2 our questions. Will you agree to a voluntary 2 used as evidence in any future criminal 3 interview with the DO] OIG? 3 proceeding or agency disciplinary proceedings 4 MS. : Yes. 4 or both. And of course, there's the DPA 5 MR. : Alright. Great. And 5 waiver. I understand the warnings and 6 then everyone that does voluntary interviews 6 assurances stated above and I am willing to 7 with the DO] we provide them with these 7 make a statement or answer questions. No 8 voluntary interview forms. I don't know if you 8 promises or threats have been made to me and no 9 guys were sent that at the time, but it says, 9 pressure or coercion of any kind has been used 10 "United States Department of Justice Office of 10 against me. You can take a look at this and 11 the Inspector General, Warnings and Assurances 11 review it. If you agree, there's a section 12 to Employee Requested to Provide Information on 12 there for your name and signature. 13 a Voluntary Basis. You are being asked to 13 MR. FOY: So the only thing that this is 14 provide information as part of an investigation 14 actually subject to is the deferred prosecution 15 being conducted by the Office of the Inspector 15 agreement. 16 General. This investigation is being conducted 16 MR. : Well so there's the 17 pursuant to the Inspector General Act of 1978 17 agreement that you had, so that's the part 18 as amended. This investigation pertains to 18 where I'm talking about the specific part where 19 your alleged misconduct to include allegations 19 it says criminal. 20 of false statements, job performance failure, 20 MR. FOY: Mm-hmm. 21 security failure, and reporting false 21 MR. : That's something I think 22 information. This is a voluntary interview. 22 that was worked out with the U.S. Attorney's 23 Accordingly, you do not have to answer 23 Office -- 24 questions. No disciplinary action will be 24 MR. Exactly. 25 taken against you if you choose not to answer 25 MR. : So -. 7 8 1 MR. FOY: I know there's no sort of 1 rest for signature of witness, name of witness, 2 protection with regard to the disciplinary 2 date, time and place. 3 internalliiiiiiiiiinistrative thing that -- 3 MR. : This is Agent signing 4 MR. : Correct. 4 on the siinat eof witness. 5 MR. FOY: -- will happen at some point. 5 MR. : And then do you understand 6 But I just wanted to make that clear. But go 6 the form as ou read and you review? 7 ahead, yoiliiiiiiii IIII. 7 MS. : Yes, I do. 8 MR. : Now obviously, that is 8 MR. : Great. Thank you. 9 pursuant to you answering questions truthfully. 9 Before starting the interview, I'd like to 10 MR. FOY: Right. Of course. That's the 10 place you under oath. Can you please raise 11 exception to our agreement. 11 your right hand? Do you swear to tell the 12 MR. : There's a line that says 12 truth and nothing but the truth during this 13 employee si nature. 13 interview? 14 MS. . Mm-hmm. 14 MS. : Yes, sir. 15 MR. Alright. And the rest 15 MR. Thank you, Ma'am. 16 will be filled out by the two of us. 16 Alright. Please let me know if you do not 17 MR. 17 understand any of my questions. I'll try to 18 MR. lila : Thank you, sir. 18 rephrase or ask it a different way. 19 MR. Si 19 MS. : Okay. 20 MR. : And thank you for signing 20 MR. : Alright. So this is 21 Ms. IIII. Alright. So I'm going to sign where 21 something we ask everybody. Do you - what's 22 it says signature of the Office of the 22 your current home address? 23 Ins ector General S ecial Agent. Again, this 23 MS. 24 is . I'm printing my name. 24 25 And Special Agent , can you fill out the 25 MR. Thank you. What's your EFTA00117644 9 10 1 date of birth? 1 worked at the Post Office. 2 MS. 2 MR. : Okay. What did you do 3 MR. And your last four of 3 there? 4 your Social Securit number. 4 MS. : I was a mail handler. 5 MS. 5 MR. And for how long? 6 MR. Thank you. What's your 6 MS. six months. 7 highest level of education? 7 MR. Six months? 8 MS. ,bachelor's degree. 8 MS. : Mm-hmm. 9 MR. : And what was your 9 MR. And that was in 2016, 10 bachelor's degree in? 10 2016? When did you do that? 11 MS. IIII: Criminal justice (Indiscernible 11 MS. : Yes. 12 *00:06:14) in law. 12 MR. 2015 and 2016? 13 MR. : And where did you receive 13 MS. No. At the post office, I was 14 that degree from? 14 there 2017. 15 MS. John Jay. 15 MR. . Oh 2017. 16 MR. : John Jay in New York 16 MS. : '16, '17. Mm-hmm. 17 City? 17 MR. Oh, okay. And do you 18 MS. Yes, sir. 18 have any military service? 19 MR. : And when did you 19 MS. : Yes. 20 graduate? 20 MR. And what is that? 21 MS. 1.7. 21 MS. : Military service? 22 MR. : Thank you. What did you 22 MR. Yeah. Can you tell me 23 do - just briefly - prior to working with the 23 what the service? 24 BOP? 24 MS. The Army. 25 MS. IIII: Prior to working with the BOP I 25 MR. Army. And how long were 11 12 1 you in the Army? 1 MR. FOY: So would it be 17 into 18? 2 MS. : Six years. 2 MS. : 18 yeah. 3 MR. : From when until when? 3 MR. Oh you did start with the 4 MS. 2008 to 2014. 4 BOP in '18? 5 MR. And what did you do with 5 MS. 6 the militar 6 MR. Not in '16? 7 MS. IIII: I was a patient administrative 7 MS. : No. That was an error in the 8 specialist. 8 (Indiscernible *00:07:49). 9 MR. And what is that? 9 MR. FOY: Right. So it's '18, then she 10 MS. Patient admin. 10 left the Post Office in '17, going to - so I 11 MR. Patient as in like a 11 think it's 16 -. No 17 - 18. 12 hospital? 12 MS. IIII: '18 - Mm-hmm. 13 MS. : Yes. 13 MR. FOY: Post Office. Then MCC. 14 MR. : Okay. So you worked in a 14 MR. : Okay. And did you work 15 hospital. And what was your rank when you left 15 for anybody prior or in between your military 16 the militar ? 16 service and the post office? 17 MS. : E4 Specialist. 17 MS. : No. 18 MR. : And did you leave - were 18 MR. No? Okay. 19 you honorabl , discharged? 19 MS. Hm-mm. 20 MS. : Yes. 20 MR. So you were unemployed at 21 MR. : Okay. 21 that time? 22 MR. FOY: Can I - one second real quick? 22 MS. No I was going to school. 23 For the post office, you said 16 - 17 but you 23 MR. Oh that's when you went 24 started MCC in 18. 24 to John Ja 25 MS. IIII: Yeah. 25 MS. IIII: That's when I was going to John EFTA00117645 13 14 1 Jay. Yeah. 1 have you held with the BOP? 2 MR. Okay. Thank you. And 2 MS. : Correctional officer. 3 when was our Enter on Duty Date with BOP? 3 MR. • Okay. The entire time? 4 MS. : June 24, 2018. 4 MS. Yes, sir. 5 MR. Okay. And when did you 5 MR. : Alright. And when you 6 graduate from BOP training down at the Federal 6 were there last, who did you report to? Who 7 Law Enforcement Training Center? 7 was your direct supervisor? Or did you have 8 MS. IIII: Um, I want to say September of 8 one? 9 2018. 9 MS. : Lieutenant 10 MR. : Okay. But you did 10 MR. : And do you know how to 11 graduate from there? 11 spell that last name? 12 MS. Yes, I did. 12 MS. 13 MR. That was a correctional 13 MR. Thank you. What is your 14 officer training? 14 current -? Again, this is something we ask 15 MS. : Yes. 15 everybody. We won't be contacting your client. 16 MR. : Alright. And when and 16 But what is our current cell phone number? 17 where was your first office assignment with the 17 MS. 18 BOP? 18 MR. : Okay. And how long have 19 MS. Sa that again? 19 you had that number? 20 MR. When and where was your 20 MS. : Years. 21 first office assignment with the BOP? So where 21 MR. • Years. 22 did you start - did you start working in MCC 22 MS. Mm-hmm. 23 and work there the entire time? 23 MR. • So for a long time. 24 MS. : Yes, sir. 24 MS. Yes. 25 MR. Okay. And what positions 25 MR. And to include in 2019? 15 16 1 MS. 1 MR. By no other means? 2 MR. : Okay. Any other cell 2 MS. 3 phone numbers? 3 MR. Okay. And when did you 4 MS. 4 last work at the MCC? 5 MR. • Okay. And your current 5 MS. August 10, 2019. 6 email address? 6 MR. And was that the same 7 MS. 7 supervisor that you mentioned? 8 MR. . Okay. Great. And have 8 MS. : Yes. 9 you had that one also for years? 9 MR. : Okay. Briefly, what 10 MS. Yes. 10 training have you attended or conducted during 11 MR. Okay. Any others? 11 your employment with the BOP? You mentioned 12 MS. Yes. 12 the correctional officer training at FLETC. 13 MR. What are the others? 13 What other trainings have they provided for 14 MS. 14 you? 15 MR. . Same? 15 MS. IIII: Um, their two-week training 16 MS. Mm-hmm. 16 when you first start at BOP. I forget what 17 MR. You've had that for 17 it's called. IF training. Yes. 18 years? 18 MR. IF training? 19 MS. Yes. 19 MS. Mm-hmm. 20 MR. Okay. Both in 2019? 20 MR. And any other training? 21 MS. Yes. 21 MS. 22 MR. Okay. Thank you. Um, do 22 MR. Annual refresher 23 you have any current -? I should have asked 23 training? 24 this. Ar2a2u currently employed right now? 24 MS. : I have one. 25 MS. IIII: No. 25 MR. : Okay. So you've gone to EFTA00117646 17 18 1 annual. And what about like a SHU training 1 you just initial and date? And that's just a 2 course? 2 way for us to verify that that's what we showed 3 MS. 3 you. 4 MR. Okay. But you did - and 4 MS. IIII: Okay. 5 this is just - you guys can take a look at this 5 MR. FOY: Each page or just to top? 6 if you would like. This is the training that 6 MR. Nope, just the top of 7 we have for you. That we asked for your list 7 each page. 8 of training. I'm not asking you to necessarily 8 MR. FOY: Okay. Is (Indiscernible 9 verify that you've conducted all of it, but it 9 *00:12:34)? 10 shows the last time you did your annual 10 MR. No, you do have that. So 11 training was on 3/8/2019 was when you actually 11 just briefly, you don't have to like list off 12 completed that week of training. 12 the course syllabus. But what did they cover 13 MS. • Yes. 13 during that annual training? 14 MR. • Does that sound correct? 14 MS. IIII: Um they spoke about different 15 MS. Correct. 15 areas like dealing with inmates. They spoke 16 MR. Again, this just goes 16 about the issues on the job like dealing with 17 along with it. It shows -. It shows what the 17 shortages. They spoke about um, basically like 18 syllabus was as well as the sign-in sheet where 18 mask fitted I remember. 19 Ms. signed in. Again, it's - we're not 19 MR. • Mask fitting? 20 asking to ou 20 MS. Mm-hmm. 21 MS. : Mm-hmm. 21 MR. • Was that back in 2019? 22 MR. : For - if you want to take 22 People were wearing masks as well? 23 a look at it you can. It just shows that you 23 MS. : No like um. 24 did that training in March of 2019. And 24 MR. : It's for OC's sprays? 25 anything that I'm going to provide to you, can 25 MR. Oh, for OC spray. 19 20 1 MS. : Yes. 1 it? Polices and guidelines? 2 MR. : Okay. Did they include 2 MS. IIII: I think I signed that like you 3 things like ethics, standards of conduct? 3 receive it. 4 MS. • Yes. 4 MR. : Right. Okay. If you 5 MR. Okay. What about like 5 don't mind, just -. 6 counts and rounds? 6 MR. FOY: You want it in the lower right? 7 MS. IIII: I don't recall them talking 7 MR. : Doesn't matter. Top or 8 about counts and rounds. 8 bottom. You know wherever there's room. I 9 MR. : Okay. So did they go 9 typically do top, but bottom is totally fine. 10 over like MCC policies and guidance? 10 MR. FOY: This one, that one. 11 MS. : Yes. 11 MR. : Today's date is lune 22nd. 12 MR. : Okay. And did they ever 12 MR. FOY: That's part of the same 13 provide you with the policies and guidelines or 13 document. 14 did they ust speak to you about it? 14 MS. IIII: Hm. 15 MS. : For in this training? 15 MR. FOY: And just the top page. 16 MR. Yes. 16 MR. : And now you mentioned 17 MS. : They just spoke about it. 17 that you didn't quite remember them going over 18 MR. At another time did they 18 training when conducting counts and rounds in 19 provide you with the polices and guidelines? 19 this training. Did you - were you - did you 20 MS. IIII: Yeah. It's on like the 20 ever receive training on conducting counts and 21 computer. 21 rounds? 22 MR. Okay. 22 MS. : Yes. 23 MS. The -. 23 MR. : Okay. When would that 24 MR. Do you have to certify 24 have been? 25 that you've like received it and you reviewed 25 MS. IIII: In an IF training. EFTA00117647 21 22 1 MR. And what does IF stand 1 rounds. Just like a general - 2 for? 2 MR. Right. 3 MS. IIII: Rm. 3 MS. Like -. 4 MS. GREGG: You want some clarity? I can 4 MR. Like you know the housing 5 tell you -- 5 orders or unit policies and things like that. 6 MR. : Sure. 6 When you're supposed to conduct counts, when 7 MS. GREGG: -- just what it stands for. 7 you're supposed to do rounds, that type of 8 Institution Familiarization training. 8 thing. 9 MR. : Okay. Great. And that's 9 MS. : The post orders. 10 something that the MCC provided directly? 10 MR. : Post orders. Right. 11 MS. : Yes. 11 Okay. Great. You mentioned you didn't 12 MR. : Okay. Great. And then 12 remember ever going to quarterly SHU training. 13 you had mentioned - did you ever receive 13 This is a sign-in sheet for quarterly SHU 14 policies on counts and rounds? 14 training. I just want to -. Is this your 15 MS. : No. 15 signature on there for June 26, 2019? 16 MR. I know you said you 16 MS. IIII: You see how I'm the last one on 17 certified. Do you remember that specific 17 the bottom of all of them? 18 policy - like receiving that? 18 MR. : Correct. 19 MS. IIII: Like specifically on counts and 19 MS. : Because I wasn't at the 20 rounds? 20 training when I came -. 21 MR. : I'm not asking you to 21 MR. : Did they provide it to 22 like verbatim tell me what it was. I'm just 22 you one-on-one though? 23 saying like were you provided and you reviewed 23 MS. : No. 24 it. DO you remember? 24 MR. So how come -? 25 MS. IIII: Not specifically on counts and 25 MS. : Because when I came back from 23 24 1 an injury, the lieutenant asked me to sign 1 MS. 2 because when they had program review, they need 2 MR. And is she a lieutenant? 3 to show that I received the training. But I 3 MS. : She's a - I don't know what she 4 never did. She just asked me to sign. That's 4 is now. But she's not at MCC anymore. She's 5 why I wonder wh 5 at somewhere in Jersey. 6 MR. Who asked to do that? 6 MS. GREGG: I'm sorry. Before you go, are 7 MS. : Lieutenant 7 you done with that question? 8 MR. : So that supervisor you 8 MR. : Actually, let me um, I 9 mentioned was your first line supervisor asked 9 didn't do this. 10 you sign without providing you the training? 10 MS. GREGG: Because I want to 11 MS. : Yes. 11 (Indiscernible *00:17:14) 12 MR. : And she didn't' like 12 MR. : And I did forget to do 13 provide you anything to review? 13 this. There's an advisory to the union 14 MS. : No. 14 representative. 15 MR. She didn't go over 15 MS. GREGG: Mm-hmm. 16 anything with you? 16 MR. : Can you review this? And 17 MS. : No. 17 I do apologize. But since you're speaking up a 18 MR. Did you discuss this with 18 little bit, let me hand this to you. and then 19 her - that how can you sign something without 19 you can review that. And then if you want to 20 being provided the training? 20 just take a look. After you're done reviewing, 21 MS. IIII: Well I just told her I wasn't 21 you may sign it if you agree. 22 here. I was out on an injury. She said she 22 MS. GREGG: Will you be able to give me a 23 knows but she needed me to sign it because they 23 copy of it? 24 need it for ro ram review. 24 MR. : Yes. I think it says on 25 MR. : What's her first name? 25 there that we will forward you a copy of that. EFTA00117648 25 26 1 MS. GREGG: I didn't even see that part. 1 MS. IIII: From March 2019 to - I came 2 MR. : Should I continue asking 2 back in June. So when I came back in June, 3 questions while she's reviewing that or do you 3 that's when I was told to sign this. 4 want to wait? 4 MR. Okay. 5 MR. FOY: Yeah, you can ask questions. 5 MS. Mm-hmm. 6 Absolutel 6 MR. Alright. Thank you for 7 MR. . : Sure. So there's another 7 signing the Advisory to Union Representative. 8 training that you - it says that you conducted 8 MS. GREGG: I signed it (Indiscernible 9 on also June 26, 2019 for SHU suicide 9 *00:19:02). 10 prevention training. Did you also not receive 10 MR. : I am just going to sign 11 that trainin ? 11 that form as name of OIG special agent. Again, 12 MS. Yeah. I didn't. 12 I do apologize for not providing that up front. 13 MR. You did not receive that 13 MS. GREGG: So I just -. 14 training? 14 MR. : I'm sorry, what was your 15 MS. 15 question? 16 MR. Did you receive - so 16 MS. IIII: I want to call because 17 there's slides in the back that shows the 17 (Indiscernible *00:19:15) I'm just saying that 18 training and how they conducted it. Did they 18 well I know that the dynamics are that I should 19 provide you with those slides? 19 interrupt you in the middle of a question. But 20 MS. No because I wasn't there. 20 interrupt her answering a question. So I was 21 MR. You weren't there? 21 asking were you done because I wanted to just 22 MS. I was out on an injury. 22 step out for Oust one second. 23 MR. Okay. Can you -? When 23 MR. You want to step out? 24 were you out on the injury? What are the 24 MS. Mm-hmm. 25 dates? 25 MR. Okay. We don't want to 27 28 1 interrupt the interview because we have a lot 1 somethingliiiiiiiiito what you're saying. 2 of questions to get through. 2 MR. : I'm going to give you a 3 MS. GREGG: Mm-hmm. 3 different form that says that I'm going to let 4 MR. : If the attorneys ask 4 you interrupt the interview now to talk to her 5 that, that's not really -. But if you would 5 out there. And if you do it again, I'm going 6 like to -. 6 to ask that you not be here any longer so that 7 MS. GREGG: So based on the agreement we 7 we can continue with the interview. Obviously, 8 just signiiiiiiiii 8 her attorneys would stay here. So I just want 9 MR. : Sure. 9 to make sure that we don't just continue. 10 MS. GREGG: It acknowledges the right to 10 MS. GREGG: I just need clarity then. I 11 have me representing her. And part of those 11 need clariiiiiiiiii 12 rights are the ability to assist in 12 MR. : Sure. 13 representing her. Right? And so I don't want 13 MS. GREGG: So the representing of and 14 to dispute and I don't want to hold up the 14 talking to the employee who I have the right to 15 process at all. I just want to say something 15 represent is considered by you an interruption 16 to her. 16 of the interview? 17 MR. : Sure. We'll let that - 17 MR. : We haven't even gotten 18 we'll do that this time, but if this continues 18 into the questions yet. So -. 19 to happen, I'm going to have to give you a 19 MS. GREGG: Well -. 20 different form that says you can stay here 20 MR. : -- yes, we need to 21 voluntarily if you want, but we're going to ask 21 continue with the interview. But we're now -. 22 you not to interrupt the interview. And if you 22 I can allow you to do that now. I'm just not 23 do, then we're going to ask her if she wants to 23 going to be able to allow you to continue to 24 continue with the interview without you. 24 stop the interview and leave the room. 25 MS. GREGG: So but that form says 25 MS. GREGG: I'm just asking for clarity EFTA00117649 29 30 1 right. So it was kind of -. 1 I would be informing her of anything. 2 MR. : Sure. Absolutely. 2 MR. : Okay. But so yes. To 3 MS. GREGG: And I don't mean to be 3 answer your question, you can be here to 4 difficult. It kind of was a yes or no. So 4 represent here if she's asking you for the 5 you're saying to me based on the document that 5 information. I don't want you stopping our 6 I signed -. 6 interview. 7 MR. I'm saying that you can 7 MS. GREGG: Mm-hmm. 8 assist her. 8 MR. : And then asking to leave 9 MS. GREGG: I didn't get to -. 9 the room. I'm going to allow that this time. 10 MR. : Sure. Go ahead. 10 After that, I will consider that an 11 MS. GREGG: Okay. So you're saying based 11 interruption of the interview. 12 on the document that I signed, in my right to 12 MS. GREGG: Mm-hmm. 13 represent the employee, which is asking to 13 MR. : And then we'll have to 14 caucus and say something to Ms. is 14 proceed from there. And then there's a 15 interrupting the interview even though I have 15 different form to provide you. So does that 16 the right to do so based on the document I 16 make sense? 17 signed? 17 MS. GREGG: No it doesn't. 18 MR. : It's more for her to be 18 MR. : Okay. So I'm asking you 19 able to ask you for a question. 19 not to interrupt -. 20 MS. GREGG: So it's just a yes or no. 20 MS. GREGG: Wait. It doesn't make sense 21 MR. : Oh, no-no. I'm the one 21 but I'm not - that was -. 22 that's leading the interview here. So if she 22 MR. : So I'm asking you not to 23 stops and asks you for clarity, absolutely. 23 interrupt the interview. She may defer to you 24 You stopping to inform her? No. 24 and ask you for questions. 25 MS. GREGG: I never identified to you that 25 MS. GREGG: Mm-hmm. 31 32 1 MR. I'm asking you not to 1 MR. They're directed at Mrs. 2 interrupt my questions. 2 3 MS. GREGG: Okay. It doesn't make sense 3 MS. GREGG: I'm not answering questions. 4 to me. What I'm interpreting is my ability to 4 I was just trying to -. I'm representing her. 5 represent is only if the employee asks a 5 But I understand that there has been a 6 question that's what you're saying to me. 6 determination of how I'm able to represent. 7 MR. : Correct. So her 7 And so I'll deal with that in a different 8 attorneys are here. 8 venue. You can move forward. 9 MS. GREGG: I got it. I got it. 9 MR. : Alright. Let me read 10 MR. : Her attorneys are here. 10 this real quick in this paperwork so that we're 11 I'm asking if she has a question for her union 11 not going to have any disputes. 12 representative -- 12 MS. GREGG: We don't have to. You don't 13 MS. GREGG: Mm-hmm. 13 have to continue. Right. Because I don't want 14 MR. -- she may at any time 14 to interrupt. So you can go on ahead and move 15 ask you. 15 forward. 16 MS. GREGG: I got it. 16 MR. Okay. So it just says 17 MR. I'm asking you not to 17 that you may not attempt to answer the 18 interrupt. 18 questions. 19 MS. GREGG: I got it. 19 MS. GREGG: Mm-hmm. 20 MR. These questions are not 20 MR. Or dictate the employee's 21 for you. 21 actions to question or otherwise take charge of 22 MS. GREGG: Mm-hmm. 22 proceedings. 23 MR. They're not directed at 23 MS. GREGG: Mm-hmm. 24 you. 24 MR. : But affin, please feel 25 MS. GREGG: Mm-hmm. 25 free to go confer with Ms. EFTA00117650 33 34 1 MS. GREGG: I appreciate it. Thank you. 1 Alright. DO you know where we left off I=? 2 MR. : I am going to pause the 2 What was the last question that we asked? 3 recording. It is currently 10:32 a.m. 3 MR. : It was what we asked for 4 [Whereupon, the above-entitled matter went off 4 (Indiscernible *00:24:53) about the injuries. 5 the record and went back on the record.] Okay. 5 MR. : Okay. So you were 6 The recorder is back on. It is 10:38 a.m. 6 telling us you said March through June you were 7 Tuesda lune 22 2021. This is Senior Special 7 injured? 8 Agent . We're resuming the 8 MS. : Yes. 9 interview. Ms. I just remind you that you 9 MR. : And you were not actually 10 are under oath and this is a voluntary 10 working during that time? 11 interview. I'm sorry. What was your question? 11 MS. : No. 12 MS. GREGG: You need me to initial 12 MR. : Do you remember around 13 (Indiscernible *00:24:24)? 13 when in March and when did it end? Was it the 14 MR. If you don't mind. And 14 beginning of March, end of March, middle? 15 again, it's just to show that you know, what we 15 MS. IIII: Um I'm not sure. I just know 16 are looking at. 16 it was March. 17 MS. GREGG: Okay. 17 MR. Sometime in March? 18 MR. Now since we took that 18 MS. 19 break, is there anything else we want to 19 MR. But when you came back, 20 discuss or -? 20 was it around the 26th when they asked you to 21 MS. FOY: No, we can move forward. 21 sign those? 22 MS. : No thank you. 22 MS. IIII: I came back in June. I don't 23 MR. : Thank you again very much 23 recall the date exactly. 24 for your cooperation with this matter. Is 24 MR. Okay. 25 there anything else you wanted to -? No? 25 MS. : But I remember the day I came 35 36 1 into work and the lieutenant asked me to go see 1 MS. : No. 2 Lieutenant . And she asked me to sign 2 MR. : Okay. Did you receive 3 and I said but I wasn't here. I was out on an 3 that training though in the annual training 4 injury. And she said she's aware but they need 4 courses as well? Like the suicide prevention 5 me to sign it for rogram review. 5 or the - you know how to operate in the SHU 6 MR. Okay. 6 during MCC annual? Or the - I think you call 7 MS. I signed. 7 it the IF training? Or during the correctional 8 MR. : So both trainings when 8 officer training at FLETC? 9 you signed, they didn't actually even provide 9 MS. IIII: Those trainings are like 10 you anythin 10 general overall training. It's not 11 MS. : N 11 specifically speaking about SHU. Like SHU may 12 MR. : Verbally? 12 come up in the conversations, but it's not 13 Electronically? Nothing? 13 specific to SHU or how to operate or run the 14 MS. : No. 14 SHU. 15 MR. : Okay. And that was on 15 MR. Okay. 16 the date that was signed that that happened? 16 MS. Mm-hmm. 17 MS. IIII: Actually she told me not to 17 MR. Do you know if they were 18 date it. I remember when I was signing, she 18 doing this with other employees as well? 19 said don't date it. 19 Having them sign training that they weren't 20 MR. : But you dated it anyway? 20 actually conducting? 21 Did you have a conversation about that? 21 MS. : I don't know. 22 MS. : No. 22 MR. : Okay. But did you do 23 MR. : After you dated it, she 23 this per the direction of your supervisor? 24 didn't say why did you date it or anything like 24 MS. : Su ervisor. Yes. 25 that? 25 MR. So she - did she EFTA00117651 37 38 1 specificall you must sign this? 1 of discovery and conversations with Ms. IIII. 2 MS. : Yes. 2 We're looEilg_2l_gout March 15 to June 24-ish. 3 MR. : Okay. And again, that 3 MR. IIIIIIIIII: Okay. 4 was 4 MR. FOY: And I note that the execution 5 MS. 5 was on the 26th. But I think there was some 6 MR. • . And you said - 6 time, you know, it's not like the first minute 7 and I apologize. I don't know if we were 7 she was there the had her sign the document. 8 interrupted when -. Where did you say she is 8 MR. : Okay. 9 currently? 9 MS. : Right. 10 MS. IIII: She is in Jersey I know. I'm 10 MR. FOY: So those are the estimated 11 trying to_ 11 times. I could be off by a day or two, but -. 12 MR. • At the FCI Fort Dix? 12 MR. : Perfect. 13 MS. Yes. 13 MR. FOY: The 15th of March to June 24th. 14 MR. Okay. 14 MR. And thank you attorney 15 MR. 10.iestion real quick. 15 Foy. 16 MR. : Absolutely. Do you want 16 MR. iiiiiiiiiiroblem. 17 a more precise answer to when she was out and 17 MR. : During your time at the 18 when she came back? 18 MCC, how often were you assigned to the special 19 MR. Uh, so far -. 19 housing unit also known as the SHU? 20 MR. FOY: Because I happen to know -- 20 MS. : Mm. 21 MR. Oh sure. If you'd like. 21 MR. And this is an 22 MR. FOY: -- the approximate dates. 22 approximate. I'm not asking you for like exact 23 MR. Sure. You can provide 23 amount. 24 that. 24 MS. IIII: When I came back from the 25 MR. FOY: And this is based on my review 25 injury, my assignment was the SHU. So from 39 40 1 June 20-whatever to August 10th, I worked the 1 SHU? 2 SHU. 2 MS. IIII: In the SHU there is post 3 MR. : Okay. And that was your 3 orders. 4 quarterly assignment was in the SHU from - for 4 MR. Oh, okay. So in the SHU 5 that whole summer -- 5 there's the ost orders. 6 MS. : Yes. 6 MS. : Yes. 7 MR. -- in 2019? 7 MR. And were you provided a 8 MS. Yes. 8 copy of that to review? 9 MR. Okay. Thank you. So I 9 MS. : Yes. 10 know that you said that you didn't - they 10 MR. And had you reviewed 11 didn't provide you with the SHU training. Did 11 that? 12 they provide you with the policies of the SHU? 12 MS. 13 MS. : No. 13 MR. : Okay. And when did you 14 MR. : So you never received 14 review that? 15 those policies? Would it have been when you 15 MS. : When I came back. 16 received and you said you had to initial and 16 MR. So sometime in that June 17 date something electronically? I think you 17 18 said when_ysT provided -? 18 MS. So in June. 19 MS. IIII: That's the employee code of 19 MR. -- or July timeframe? 20 conduct. 20 MS. 21 MR. : Okay. 21 MR. Okay. So aside from hose 22 MS. : That's the - like the handbook 22 post orders, did you receive any other SHU 23 that's online. 23 training? 24 MR. Should have they provided 24 MS. 25 you with the polices and post orders in the 25 MR. : No. And who was EFTA00117652 41 42 1 responsible for making sure that you actually 1 MR. But if you need to like, 2 did receive SHU training? 2 yeah, that's fine. 3 MS. : I don't know. 3 MS. : Mm-hmm. Yeah. 4 MR. : You don't know was that a 4 MR. : And if you don't know, 5 lieutenant issue -- 5 that's totally acceptable. 6 MS. : I assumed -. 6 MS. : Yeah because I don't know. 7 MR. • -- or your first line 7 MR. • Okay. No-no, that's a 8 supervisor? 8 totally acce table answer. 9 MS. IIII: I would assume the lieutenant. 9 MS. : Mm-hmm. 10 My supervisor. I don't know. 10 MR. • So yeah, if you know - if 11 MR. And when you say the 11 you don't know something or you do know 12 lieutenant, who was the lieutenant in the SHU 12 something, that's great. You don't really want 13 at the time? 13 to ask other people for the answers. 14 MS. : Lieutenant IIII. 14 MS. : Ri ht. 15 MR. : IIII. Do you know his 15 MR. : You know, obviously if 16 first name? 16 you need to confer, and you know with your 17 MS. 17 attorneys or your union representative, 18 MR. . Okay. And would he be 18 absolutely fine. But we just want to try to 19 responsible for making sure that you were 19 get away from them answering for you. 20 training when you were in the SHU? 20 MS. : Okay. 21 MS. IIII: I mean, I'm going to direct 21 MR. : Alright. And then from 22 that question to her. I don't know. 22 your recollection though, you don't remember 23 MR. : I don't want you to 23 receiving SHU training during the annual 24 direct a 222tion to her. 24 refresher training? 25 MS. fl: Okay. 25 MS. IIII: No. 43 44 1 MR. No. Okay. Did you 1 know, is suicidal or placed on suicide watch? 2 receive training on how to conduct rounds? 2 What was your understanding of how you should 3 MS. : Yes. 3 treat those inmates? 4 MR. . And when was that? 4 MS. IIII: If an inmate is placed on 5 MS. In IF. 5 suicide watch, I don't deal with them. They go 6 MR. In IF? 6 downstairs to suicide watch and they're being 7 MS. Mm-hmm. 7 watched b other inmates. 8 MR. Okay. And what did it 8 MR. : Mm-hmm. 9 teach you about conducting rounds? 9 MS. : But and then when they're 10 MS. IIII: That you need two people to 10 cleared, the come back to the unit. 11 count and conduct rounds. And one person goes 11 MR. : And are you trained - are 12 and counts. The other person goes and counts. 12 you supposed to handle them differently when 13 And then ou confirm the numbers of counting. 13 they come back to the unit? 14 MR. : Okay. 14 MS. • Uh no. 15 MS. : And make sure when you're 15 MR. You're not? 16 counting that you're counting everybody's 16 MS. You're not. 17 standing at their bed when you're counting. 17 MR. You're not supposed to 18 MR. : Okay. And did you 18 handle them differently? 19 receive suicide prevention training during the 19 MS. : No. 20 MCC annual refresher training? 20 MR. Not at all? 21 MS. : I don't recall. 21 MS. Because they're cleared to come 22 MR. You don't recall. 22 back. 23 MS. : Mm-hmm. 23 MR. IIIIIIIIII: Okay. 24 MR. Okay. What was your 24 MS. : So once you're cleared, you're 25 understanding if an inmate was placed, you 25 back to normal. EFTA00117653 45 46 1 MR. Okay. And were you 1 it. I rely on the senior officer that I'm 2 assigned to the SHU on August 9th and 10th of 2 working with. 3 2019? 3 MR. : Okay. So you didn't 4 MS. • Yes. 4 really know what your duties and 5 MR. • Do you recall what time 5 responsibilities were? Is that what you're 6 you began working on the SHU on August 9th? 6 saying? 7 MS. : 4:00 to midnight. 7 MS. IIII: In the SHU like um, to give out 8 MR. : Four to midnight. And 8 food, to collect the trays, to give out linen, 9 then on Amlt 10th? It was? 9 collect linen. Whenever we would go down range 10 MS. IIII: Midnight to eight in the 10 to give out those, we count that as a round to 11 morning. 11 make sure the inmates are good. You shower I 12 MR. Okay. You said, again, 12 think ever other Count, that's it. 13 that was our quarterly bidded post. 13 MR. : So rounds and counts are 14 MS. • Yes. 14 a part of that though? 15 MR. Quarterly assignment. 15 MS. IIII: Rounds and counts are a part of 16 And what were your overall duties and 16 it. But I've never worked in the SHU and 17 responsibilities when you were assigned to the 17 actually done rounds every 30 minutes. We go 18 SHU? 18 down range to do stuff and we count it as a 19 MS. IIII: It varies because I'm new and 19 round. 20 because I don't know how to run the SHU. I 20 MR. Perfect. And that's 21 just always rely on the senior person that I'm 21 going to be something that we're going to 22 working with. So even if the roster reflects 22 discuss. 23 that I'm the senior officer, because sometimes 23 MS. : Mm-hmm. 24 I'm assigned SHU 1, I don't do what SHU 1 is 24 MR. : And ask you things like 25 supposed to do because I don't know how to do 25 who told you that and houses that, you know who 47 48 1 should have provided you with the proper 1 classifications of an inmate? They never 2 training and information on how it was 2 discussed that with you? 3 technicall supposed to be done. 3 MS. : No. 4 MS. : Mm-hmm. 4 MR. : No? Okay. Did you ever 5 MR. : And were there any 5 see training on medical emergencies? With 6 requirements - special requirements - for 6 inmates? 7 inmates who are assigned to the SHU? 7 MS. Mm. No. I just know like if 8 MS. : I don't know. 8 you are making a round and something happens to 9 MR. : That's fine. Do inmates 9 an inmate, you call and you wait for somebody 10 in the SHU have cellmates? 10 to come before you enter the cell. That's all 11 MS. : Yes. 11 I know. 12 MR. : Okay. And are they 12 MR. : Okay. But did you - were 13 required to have cellmates? 13 you provided like CPR training or any kind of 14 MS. : I don't know. 14 like you know, if something were to happen in 15 MR. You're not sure? 15 front of y2lhow you would respond? 16 MS. Hm-mm. 16 MS. IIII: Yes. We had CPR training 17 MR. Are there any inmates 17 (Phoneticiiiiiiiiii5:08) 18 that don't have cellmates? 18 MR. : Okay. And when would you 19 MS. : Yes. 19 conduct training like that CPR training or you 20 MR. : And do you know why they 20 know if someone is trying to kill themselves or 21 wouldn't have cellmates? 21 something like that. When did you receive that 22 MS. : I don't know. 22 training? How you would respond to a medical 23 MR. : Did you ever - were you 23 emergency? 24 ever told it's because another inmate could 24 MS. : That was in IF. 25 harm that inmate? Or there were certain 25 MR. IF as well? EFTA00117654 49 50 1 MS. : Mm-hmm. 1 MS. : Uh-huh. 2 MR. : Okay. So who is or was 2 MR. : And what is first 3 Inmate Jeffrey Epstein? Reg number 76318-054? 3 name? 4 MS. : Who was he? 4 MS. EIM I 5 MR. : Who was he? Was he an 5 MR. 6 inmate asst ned to the MCC? 6 MS. : Mm-hmm. 7 MS. : Yes. 7 MR. : And what did he inform 8 MR. : Was he assigned to the 8 you? 9 SHU? 9 MS. IIII: He basically said that this is 10 MS. : Yes. 10 Jeffrey Epstein. You don't know who he is? 11 MR. . Okay. Do you know what 11 And I said no. And he was like he's in the 12 he was at the MCC for and why he was 12 news every day. And I was like okay. I didn't 13 incarcerated by the BOP? 13 know. 14 MS. IIII: Actually I didn't even know who 14 MR. : Do you remember when you 15 he was when I worked with him. It was the 15 had that conversation? Like at least if you 16 other coworker that told me who he was. I 16 think about August 9th, August 10th? 17 didn't know who he was. 17 MS. : Mm. No. 18 MR. : And who -? 18 MR. : Was it obviously it was 19 MS. : As in I knew his name but 19 then prior to August 9th? 20 didn't know like what he was there for and who 20 MS. : Yes. 21 he actualireav 21 MR. : Okay. But you were 22 MR. : So and when you say the 22 working in the SHU together? 23 other coworker told ou, who told you? 23 MS. : Yes. 24 MS. 24 MR. : Okay. Was Epstein in the 25 MR. 25 SHU when you had that conversation? 51 52 1 MS. : Never. 1 the hotlist is like um, how should I say, like 2 MR. : No. Was he with his 2 inmates that are like -. Inmates that are like 3 attorneys? 3 - mm. 4 MS. : Mm-hmm. 4 MR. I'm just going to show 5 MR. : Okay. Do you remember 5 you this and ask you if you ever received this 6 anything else about that conversation when he 6 training either. 7 told you about him? 7 MS. : Mm-hmm. 8 MS. : No. That was it. 8 MR. : Or if you've ever seen 9 MR. Did he tell you why he 9 it. This will spell out exactly what the 10 was in? 10 hotlist is. 11 MS. : 11 MS. : Mm-hmm. 12 MR. : No? Just that he was 12 MR. : So this is the MCC New 13 famous and in the SHU? 13 York special housing unit. Slides. 14 MS. : Mm-hmm. 14 (Indiscernible *00:38:01) 15 MR. Okay. Why was - do you 15 MR. Ed sorry. 16 know why stein was assigned to the SHU? 16 MR. : This one is special 17 MS. : No. 17 housing unit management suicide prevention. 18 MR. Did anyone ever tell you 18 MS. : Mm-hmm. 19 it was because he was a risk for suicide or 19 MR. : So can you just have - 20 safety concerns? 20 there's two different tabs here which -- 21 MS. : No. 21 MS. : Mm-hmm. 22 MR. : No? We're going to get 22 MR. : -- the first one is going 23 into this a little later, but do you know what 23 to say -. I'll just read it for the record. 24 the hotlist is? 24 SHU hotlist identifies inmates with mental 25 MS. IIII: Um.... Are those -? I think 25 health conditions who may become dangerous, EFTA00117655 53 54 1 self-destructive, or suicidal when placed into 1 the front. 2 the SHU. 2 MS. : Mm-hmm. 3 MS. 3 MR. Was that ever provided to 4 MR. And that - did you know 4 you? Did ou ever see this? 5 that? 5 MS. : Hm-mm. No. 6 MS. 6 MR. No. Okay. 7 MR. • So do you know what I'm 7 MR. FO1 Dclou want her to initial? 8 talking about when I say hotlist? There was a 8 MR. : If you could. Yeah. 9 list in the SHU of -. 9 Just so that we can -. You can do it on the 10 MS. IIII: No. I actually thought that 10 top page. No-no. Sorry. The front page. 11 the hotlist was something else. Like that was 11 MR. : ON the front page. 12 on the coiiiiiiiiiio. I don't know that. 12 MR. FOY: Just the first page. 13 MR. : Okay. And then it talks 13 MS. : Oh. 14 about when someone is on the hotlist, it's 14 MR. And do you know who would 15 supposed to be a special notation on the 15 have been re uired to provide you that -- 16 hotlist, a special notation on the cell door, 16 MS. : No. 17 and there's also a special notation on the SHU 17 MR. -- information? No? And 18 board. 18 no one discussed that with you? 19 MS. IIII: Mm. There was never none of 19 MS. : No. 20 that. 20 MR. : Did anyone ever discuss 21 MR. : So did you ever -? Can 21 the hotlist with you? 22 you just take a look quickly? You don't have 22 MS. : Na. 23 to look throw h that. Just basically the -- 23 MR. Had you ever heard of the 24 MR. : The two tabs. 24 term hotlist? 25 MR. : -- two tabs as well as 25 MS. IIII: No. 55 56 1 MR. You never even heard the 1 MS. : I think so. 2 term? 2 MR. : And are they monitored 3 MS. IIII: I thought that hotlist was like 3 24/7? 4 inmates that were like, um.... Like the 4 MS. : Yes. 5 inmates that were up on 10 South. Like those 5 MR. : Okay. But you don't know 6 high inmates. Like El Chapo and those type of 6 how they're monitored? 7 inmates. 7 MS. : No. 8 MR. : Sure. 8 MR. : Okay. But they're for 9 MS. : That's what I though hotlist 9 like a terrorist, high-profile, drugs -. 10 was. 10 MS. : Yes. 11 MR. : Okay. And because you 11 MR. You know? 12 brought u 10 South, what's 10 South? 12 MS. : Mm-hmm. 13 MS. : The level above the SHU. 13 MR. Okay. And that's one 14 MR. And is that a specialized 14 floor above where the SHU is? 15 unit that are even more secure than the SHU? 15 MS. : Yes. 16 MS. . Yes. 16 MR. : Is it kind of in the 17 MR. : And can you just explain 17 general location of the SHU though? 18 to me a little bit about who goes there? What 18 MS. : It's upstairs. 19 the cell makeup is? Are there cameras in each 19 MR. Can you get to it through 20 individual cell? 20 the SHU? 21 MS. : I don't know. 21 MS. 22 MR. Oh, you don't know? 22 MR. And would it be 23 MS. Hm-mm. 23 considered as - I know it's 10 South and it's 24 MR. Okay. Are inmates that 24 unique. But is it also part of the general 25 are in those cells only one inmate per cell? 25 SHU? EFTA00117656 57 58 1 MS. IIII: I mean when you come into the 1 MR. Okay. Do you recall who 2 SHU, you iiiiiiiiiistairs and it's right there. 2 was workin on 10 South on August 9th or 10th? 3 MR. : Okay. Can you get to it 3 MS. 4 by other means? 4 MR. ' In? 5 MS. • No. 5 MS. Mm-hmm. 6 MR. So you have to go thought 6 MR. Okay. Was that August 7 the SHU -- 7 9th or 10th or both? 8 MS. Co through the SHU. 8 MS. IIII: I don't know about the 9th but 9 MR. -- to get -- 9 the 10th. 10 MS. Mm-hmm. 10 MR. : That's fine. And some of 11 MR. -- into it? Okay. And 11 this stuff I'll probably at some point give you 12 how many correctional officers are placed in 12 a list of the people so you can refer to like 13 the 10 South? 13 the roster so you don't have to -. 14 MS. : Um, one. 14 MS. : Okay. 15 MR. One? 15 MR. : You know you can recall 16 MS. : Mm-hmm. 16 that way if you remember that those people were 17 MR. And there's no way in or 17 in (Indiscernible 00:41:35). 18 out other than through the SHU? 18 MS. : Okay. 19 MS. : Mm-hmm, through the SHU. 19 MR. : But you did say Epstein 20 MR. : Okay. So when they come 20 was assigned to the SHU on August 9th and 21 in and out, do the officers that are working in 21 August 10th, 2019? 22 the SHU - you know where you are working - are 22 MS. : Yes. 23 you the ones that have to allow them to get in 23 MR. Okay. And he was 24 and out of the SHU? 24 assigned to the SHU on the days leading up to 25 MS. IIII: Yes. 25 August 9, 2019? 59 60 1 MS. : Yes. 1 MS. IIII: Oh I come in at 2:00. And I 2 MR. : Okay. Do you know 2 come in at 4:00. And when I come in he's not 3 approximately how long Epstein was assigned to 3 there. He would come back like around after 4 the SHU? 4 8:00. 5 MS. : No. 5 MR. 8:00 p.m.? 6 MR. : Was he assigned to the 6 MS. 7 SHU for the most part of when you were doing 7 MR. Okay. And did you 8 you assignments in the SHU? 8 typically work after 8:00? So you come in at 9 MS. IIII: When I came back and I was 9 2:00 or 4:00. When would you typically work 10 working there? 10 until? 11 MR. : Correct. 11 MS. IIII: 2:00 to 10:00 or 4:00 to 12 MS. 12 midnight. Mm-hmm. 13 MR. Okay. 13 MR. : And then would you 14 MS. Mm-hmm. 14 typically do overtime shifts after that? 15 MR. : Yes? Okay. So does July 15 MS. IIII: No because I usually do it on 16 and August sound about right? That he was in 16 the front end. 17 the SHU? 17 MR. Okay. 18 MS. : Mm-hmm. 18 MS. : So I usually come in the 8:00 19 MR. : Yes? What was Epstein's 19 to 4:00 and do 4:00 to 12:00. 20 routine while he was assigned to the SHU? We 20 MR. : And when you would come 21 talked about it briefly. He was with attorneys 21 in 8:00 to 4:00, would he be gone already? 22 and stuff. So was that like a daily routine? 22 MS. 23 Can you just tell me when he would come and go? 23 MR. : Okay. But he would come 24 And when he would be in the SHU and not be in 24 back around -? So he would be gone before 8:00 25 the SHU? 25 a.m. and come back around 8:00 p.m.? EFTA00117657 61 62 1 MS. : Mm-hmm. 1 MS. Yes. 2 MR. : Would he eat when he was 2 MR. : You were the one who did? 3 in the SHU? 3 MS. : Mm-hmm. 4 MS. IIII: He gets common fare. That's 4 MR. : Okay. Did you ever have 5 all I know. I don't know if he eats it. But 5 any communications with Epstein during his stay 6 he gets common fare. 6 at the MCC? 7 MR. : Would that be something 7 MS. 8 you supplied after 8:00 p.m.? 8 MR. : Never any conversations 9 MS. : When he comes back. Yes. 9 at all? 10 MR. : Okay. What time is 10 MS. 11 typically feeding time? In the evening? 11 MR. : Okay. Did you even 12 MS. : Um...after 4:00? 12 verbal say hello - hello back? Anything like 13 MR. : And so because he was 13 that? 14 away, does he get -? Would he get an 14 MS. Mm. He was in the shower to 15 individual tray that was saved for him or 15 make a phone call. And he was calling because 16 provided when he returned? 16 he wanted to come out of the shower. And I 17 MS. : Yes. 17 told him that he had to wait because there were 18 MR. : Okay. And would you 18 other inmates out. And you can't move him and 19 provide that try to him? 19 them out at the same time. That's the only 20 MS. IIII: Not necessarily me just 20 conversation I ever had with him. 21 whomever. 21 MR. : And we'll get into that 22 MR. : Did you ever? 22 but was that phone call on August 9, 2019? 23 MS. Yes. 23 MS. • Yes. 24 MR. : Okay. Did you provide 24 MR. : Okay. But when you would 25 that to him on August 9th? 25 provide food or anytime he would come back 63 64 1 after 8:00 p.m. - even when he was coming in or 1 you had that interaction with the one 2 out, you wouldn't even say hello? 2 individual who told you that he was a high- 3 MS. : No. 3 profile person, that he was in the news all the 4 MR. : No? Okay. For the one 4 time, there was never a discussed that we need 5 interaction you can think of with the phone 5 to pay close attention to him? 6 call, do you remember if that was a positive or 6 MS. : No. 7 a negative interaction? Do you remember it at 7 MR. And Lieutenant IIII, you 8 all? Was it -? 8 said was the lieutenant in the SHU, he never 9 MS. : It was regular. 9 told you to ay special attention to Epstein? 10 MR. : Regular? 10 MS. : No. 11 MS. Mm-hmm. 11 MR. Okay. Was Epstein 12 MR. : Did he seem upset? 12 assigned any cellmates when he was assigned to 13 MS. Uh, no. 13 the SHU? 14 MR. : No? Abnormal? Anything 14 MS. : Yes. 15 out of the ordinary? 15 MR. And do you know when he 16 MS. : No. 16 was assigned to the SHU was he always assigned 17 MR. : No. What were your 17 a cellmate? 18 instructions with regard to Epstein being 18 MS. IIII: Um, I just know he had two 19 assigned to the SHU? 19 cellmates. 20 MS. : There was no instructions. 20 MR. Okay. Two different 21 MR. : So no one said Epstein 21 ones? 22 was a high priority here? Pay closer attention 22 MS. Yes. 23 to him? 23 MR. Alright. Did anyone ever 24 MS. : No. 24 speak with you about Epstein needing a cellmate 25 MR. : Alright. So even when 25 when he was in the SHU? EFTA00117658 65 66 1 MS. : No. 1 in charge of the SHU? 2 MR. : No? Who was the officer 2 MS. 1.1o. 3 in charge or the OIC in the SHU? 3 MR. : Do you know who - wasn't 4 MS. : Me. 4 it Grill? MR. 5 6 7 at 12:00 a.m.? Um, are you talking about 5 MS. IIII: Yes. On (Indiscernible 6 7 is? MR.Mr MR. : Do you know who 8 *00:46:06) -. 8 MS. : Yes. 9 MR. In general, was there 9 MR. : Would he be considered 10 like one officer in charge that has like is 10 the officer in charge? 11 considered the OIC in the SHU? 11 MS. IIII: See I don't know. Because on 12 MS. IIII: That's what I'm telling you. 12 the roster, it can be a differentiiiiiiii 13 On paper, it says me. But I don't know how to 13 MR. : Okay. Did have 14 run the SHU. So I rely on the senior officer. 14 like a desk or a computer area that he always 15 Well on the roster, it says that I was the OIC. 15 sat in when he was there? 16 MR. And -. 16 MS. : No. 17 MS. 17 MR. Specifically? 18 MR. I think I'm just not 18 MS. It's the one that we all sit 19 asking the question correctly. I'm not talking 19 at. 20 about like from 12:00 a.m. to 8:00 a.m. on 20 MR. But he didn't have one 21 August 10th. I mean in general. Like in July 21 specific location that he would sit at? Like - 22 and August when you were in the SHU, was there 22 ? 23 one person that was considered the officer in 23 MS. : No. 24 charge? Like hot, there's one lieutenant of the 24 MR. : No, he would sit 25 SHU which was El? Was there also an officer 25 wherever? 67 68 1 MS. : Yes. 1 Am I pronounciiiiiiiiiright? 2 MR. : Can you give me just like 2 MR. : Yeah. 3 a layout? How many desks and computers were 3 MR. How do you spell that 4 there in the SHU where the officers sat? 4 last name? Do you remember? 5 MS. IIII: It was two desks. One this way 5 MR. 6 and one this wa . 6 MR. Thank you Agent 7 MR. : So kind of like an L type 7 So he didn't have a specialized computer where 8 of formation? 8 he would have posted a sign on a computer? 9 MS. IIII: Yes. And computers, about 9 MS. : No. 10 three. 10 MR. : No? What about - do you 11 MR. . About three computers? 11 recall ever seeing a sign posted on Epstein's 12 MS. Mm-hmm. 12 door? 13 MR. And had you sat at all 13 MS. : No. 14 three of those computers at least one time 14 MR. : Saying that he was 15 during your shifts? 15 required to have a cellmate? 16 MS. : Um, yes. 16 MS. : No. 17 MR. Okay. So it's just - it 17 MR. No? Oka . Who was 18 rotates. You can sit at each one? 18 Inmate 19 MS. I mean you can sit at any one. 19 IMI? 20 MR. And do you remember ever 20 MS. Uh, his first um cellmate that 21 there being a sign posted on any of the 21 he had. 22 computers saying that Epstein was required to 22 MR. Epstein's first cellmate? 23 have a cellmate? 23 MS. Mm-hmm. 24 MS. : No. 24 MR. Was that his cellmate in 25 MR. Alright. And then 25 July of 2019? EFTA00117659 69 70 1 MS. IIII: I'm not sure about the month, 1 have any involvement in that matter though? 2 but that was his first cellmate. 2 MS. I wasn't at work. Hm-mm. 3 MR. : Okay. Do you recall if 3 MR. : Do you know if 4 was already in the SHU or was he 4 was removed as Epstein's cellmate? 5 brought in specifically to be Epstein's 5 At that point? 6 cellmate? 6 MS. After that he had another 7 MS. • I don't know that. 7 cellmate: 8 MR. : You don't know that? 8 MR. : And do you know why they 9 MS. 9 changed? 10 MR. : Okay. Are you aware of 10 MS. • But I don't know why. 11 an issues that took place between Epstein and 11 MR. : Okay. Do you know who 12 when they were cellmates? 12 would have made that decision to change 13 MS. No. 13 cellmates? 14 MR. : No. Were you aware that 14 MS. 15 on or around July 23 of 2019 um that Epstein 15 MR. : No. Had you ever heard 16 allegedly attempted to commit suicide? 16 that attempted to harm Epstein? 17 MS. IIII: I wasn't at work that day but I 17 MS. No. 18 was told. 18 MR. : You didn't even hear that 19 MR. : Okay. And were you told 19 rumor? 20 anything else about the incident? 20 MS. 21 MS. No. 21 MR. : Okay. Do you know what 22 MR. : Are you aware if 22 was used in the incident when Epstein attempted 23 was his inmate at the time? 23 to - alle edly attempted to take his life? 24 MS. Yes. 24 MS. : No. 25 MR. : And you said you didn't 25 MR. : No? 71 72 1 MS. : Hm-mm. 1 or elsewhere? 2 MR. : Do you know if it was 2 MS. : It's done downstairs. 3 like linens or a shirt or any kind of -? 3 MR. : And when you say 4 MS. : I don't know. 4 downstairs, what - do you know where? 5 MR. • No? 5 MS. IIII: Where the suicide watch is or 6 MS. 6 Unit 2. 7 MR. • No one discussed that 7 MR. • Okay. So second floor? 8 with you? 8 MS. Mm-hmm. 9 MS. 9 MR. And do you know who makes 10 MR. • And you didn't ask 10 the determination to be able to place someone 11 anybody about it? 11 on suicide watch or psychological observation? 12 MS. : N 12 MS. : No. 13 MR. Do you know if Epstein 13 MR. : No? Okay. Does it sound 14 was placed on suicide watch or psychological 14 right that he was placed on suicide watch on or 15 observation? 15 around July 23, 2019? And returned to the SHU 16 MS. IIII: I think he was placed after 16 on or around July 30, 2019? 17 that. But I don't know which one. 17 MS. : Yes. 18 MR. : Okay. Is it usually that 18 MR. That sounds about right? 19 someone will go on suicide watch for about 24 19 MS. Mm-hmm. 20 hours? Then after that they would go on what's 20 MR. And at that time, was 21 called ps chological observation. 21 Epstein assi ned another cellmate? 22 MS. : I'm not sure. 22 MS. 23 MR. • You're not sure? 23 MR. Who - which cellmate? 24 MS. Hm-mm. 24 MS. 25 MR. Is that done in the SHU 25 MR. EFTA00117660 73 74 1 MS. Mm-hmm. 1 you ever know why people were specifically in 2 MR. : On or around Sul 30th. 2 the SHU? 3 And who was Inmate ? 3 MS. 4 MS. His cellmate. 4 MR. : No. Do you know why 5 MR. : Do you know anything 5 Inmate was removed from the MCC on August 6 about him? 6 9, 2019? 7 MS. 7 MS. 8 MR. : Okay. But you do know he 8 MR. So even at this point do 9 was his cellmate from that point until about 9 you know _ylEhe was removed? 10 August 9, 2019? 10 MS. IIII: No. I didn't even know he was 11 MS. Yes. 11 removed. 12 MR. : Okay. And do you know if 12 MR. : No, I'm saying even today 13 Inmate was already in the SHU? Or was he 13 do you know that? 14 brought in specifically to be Epstein's 14 MS. • Oh no. 15 cellmate? 15 MR. : You don't even know that 16 MS. I don't know. 16 he was removed? 17 MR. : You don't know if he was 17 MS. No. I'm saying at that point 18 already in 18 in time, I didn't know that he was removed. 19 MS. 19 MR. : Yeah. So I'm even saying 20 MR. : Now do you ever -? Do 20 as of tod.iy_:. 21 you have any involvement with the inmates when 21 MS. IIII: But for now, I don't know the 22 you're in there? Would you like converse with 22 reason wh he was removed. 23 them or do ou just kind of -? 23 MR. : Okay. 24 MS. : No. 24 MS. 25 MR. : No? so you don't -. Did 25 MR. • But you do know that he 75 76 1 was removed? 1 MS. : No. 2 MS. : Yes. 2 MR. : No. Do you know if it 3 MR. : And did you know that he 3 was antici ated or not an anticipated move? 4 was removed on August 9, 2019? 4 MS. : I don't know. 5 MS. : No. 5 MR. : No? So on August 9th 6 MR. : So even on August 9th you 6 during your time from 4:00 p.m. even to just 7 didn't know that he was removed? 7 12:00 a.m. That was not discussed with you at 8 MS. : No. 8 all or within the SHU? That Epstein's roommate 9 MR. : You knew that Epstein had 9 was removed? 10 a cellmate. You just didn't know that he 10 MS. Never. 11 didn't have a cellmate on that day? 11 MR. Never? 12 MS. IIII: He had a cellmate. I didn't 12 MS. Never. 13 know that the cellmate was removed and wasn't 13 MR. Okay. And are you pretty 14 coming back. 14 confident about that? 15 MR. : Okay. So you never 15 MS. : Yes. 16 learned on August 9th or August 10th for that 16 MR. : Okay. Are you aware if 17 matter, prior to 6:30 that there was no other 17 Epstein should have been reassigned a cellmate 18 inmate within Epstein's cell? 18 after Inmate was removed on August 9, 19 MS. : No. 19 2019? 20 MR. : Oka And do you know if 20 MS. 21 anybody was aware that MI was departing the 21 MR. So you're not aware? 22 MCC or SHU rior to August 9, 2019? 22 MS. 23 MS. : I don't know. 23 MR. If he should have been? 24 MR. : You don't even know that 24 MS. 25 - you know at this point- if anyone was aware? 25 MR. So your understanding was EFTA00117661 77 78 1 he had cellmates. You just didn't know if one 1 SHU staff assign inmates with other inmates? 2 of them was removed that he should be 2 MS. IIII: When an inmate comes, they 3 reassigned one? 3 place them with another inmate. 4 MS. : Exactly. Mm-hmm. 4 MR. : And would they do that 5 MR. : Okay. Do you know who 5 based upon their own responsibilities and 6 was responsible for assigning Epstein a new 6 duties or would someone tell them to do that? 7 cellmate? 7 MS. : See I don't know. 8 MS. : I don't know. 8 MR. You don't even know? 9 MR. No. Could SHU staff have 9 MS. Hm-mm. 10 assigned Epstein a new cellmate? Would you 10 MR. Okay. So you saw people 11 have the authority being - working in the SHU - 11 be assigned with other ones, but you don't know 12 if you knew someone was supposed to have a 12 how -- 13 cellmate? Do you have the authority to place 13 MS. No. 14 another inmate with that person? 14 MR. -- that was determined? 15 MS. IIII: See I don't know. Because I'm 15 MS. Yeah. 16 that new. 16 MR. Okay. So you don't even 17 MR. Okay. 17 know if you could have assigned Epstein a new 18 MS. : So like I said, I rely on the 18 cellmate? 19 senior person a lot. So I don't know. like 19 MR. : I don't know. 20 that would be a question I would ask them. So 20 MR. : Do you know if SHU staff 21 I don't know. 21 should have assigned? You know like -. Or I 22 MR. : When you were - during 22 guess you just answered that. So you said you 23 your time in the SHU, which you said I guess 23 know. And again, on August 9th, no one 24 was from you know late June through August 9th 24 notified ou that was gone from the SHU? 25 or 10th. Did you ever see that happen before? 25 MS. IIII: No. 79 80 1 MR. And you were working in 1 MS. 2 the SHU. 2 MR. No? How about staff 3 MS. : No e. 3 psychologist 4 MR. Do they typically tell 4 MS. Mm-hmm. I know her. 5 you when an inmate in the SHU is - has left and 5 MR. Okay. Who is she? 6 is not comm back? 6 MS. She's one of the psychologists. 7 MS. IIII: Nobody said anything to me. I 7 MR. Okay. And did you heave 8 don't know. 8 dealings with her? 9 MR. : Because don't you have to 9 MS. : I had dealings with her after. 10 be able to keep your counts correct? And be 10 MR. You after August 10th? 11 able to know how many people are in the SHU? 11 MS. : Like on August 10th she came to 12 So if someone is removed, don't they have to 12 the unit. 13 tell you? This person's not coming back so 13 MR. : Okay. Prior to August 14 your count is going to be lower. 14 10th did ou have any dealings with her? 15 MS. IIII: Mm-hmm. But it wasn't told to 15 MS. : No not really. 16 me. So I don't know. 16 MR. No. What about a 17 MR. : Um okay. Do you know who 17 Samantha Demisa? 18 the MCC staff psychologists were in August of 18 MS. Yes I know her. 19 2019? 19 MR. And who is she? 20 MS. : N 20 MS. sychologist. 21 MR. : Do you have any dealings 21 MR. Did you have any dealings 22 with them at all? 22 with her? 23 MS. : No. 23 MS. 24 MR. Does the name Chief 24 MR. : So only with 25 ring a bell? 25 2 EFTA00117662 81 82 1 MS. IIII: Yes but she came after the 1 that he was laced on suicide watch? 2 incident. 2 MS. Yes. 3 MR. : But what was your dealing 3 MR. : And they never - no one 4 with her after the incident? 4 from psychology ever provided you instructions 5 MS. : She just asked was I alright. 5 with regard to when he returned - how he was to 6 MR. : Okay. Did she ask you 6 be treated? 7 anything about Epstein or his cellmate or 7 MS. • No. 8 anything like that? 8 MR. : Or that he was - needed 9 MS. No. 9 to have a cellmate at all times. 10 MR. : No? So it was specific 10 MS. • No. 11 to you? 11 MR. : Or that you needed to 12 MS. Yes. 12 watch him? 13 MR. : Okay. Are you aware was 13 MS. 14 Epstein meeting with staff psychologists during 14 MR. : Do you know who placed 15 his stay at the MCC? 15 him on suicide watch? 16 MS. No. 16 MS. No. 17 MR. : No. Would have he met 17 MR. : No? So what is your 18 with them I guess during suicide watch and 18 understanding of suicide watch? When someone 19 psychological obviously? 19 is on suicide watch and comes back. What is 20 MS. : Yes. 20 your understanding of how you're supposed to 21 MR. : Okay. So that. Did you 21 treat those people? Now my understanding is 22 know that he did meet with them then? 22 that you would have received this training you 23 MS. IIII: I don't know if he did, but I'm 23 know. Now I know you said you didn't do the 24 going to assume he did. 24 SHU training. But the other trainings that you 25 MR. : Okay. But you do know 25 attended - the IF, the MCC annual, and the 83 84 1 correctional officer training at FLETC. Did 1 MS. : No. 2 they discuss suicide? 2 MR. : You said suicide watch 3 MS. IIII: I mean if someone is like 3 though, that is on the second floor? 4 explains to you that they're feeling a certain 4 MS. : Yes. 5 kind of way or they want to harm themselves, 5 MR. : Okay. So you're not 6 then you report it to them. They will place 6 aware that the requirement that if someone is 7 them on suicide watch. But as far as when they 7 returned to the SHU that they're required to 8 return, there's no - nothing special that we're 8 have a cellmate if they were on suicide watch? 9 told to do when someone returns from suicide 9 MS. : No. 10 watch. 10 MR. : Do you know the 11 MR. So they don't tell you 11 difference between suicide watch and 12 like this person's on suicide watch, he's 12 psychological observation? 13 returning, he needs, you know a high likelihood 13 MS. : No. 14 of attemptin to harm himself. 14 MR. • No? Are they both done 15 MS. : No. 15 in - on the second floor? 16 MR. We should place him with 16 MS. : Yes. 17 another cellmate. 17 MR. Okay. But you don't even 18 MS. : No. 18 know what that is? 19 MR. That we should watch him. 19 MS. : No. 20 MS. 20 MR. . Did you know that Epstein 21 MR. Or make sure that he 21 was also on sychological observation? 22 hasn't harmed himself. 22 MS. : No. 23 MS. : No. 23 MR. • No? Just suicide watch? 24 MR. : Or pay special close 24 MS. : Mm-hmm. 25 attention to that individual. 25 MR. And to you it's one and EFTA00117663 85 86 1 the same thing? 1 MR. So you don't even 2 MS. : Yes. 2 remember there being a hotlist in the SHU? 3 MR. : Okay. 3 MS. : No. 4 MS. Mm-hmm. 4 MR. : Would you like look 5 MR. • And I did ask about 5 around at the boards and look at the walls and 6 suicide watch, but do you know who placed 6 see different things? 7 Epstein on sychological observation? 7 MS. : There is no board. 8 MS. : No. 8 MR. No? There's no like -- 9 MR. : No? And you don't know - 9 MS. 10 . Are inmates that come from psychological 10 MR. -- where the post orders 11 observation required to have a cellmate? 11 are - where are they kept as -. 12 MS. No. 12 MS. : It's on the desk. 13 MR. : You don't know? 13 MR. : Was there also on the 14 MS. I don't know. 14 desk something called the hotlist? 15 MR. : So were you aware of any 15 MS. : No. 16 inmates that are in the SHU that were on 16 MR. : Was there a list on the 17 suicide watch - came from suicide watch and 17 desk that had like inmate's names and anything 18 psychological observation? 18 next to them? Like a description? 19 MS. : No. 19 MS. : There's a roster. 20 MR. : And again, that hotlist. 20 MR. : A roster like of all the 21 Did you say that you do remember there being 21 inmates in the SHU? Total? 22 one? 22 MS. : Yes. 23 MS. : No. 23 MR. : Well what about like - 24 MR. : In the SHU? 24 and I only say this because I know that there 25 MS. : No. 25 was one. So you don't recall saying like - 87 88 1 seeing like one list where there's special 1 visited him when he was with his attorneys? 2 people assigned to that list called the 2 MS. : I don't know. 3 hotlist? 3 MR. : You don't know. So did 4 MS. 4 anyone - so psychologist, peers, supervisors, 5 MR. • No? And you did work 5 or anyone else - ever tell you that Epstein was 6 there all June, July, and August? Or not all - 6 required to have a cellmate? 7 end of June July, and then it's August. 7 MS. : Nobody. 8 MS. : Yes. 8 MR. : Nobody. Did you ever 9 MR. : Did any staff 9 receive any emails? So any type or form of 10 psychologist visit the SHU? 10 communication? So not just verbal. Emails and 11 MS. : Yes. 11 writing, text messages - anything? 12 MR. Did they ever visit 12 MS. : No. 13 Epstein in the SHU? 13 MR. : No? Do you have that 14 MS. No. 14 email? This isn't an email that was sent to 15 MR. No? What time typically 15 you. I just want to see if you - if someone 16 would they come to the SHU when they would 16 ever forwarded this to you. Did anyone ever 17 visit? 17 forward you -? This is -. First of all, this 18 MS. IIII: Um like after -. When I worked 18 is an email from . It says 19 the 8:00 to 4:00. I don't know. Sometime in 19 suicide watch / psychological observation 20 the day like ma be around 12:00. 20 update. It's what was sent on July 30, 2019. 21 MR. : And would they not have 21 It says inmate Epstein is being taken off 22 come to the SHU to see Epstein because he 22 psychological observation and needs to be 23 wasn't there at 12:00? 23 housed with an appropriate cellmate. Did 24 MS. : Because he wasn't there. 24 anyone ever forward this information to you? 25 MR. Do you know if they ever 25 Being that you worked in the SHU where he was EFTA00117664 89 90 1 assigned? 1 MR. : None of those people were 2 MS. 2 assigned to the SHU? Towards the bottom of 3 MR. : No? So no one ever 3 that? 4 discussed that with you in the SHU? Like none 4 MS. : No. 5 of the other employees in the SHU that would S MR. : No? Okay. So just the 6 have received this? 6 only person that you see on that is Lieutenant 7 MS. . No. 7 IIII? 8 MR. Do you know why other 8 MS. : Lieutenant IIII. 9 employees would have received this and you 9 MR. : And he never discussed 10 wouldn't have? 10 that matter with you? 11 MS. IIII: I'm not going to say that they 11 MS. : No. 12 received it and I didn't. 12 MR. : If you don't mind, could 13 MR. : Well if you look at the 13 you initial and date it? 14 back it's all the people that it was sent to. 14 MS. : I initialed. 15 So if you go to the last page, do you recognize 15 MR. And date. 16 any of the people on there that worked in the 16 MS. Ten.... 17 SHU with you? The names. Look at the last - 17 MR. : The 22nd. 6/22/21. 18 sorry, that middle page and toward the bottom. 18 MR. Agent just has a 19 The following page I think. Middle, toward the 19 couple questions on that. 20 bottom. 20 MR. Here. 21 MS. . That's the lieutenant. 21 MR. : During your time in the SHU 22 MR. . Do you recognize 22 23 Lieutenant on there? 23 MS. Mm-hmm. 24 MS. . Yes. But this is not sent 24 MR. : Did any new inmates come in 25 This is not the workers. 25 during your shift? 91 92 1 MS. III': On that specific day or in 1 there was only one that was by themselves? 2 general? 2 MS. IIII: I think it was an inmate by 3 MR. : Yeah. From June to August. 3 himself on C tier. 4 When you worked in the SHU. Did the SHU 4 MR. : Now you mentioned that day 5 receive an new inmates? 5 were you on August 9th you were notified that 6 MS. : Yeah. 6 was removed. But during your time 7 MR. : When they came in, how did 7 in the SHU, were you ever notified if an inmate 8 you assign the inmates? 8 was ever removed from the SHU for whatever 9 MS. IIII: I didn't. The senior officer 9 reason? Were you notified about it? 10 did. 10 MS. No. 11 MR. : Senior officer. Did you see 11 MR. : How would you find out if the 12 them assigp_inmates? Assign a cell to them. 12 inmate was supposed to be in the SHU or not? 13 MS. IIII: Like they put them in a cell? 13 MS. IIII: How would I find out if an 14 Yes. 14 inmate isiiiiiised -? 15 MR. : Were they ever put by 15 MR. : Let's say the morning 16 themselves? 16 started. 17 MS. : I don't remember. 17 MS. Mm-hmm. 18 MR. : Do you recall any inmates 18 MR. : You came on shift at 2:00 19 being placed by themselves in the SHU? 19 p.m. or possibly 4:00. After that, there's 20 MS. IIII: I think there was one inmate by 20 counts and rounds. When you do the counts, 21 himself. 21 right. I just want to know in terms of how 22 MR. : Any reason why he was placed 22 would you know if an inmate was removed or not? 23 by himself? 23 MS. IIII: When I count and he's not 24 MS. : I don't know. 24 there. 25 MR. So of all the inmates, 25 MR. : You wouldn't be notified any EFTA00117665 93 94 1 other way? 1 MS. : No. 2 MS. No. 2 MR. : Did the warden ever visit 3 MR. : That's all I have. 3 the SHU during Epstein's stay at the MCC? 4 MR. : And I know we discussed 4 MS. I don't know. Not on my shift. 5 the cellmates, but were you ever told you 5 MR. : Not during your shift? 6 needed to keep a close watch on Epstein -- 6 MS. 7 MS. : No. 7 MR. : No? Okay. Do you know 8 MR. : -- when he was there? 8 if the warden ever met with Epstein during his 9 No? Who was the MCC warden in July and August 9 stay? 10 of 2019? 10 MS. • I don't know. 11 MS. 11 MR. : Who were the MCC 12 MR. : Is that ? 12 associate wardens in August of 2019? 13 MS. Yes. 13 MS. Um, associate warden was 14 MR. : Okay. What 14 15 communications did you have with the warden 15 MR. 16 with regard to Epstein being housed within the 16 MS. Yes. 17 MCC or the MCC SHU? 17 MR. : Anyone else? That you're 18 MS. : None. 18 aware of? 19 MR. : None. And he never 19 MS. 20 provided you special instructions with regard 20 MR. : Okay. And what 21 to Epstein? 21 communications did you have with 22 MS. 22 or the other AW with regard to 23 MR. : Did the warden ever tell 23 Epstein being housed within the MCC or the MCC 24 you that Epstein was required to have a 24 SHU? 25 cellmate? 25 MS. IIII: None. 95 96 1 MR. None? Would you have 1 MR. FOY: Oka 2 communications with any of the AWs? 2 MR. : Do you know if any of the 3 MS. . No 3 AWs ever visited the SHU during Epstein's stay? 4 MR. : No? So did you not even 4 MS. .lon't know. 5 ever speak with them? 5 MR. : You don't know. Not 6 MS. : Not in the SHU. 6 during your watch though? 7 MR. • Not in the SHU. When 7 MS. 8 would you_laak with them? 8 MR. : Okay. Do you know if any 9 MS. IIII: On the regular housing unit 9 of the AWs ever met with Epstein during his 10 when they made rounds. 10 stay at the MCC? 11 MR. So in July and August did 11 MS. : I don't know. 12 you ever s eak with them that you recall? 12 MR. : You don't know. But not 13 MS. : No. 13 when you were in the SHU? 14 MR. • No. So not since you 14 MS. : Not on my shift. 15 were assi ned to the SHU at the end of June. 15 MR. Who was the MCC captain 16 MS. : Mm-hmm. 16 in July and August of 2019? 17 MR. Okay. What about the 17 MS. : Captain 18 warden? Is that the same thing? 18 MR. . Is that 19 MS. . Mm-hmm. 19 MS. Yes. 20 MR. No communications? 20 MR. Okay. And what 21 MR. FOY: Don't know. 21 communications did you have with Captain 22 MS. : No. 22 with regard to Epstein being housed within the 23 MR. : No? 23 MCC or the MCC SHU? 24 MR. FOY: Don't answer if you don't know. 24 MS. : None. 25 MS. IIII: Okay. 25 MR. None? And did he ever EFTA00117666 97 98 1 provide you with special instructions with 1 10th? I'm giving you the MCC New York daily 2 regards to E stein? 2 assignment roster. So there's August 9th and 3 MS. : No. 3 August 10th. So who were the MCC supervisors 4 MR. Captain 7 4 on duty with responsibility for overseeing the 5 MS. 5 SHU on August 9th and 10th? Do you recall if 6 MR. Did the captain ever tell 6 Lieutenant was there on August 9th or 7 you that Epstein was required to have a 7 10th? 8 cellmate? 8 MS. : I don't recall. 9 MS. 9 MR. You don't recall. 10 MR. In the SHU? No? Did the 10 MS. 11 captain ever visit the SHU during Epstein stay 11 MR. Okay. So he wasn't 12 at the MCC? 12 there. So if he's not there, who has oversight 13 MS. : Not on my shift. 13 over the SHU? 14 MR. : Not during your time? 14 MS. : I don't know. 15 Okay. And do you know if the captain ever met 15 MR. : Do you - would it be the 16 with Epstein during his stay at the MCC? 16 operations lieutenant or the activities 17 MS. : I don't know. 17 lieutenant? 18 MR. : You don't know. So who - 18 MS. : I don't know. 19 ? I'm going to give you now just because -. 19 MR. : You don't even know who 20 Uh okay, where are the rosters? I'm going to 20 is - that would have responsibility if the 21 ask her about some of the supervisors that were 21 lieutenant of the SHU wasn't there? 22 on duty. So are you familiar with these 22 MS. : No. 23 rosters? Like just by looking at it are you 23 MR. : Would anybody if 24 able to decipher who was on duty and who 24 Lieutenant wasn't there check in with you? 25 wasn't? Or who was on duty on August 9th and 25 MS. : I mean the other lieutenant 99 100 1 would make a round. 1 MR. Was it SOS 2 MR. What other lieutenant 2 Senior Officer Specialist 3 would that be? 3 MS. Yes. 4 MS. IIII: Whoever was on. You mean that 4 MR. Is that 5 day? 5 MS. (Indiscernible *01:11:25) 6 MR. Yes. On August 9th and 6 MR. I might be saying that 7 August 10th. I'm wondering who had 7 name wrong,__ 8 responsibility of the SHU? If Lieutenant IIII 8 MS. IIII: I'm not sure of her first name, 9 wasn't there. He was the SHU lieutenant. 9 but -. 10 MS. IIII: In the daytime, it was a 10 MR. That's fine. Oki. 11 regular officer acting. 11 those are the two that you remember: 12 MR. • Okay. 12 and 2 13 MS. : From the when I was on at 4:00 13 MS. Was Acting in the day. Yes. 14 to 12:00. 14 MR. • Okay. What about by 15 MR. : Okay. 15 looking at that. Would the - do you see where 16 MS. : And then from midnight it was 16 it says 7 17 Lieutenant 17 MS. Yes 18 MR. Okay. So would that 18 MR. . Would that person have 19 other person that you're referring to. Do you 19 oversight over the SHU from - does it say that 20 know who that was? 20 that person was the operations lieutenant? 21 MS. : The acting? That was acting? 21 MS. IIII: That's what it says here but I 22 MR. Acting. 22 didn't see Lieutenant 23 MS. 23 MR. : And do you know as being 24 MR. SOS =? 24 the operations lieutenant would they be 25 MS. : Say that again. 25 responsible for overseeing the SHU? If -? EFTA00117667 101 102 1 MS. : I don't know. 1 the operations lieutenant and the activities 2 MR. : You don't even know that? 2 lieutenant? 3 Okay. So you don't know if after -. Is it 3 MS. • No. All the lieutenants. 4 true that after replaced him 4 MR. : Okay. They all just sit 5 as the operations lieutenant? 5 in there to ether? 6 MS. : According to this, yes. 6 MS. Mm-hmm. 7 MR. : Okay. And you're not 7 MR. : Not one of them 8 aware that that person would have oversight 8 specificall answers the phone though? Just -? 9 over the SHU? 9 MS. No. Anybody. 10 MS. • I don't know. 10 MR. : Okay. Do you remember -? 11 MR. : You don't know. No one 11 Again, Lieutenant was reportedly off on 12 ever talked to you about isn't there. Who 12 August 9th and August 10th. 13 should you go to if there are any problems or 13 MS. Mm-hmm. 14 who would check in with you? 14 MR. : Do you recall ever seeing 15 MS. IIII: No. I would call downstairs to 15 him on Au ust 9th or August 10th? 16 the lieutenant's office. 16 MS. Hm-mm. 17 MR. : And would you just talk 17 MR. : Where would Lieutenant 18 to whoever answered? 18 sit? When he was at the MCC? 19 MS. Yes. 19 MS. : U stairs. 20 MR. : And who would sit in the 20 MR. : When you say upstairs, 21 lieutenant's office? 21 upstairs where? 22 MS. The lieutenants. 22 MS. IIII: There's an office right next to 23 MR. : All of them? 23 10 South u stairs there. 24 MS. 24 MR. : Within the SHU? 25 MR. : So it wouldn't be like 25 MS. : Yes. 103 104 1 MR. Okay. So he was 1 lieutenant's office. 2 physicall in the SHU? 2 MS. : Yes. 3 MS. Yes. 3 MR. : Okay. And I believe you 4 MR. . Alright. So when he 4 answered this, but did you have an 5 wasn't there, would any other lieutenant come 5 communications with Lieutenant IIII regarding 6 visit the SHU? 6 Epstein at all? 7 MS. : When they make rounds. 7 MS. : No. 8 MR. : Okay. When they make 8 MR. So he never provided you 9 rounds. And do you remember if that person was 9 any special instructions with Epstein? 10 the acting or the operations lieutenant or the 10 MS. : No. 11 activities lieutenant? The person that would 11 MR. And you never - 12 do those rounds? 12 Lieutenant never told you Epstein was 13 MS. : I don't know. 13 required to have a cellmate in the SHU? 14 MR. : You don't know. you just 14 MS. No. 15 knew that they were a lieutenant. 15 MR. I" know who 16 MS. : Yes. 16 Operations Lieutenant was from 17 MR. : Okay. So would you even 17 August 9th? Do you know that individual? 18 be provided that information where there's a 18 MS. : Yes. 19 duty agent roster? Is that something that 19 MR. • But as the operations 20 would be like, hey. It's up. If I need to get 20 lieutenant, you don't know that he was 21 in contact with somebody, I can look at that 21 responsible for overseeing the SHU on August 9, 22 roster and see who is where? 22 2019? 23 MS. IIII: No. Just call the lieutenant's 23 MS. : I don't know. 24 office. 24 MR. : Did you have any 25 MR. Just call the 25 communications with Lieutenant regarding EFTA00117668 105 106 1 Epstein bein housed at the MCC or in the SHU? 1 at that roster, was he on it on August 9th? 2 MS. : No. 2 MS. : No. 3 MR. : He never did - did 3 MR. : No. Do you know if he 4 Lieutenant ever provide you with special 4 was physically present at -? Do you recall if 5 instructions with regard to Epstein? 5 he was ph sically present on August 9th? 6 MS. : No. 6 MS. : I don't recall. 7 MR. : Did Lieutenant ever 7 MR. He was reportedly on sick 8 tell you that Epstein was required to have a 8 leave. I just want to make sure that he wasn't 9 cellmate while he was assigned to the SHU? 9 there. 10 MS. IIII: No. I'm going to ask you these 10 MS. • Okay. 11 questions with a couple people. So I just want 11 MR. : So you don't recall 12 you to like really think about those people and 12 having an communications with him? 13 they're goin to be repetitive. 13 MS. : No. 14 MS. : Okay. 14 MR. Alright. And did 15 MR. : Because I know you can 15 Lieutenant ever provide you with special 16 just simply say I didn't have any 16 instructions with regard to Epstein? 17 communications. But I want you to really think 17 MS. : No. 18 about that individual and any communications 18 MR. : No. Did Lieutenant 19 you had with that person with regard to Epstein 19 ever tell you that Epstein was required 20 and the SHU and your assignments. Okay? 20 to have a cellmate while he was assigned to the 21 MS. : Okay. 21 SHU? 22 MR. Who is Lieutenant 22 MS. No. 23 7 23 MR. And then this is who you 24 MS. : A lieutenant. 24 were just referring to. Who was senior officer 25 MR. : A lieutenant. By looking 25 specialist 107 108 1 MS. : An officer. 1 Can you tell? 2 MR. : And on August 9th, was 2 MS. : It says 8:00 to 4:00. 3 she the acting lieutenant responsible for 3 MR. I think it would just be 4 overseein2_1be SHU? 4 on that first age. 5 MS. IIII: I don't know if she was 5 MR. : Is that August 10th or 9th? 6 responsible for overseeing the SHU, but I know 6 MS. This is 9th. 7 she was the acting lieutenant. I don't know 7 MR. It just says 8:00 to 8 for the whole building. 8 4:00? 9 MR. But you said she -- 9 MS. Yes. 10 MS. But she -. 10 MR. : Can you check on the 11 MR. -- conducted a round? 11 lieutenants column up top? 12 MS. She did. 12 MS. • (Indiscernible *01:17:34) 13 MR. Okay. So if she 13 MR. : Is there a name? 14 conducted a round, would that lead you to 14 MR. It should be under 15 believe that she was probably -? Hey, 15 activities lieutenant. 16 Lieutenant isn't there, she's conducting 16 MS. : Oh yeah. 4:00 to midnight. 17 the round here, she's probably got oversight 17 MR. : 4:00 to midnight? Okay. 18 over the SHU? 18 So you knew that - you do recall having an 19 MS. IIII: I don't know. It could be 19 interaction with her. Did she have any 20 another lieutenant also. I don't know. 20 communications with - we're talking 21 MR. Okay. Did she visit the 21 about now - with regard to Epstein being housed 22 SHU on Au ust 9, 2019? 22 within MCC or the SHU? 23 MS. : Yeah, she did. 23 MS. : No. 24 MR. And what time was she on 24 MR. No? And did she provide 25 duty on August 9th? By looking at that roster. 25 you with any special instructions with regard EFTA00117669 109 110 1 to Epstein? 1 2 MS. 2 MS. : Yes. 3 MR. : Did SOS ever tell 3 MR. Were either of them in 4 you that Epstein was required to have a 4 the SHU on August 9 2019? 5 cellmate when he was assigned to the SHU? 5 MS. 6 MS. : No. 6 MR. 2 7 MR. : Okay. Now we're going to 7 MS. Mm-hmm. 8 go on to some staff members. Who was present 8 MR. But while you were there, 9 in the SHU when you worked in the SHU on August 9 not 10 9, 2019? So you said you were from 4:00 to 10 MS. I don't remember. But I 11 midnight on that August 9th. Do you recall who 11 remember because he spoke to me. 12 that was? 12 MR. Okay. So 13 MS. and 13 are the people that you 14 MR. IIIIIIIIII: Just and 14 remember that were in the SHU? 15 When you arrived to the SHU was anybody else 15 MS. : Yes. 16 there? 02_2u recall replacing? 16 MR. Okay. And you said that 17 MS. IIII: I don't remember who I 17 you remember speaking with you? 18 relieved. 18 MS. 19 MR. Do you know a 19 MR. About what? 20 IIIIIII? 20 MS. : He told me he placed Epstein in 21 MR. 21 the shower to use the phone. And he called and 22 MS. LPL 22 told me to take the phone from him. 23 MR. . . 23 MR. : Can you give me a little 24 MS. : Yes. 24 more detail on that? What do you mean? 25 MR. : Alright. And 25 MS. IIII: So because he -. 111 112 1 MR. lust walk me through. 1 MR. So do you know if someone 2 This one is one of those ones I'll ask you to 2 is calling from a non-recorded line, are you 3 explain a little more. Can you just from eh 3 supposed to take notes of that call? 4 start of the conversation to what you did with 4 MS. : I don't know. 5 Epstein to the finish. 5 MR. : Do you know if you're 6 MS. IIII: Okay. So Epstein stays in 6 supposed to log the telephone call in any kind 7 attorney conference all day. So I guess when 7 of a logbook? 8 it's time to use the phone, he's not present. 8 MS. : N 9 So when he came upstairs, gave him the 9 MR. Okay. So your 10 hone in the shower to use the phone. And then 10 understanding is gave him - plugged in 11 left. He called on the phone. I 11 the line, ave him the phone, and then left? 12 happened to answer and he said, "Hey can you 12 MS. : Yes. 13 take the phone from Epstein? Because the time 13 MR. No one was there to 14 is up." So -. 14 monitor? 15 MR. : So when he gave him the 15 MR. Okay. So he -. 16 phone he left and no one else was present with 16 MS. : We were in the SHU, but nobody 17 Epstein when he was on the phone? 17 was monitiiiiiiiiii 18 MS. : No. Nobody was there. 18 MR. : How far away from you was 19 MR. : Do you know that to be a 19 he when he was making this call? 20 legitimaq_pfactice? 20 MS. IIII: He was on C tier. And like 21 MS. IIII: I mean it's in the SHU, so 21 that's far from the desk. 22 yeah. 22 MR. : Approximately - do you 23 MR. So is no one supposed to 23 know how to like -? 24 be - because is the SHU a recorded line? 24 MS. : I don't know. 25 MS. IIII: I don't know. 25 MR. Is it like from here to EFTA00117670 113 114 1 like that fire extinguisher over there? Or is 1 MS. 2 it further? 2 MR. : Was it abnormal for an 3 MS. IIII: No. Maybe from the wall by the 3 inmate to be out by himself on the phone in the 4 AC to over there. 4 SHU? 5 MR. : Okay. So approximately 5 MS. : No. 6 25 feet? 6 MR. : So they can just freely - 7 MS. : Mm-hmm. 7 that's not an abnormal circumstance? 8 MR. : Could you hear his 8 MS. IIII: No because he wasn't free. He 9 conversation from there? 9 was in a cell. He was in a cell on the phone. 10 MS. No. 10 But he -. 11 MR. : And were you asked to 11 MR. : Oh so he was in a cell? 12 listen to his conversation? 12 MS. : Yeah but he was - he was in the 13 MS. No. 13 shower because the jack - where his cell is, 14 MR. : Prior to placing the 14 the jack didn't work. So he was placed in the 15 call, did speak to you at all? 15 shower to use the phone there. But the shower 16 MS. No. 16 is like a cell. 17 MR. : So just after he placed 17 MR. : Okay. So was the door 18 the call, he called you and what did he say? 18 closed -- 19 MS. IIII: He said to take the phone from 19 MS. Yes. 20 him because the time is up. 20 MR. -- in the cell? So he 21 MR. : Do you know how long he 21 was in the shower area. Was he by himself? 22 was on that hone? 22 MS. Yes. 23 MS. No. 23 MR. : Were showers running? 24 MR. : Were you watching him 24 MS. 25 while he was on that phone? 25 MR. : He was just - he placed 115 116 1 the call in the shower, cell closed behind him, 1 MR. : Okay. Can you explain 2 it was approximately 25 feet from you but you 2 what that is? 3 didn't hear anything? 3 MS. IIII: I mean I don't know too much 4 MS. : No. 4 about it. I just know that they have a PIN 5 MR. • And he didn't - and 5 that they use to use the phone. 6 didn't instruct you? 6 MR. : Okay. Do you know if 7 MS. : No. 7 Epstein had that PIN to use the phone? 8 MR. Did you ever experience 8 MS. : I don't know. 9 that prior to that instance? Where an inmate 9 MR. : But specifically with 10 would do that in the SHU? 10 regard to the shower, having an inmate call 11 MS. IIII: Yeah. If they have to use the 11 from the shower, have you ever experienced that 12 phone and where there cell is, it's not 12 before? 13 working. They place them in there because they 13 MS. : Yes. 14 have to plug it close to where they can have 14 MR. When was the last time 15 access to the hone. 15 you had eaLienced that prior to August 9th? 16 MR. : Okay. So in their cells 16 MS. IIII: If the jack is not working. 17 do they have cell lines that they can typically 17 The jack that's closest to their door. If it's 18 call from? 18 not working, then it's being plugged at the 19 MS. N 19 bottom where the shower is. So you place them 20 MR. Are the inmates provided 20 in the shiiiiiiiiiiso they can reach the phone. 21 anything to be able to make calls? 21 MR. : And do you know if that 22 MS. : No. 22 was an authorized practice? 23 MR. : Some kind of a card pass 23 MS. : I don't know. 24 or number or like something to be able to -? 24 MR. : Okay. And did you ever 25 MS. IIII: Oh, like a pack and - yeah. 25 place anybody in the shower to do that? EFTA00117671 117 118 1 MS. 1 or anythin 2 MR. No? 2 MS. IIII: No. 3 MS. 3 MR. FOY: We can continue. 4 MR. . Who typically does that? 4 MR. : Great. Alright. So what 5 MS. The officers. 5 were instructions. You said that 6 MR. Okay. But not you, 6 he's - his time is up. So what's - how much 7 right? 7 time is he allotted? 8 MS. 8 MS. : I don't know. 9 MR. Would you ever allow 9 MR. : Do you know how long he 10 inmates to lace calls? 10 was in that shower? 11 MS. : When -. 11 MS. : Mm.... I don't know. 12 MR. • You personally. 12 MR. : You don't know. Was it 13 MS. • When I come on, they have 13 like 5 minutes, 10 minutes -? 14 already like of their phone calls. 14 MS. IIII: It wasn't 5 minutes. He was in 15 MR. : Oh, okay. So it's not 15 there for ma be 20 minutes. 16 typically one of your responsibilities? 16 MR. 20 minutes? Okay. And 17 MS. : No. 17 where was 7 18 MR. : What was unique about 18 MS. He was gone. 19 this situation with Epstein? 19 MR. Like left the SHU 20 MS. IIII: Well I guess because he's 20 altogether? 21 always downstairs, so they made an exception 21 MS. Mm-hmm. 22 for him to make a call. 22 MR. So he placed him in there 23 MR. : Okay. Do we need to take 23 24 a break? 24 25 MR. FOY: DO you need to use the bathroom 25 MR. MS' : -- left the SHU, and then 119 120 1 where did he call you from in order to say get 1 MS. Like the time? 2 the phone from him? 2 MR. : Yep. 3 MS. IIII: A phone in the building. I 3 MS. : It had to have been about after 4 don't know where because it doesn't say where. 4 8:00 because that's the time he comes back from 5 Like the phone rang and I answered. And he 5 attorney conference. 6 just told me to take the phone from Epstein. 6 MR. Okay. So around 8:00 7 His time is .. 7 p.m. - ish? 8 MR. : Is that weird to you at 8 MS. : After. 9 all? That he again, he gave someone a phone, 9 MR. After 8:00 p.m. - ish? 10 put them in the shower and then left? 10 MS. Mm-hmm. 11 MS. 11 MR. Okay. Are you able to 12 MR. That's not weird? 12 look? Was assigned to the SHU when he 13 MS. 13 gave him his phone call? 14 MR. • Okay. But without 14 MS. : No. 15 filing anybody -. Did you know if he - 15 MR. Where was he assi ned? 16 - provided anybody instructions prior 16 That's fine. Do you know what - why 17 to him de arting the SHU? 17 went to the SHU in the first place? 18 MS. • I don't know. 18 Was the escorting Epstein back from his 19 MR. You don't know. 19 attorneys? 20 MS. 20 MS. : I'm not sure. 21 MR. else was in the SHU 21 MR. So you don't know the 22 with you 22 reason wh he actually entered the SHU? 23 MS. 23 MS. : No. I don't know. 24 MR. And did you recall when 24 MR. And you -? Do you 25 around that took place? 25 remember if he walked into the SHU with Epstein EFTA00117672 121 122 1 and immediately placed him into the shower 1 MR. Alright. But you don't 2 area? Or do you think that he went and 2 know who brough Epstein -- 3 retrieved_Lpitein from his cell? 3 MS. : No because -- 4 MS. IIII: No. He didn't retrieve him 4 MR. : -- back there? 5 from his cell. He came in and said that he was 5 MS. -- somebody could have brought 6 going to ive him a phone call. 6 him up and then - so I don't know. 7 MR. : So he was with him at the 7 MR. : Okay. Now in order to 8 time? 8 et tto the SHU though, either you, or 9 MS. IIII: Yes. And he placed him in the 9 10 shower. 10 i MS. : Had to open the -. 11 MR. So do you recall then if 11 MR. : -- open the door. Do you 12 he walked in the SHU with Epstein? 12 remember who opened the door on that day? 13 MS. IIII: I don't know if he walked in 13 MS. : I don't know. 14 with him. But after because you could come in 14 MR. It was not you? 15 and he could have been -. There's a holding 15 MS. 16 cell there. That's why I'm saying I don't 16 MR. Okay. And I'm sorry, you 17 know. And then he came in after with him. But 17 may have said this and I do apologize. What 18 from that door to the shower, he walked in with 18 time didMI angIIIIIIII work there until? 19 19 MS. IIII: .= was 4:00 to 12:00 and 20 MR. Okay. So Epstein wasn't 20 was 2:00 to 10:00. 21 in his own cell? 21 MR. : Okay. And what was the 22 MS. : No. 22 hierarchy with the three of you that were 23 MR. He could have potentially 23 present at that time? Is there someone that 24 been in a holding cell? 24 was in charge as an officer in charge? Or how 25 MS. IIII: Yes. 25 does that work when you're working together 123 124 1 with those two other individuals? 1 MR. On that roster on August 2 MS. IIII: I don't know who was in charge. 2 9th of those three people, who does it say 3 We just kind of worked together that day. But 3 should have been in charge? 4 I don't know as far as who is the -. 4 MR...t's on the first page. 5 MR. : Is everyone considered 5 MR. : It's on the first page. 6 equals? When you're working together? 6 If you look all the way to the left, you'll see 7 MS. IL Well I'm the newest person 7 SHU assignments. And then you can look - go 8 there, so and - I don't know how 8 over to the right and see their names. I 9 long they've been there, but -. 9 believe. 10 MR. : Does it - does then when 10 MS. : I don't see I'm looking 11 you work with someone else, is it based upon 11 for . I don't see that. 12 how long the 've been with the Bureau? 12 MS. GREGG: Really quick, can I just show 13 MS. : No. 13 her how she reads -- 14 MR. : So is there -. I know 14 MR. : Absolutely. 15 you're saying you're the newest. So you might 15 MS. GREGG: -- a roster? 16 ask them questions. But is there like when 16 MS. IIII: Oh I see him here. 17 there's three of you in there, is there someone 17 MS. GREGG: So - sorry. Most of what 18 that's supposed to be in charge? Or are you 18 they're asking you would be on page one and 19 all equaljy_:? 19 page two, right? So these are your shifts. 20 MS. IIII: On the roster it'll say who is 20 These are the posts. And then these are the 21 supposed to be in charge. 21 people who worked that shift too. If morning 22 MR. : Okay. So (Indiscernible 22 watch, 3:00, 6:00 to 2:00, 6:00 and 8:00 is day 23 *01:28:25) -. 23 watch. This is the p.m. 12:00 to 8:00, 2:00 to 24 MS. IIII: But that doesn't necessarily - 24 10:00, and this is all your evening watch. 25 that's not necessarily the case. 25 This is like a person with a day off, sick EFTA00117673 125 126 1 leave, so on and so forth. These things I 1 MS. GREGG: Here. SHU I. That's your 2 don't believe apply to their questions because 2 OIC. 3 these are all the changes that took place on 3 MS. IIII: Okay. 4 the roster. 4 MS. GREGG: Straight across. SHU II. SHU 5 MR. : Most everything is going 5 III is your 6:00 to 2:00, 2:00 to 10:00. And 6 to be on the first page. 6 SHU IV is straight across. Right? So for 7 MS. GREGG: Yeah, so this can be a little 7 example, SHU IV was vacant on Sevel i watch. 8 bit confuilg. 8 And then this is showing that was SHU 9 MS. IIII: Okay. 9 number one for the evening watch shift. 10 MS. GREGG: And it probably doesn't apply 10 MS. IIII: And this one to what time? 11 to the stuff that they're asking. 11 MS. GREGG: Shift III is 6:00 to 2:00. 12 MS. IIII: Okay. 12 MS. IIII: Oh, okay. 13 MS. GREGG: So you would just focus on -. 13 MS. GREGG: And then shift ten is 2:00 to 14 MS. IIII: These two pages. 14 10:00. 15 MS. GREGG: Yeah. The shifts are up top. 15 MS. Okay. 16 MR. FOY: So how does she determine who's 16 MR. : Thank you very much for 17 the boss? Because that's the question. 17 that assistance. 18 MS. IIII: Yeah. 18 MS. GREGG: Mm-hmm. 19 MS. GREGG: So this - these positions will 19 MS. • So basically on this it would 20 tell you who is in that position for that 20 have been 21 shift. Right? I don't want to answer the 21 MR. : Okay. would 22 question for you, but when you look at the SHU 22 have been 23 23 MS. In charge. Mm-hmm. 24 MR. FOY: Can you show her where the 24 MR. : Okay. Because he was SHU 25 answer is on the paper? 25 I? 127 128 1 MS. : Yes. 1 MS. : Doing what we need to do. 2 MR. : And do you know what SHU 2 MR. : Okay. So everybody 3 I means he was the officer in charge? 3 basically has the same job responsibility. 4 MS. : Yes. 4 MS. : Yes. 5 MR. : What does SHU II and SHU 5 MR. : Okay. So you don't look 6 III represent? Are there different duty 6 to someone as the actual officer in charge. 7 responsibilities - duties and responsibilities 7 MS. IIII: I do because I don't know. So 8 based upon if you're SHU I, SHU II, or SHU III? 8 - but not necessarily the officer in charge, 9 MS. IIII: I just know whoever the number 9 just whoever that I'm working with. 10 one is would be the person in charge. But as 10 MR. : Okay. And what was your 11 far as two and three, I don't know the 11 -? I don't know, this may have just answered 12 differenciiiiiiiiiinsibility. 12 that, but what was your role in the SHU on 13 MR. : Now in the time that you 13 August 9, 2019? What SHU number were you? 14 worked there, did that actually play into 14 MS. : Number two. 15 anything? If someone was SHU I or SHU II or 15 MR. : Number two. Like again, 16 SHU III? 16 you don't believe that actually provided you 17 MS. : N 17 with a different responsibility that SHU I or 18 MR. : No? So -. 18 SHU III? 19 MS. Because we're always short- 19 MS. : No. 20 staffed. 20 MR. No? Okay. And what 21 MR. Okay. So would that mean 21 conversations did you have with the SHU staff 22 that like if the person SHU I even though on 22 that you worked with on August 9th regarding 23 paper they're the officer in charge, they're 23 Epstein? 24 actually not providing orders or anything? 24 MS. : None. 25 Everyone's equally -. 25 MR. : So you said that the one EFTA00117674 129 130 1 was with 1 MR. : And is that what you did? 2 MS. Yes. 2 MS. : I didn't place him back in the 3 MR. Correct? With regard to 3 cell. I went to the bathroom upstairs on 10. 4 the phone call. 4 MR. : Okay. 5 MS. : Yes. 5 MS. : And when I came back, he was 6 MR. Now try to put yourself 6 placed back in his cell. 7 back then. 7 MR. : Okay. So what did you 8 MS. Mm-hmm. 8 do? You went to the shower and just instructed 9 MR. Any other conversations 9 him throu h the door? 10 at that point with regard to Epstein? 10 MS. : Yeah. 11 MS. : Um.... No. 11 MR. To hang up? 12 MR. : Any follow on to when he 12 MS. : No. I told him that I was told 13 said get the phone from Epstein? 13 that his time was up and I have to take the 14 MS. IIII: No. When he said to get the 14 phone in. And he said okay. And then he 15 phone, I got the phone. And I spoke to 15 handed me the hone. It's like a slot. 16 Epstein. 16 MR. : Okay. And then you 17 MR. : Okay. And what was it 17 walked awa ? 18 that you lake with Epstein about? 18 MS. : Yes. 19 MS. IIII: I was told that your time is up 19 MR. : And he just stayed there 20 and I have to take the phone. And he said 20 and waited? 21 okay. 21 MS. Yes. 22 MR. : Okay. And did 22 MR. And then who brought him 23 say to then place him back in his cell? Or was 23 from the shower to his cell? 24 that understood? 24 MS. IIII: I don't know. well it had to 25 MS. IIII: No. That was understood. 25 be and because it takes two 131 132 1 people to move him. And I went to the 1 worked that day? 2 bathroom. 2 MS. : In the morning. 3 MR. : Okay. So you used the 3 MR. And who replaced him? 4 restroom at the time that he was transported -? 4 MS. 5 MS. : Back to his cell. Yes. 5 MR. 6 MR. : Okay. And did you have 6 MS. Because he worked 6:00 to 2:00 7 any conversation with the individuals after 7 and in 2:00 to 10:00. 8 they placed - before or after they placed him 8 MR. Okay. So when someone 9 into the cell? 9 gets replaced, do they typically give a 10 MS. N 10 briefing? Like so would - and I apologize 11 MR. . Did you instruct them, 11 about the name but - . Would they - 12 hey I just took the phone from him, can you 12 would he typically be responsible to provide 13 place him back into the cell? 13 with information so that he - you know 14 MS. : Yes. 14 with regard to what happened on his assignment 15 MR. : Okay. So you did talk to 15 so that he can utilize that for when he's not 16 them about that. 16 replacing him? 17 MS. IIII: Yes. I said I was going to the 17 MS. : I don't know. 18 bathroom and he has to go back to the cell. 18 MR. Does that make any sense? 19 MR. Okay. That was the 19 MS. : I mean I don't know if he's 20 extent of it? 20 typically required to, but I guess if there's 21 MS. That was the extent of it. 21 information to give, he would give it to him. 22 MR. . Alright. And again we 22 But I don't know if he has to. 23 briefly talked about him, but IIIIIIII. 23 MR. : Okay. And during your 24 MS. : Yes. 24 time, was there an- iiiiirsation with any 25 MR. Now do you know if he 25 information that gave to ? Or EFTA00117675 133 134 1 passed alon 1 When you're in SHU, like let's say if you did 2 MS. : I wasn't -. 2 something and you're in trouble. So you're in 3 MR. : For the replacements? 3 the SHU. You could be sent back to your 4 MS. : I wasn't there at 2:00. I came 4 regular unit. So it wouldn't be odd like if I 5 in at 4:00. But nothing was told to me. 5 was counting and the person wasn't there. It 6 MR. So never informed 6 would just be lesser the count. But it 7 you or in your presence? 7 wouldn't be odd if the physical person wasn't 8 MS. No. 8 there to me. Because people move back all the 9 MR. Okay. So there was no 9 time. 10 discussion for Epstein to be reassigned a 10 MR. : But wouldn't they have to 11 cellmate? 11 advise you if you knew that there was only one 12 MS. 12 person without - you know, one person that 13 MR. And again, you didn't 13 doesn't have a cellmate. Wouldn't they have to 14 even know that his cellmate wasn't there? 14 advise you? Hey, this person left, so this 15 MS. : Wasn't there. 15 persons' in there by himself. 16 MR. : Okay. And should have 16 MS. IIII: I don't know. Because nobody 17 you known that his cellmate wasn't there? 17 said anytiiiiiiiiii. 18 MS. : I don't know. 18 MR. : So I'm not -. I'm just 19 MR. : So when you're doing 19 saying in general now. So like if you're 20 rounds and conducting counts, wouldn't that be 20 conducting your rounds and your counts, in 21 when you would know if someone was with or 21 order for you to know who you're supposed to be 22 without a cellmate? Because you said only one 22 counting and what -. During both rounds and 23 other person there didn't have a cellmate. 23 counts, you know, who are you supposed to be 24 Correct? 24 checking on. Wouldn't you need to know if a 25 MS. IIII: But people move all the time. 25 cellmate was removed and now there's only one 135 136 1 inmate in the cell? 1 now because the person is not there, I'm going 2 MS. IIII: No. like if I'm counting and 2 to just count 65. But the number is not going 3 the person is not there. Like say the count 3 to be off because whoever moved the body 4 was 66. And I counted 6S, that's just what 4 already moved them to like let's say back to 5 I'll count. 5 the unit or wherever. So I wouldn't be trying 6 MR. : And you wouldn't try to 6 to find or figure out where the person went. 7 like figure out where is the 66th? 7 I'm just S coui i i. 8 MS. IIII: No because whoever moved the 8 MR. : Okay. So and you're 9 person would have I guess documented where they 9 counting during the counts, right? Not during 10 moved them to. 10 the rounds? 11 MR. : So you wouldn't - it is 11 MS. : Ri ht. During the counts. 12 after you count at 65, then would you have to 12 MR. : Rounds are every 30 13 just go try to find paperwork. Hey, is there 13 minutes a roximately? 14 another gu that someone else moved? 14 MS. Yeah. 15 MS. : No. 15 MR. So during those rounds, 16 MR. : Okay. So how do you 16 are you supposed to be when you're conducting 17 reconcile the numbers? Rather than me saying 17 the rounds, what is the intent of those rounds? 18 so many words, you tell me how -- 18 MS. IIII: Whoever is in there to make 19 MS. : Okay. So let's say -. 19 sure that the 20 MR. : -- do you know who's in 20 MR. : So if you don't know who 21 the SHU? 21 is in there, how do you make sure that they're 22 MS. IIII: So let's say like if there was 22 there and okay? 23 66 people in there. And one person moved to 23 MS. IIII: Because they would have already 24 wherever. They would have already did that. 24 been -. If the person is not there, like they 25 So it wouldn't be for me to do. When I count 25 would have already been moved in the system. EFTA00117676 137 138 1 So if I'm making a round, I'm not going be like 1 though the one person doesn't have a cellmate, 2 well oh this person is not in here. Because 2 it's not odd to me because I don't know that 3 people go to different places. They go back to 3 they have to have a cellmate. What if the 4 the unit. They go to court. They go to 4 person went back to the unit? I didn't know 5 different places. So again, it wouldn't be 5 where went to. 6 odd if somebody is not there. I mean I could 6 MR. Okay. 7 ask the person that I'm working with. Like oh 7 MR. : Can I ask her something? 8 hey, whatever ha to so-and-so, but. 8 MR. Yes, please. 9 MR. : Alright. So you're 9 MS. Mm-hmm. 10 saying that even though you knew only one 10 MR. : I just want to clarify. When 11 inmate didn't have a SHU and especially, it 11 you come in, right. Let's say you come on re- 12 sounds like ou're working later. 12 shift. Is there somewhere near the computer 13 MS. : Mm-hmm. 13 that tells you how many inmates are supposed to 14 MR. • So everyone should pretty 14 eb in the SHU? 15 much be back from wherever they went to. 15 MS. : On the roster. 16 Correct? 16 MR. : On the roster? 17 MS. : Correct. 17 MS. Yes. 18 MR. So at that point, you 18 MR. : And now let's say - do you 19 only know one person doesn't have a cellmate. 19 review the roster when you come in? 20 You're walking through and you see that someone 20 MS. No. 21 doesn't have a cellmate. You're not asking -- 21 MR. : So how do you know? Let's 22 MS. : But see I don't know -. 22 just say someone went missing. How do you 23 MR. • -- where is that person? 23 know? 24 MS. : But see I don't know that the I 24 MS. IL I don't know. 25 person has to have a cellmate. So again, even 25 MR. : But isn't that - when you 139 140 1 come on shift, right. You're responsible. I'm 1 MR. Alright. 2 not saying this is the case. But you're 2 MS. GREGG: What - I've got a question. 3 responsible to know how many inmates are in the 3 MR. : Absolutely. 4 SHU at that time. Right? 4 MS. GREGG: Would procedural clarification 5 MS. IIII: When I come on shift, I just S help with the 6 come on and relive the person and just -. Like 6 MR. : Sure. We have all the 7 when I come on at 4:00, it's time to feed. So 7 polices here. Would you like me to show her 8 I'm doing trays and I'm feeding. I'm not 8 the policies? I'm happy to do that. 9 looking to see who's on the roster or -. You 9 MS. GREGG: Yeah. Or I could explain it. 10 would probably wait for count time to count and' 10 MR. : I'll give her the 11 then count to see how much people is in there. 11 policies and just ask if she's familiar with 12 But I'm not looking to see okay the roster says 12 them. That's fine. So she knows what she 13 75 and I'm counting to make sure there's 75 13 should have done. 14 people. Ilf•iunt time. 14 MS. GREGG: I'll just say this to you. 15 MR. : So when you're doing your 15 The policy is very general for the entire 16 rounds, all you're doing is the people that you 16 agency, to MCC New York. 17 see, are they okay. If someone escaped, you 17 MR. : Okay. 18 wouldn't know that until count time? 18 MS. GREGG: So. 19 MS. : I wouldn't. No. 19 MR. : While he's looking, I just 20 MR. : Okay. And that's 20 want clarification. 21 basically - that answers it. So she's saying 21 MS. Mm-hmm. 22 that she's not even worried about if someone is 22 MR. When you came in, if an 23 not there. She's only worried about the people 23 inmate was removed, would that roster have been 24 that are there. Is that correct? 24 edited? 25 MS. IIII: Yes. Yes. 25 MS. IIII: It should be. EFTA00117677 141 142 1 MR. : Do you recall if that roster 1 additional information. Begin making 30 -. So 2 - was there a roster on your desk? 2 according to this, it says when you're report 3 MS. IIII: There's always a roster. But I 3 to duty, you're supposed to talk to the 4 don't look at the roster. 4 operations lieutenant and receive whatever 5 MR. : But you don't recall if there 5 information you're supposed to on your shift. 6 was anything - if there was a notification or 6 It says, "Begin making 30-minute rounds 7 anything written down saying inmate 7 ensuring you document the findings into True 8 was removed from the SHU? 8 Scope (Phonetic Sp. *01:42:49). Staff will 9 MS. No. 9 observe all inmates in continued lockdown 10 MR. : Is that something the 10 status once in the first 30-minute period of 11 previous shift should have communicated to you? 11 the hour. Example, 12:00 to 12:30 a.m. 12 MS. : They could have. 12 Followed by another round in the second 30- 13 MR. : Alright. So I'm going to 13 minute period of the same hour 12:30 to 1:00 14 read this out loud and then I'll provide it to 14 a.m. This will ensure an inmate is observed at 15 you. This is the Metropolitan Correctional 15 least twice per hour. These rounds are to be 16 Center, New York, New York specific post 16 conducted on an irregular schedule and no more 17 orders. This is specifically says SHU number 17 than 40 minutes apart. All observations must 18 one. And I think that would be the officer in 18 be documented. It should be clearly understood 19 charge as we just discussed. But I think that 19 that none of these activities are to take place 20 they're, like you said, everyone's kind of 20 until the evening watch officer is relieved. 21 responsible for the same thing. But it 21 It should be noted that it is understood that 22 discusses right here, I'm going to go down to 22 not all of the above will be accomplished by or 23 the third paragraph on page 2 of 18. It says 23 before the count." Then it talks about 24 report for duty by telephone with the 24 official count time. The SHU number two 25 operations lieutenant and receive any 25 officer you said you were working, is that for 143 144 1 both your shifts? Because this is specifically 1 at all? 2 talking about 12:00 a.m. What were you at 2 MS. : No. I've never -. 3 12:00 a.m. on August 10th? 3 MR. : Was that ever put into 4 MS. : I think I was number one. Yes. 4 practice? 5 MR. : Alright. So this 5 MS. IIII: No. Nobody ever calls the 6 actually is pertaining to your shift during 6 lieutenant when they get on shift. 7 12:00 a.m. to 8:00 a.m. So -. 7 MR. So no one ever talked to 8 MR. FOY: You mean according to what you 8 them? 9 just read? 9 MS. 10 MR. What I just read. This 10 MR. Okay. Is there - I don't 11 says for -- 11 know if I need to continue reading this because 12 MR. FO tiliA. 12 we're going to take a lot of time with it if we 13 MR. : -- the specific 13 do. Just because I read it, if you want to 14 (Indiscernible *01:43:58) so we're SHU number 14 take a look. And just initial and date there. 15 one. So I guess what you were supposed to do 15 And then we're just going to move on. 16 per post orders was when you get on board, 16 MS. : Mm-hmm. 17 you're supposed to call the operations 17 MR. Because that's - this is 18 lieutenant. And then you're supposed to say 18 taking up. 19 hey, is there any information I need to know. 19 MR. FOY: Initial the top. 20 And then you're supposed to start making your 20 MR. : But the point on that 21 counts. And that would be like where you would 21 matter was that you knew you were supposed to 22 find out Epstein doesn't have a cellmate. Make 22 observe the people that were there. You 23 sure that when you're doing your rounds, you 23 weren't too concerned about people that weren't 24 know there's nobody in there. You know I would 24 there. 25 think. Is that - was that your understanding 25 MS. IIII: Nothing. Correct. EFTA00117678 145 146 1 MR. Is that a correct 1 MR. No? Did you discuss the 2 understandin ? 2 need for Epstein to be reassigned a cellmate 3 MS. : Yes. 3 with anyone on August 9th? 4 MR. Alright. On August 9th L_. 4 MS. : No. 5 do you recall having any discussions with IIIII 5 MR. : No. When did 6 regarding E stein? 6 depart the SHU? On August 9th? 7 MS. No. 7 MS. : At 10:00. 8 MR. And again, would 8 MR. 10:00 p.m.? Correct? 9 have been the one - did you say he was the one 9 MS. Correct. 10 who replaced -? 10 MR. You said unit manager 11 MS. : Relieved 11 Nathan . He actually wasn't in the SHU? 12 MR. Okay. So if 12 I mean he wasn't assigned to the SHU. I'm 13 provided with information, did not 13 sorry. 14 provide you with that information. 14 MS. 15 MS. I don't know if 15 MR. He was just in there in 16 MR. Yeah-yeah-yeah, I know. 16 order to facilitate the start of this telephone 17 I'm askin that -. 17 conversation? 18 MS. : Oh about didn't -. 18 MS. : Phone call. Yes. 19 MR. If he did that, 19 MR. And you don't know why he 20 certainly didn't provide it to you. 20 was in there in the first place? 21 MS. : No. 21 MS. No. 22 MR. : Okay. And didn't 22 MR. So you don't know if he 23 provide you with any special instructions 23 brought E stein in? 24 regarding22tein? 24 MS. : No. 25 MS. IIII: No. 25 MR. : He just - and you're not 147 148 1 the one to allow them? 1 where he said get the phone from Epstein his 2 MS. : No. 2 time is uph__ 3 MR. : Alright. So he didn't 3 MS. IIII: And when he came in, he said 4 actually have any responsibilities in the SHU? 4 I'm going to put him in the shower to use the 5 MS. : No. 5 phone. 6 MR. : And aside from the 6 MR. And that was the extent 7 iine conversation that you had with 7 of it? 8 9 iiiii , with specifically with regards to get the phone away from him, his time is up. Any 8 9 MS. MR. That was the extent of it. Okay. Nothing to do with 10 other conversations? 10 Epstein bein housed with MCC or SHU? 11 MS. : With , no. 11 MS. No. 12 MR. No. About Epstein or 12 MR. Or the need for a 13 otherwise. 13 cellmate? 14 MS. 14 MS. 15 MR. No. Any conversations 15 MR. Do you know who 16 with him ip_person? 16 authorized to provide Epstein with that 17 MS. IIII: Only when I took the phone from 17 telephone call? 18 him. 18 MS. : I don't know. 19 MR. No-no, not Epstein. 19 MR. : No. Who plugged the 20 20 telephone line into the legal line in the 21 MS. : Oh, no. 21 shower area? 22 MR. : And that's what I was 22 MS. 23 asking about before. It's just to make sure 23 MR. did. And do you 24 that we're clear. Any other conversations 24 know if he did that per ' direction? 25 aside from that one conversation on the phone 25 MS. IIII: No. EFTA00117679 149 'so 1 MR. You're not sure. And to 1 MS. IIII: Um. When they had them the 2 you, that was an authorized practice? 2 phone in the cell and they use that PIN - the 3 MS. IIII: To use the phone in the shower? 3 number - to make the phone call. How often, I 4 Yeah. 4 don't know. Because that's usually done before 5 MR. : What is that line in the 5 I come in. But I know showers are every other 6 shower area for? 6 day. I don't know if phones is every other day 7 MS. I don't know. 7 also. 8 MR. : Is it -? Okay. Is there 8 MR. Okay. So you're not 9 usually a phone that's plugged in there? Or is 9 sure? 10 it just a 10 MS. I'm not sure. 11 MS. 11 MR. You said you didn't hear 12 MR. -- line that's available? 12 any part of that telephone conversation? 13 MS. The jack is there. 13 MS. : No. 14 MR. Just the jack. And you 14 MR. : Did you see any part of 15 know that to be a legal line like for 15 that teleftwine conversation? 16 attorneys? 16 MS. IIII: Only when I went to go get it 17 MS. : I don't know. 17 from him. 18 MR. : You don't know that 18 MR. But while he was on it? 19 that's what that is - a legal line? 19 MS. 20 MS. : I don't know. 20 MR. Discussing? 21 MR. : But what is just your 21 MS. 22 overall understanding briefly about policy for 22 MR. And no one observed him? 23 inmates assigned to the SHU when they need to 23 MS. 24 make a phone call? How often do they get to do 24 MR. So no one watched him or 25 it? How do they do it? 25 listened? 151 152 1 MS. : No. 1 MR. Around 9:00 p.m. 2 MR. : And no one informed you 2 MS. Mm-hmm. 3 to watch or listen? 3 MR. Okay. And you said 4 MS. : No. 4 you're not the person who brought him. Someone 5 MR. And previous instances 5 else did. After someone else brought him to 6 when people have used that line, were other - 6 his cell, did you have any more conversations 7 were people watching and listening to those 7 with Epstein? 8 people? 8 MS. : Yes. 9 MS. 9 MR. Okay. What - when was 10 MR. And around what time was 10 that and where? 11 Epstein brou back to his cell did you say? 11 MS. IIII: Not a conversation when I 12 MS. : Ma be about after 9:00. 12 counted. 13 MR. : So he did the telephone 13 MR. When did you count? 14 call sometime before 9:00 and around after 9:00 14 MS. At 10:00. 15 is when he has put back into his cell? 15 MR. At 10:00 p.m. you 16 MS. IIII: Probably because I was in the 16 counted? 17 bathroom. 17 MS. 18 MR. : And you went to the 18 MR. So you actually went 19 bathroom ou think around 9:00? 19 through each tier and counted? 20 MS. I'm not sure. 20 MS. : Yes. 21 MR. : Sure. 21 MR. : And did you go into the 22 MS. But around. 22 tier? Or did you just go up to the door? 23 MR. : I'm not asking for 23 MS. : I went into the tier. 24 specifics. 24 MR. : Okay. So you didn't head 25 MS. IIII: Yeah. Like around. 25 around at 10:00 p.m. you didn't stop at the EFTA00117680 153 154 1 door and just look in? You actually went 1 MR. Take the mattress off the 2 through? 2 bunk? 3 MS. : Yeah, I went through. 3 MS. And put it on the floor. 4 MR. : And looked through and 4 MR. Sleep there. Is that 5 counted each person? 5 typical? 6 MS. IIII: Yes because he was on the 6 MS. : For him. 7 floor. And I knocked. And he put his hand up. 7 MR. : For him? Which other 8 MR. : Okay. So that wasn't 8 inmates do that? 9 just from the outer door of the tier. 9 MS. IIII: Not in the SHU, but sometimes 10 MS. No. 10 they do that. 11 MR. . That was actually -. 11 MR. : And is there anything up 12 MS. , that was in there. 12 with policy that prohibits people from doing 13 MR. Okay. And you said you 13 that? 14 don't know who brought him back to the cell. 14 MS. : Not that I know of. 15 MS. : No I was in the bathroom. 15 MR. : No. So it wasn't 16 MR. : Okay. And when - around 16 anything of concern? 17 10:00 p.m. you looked in and you said he was on 17 MS. No. 18 the floor and he put his hand up? 18 MR. : Okay. But he - did you - 19 MS. IIII: Yeah. He sleeps on the floor. 19 did he verbalize anything or just put his hand 20 The mattress - he puts the mattress on the 20 up? 21 floor. 21 MS. : He put his hand up. 22 MR. : Okay. So you never 22 MR. : lust like, I'm accounted 23 actually see his bunk. He would sleep on the 23 for? 24 floor. 24 MS. : Ri ht. 25 MS. IIII: The floor yeah. 25 MR. : Okay. And is that after 155 156 1 you said ou knocked? 1 MR. : Okay. 2 MS. : Yes. 2 MS. : So the cord has to be ran from 3 MR. : And did you communicate 3 outside of his room all the way down to be 4 with him at all? 4 plugged in. 5 MS. Mm... 5 MR. : It's for sleep apnea? 6 MR. You okay? 6 MS. : I don't know what else it's 7 MS. 7 for. But that's what I know people use it for. 8 MR. No. So it was just a 8 MR. : And did you get it for 9 knock and hand up. 9 him? 10 MS. : Yes. 10 MS. IIII: It's in his room. It's just 11 MR. No communication. 11 for it toliiiiiiiiid in. 12 MS. None. 12 MR. : Oh. And did you plug it 13 MR. lust visualization. 13 in for him? 14 MS. Yeah. 14 MS. Yes. 15 MR. And notice anything 15 MR. Okay. So you did have 16 different about him at that time? 16 some communication with him then? 17 MS. No. 17 MS. IIII: Well he asked and I just 18 MR. No. You said that was 18 nodded. Anc aliged it in. 19 around 10:00 p.m.? 19 MR. : So okay. So when I ask 20 MS. IIII: I think he asked for the CPAP 20 you these things, I just really want you to be 21 machine to be plugged in because he had a CPAP 21 clear with like -- 22 machine. 22 MS. : Mm-hmm. 23 MR. : What's a CPAP machine? 23 MR. : -- if there's 24 MS. rthen people have sleep apnea, I 24 communications just really think about like 25 guess they use that machine. 25 what communications you actually had. EFTA00117681 157 158 1 MS. : Mm-hmm. 1 MS. : Yes. 2 MR. : So just tell me about 2 MR. : Okay. And then any 3 specifically what you can remember. Because 3 conversations afterwards? 4 again, if this is the last time you saw him. 4 MS. : No. 5 Just try to recall -- 5 MR. : No. Alright. Can you 6 MS. : Remember it. 6 just briefly explain the process of people 7 MR. : -- what it is he said. 7 entering and exiting the SHU? 8 MS. : I remember he put his hand up. 8 MS. : There's double doors. 9 And he asked about the CPAP machine to be 9 MR. Okay. 10 plugged in. That's it. 10 MS. : And we open the doors to let 11 MR. Do you remember his 11 the person in. 12 words? Like -- 12 MR. : So is there somebody that 13 MS. : NO. 13 they have to go through an outer door first to 14 MR. • -- did he say, "CPAP 14 get to your door? 15 machine." Or, "Can you plug this in for me?" 15 MS. IIII: Yeah. There's two doors. And 16 MS. IIII: I don't remember how he said 16 so they come in the first door, then the second 17 it, but basically he asked for it to be plugged 17 door, and then in the SHU. 18 in. But I don't remember exactly what he said 18 MR. : How do they get into the 19 or how he said it. 19 first door? 20 MR. : Alright. So at that 20 MS. We open the door. 21 point you went and plugged it in? 21 MR. Not the control center? 22 MS. : Yes. 22 MS. 23 MR. : Alright. And that's like 23 MR. • So you're able to - from 24 a cord that runs like under his cell door or 24 the first door before they get to your door, 25 something? 25 you open both doors? 159 160 1 MS. : Yes. 1 MS. : Yes. 2 MR. : Okay. So the control 2 MR. And you have control over 3 center, they don't call for it first and the 3 both doors? 4 control center pops the first door? And then 4 MS. Yes. 5 you have ke s for the second door? 5 MR. Alright. Does the 6 MS. : No. 6 operations center also have control over that 7 MR. : Alright. Okay. So I'm 7 outer door? 8 going to stop talking. You tell me exactly how 8 MS. IIII: I don't know. I don't think 9 they do it. Somebody knock or they call or 9 for SHU don't know. 10 buzz or what? 10 MR. : Alright. Anytime people 11 MS. IIII: Somebody knocks. Or sometimes 11 enter and exit, you've always - 12 they use the radio. And then we go to the door 12 MS. • The person on the inside yes. 13 and open the door. 13 MR. • For both doors. 14 MR. : So do you have a - from 14 MS. Yes. 15 your desk is there a buzz to -? 15 MR. Alright. And that's the 16 MS. IIII: No. You've got to open it with 16 same as when they leave? 17 a key. 17 MS. : Yes. 18 MR. . The initial outer door? 18 MR. So after they leave that 19 MS. Both doors. 19 second outer door -- 20 MR. So you go, you open the 20 MS. : Mm-hmm. 21 inner door to you and then go to the -- 21 MR. -- you go, you lock that 22 MS. Door. 22 manually - 23 MR. outer door -- 23 MS. : Mm-hmm. 24 MS. 24 MR. -- and then lock the 25 MR. - and do the second? 25 other one? EFTA00117682 161 162 1 MS. : Yeah. 1 you said between 9:00 p.m. and 12:00 a.m. I 2 MR. : Manually? Both manually 2 don't remember exactly when made her 3 from the SHU? 3 rounds, but -. 4 MS. IIII: If that one I think - the outer 4 MR. : Okay. would have 5 one like once you Dull it in it locks. 5 showed up at one time or another though? 6 MR. : Okay. Which one is that? 6 MS. : Yes. 7 MS. outer door. 7 MR. : Do you remember that 8 MR. : The outer door. And who 8 conversation when she showed up? 9 entered and exited the SHU on August 9, 2019 9 MS. No. 10 between let's say for the first shift: 9:00 10 MR. : Did she talk to you about 11 p.m. and 12:00 p.m. So if you have to open up 11 anything? 12 two doors, I'm assuming that's kind of a 12 MS. 13 process and there aren't many of you in there. 13 MR. : Did you specifically 14 MS. Lieutenant 14 speak to her at all? 15 MR. : Lieutenant 15 MS. I mean I said hey. 16 MS. No you said on the first shift? 16 MR. : Just hey. 17 MR. : First shift. From 9:00 17 MR. : What's up. 18 p.m. to 12:00 a.m. - 12:00 a.m. sorry. 18 MR. : Okay. And who allowed 19 MS. : From - I don't know. 19 to enter and exit? 20 MR. : So it would be the people 20 MS. I don't remember that. 21 that were in there. Correct? Would that be 21 MR. : Alright. Do you know who 22 and 22 - when and left, who allowed 23 MS. . And me. 23 them to leave? 24 MR. : And you. Anyone else? 24 MS. Mm. I don't remember that. 25 MS. I'm trying to remember because 25 MR. You don't remember that. 163 164 1 MS. 1 MR. Alright. And then when 2 MR. : Alright. And who was 2 he leaves 10 South to come to the SHU, do you 3 present with you in the SHU after midnight? 3 also have to allow him access into the SHU? Or 4 From approximately 6:30, 6:33 a.m. on August 4 is he able to get into the SHU by himself? 5 10, 2019? 5 MS. : Coming down from 10 South? 6 MS. : Me and 6 MR. Mm-hmm. 7 MR. Anyone else? 7 MS. relieved him. And then 8 MS. 8 he came down and went. 9 MR. Visitors? 9 MR. relieved the 10 MS. Lieutenant 10 person on 10 South? 11 MR. At around what time did 11 MS. : Yes. 12 she visit? 12 MR. So wasn't assigned 13 MS. : I don't remember the time. 13 to the SHU? He was assigned to 10 South. 14 MR. Does around 4:00 a.m. 14 MS. He was assigned to the SHU. 15 sound right? 15 MR. : So can you just explain 16 MS. IIII: I don't remember the time. To 16 what you mean by relieved? You mean he relived 17 be honest. 17 him temporarily while he got food? 18 MR. Okay. Was there another 18 MS. IIII: He called and said that the 19 officer that you remember around like 5:30 a.m. 19 lieutenant said that he could go get his food. 20 visiting? 20 So can one of us relieve him to go get his 21 MS. IIII: No. The officer upstairs - he 21 food. So went, relieved him, and he 22 left to go et food and come back. 22 came down and he went out to get his food. 23 MR. : So would that be 10 23 MR. : Okay. So you were the 24 South? 24 only person in the SHU at that point? 25 MS. IIII: Yes. 25 MS. IIII: Downstairs I guess. EFTA00117683 165 166 1 MR. r: And MI'? 1 for me to relive to get food? But 2 MS. : As far as the time, I don't 2 another lieutenant came on, so he said well I 3 know. 3 don't know if the lieutenant before said that. 4 MR. : Okay. So are they the 4 So I said okay and I hung the phone up. And 5 only two people that were in the SHU between -? 5 said I'll go relieve him so he could go 6 MR. FOY: Do yaLynt the context of when 6 get his food. 7 that request from IIIII to get coverage to get 7 MR. Okay. And I do 8 food? Because there's a context there. 8 apologize. You counted with him? 9 MR. : Sure. I mean. 9 MS. : Yes. 10 MR. FOY: Alright. So I want you to talk 10 MR. And you're talking about 11 about what you were doing before when he asked 11 the individual in 10 South. 12 you. Right. 12 MS. : Yes. 13 MS. IIII: Okay. 13 MR. And then you came back to 14 MR. FOY: You remember what you were 14 the SHU and then relieved him? 15 doing, rigtti 15 MS. : Yes. 16 MS. IIII: I remember what I was doing but 16 MR. Um. 17 I -. 17 MS. : But I don't remember if it was 18 MR. FOY: This is a three event, there's a 18 at the 3:00 or the 5:00. I don't remember 19 five event and then -. 19 which one. 20 MS. •: Oh! Like I counted with 20 MR. : Alright. And I do 21 upstairs at that time. And when I came back 21 apologize. I just want to make sure I have 22 downstairs, he called and he said that the 22 this clear. So when you went up at either 3:00 23 lieutenant said to relive him to get food. I 23 or 5:00, and I'm assuming it was 5:00, you 24 didn't believe him, so I called the 24 helped him count. And at that point he's - 25 lieutenant's office. And I said, did you say 25 when he said he wanted to go get food? 167 168 1 MS. IIII: When I came back downstairs he 1 schedule, can you tell me what time came 2 called. 2 on? 3 MR. Oh so not while you were 3 MS. On here it says 8:00 to 4:00. 4 doing the count. 4 MR. Are you looking at 8/10 - 5 MS. : No. 5 August 10th? 6 MR. : So you left. 6 MS. IIII: Yes. But it was before that. 7 MS. Came back downstairs. 7 It was (Indiscernible *02:00:18). 8 MR. : He called and said I just 8 MR. : Oh, sorry. So there's a 9 spoke to the lieutenant? 9 little caveat there. So the officers' times 10 MS. IIII: He said the lieutenant said for 10 are two hours before, do he would have started 11 when you had to relieve me to get food. 11 at 6:00. But I believe he actually - his would 12 MR. And then you said you 12 be 6:00 to 2:00 as opposed to 8:00 to 4:00 like 13 verified that? 13 the roster. So it's confusing. Um, they 14 MS. : I called. 14 allowed the lieutenants to come in two hours 15 MR. : The lieutenant? 15 earlier and end their shift two earlier. 16 MS. : Yes. 16 MS. : Hm. 17 MR. : Was this both 17 MR. : But I do believe he 18 both times? Was that who it was? 18 arrived at 5:30. So this would have been 19 MS. IIII: No. When I called, Lieutenant 19 probably you said - you said there were two 20 answered and he said he didn't know. 20 different lieutenants you spoke to. So I'm 21 MR. : SO it was Lieutenant 21 assuming one - 22 IIII. So this would have been at like 5:30 22 MS. IIII: No I spoke to Lieutenant , 23 then probabl ? 23 asking did he say for me to relive to 24 MS. : Probably. 24 get the food. So he said he doesn't know. 25 MR. : Okay. If you look at the 25 Maybe Lieutenant told him. But I EFTA00117684 169 170 1 didn't speak to her. 1 2 MR. : Sure. And what I'm - I 2 S. : Yes. 3 think that he started around S:30. So he 3 MR. Okay. No one else? 4 probably called around like 5:28, spoke with 4 MS. 5 lieutenant - and then you probably called 5 MR. Okay. When you were in 6 shortly after 5:30. Does that sound like 6 the SHU with was there a hierarchy 7 potentiall could have happened? 7 then? 8 MS. : Could have. Yes. 8 MS. IIII: On the paper it says that I was 9 MR. : Okay. So does around 9 the number one. 10 that 5:30 timeframe right before you know you 10 MR. And would that be - I 11 were going to feed the inmates. Does that 11 know you said a lot of time it's because you're 12 sound about right? 12 new, you would ask other people for guidance. 13 MS. : Ri ht. 13 Is that because that was your quarterly post? 14 MR. : Okay. So the 5:00 a.m. 14 MS. : Yes. The post. 15 count. That (Indiscernible *02:01:18)? 15 MR. And was in there 16 MS. : Ri ht. 16 as an overtime post? 17 MR. : Okay. So he is - and I'm 17 MS. : Yes. 18 sorry, who was in the 10 South? 18 MR. Not his regular 19 MS. 16r. 19 assignment? 20 MR. It was and then who 20 MS. : Correct. 21 else visited the SHU where Epstein was housed 21 MR. Okay. So on paper, you 22 between 12:00 a.m. and 6:30? 22 were in charge. But in practice, you're both 23 MS. : Lieutenant 23 the same. 24 MR. : Are they the only two 24 MS. IIII: In practice, I ask because I 25 people that visited the SHU aside from you and 25 don't know. So even if I'm in charge, I don't 171 172 1 know everything because I'm new. So I ask the 1 MS. : Correct. 2 senior officer. 2 MR. What was the purpose of 3 MR. : Okay. Do.remember 3 visit? 4 any conversations you had with that 4 MS. To conduct a round. 5 night? 5 MR. Okay. And what is she 6 MS. : As far as -? 6 required to do during a round? 7 MR. : Just were you conversing? 7 MS. : I don't know. 8 While you were there? Just the two of you? 8 MR. Are you aware if she was 9 MS. : I'm not -. 9 supposed to conduct a count with you during her 10 MR. : I'm not asking for what 10 round? Or -? 11 conversations at this point. I'm just saying 11 MS. IIII: She's not supposed to conduct 12 were you talking to one another? 12 the count. But I don't know how she's supposed 13 MS. : No not really. 13 to conduct her rounds. 14 MR. : You guys didn't really 14 MR. : So do you understand if 15 communicate or talk? 15 her round is at a round of her staff members? 16 MS. : No. 16 Or is it also she's supposed to do anything 17 MR. Okay. Do you remember 17 with inmates when she does rounds? 18 any conversations with regard to Epstein at 18 MS. : I don't know. 19 all? 19 MR. : You don't know. And do 20 MS. No. 20 you remember when she entered and exited the 21 MR. • No. Alright. So it's 21 SHU who let her in and out? 22 just you two, you said , and 22 MS. : I did. 23 IIII. The only four people from that - those 23 MR. Both times? Both in and 24 periods when you started your shift at 12:00 24 out? 25 a.m. to 6:30? 25 MS. IIII: Yes. EFTA00117685 173 174 1 MR. : Okay. And then what 1 MS. : Who Lieutenant 2 about when departed the SHU? Who let him 2 MR. : Was their presence in the 3 in and out? 3 SHU authorized? 4 MS. : That I don't remember. 4 MS. . Yes. 5 MR. : Would it be -? 5 MR. Was it justified. And 6 MS. : But it probably would have been 6 did you see them the entire time that they were 7 me. 7 actually in the SHU? 8 MR. -- you since 8 MS. : Yes. 9 relived him -- 9 MR. Was there anything out of 10 MS. Ri ht. Went upstairs. 10 the ordinar 11 MR. -- Correct? 11 MS. 12 MS. Yes. 12 MR. No. Any - either of them 13 MR. I would think went 13 have any conversations about Epstein? 14 up there then you probably would have -- 14 MS. : No. 15 MS. : Let them out. Mm-hmm. 15 MR. : And you say 16 MR. Okay. And both with 16 was the o erations lieutenant on August 10th? 17 and r, you verified that that 17 MS. : Yes. 18 those doors were shut and sealed? 18 MR. . Did you have any 19 MS. : Yes. 19 conversations with her on the phone? 20 MR. : And no one else got in 20 MS. : No. 21 and out between those times? 21 MR. : That you recall? No. 22 MS. : No. 22 What about like when you guys would call in 23 MR. And were they - those two 23 counts? 24 individuals authorized visitors - and 24 MS. IIII: I don't remember who took the 25 authorized visits - within the SHU? 25 count, but when I got called control to give 175 176 1 the count, I don't remember if it was her that 1 2 took the count. But. 2 MS. IIII: The lieutenant that came on in 3 MR. : Okay. So you don't 3 the morniii i 4 recall any other conversations with 4 MR. : Okay. And he started - 5 aside from when she visited at 4:00 to 5 we believe around 5:30 based upon what we just 6 check in? 6 talked about. 7 MS. : Correct. 7 MS. : Correct. 8 MR. And she never provided 8 MR. : Okay, 5:30 a.m. on August 9 any special instructions? 9 10th. And during that conversation, you said 10 MS. No. 10 that you called Lieutenant IIII. What all was 11 MR. About anything during 11 spoken about during that call? 12 that shift? 12 MS. IIII: If I should relive to get 13 MS. : 13 food. If that's what he said. 14 MR. • She never told - 14 MR. Any discussion about 15 never told you that Epstein was 15 inmates? 16 required to have a cellmate? 16 MS. 17 MS. No. 17 MR. Any discussion about 18 MR. Didn't ask about or 18 Epstein? 19 anything? 19 MS. 20 MS. 20 MR. No. He didn't' provide 21 MR. : Or about a new cellmate 21 any special instructions or ask about anything 22 being place in? 22 about your shift? 23 MS. 23 MS. No 24 MR. Alright. And we just 24 MR. About him coming on? 25 briefly mentioned that who was Lieutenant 25 MS. : EFTA00117686 177 178 1 MR. No. Do you remember if 1 happened where like an inmate was released when 2 the control center, R&D, or anyone else called 2 I'm there. 3 the SHU on August 9th or 10th during your two 3 MR. : So from 4:00 p.m. on 4 shifts? About Epstein's cellmate leaving? 4 August 9th, you don't recall that call coming 5 MS. IIII: I don't know. If they did, 5 in -- 6 they didn't s eak to me. 6 MS. . 0. 7 MR. : You didn't speak with 7 MR. : -- or a discussion 8 anybody? 8 happening -- 9 MS. 9 MS. : Not to me. 10 MR. R&D or anyone else?› 10 MR. -- about not coming 11 MS. 11 back? 12 MR. • If an inmate is removed 12 MS. : Not to me. No. 13 from the SHU and is released from the MCC, how 13 MR. And you didn't have a 14 does the SHU find out? 14 conversation with anybody at all? 15 MS. : I don't know. 15 MS. : No e. 16 MR. : You don't know? 16 MR. : And you don't know if 17 MS. 17 control or R&D or anybody spoke with anyone 18 MR. Has that ever happened to 18 else? 19 you before? 19 MS. . I don't know. 20 MS. : Where an inmate had gone? No. 20 MR. Even if they didn't 21 MR. • When an inmate goes to 21 discuss the details of it. You didn't overhear 22 court or something and then is released? 22 that conversation? 23 MS. IIII: But I don't -. If that 23 MS. : No. 24 happens, like I'll give the phone to the senior 24 MR. So what is your 25 officer because I don't know. But that never 25 understanding? If is released on August 179 180 1 9th from the SHU. Epstein is required to have 1 MS. : I don't know. 2 a cellmate. What should have happened? 2 MR. : Again, no conversations 3 MS. IIII: I don't know what should have 3 at all with -? 4 happened because when I came in at 4:00, the 4 MS. : None. 5 cell was empty. So I don't know what should 5 MR. : He's gone. No? Um and 6 have happened. Epstein came back and went to 6 you don't remember him being removed from the 7 his cell. I don't know where is or if 7 roster list so when you're doing your rounds 8 he's coming back. So I don't know what should 8 and your counts. 9 have happened. 9 MS. : N 10 MR. : Okay. So if an inmate is 10 MR. You know how many are 11 required to have a cellmate, such as Epstein, 11 supposed to be counting. 12 when the cellmate -. Sorry, I don't know if I 12 MS. : No. 13 just misspoke. If Epstein was required to have 13 MR. : Alright. We're just 14 a cellmate, as Epstein was, after his cellmate 14 going to talk a little bit about counts and 15 departs, which was , do you know if 15 rounds. According to you, what is a cell count 16 there's a - how long it should take for him to 16 and you have it in front of you if you need to 17 get replaced? 17 refer to the policy. But what is your 18 MS. Oh. I don't know. 18 understanding of a cell count? Or sorry, an 19 MR. You don't know that? 19 inmate count. 20 MS. 20 MS. IIII: You count every inmate to make 21 MR. Do you know who the 21 sure thatiiiiiiiiiilive. 22 decision-makers would be on that? 22 MR. : To make sure that they're 23 MS. : I don't know. 23 alive? And accounted for? 24 MR. : Do you know if you were 24 MS. : Yes. 25 authorized to assign Epstein a cellmate? 25 MR. Alright. And can you EFTA00117687 181 182 1 just explain the process? 1 move. 2 MS. IIII: The first officer goes down and 2 MR. Do you have to like talk 3 counts. And then the second officer goes down 3 to them? Make sure they're responsive or 4 and counts. And we confirm the numbers. 4 anything? 5 MR. : Okay. And prior to 5 MS. IIII: Or you could see them 6 confirming the numbers, do you tell the other 6 breathing. 7 officer how many you counted? 7 MR. : Just as long as you see 8 MS. : No. 8 some life. Okay. So what are the requirements 9 MR. : Alright. So you get your 9 in the SHU on how often is a count conducted 10 number, then another officer goes down, gets 10 for counts? 11 their number. 11 MS. IIII: Counts is at 4:00. I mean it's 12 MS. And when they come back. 12 been a long time. I really don't remember. 13 MR. And is that tier by tier 13 But I think 4:00, 10:00, 12:00, 3:00, and 5:00. 14 or do you 14 MR. : Okay. So 4:00 p.m., 15 MS. Yes. Tier by tier. 15 10:00 p.m., 12:00 a.m., 3:00 a.m., and 5:00 16 MR. Tier by tier. Just one 16 a.m.? 17 person stands outside while the other person -- 17 MS. : Yes. 18 MS. : Yes. 18 MR. : And is that every day or 19 MR. -- goes down range and 19 is it Monda through Friday? Do you know? 20 counts the inmates? 20 MS. : Every day. 21 MS. : Yes. 21 MR. Every day. And you're 22 MR. So do you have to like 22 just making sure they're alive. You don't 23 see the person moving, see - what do you need 23 actually have to speak with them? 24 to do wheLLysiu're doing that count? 24 MS. : No you don't. 25 MS. IIII: You need to see the prisoner 25 MR. Okay. And what's the 183 184 1 difference? What's a round? 1 the door to make sure that CO is okay? 2 MS. IIII: I mean the round you're walking 2 MS. : Yes. 3 down the tier basically checking to see if 3 MR. : Okay. So is that the 4 they're okay. But you're not counting. You're 4 difference then? 5 just checiiiiiiiiiike sure. 5 MS. IIII: Between the counts and the 6 MR. : So you're doing the same 6 rounds. Yes. 7 thing you're just not counting -- 7 MR. Only one CO is required 8 MS. : Counting. 8 and that's er your understanding of policy. 9 MR. : -- the inmates? Alright. 9 MS. : Yes. 10 So you're making sure that they're okay and 10 MR. Okay. And during a 11 they're alive. But you're not just -- 11 round, do ou have to speak with the inmates? 12 MS. Counting. 12 MS. : You don't have to. 13 MR. -- actually making sure 13 MR. No? But on both 14 they're -. 14 instances both COs have to be present. You're 15 MS. IIII: Yeah like you don't need a 15 just saying with rounds, only one CO actually 16 number. 16 needs to o down. 17 MR. But one CO goes down, 17 MS. : Co down range. Yeah. 18 checks, and then does the other one? Or does 18 MR. : You said the purpose is 19 there onl need to be one? 19 to make sure they're okay and they're alive? 20 MS. : Well it's one. 20 MS. : Yes. 21 MR. : So both don't need to 21 MR. : And are they - are the 22 actually do that? 22 counts and the rounds both documented? 23 MS. : No. 23 MS. : Yes. 24 MR. Alright. So just one CO 24 MR. : And do you have to sign 25 goes down. Does the other CO have to remain at 25 documents when you conduct counts and rounds? EFTA00117688 185 186 1 MS. : Yes. 1 cell counts and the rounds so that there's no 2 MR. : Okay. Now if you and 2 misunderstanding. So this first one is going 3 another officer like on the case of when you 3 to be the 8/9/2019 for the 30-minute check 4 work 12:00 a.m. to 8:00 a.m. If you and 4 sheet. And the other one is going to be 5 another officer are the only ones assigned to 5 8/10/2019. Can you just let me know if you see 6 the SHU, are you both just as responsible for 6 your handwriting and initials on these two 7 documenting the round sheets and the count 7 documents? 8 slips? So if you're the one documenting all 8 MS. : Yes. 9 the rounds for the 30-minute rounds, is your 9 MR. Okay. Do you see it on 10 documentation - does that also carry weight for 10 both? 11 the other person that's with you? Are you 11 MS. : Yes. 12 signing for both of you? 12 MR. Okay. And I guess we'll 13 MS. IIII: I don't think so because it's 13 first discuss August 9th. Where do you see it 14 just my si nature. 14 and from what time to what time? 15 MR. : So you would take 15 MS. : From 4:00 to 11:30. 16 responsibility for the cell count rather than 16 MR. : And are you ever one of 17 saying that you're both responsible? Or the 17 them? 18 round -? 18 MS. : Yes. 19 MS. IIII: Well the rounds and the counts 19 MR. : Okay. So every 30 20 have to be done with two people. 20 minutes, you have your initials. And you wrote 21 MR. : But -. 21 those. That's actually your initials on that 22 MS. : But on the -. 22 one? 23 MR. : Let me just show you so 23 MS. : Yes. 24 you know what I'm talking about. I'm just 24 MR. : And what about on August 25 going to show you for August 9th and 10th the 25 10, 2019? 187 188 1 MS. : Yes. 1 round every 30 minutes. Like when you go down 2 MR. : Okay. So what I'm asking 2 to give out toilet paper, that's counted as a 3 here is by you placing those initials is that 3 round. To pick up trays, it's counted as a 4 now fall on you? Or if you're only two people 4 round. To give out food, that's counted as a 5 in there like on August 10th -- 5 round. But and then you fill it out either 6 MS. : Mm-hmm. 6 after or before. You're not sitting like every 7 MR. : -- are you basically 7 30 minutes like filling it out. 8 signing for both people? Or do you think 8 MR. : Okay. And you're - you 9 you're only signing for yourself there avowing 9 said you do it a lot of times prior to actually 10 that the round was conducted. 10 conductin the round? 11 MS. : I don't know. 11 MS. : Yes. 12 MR. : Okay. 12 MR. : Alright. And with 13 MS. : I guess because like you're 13 rounds, do you call anybody with that 14 trying to say if the rounds have to be 14 information? 15 conducted with two people, when I sign it would 15 MS. • No. 16 be -. I don't know. 16 MR. : What's done with the 17 MR. : Okay. But you did sign 17 sheet? Is it at the end of the shift something 18 and certif that they were conducted? 18 done with it? Are they logged into the BOP 19 MS. : Yes. 19 database at all? What happens with those 20 MR. : Okay. And what do you do 20 sheets? 21 with the rounds - the sheets - how are they 21 MS. IIII: I don't know. Because it's 22 maintained? 22 left on the table. I don't know what they do 23 MS. IIII: Well I usually fill it out like 23 with them. 24 prior in hopes to conduct the round. Like when 24 MR. : So as far as you know, 25 I work in the SHU, I've never actually done the 25 you just fill it out and you leave it there? EFTA00117689 189 190 1 MS. : Yes. 1 ones? 2 MR. : Okay. You don't ever 2 MS. Which ones. 3 provide it to anyone. 3 MR. : Okay. And do you 4 MS. No. 4 remember speaking with lieutenants when you're 5 MR. : And you don't ever go 5 there or with regular officers assigned to the 6 into any BOP database and enter those rounds. 6 control center? 7 MS. • No. 7 MS. IIII: I don't remember who I spoke 8 MR. : Do you know if someone 8 to. 9 else does? 9 MR. : You don't remember. Well 10 MS. I don't know. 10 with the count slips, you said you just leave 11 MR. : You don't know. Okay. 11 those round slips on the table. When you're 12 What about with counts? Do you call people 12 done - when you do the count slips, what do you 13 after you do the counts? 13 do with those slips? 14 MS. Yes. Control. 14 MS. IIII: We did the same thing. We 15 MR. : You call control? 15 filled them out before. 16 MS. Yes. 16 MR. : Before you actually 17 MR. : And do you recall on 17 conduct the count before you filled them out. 18 August 9th or August 10th you called - did you 18 MS. : Yes. 19 call anyone with those numbers? 19 MR. : So before actually even 20 MS. : Yes. 20 getting the number, you fill out the number? 21 MR. : Okay. And do you 21 MS. : Because we know the number. 22 remember which counts you called? 22 MR. : Okay. So do you then 23 MS. : I don't remember which. 23 call somebod with the number? 24 MR. : You know you did some of 24 MS. : Yes. 25 them you just don't remember specifically which 25 MR. : Who do you call? 191 192 1 MS. : Control. 1 comes in though? 2 MR. : Control? Okay. And you 2 MS. IIII: They didn't that day. I don't 3 provide them the number that you wrote on that 3 know if they ever come in, but they didn't 4 document? 4 (Indiscernible *02:17:51). 5 MS. : Yes. 5 MR. : Okay. On August 9, 2019, 6 MR. : Sorry, we did this. My 6 you said you filled all that out. What rounds 7 question was supposed to be what do you do with 7 did you conduct during your shift on August 9, 8 the physical pieces of paper? 8 2019? 9 MS. IIII: Stick it in the door and then 9 MS. IIII: That's hard for me to tell 10 internal takes it. 10 because I didn't conduct it every 30 minutes. 11 MR. So no one actually comes 11 It was give out food, pick up the trays, give 12 in -- 12 out toilet paper, go down. So those were the 13 MS. : No. 13 rounds that I conducted. Bu it don't. 14 MR. : -- to the SHU? You stick 14 MR. : So you were counting a 15 it in what door? 15 round as j21/ doing something with an inmate? 16 MS. : The outer door. 16 MS. IIII: Yes because I actually 17 MR. : So you open up the 17 physicall walked. 18 interior - the inner door and then you go to 18 MR. Every tier all six? 19 the outer door and you -- 19 MS. 20 MS. : Stick it in there. 20 MR. Is there six tiers in the 21 MR. • -- there's like a special 21 SHU? 22 slot for it? 22 MS. : Yes. 23 MS. IIII: Not a slot. It's just between 23 MR. : Okay. 24 the door. 24 MR. : Two floors - two levels. 25 MR. Okay. Internal never 25 MS. : Yes. Yes. EFTA00117690 193 194 1 MR. So when you do these 1 MR. FOY: When did you write the times 2 rounds, when you would go down range and handle 2 down? 3 an inmate or give something to an inmate, you 3 MS. IIII: Before. 4 would then also do all six? 4 MR. FOY: Alright. So when you did a 5 MS. : Yes. 5 round to take toilet paper, did you change the 6 MR. : Alright. So about how 6 time to reflect that particular round? Did you 7 often -. Let's ask it a different way. About 7 do anything_2ith the paperwork to change -- 8 how many of those didn't you do on August 9th? 8 MS. IIII: No. 9 MS. IIII: I don't know. I can't give a 9 MR. FOY: -- the actual time? 10 number of how much I didn't do. But. 10 MS. : No. 11 MR. : Are some of those that 11 MR. : And why did you do that? 12 were documented, were they not done? 12 Is it because of the requirement? 13 MS. : Yes. 13 MS. : kph did I fill -? 14 MR. : Alright. So you didn't 14 MR. : Why did you fill these 15 do some of them. You just don't know which -- 15 ahead of time? Were you just trying to stay on 16 MS. : Ones. 16 top of what the actual requirement was to 17 MR. -- ones? 17 conduct a 30-minute round was? 18 MS. Ri ht. 18 MS. IIII: I mean I don't know why I did 19 MR. Alright. And -. Okay. 19 it. I juiiiiiiiiiidid it that way. 20 MR. FOY: Let me just say to help clarify. 20 MR. : Did someone train you to 21 MR. Absolutely. 21 do it that way? 22 MR. FOY: The times that you wrote down. 22 MS. IIII: I mean I've seen it done that 23 MS. IIII: Okay. 23 way before - after. And three's people that 24 MR. FOY: Right? 24 actually do it as they do it. It's been done 25 MS. Mm-hmm. 25 all three different ways. 195 196 1 MR. Some do it before, some 1 MS. : Yes. 2 do it durin some do it after? 2 MR. : And that's - this is the 3 MS. Yes. 3 under-oath thing. We've got to make sure 4 MR. . And just this instance 4 because the video is and all that kind of 5 you did it all before? 5 stuff. 6 MS. : Yes. 6 MS. : Yes. 7 MR. : Alright. And some - at 7 MR. : That's your 8 least some of them. Would you say the majority 8 understandin 9 were not done or were done? 9 MS. 10 MS. : On the 9th? Majority was done. 10 MR. Alright. That you're 11 MR. : You believe the majority. 11 actually checking every door. 12 Now I know we're doing estimates because you 12 MS. : Yes. 13 don't know exactly. You think like 51% or do 13 MR. : And when you go give that 14 you think -? 14 one-person toilet paper or whatever, you're 15 MS. : I don't know. 15 actually looking at all the different doors? 16 MR. You don't know. 16 MR. FOY: Can we take a break real quick? 17 MS. 17 Because I need to take a break. 18 MR. . Alright. But again, for 18 MR. : Absolutely. 19 the ones that you did do, you're not just going 19 MR. FOY: ldiscernible *02:20:53) 20 down one tier. 20 MR. : Yeah-yeah. Absolutely. 21 MS. No 21 Alright. So it is currently 12:35 p.m. We are 22 MR. You're going down all six 22 going to take a quick break. [Whereupon, the 23 tiers? 23 above-entitled matter went off the record and 24 MS. : I'm doing all. 24 went back on the record.] The recorder is back 25 MR. : You are? 25 on. This is Senior Special Agent EFTA00117691 197 198 1 . It is 12:49 p.m. Ms. IIII, I 1 control the inner door. 2 remind you this is a voluntary interview and 2 MR. : Okay. And then just 3 you are under oath. 3 while we're going back. It's something I was 4 MS. : Mm-hmm. 4 probably going to follow-up on later. But 5 MR. : Alright. Is there 5 there's been a ton of questions of like you 6 anything that we wanted to revise before we 6 don't know. 7 continue? 7 MS. : Yes. 8 MR. FOY: Yeah. I want her to go back. 8 MR. I just want to remind you 9 This was from earlier about the double door. 9 - you did go to the Federal Law Enforcement 10 How they o erate. 10 Training Center -- 11 MR. : Okay. 11 MS. : Yes. 12 MR. FOY: I think there were some 12 MR. : -- where you were trained 13 unintentional inaccuracies on that. 13 as a correctional officer. And you also 14 MR. : Sure. 14 received this IF training which I think you 15 MR. FOY: That we clarified. So let's 15 said was like a two-week in-house training. 16 start with that first. 16 MS. : Yes. 17 MS. IIII: The outer door control pops the 17 MR. : Is that what that was? 18 outer door. I control the inner door. So the 18 As well as you received the annual training. 19 outer dooiliiiiiiii be opened by control. 19 And all this stuff that we're talking about 20 MR. : Okay. So we were talking 20 isn't like the real detailed stuff. This is 21 about like popping the -. It was just your 21 like you know conducting counts and rounds. 22 memory was foggy? 22 And the essential duties as a correctional 23 MS. IIII: I don't remember a lot of 23 officer. So I'm assuming you -. Is it safe to 24 stuff. But yeah. The outer door, you have to 24 assume that you received this training you know 25 call control to pop the 27 door. And we 25 during those trainings? I know you didn't go 199 200 1 to the SHU trainings. But not too far from 1 well you went to all these trainings. You 2 when this happened, you were only on for a 2 should know at least some of this stuff. So I 3 little over a year. And you conducted all 3 just wanted to try to get you to like think 4 three of those trainings. Correct? 4 back on your training. 5 MS. IIII: I was only on for a little 5 MS. : Mm-hmm. 6 under a year. The training that I received in 6 MR. : And your duties and your 7 Georgia is specific to camps and not 7 responsibilities when I'm asking these 8 necessarily high rises. And the in-house 8 questions just so you can really like think. 9 training, the roster reflects all these 9 Do I really now know or is that you know, did I 10 trainings but we didn't' actually receive all 10 know that these things should be done. Does 11 the training because sometimes there was nobody 11 that make sense? 12 to train us. 12 MS. : Correct. 13 MR. . Okay. 13 MR. And then um -. 14 MS. So when I say I don't know, I 14 MR. Can I say -? 15 don't know. 15 MR. Yes, please. 16 MR. Yeah, no. It's just 16 MR. : lust to clarify. I know you 17 almost every question. I feel like we've gone 17 might not have received some of the official 18 through 18 pages so far and so many of them are 18 trainings. Some of this stuff you might learn 19 19 along the wa 20 MS. ,cause I really -. 20 MS. : Mm-hmm. 21 MR. : -- like I don't know. 21 MR. : From your daily duties. 22 So. 22 MS. : Right. 23 MS. .eally don't know. 23 MR. : Like it's repetitive. Some 24 MR. : Alright. It's just 24 of the stuff that you do. So you might have 25 because you know people are going to say like 25 known this based on the fact that you've done EFTA00117692 201 202 1 it on a daily basis. So if you say I don't 1 tell you that I conducted rounds as I went to 2 know and you actually done it as part of your 2 go do something. But I can't give you a 3 daily duties, it kind of contradicts each 3 number. 4 other. 4 MR. : And I want to make sure 5 MS. I understand. 5 we understand too, if you're going down range 6 MR. : And I just had a question. 6 to give some inmate like toilet paper or 7 You mentioned the door. Was at any point in 7 something, that you're also at that time where 8 time - on the 9th, 10th or - was there a 8 you're saying you did a round, not just talking 9 practice to ever leave the doors propped open 9 about that tier, but all six tiers. 10 in the SHU? 10 MS. : Yes. 11 MS. 11 MR. : Alright. So you're going 12 MR. • Alright. I think my last 12 down to give somebody a toilet paper. At that 13 question, I just want to revisit it just to 13 point -- 14 make sure that we're of the same understanding. 14 MS. IIII: Because I'm giving toilet paper 15 So again when you're pre-populating all of 15 to everybod . 16 these rounds. Correct? 16 MR. : Alright. So you're not 17 MS. : Correct. 17 just addressing one inmate. 18 MR. : But you're saying you 18 MS. No. 19 believe you did more than 50% of the rounds 19 MR. You're saying when you're 20 that were listed. 20 giving ever body toilet paper. 21 MS. IIII: I can't give you a percentage - 21 MS. : Yes. 22 22 MR. So on August 9th -. 23 MR. : Sure. 23 MS. : When I'm giving food, I give 24 MS. I don't know how to 24 everybody food. When I'm collecting trays, I'm 25 put a percentage to a round. But I can only 25 collecting all the trays. I'm giving toilet 203 204 1 paper. 1 9th, you didn't conduct all the documented 2 MR. So aside from eh times 2 rounds. 3 you're now giving toilet paper and giving food 3 MS. : No. 4 and collecting trays, which are a handful of 4 MR. : But you did do some of 5 those times, granted. 5 them? 6 MS. : Mm-hmm. 6 MS. Yes. 7 MR. • Are you doing any other 7 MR. And you don't have a -- 8 rounds? 8 MS. A number. 9 MS. : Yes. And if somebody calls -. 9 MR. -- half or anything -- 10 MR. • On August 9th -- 10 MS. 11 MS. Yes. 11 MR. -- like that. Okay. 12 MR. • -- we're talking about. 12 MR. FOY: But I think the clear point is 13 MS. : On the 9th. If somebody calls 13 when she did it, it's not based on the times on 14 and asks for something, yes, I conduct a round. 14 the paper. 15 MR. And that's kind of what 15 MR. : Okay. 16 I'm getting at. You're - if you're handling 16 MR. S lit? So that doesn't match. 17 one specific inmate, because they called and 17 MR. : Alright. So -. 18 asked for something. You're then also 18 MR. FOY: The times she did it versus the 19 addressin the other five tiers? 19 time on the paper. Because that paper is done 20 MS. : Yes. 20 at the beginning of the shift. With the time 21 MR. • Okay. 21 already selected. 22 MS. Because usually when one calls, 22 MR. : Oh, are you filling out 23 everybody else hears and everybody wants 23 the entire aper at the beginning of the shift? 24 somethingiiiiiiiiiist do it. 24 MS. : Yes. 25 MR. : Alright. So on August 25 MR. : Oh! So you're not doing EFTA00117693 205 206 1 it every 30 minutes just prepopulating before 1 MS. : Yes. 2 you do the round. 2 MR. : Who else have you seen do 3 MR. FOY: Right. 3 that? 4 MS. : No. 4 MS. IIII: I mean I don't have a specific 5 MR. : You're going at the very 5 name, but I've seen it done. 6 beginning of the shift, filling everything out 6 MR. : Did anyone ever tell you 7 the -. 7 to do that? 8 MS. : Yes, sir. 8 MS. IIII: This is actually I think the 9 MR. : So that -. When did you 9 first time I've ever done the round sheets 10 fill out the August 9th round sheet? 10 because I've never actually done the round 11 MS. IIII: Like how the numbers are like 11 sheets in the SHU. But those two days were the 12 the round sheets before, like the times. So I 12 days that I've done the round sheets in the 13 just fill it out because that's what I've seen 13 SHU. 14 being done. Like it's filled out before or 14 MR. : So if this was your first 15 sometimes at the end after. So I fill it out 15 time doing a round sheet, did someone instruct 16 all before. 16 you on how to do it? 17 MR. : Okay. So you 17 MS. IIII: No because I just followed what 18 prepopulated that entire thing at the very 18 I seen. But I've worked with people before 19 beginning of your shift? 19 that was filling it out and that's how it's 20 MS. : Yes. 20 been done. 21 MR. : And then you just 21 MR. : And did you have 22 conducted rounds as needed? 22 discussions with them when you were -? 23 MS. • Yes. 23 MS. IIII: No. I never had a discussion 24 MR. Alright. And you've seen 24 about it. 25 people do that? 25 MR. So you just observed 207 208 1 people doin this? 1 MR. Yeah. 2 MS. : Yes. 2 MR. FOY: She followed. But like when you 3 MR. : But no one ever told you 3 look at the policy and now that we're here and 4 to do that? 4 we've had discussions. Okay. That's not how 5 MS. : No. 5 it's supposed to work. 6 MR. : And did you know that it 6 MR. : But at the time that 7 was wrong to do that? 7 you're filling this out on August 9th at the 8 MS. : No. 8 beginning of your shift saying that you 9 MR. : You didn't know that it 9 conducted these rounds at a time that they 10 was wrong to prepopulate the rounds you 10 weren't conducted yet. You had to have known 11 conducted when you weren't conducting those 11 that that wasn't -. Maybe you saw people doing 12 rounds? 12 the wrong thing, but you couldn't have possibly 13 MS. IIII: No. I mean if I'm putting the 13 thought that that was correct. 14 time on there saying that I conducted the round 14 MS. : Well I -. 15 at this time, and I didn't conduct the round at 15 MR. : Because you're falsely 16 this time, that's wrong. But I didn't think it 16 certifying that rounds are completed when you 17 was wrong to fill it out all before or after 17 didn't. There's times even that they're events 18 because that's how they do it. 18 in the future. 19 MR. : So that's a contradicting 19 MS. IIII: I understand but I didn't know 20 statement. You know that it's not right to 20 that. I just followed whatever I saw that was 21 conduct a round at the time that you conducted 21 being done. 22 it, but you didn't know that it was wrong to 22 MR. : I absolutely understand 23 (Indiscernible *02:28:16). 23 the defense that you said other people have 24 MR. FOY: She knows that now. But this is 24 done this and you're following their guidance. 25 the way it was done. 25 But you can't possibly think that it's okay to EFTA00117694 209 210 1 fill out certifications saying that you 1 that. 2 conducted rounds in the future that haven't 2 MR. : -- observed people. So 3 taken place and that you actually didn't do at 3 who did you -- 4 the same time. Is that something being lost in 4 MS. Because I never had -. 5 translation? Do you follow what I'm asking 5 MR. -- observe do that? 6 you? Do you think it's okay to sign on the 6 MS. I never had a conversation with 7 round sheet that you conducted a time -? 7 about filliac,tround sheets. 8 Conducted a round -? 8 MR. : Right. So if that's 9 MS. IIII: But it's the same thing as the 9 going to be the argument that you're doing it 10 end. Like if I do it all at the end at the 10 based upon your training and experience, I need 11 times that I'm putting, I'm not going to 11 to know more about this training and 12 remember all those times specifically. 12 experience. Who is it that you experienced do 13 MR. : Absolutely. I would also 13 this in the ast? 14 argue that anytime you're falsifying a record, 14 MS. : People that I've worked with. 15 you always know that that's wrong. 15 MR. : So I'd like you to think 16 MS. : So. But. I mean. 16 about alright, I know this because I saw that 17 MR. : So I do understand that 17 person do it. Who? 18 you're saying other people do it. And that's 18 MS. Um. 19 why I want to get into who else is doing this? 19 MR. : So you've witnessed 20 Who trained you on that? How do you know that 20 prepopulate or at the end of the shift? 21 was the way that things were done? So that's 21 MS. IIII: I don't remember exactly. But 22 where my question of who talked to you about 22 it's done either or the way. 23 it. You said no one actually spoke to you 23 MR. : Alright so you saw 24 about it. But you -- 24 and who else? 25 MS. IIII: No. I just seen people do 25 MS. IIII: 211 212 1 MR. , is that the SOS 1 MR. FOY: Oh. 2 2 MS. IIII: Yes. 3 MS. 3 MR. FOY: 4 MR. No. A different 4 MS. 5 What's - is a gentleman's name? 5 MR. one else aside from 6 MS. Yes. 6 those three 7 MR. • What's that person's name 7 MS. 8 - first name? 8 MR. 7 9 MS. : I don't know the first name. 9 MR. 10 MR. who worked in the 10 MR. ? Alright. So 11 SHU? 11 in the recollections of the three people that 12 MS. Yes. 12 you named what did you observe them do? 13 MR. : You mentioned before. 13 MS. •: Fill it out after or fill it 14 Is it 14 out before. 15 MS. Yes. 15 MR. And was that on numerous 16 MR. U: 16 occasions? 17 MS. Um. • 17 MS. : Yes. 18 MR. : Say that again? 18 MR. Alright. So during your 19 MS. 7 19 time in the SHU, which I think was from around 20 MR. It's like (Indiscernible 20 June 24, 2019 through August 10th, was it on 21 *02:32:40). 21 many of those days that you were working in the 22 MR. FOY: It's a first or last name? 22 SHU - this is how it was done? 23 MR. ? Is the first name 23 MS. : Yes. 24 7 24 MR. : Where the rounds weren't 25 MS. M: M. 25 conducted and they were prepopulated or EFTA00117695 213 214 1 populated at the end? 1 sheet out. No one actually directed you or 2 MS. : Yes. 2 instructed you that's how we do it, you just 3 MR. • And it was never spoken 3 saw people do it that way? 4 of? 4 MS. : Ri ht. 5 MS. : No. 5 MR. : Alright. And this goes 6 MR. : And you never asked? Hey 6 back to -. I understand - your attorney did 7 why are we you know certifying that we're 7 say that ou know now that it was wrong. 8 conducting rounds that we're not actually 8 MS. : Yeah. 9 conductin 9 MR. : But at the time, you 10 MS. I never asked. 10 thought it was okay to certify times that you 11 MR. . Never asked? 11 know you conducted rounds when they weren't 12 MS. 12 conducted? 13 MR. . And they never told you 13 MS. IIII: Because that's the culture of 14 to do that though? 14 it there. I didn't consider it as being like 15 MS. : Who? 15 I'm falsifying a time or a document. No I 16 MR. : No one ever told you that 16 didn't. 17 this is the way that it's done? 17 MR. : Is this something that's 18 MS. IIII: I mean that's the way that I've 18 addressed in training and policy? Hey when you 19 seen them do it. But no one ever -. 19 conduct a round, it's documented? At the time 20 MR. : You observed it. You saw 20 you conducted it. 21 that people did that. 21 MS. • No. 22 MS. IIII: Because I never asked so nobody 22 MR. So it's not in the policy 23 ever told me. But that's just what I saw. 23 that I provided for you? 24 MR. : So on August 9th, you 24 MS. IIII: I don't know if it's in the 25 believe that's the first time you filled the 25 policy. But in training, you're just told to 215 216 1 conduct rounds and counts. But if -. 1 you had to know that you shouldn't have done 2 MR. : And document it at the 2 it. 3 time it's been conducted. 3 MS. : But -. 4 MS. : And document it. 4 MR. You're saying that you're 5 MR. : Right. So it's a 5 doing it because that's how other people are 6 cultural - it's a culture of falsification of 6 doing it. But you're all doing it wrong. 7 records? 7 Correct? 8 MS. IIII: In MCC? Yes. Like the 8 MS. IIII: But -. But in a case like 9 lieutenant told me to sign I did SHU training 9 this, who am I telling because like -. 10 and I didn't. 10 MR. : I'm not asking you to 11 MR. Absolutely. There's a 11 tell anybod 12 lot of it eah. 12 MS. IIII: No-no-no. When I say telling, 13 MS. • Yeah. 13 I'm like okay. If it's -. Okay. I understand 14 MR. • So my point being is it 14 you're saying that I know that it's wrong. But 15 sounds like this is a cultural problem. 15 I'm saying like okay, like how the lieutenant. 16 MS. : Yes. 16 Like when you said to me, does she know that I 17 MR. : But you have to - as a 17 didn't do the training? And I said yes she 18 person who received a college degree. A person 18 knows that but she still told me to sign that. 19 that went to you know standard - conducted 19 MR. : Absolutely. 20 ethics training. You have to know that -. I 20 MS. : So again, I'm not going to 21 understand other people are doing it. And 21 think. Like I said, I'm not thinking of this 22 you're saying I'm going to do what they're 22 as like I'm falsifying a document. It's just 23 doing. But you have to know - you have to 23 the culture of MCC and I just followed. I'm 24 question like hey. I didn't conduct this 24 new. I don't know. I just lean on the senior 25 training. I didn't conduct those rounds. So 25 officer or the people that I'm working with for EFTA00117696 217 218 1 - to do what the do. 1 MS. : Yes. Irregular rounds. 2 MR. Okay. 2 MR. : Irregular rounds. 3 MS. Or to guide me so to speak. 3 Correct. So you know that you're supposed to 4 MR. Let's ask it this way. 4 do them ever 30 to 40 minutes. 5 Did you know that you were supposed to conduct 5 MS. : Yes. 6 rounds ever 30 minutes? 6 MR. Two rounds and hour. And 7 MS. : Yes. 7 those rounds are supposed to be documented. 8 MR. Yes. Did you know that 8 MS. : Yes. 9 those rounds that are supposed to be conducted 9 MR. On that sheet. 10 every 30 minutes are supposed to be documented 10 MS. On the sheet. 11 on that sheet? 11 MR. So obviously that leads 12 MS. . Yes. 12 to the training of they're supposed to be 13 MR. And they're supposed to 13 documented when you conduct the rounds. 14 be documented on the time that you conducted 14 Correct? 15 those rounds? 15 MS. : Okay. 16 MS. IIII: No. Because nobody documents 16 MR. So I'm - I do understand 17 it on the time. 17 that you're doing it because other people that 18 MR. I understand that that's 18 you just mentioned did it that way as well. 19 why you did it. But do you understand that in 19 You have to know that you were supposed to do 20 training, every 30 minutes and they're supposed 20 it the wa I just explained. Correct? 21 to be not as it's corrected, they're not 21 MS. : I know now. 22 supposed to be on the exact dot 30 minutes. 22 MR. : Well you had to know then 23 You're supposed to do it within like a 30- to 23 too because it's like you're supposed to do a 24 40-minute window. Correct? So that's not a 24 30-minute round and you've got to document when 25 regular occurrence? 25 you did the 30-minute round. Correct? 219 220 1 MS. IIII: I never seen nobody do that 1 MR. . Therefore, you knew that 2 that I've worked with. 2 what you were doing was false. Correct? 3 MR. • So you never saw 3 MS. IIII: As in putting the time and the 4 or do it that way? 4 time that I conducted the round. And I didn't 5 MS. : See like when -. 5 do that at that time. See again -- 6 MR. And hey -. If 6 MR. So you knew it -- 7 everybody's doing it wrong, obviously that's a 7 MS. -- with the time. 8 huge problem. 8 MR. -- that what you were 9 MS. IIII: No, but what I'm saying is like 9 writing in there wasn't true and accurate as 10 I'm not next to them. Like okay, let's say if 10 you wrote it. Correct? 11 they're doing the sign-in sheet, I'm not - 11 MS. : Correct. 12 that's wiiiiiiiie how you're saying 12 MR. : And the reason you did it 13 like if is turning a sign-in sheet, I 13 was because the people that you observed in 14 don't necessarily have to be next to him. I 14 there before did it that way. 15 could only tell you the people that I've seen. 15 MS. : Correct. 16 Do I don't know like I can't speak for 16 MR. : Is that correct? I think 17 everybody on this -. On there that I see. 17 that's how satisfies us. Any -?> So you knew 18 MR. : Right. But what I'm 18 it was wron you knew what you were -- 19 saying is you know that you need to conduct 30- 19 MS. : But -. 20 minute rounds. You know those rounds need to 20 MR. -- writing was wrong, but 21 be documented. You know those rounds need to 21 you did it because it's how they did it. 22 be documented on that sheet. 22 MS. IIII: Right. But didn't -. I'm not 23 MS. : Mm-hmm. 23 thinking it's wrong. Like specific to the 24 MR. Correct? 24 times because I've never seen it done every 30 25 MS. : Correct. 25 minutes - every 30 minutes - every 30 minutes. EFTA00117697 221 222 1 MR. Right. 1 you filled out a round sheet in the SHU. Prior 2 MS. I've never worked -. 2 to the SHU, before you got to the SHU, did you 3 MR. : So it's always been 3 fill out those round sheets? 4 falsified. Ever since you've been there, it's 4 MS. Prior to working in the SHU? 5 always been falsified record is what you're 5 MR. : in the SHU. Did you fill out 6 saying. 6 7 MS. IIII: That - at the times that I've 7 MS. IIII: On other units, we don't have 8 worked and the people that I've worked with, 8 um round sheets like this. 9 I've never seen it done every 30 minutes like 9 MR. : DO you have to conduct rounds 10 that. No. 10 in the other units? 11 MR. . Correct. 11 MS. IIII: Yes. But it's not documented 12 MS. I've never seen it. 12 on a round sheet. 13 MR. So you're trained on 13 MR. : But this was the first time 14 conducting 30-minute rounds and documenting 14 you would have to? 15 when the 30-minutes -. Your experience has 15 MS. IIII: In the SHU it's documented on 16 taught you that that's not how they do it 16 the sheet. 17 there. They always falsify those records and 17 MR. : Alright. So is it the 18 just put in whatever in order to satisfy the 18 first two times that you can recall 19 30-minute re ui rement. 19 documenting? Are we going to find other round 20 MS. : Correct. 20 sheets that -? 21 MR. Okay. 21 MS. IIII: The first two times that I can 22 MR. : Just one follow-up question. 22 recall -- 23 MR. Yep. 23 MR. These were the first two 24 MR. : You mentioned that was the 24 times these two times? 25 first time. Those two days were the first time 25 MS. IIII: -- that I recall documenting. 223 224 1 MR. Alright. And did you -? 1 and got mandated. So now she's the officer in 2 MR. FOY: You haven't gotten to this yet. 2 charge for the first time at midnight with a 3 You know, I'm to lay back -- 3 senior officer, even though he's really worked 4 MR. Absolutely. 4 there regularly. And he's not there for 5 MR. FOY: -- and let you do your thing. 5 guidance so to s eak. 6 MR. : Absolutely. 6 MR. Sure. 7 MR. FOY: But at some point you'll learn, 7 MS. : And you know. 8 she never worked midnight to 8:00 -- 8 MR. So this one -. This was 9 MR. : Yep. 9 your daily assignments and I see where it says 10 MR. FOY: -- a.m. before. Right? 10 you're relieved without pay for a great amount 11 MR. : And we never -. 11 of time up until -. It looks like 6/26/2019 12 MR. FOY: And there's a reason. 12 you were assigned SHU number three. And then 13 MR. : And we have that. Do you 13 through - what we're looking at is 8/10, SHU 14 want to give her a duty roster - her daily 14 number one. So if you want to reference this 15 assignment -- 15 on days that you worked or -- 16 MR. Sit. 16 MS. : Mm-hmm. 17 MR. -- roster so that she can 17 MR. • -- assignments you were 18 see -- 18 on. 19 MR. FOY: Ri ht. 19 MR. FOY: Where? 20 MR. : -- where she -? 20 MR. : That's that thing. So I 21 MR. FOY: So there were events in her 21 understand what you're saying is that this is 22 personal life. Because she used to do that I 22 your first time and she was the one in charge 23 come in mearli,oid being mandated. 23 and she wasn't having an officer in charge to 24 MR. : Sure. 24 confer with I guess. 25 MR. FOY: But she couldn't do it that day 25 MR. FOY: Right. EFTA00117698 225 226 1 MR. And that's why I'm 1 MCC way of doing things that she's assimilating 2 getting back to -- 2 to that's not the proper way. That what should 3 MR. FO tiiit. 3 happen - a person needs to have the strength to 4 MR. : -- the fact that she 4 step up apij@Litand be the -- 5 observed, you know, she knew that what she was 5 MR. IIIIIIIIII: Mm-hmm. 6 writing was false. But she did it because she 6 MR. FOY: -- whistleblower or whatever. 7 saw everybody else doing -- 7 No. She didn't do that. Right? 8 MR. Sit. 8 MR. And I can so appreciate 9 MR. : -- falsifying records. 9 that. 10 MR. FOY: So part of it is, right, and 10 MR. FOY: Ri ht. 11 you're not wrong when you say, "Well that's 11 MR. : And that's why I say this 12 falsification of documents." And all that. 12 is a cultural, institution problem 13 Right. And I can understand and can appreciate 13 MR. FOY: Right. 14 how it looks that way. 14 MS. : Mm-hmm. 15 MR. : Sure. 15 MR. : And I agree with that. 16 MR. FOY: Right. And I'm not - we're not 16 MR. FOY: Ri 17 disputing that. Okay. But I think there's 17 MR. IIIIIIIIII: And I'm saying this was 18 also another way. It's like well it's 18 wrong that she observed this. And those people 19 inaccuratiiiiiiiiii 19 that were doing that were absolutely wrong. 20 MR. : Mm-hmm. 20 MR. FO'i tight. 21 MR. FOY: But that's not committing a 21 MR. IIIIIIIIII: All I was trying to get 22 fraud to try to deceive the institution because 22 to is that we can all agree that that - you 23 I just want to collect a paycheck and not do my 23 know every 30 minutes is when the round is 24 job. It's not for those reasons. It's just 24 supposed to be entered in there. 25 because there's a BOP formal way and there's an 25 MR. FOY: So -. 227 228 1 MR. you know and she knew 1 where the rounds should have been. So they 2 that she was entering the wrong information 2 accurately reflected I suppose when they did. 3 when she did it. 3 But I think a lot more common is it's not that. 4 MR. FOY: We don't disagree. 4 MR. : Absolutely. 5 MR. : Sure. 5 MR. FOY: Right? So she followed the 6 MR. FOY: She understood I didn't really 6 strain. 7 do a 6:03 round or whatever. Right? 7 MR. : Absolutely. 8 MR. : Absolutely. 8 MR. FOY: She did not chart her own path 9 MR. FOY: But I don't know if she 9 which is with - you know, why she's got to take 10 experienced that as I'm falsifying records to 10 responsibilit for that part. 11 my job. 11 MR. : And that's also why we 12 MS. IIII: Mm-hmm. 12 discuss this isn't all about you. It's about 13 MR. Slit? 13 the institution. 14 MR. : Right. 14 MR. FOY: Yeah. Understood. 15 MR. FOY: Which she is in her mind doing 15 MS. : Mm-hmm. 16 is well we're supposed to do rounds. But no 16 MR. : And this seems like this 17 one ever really does them every 30 to 40 17 is an institutional problem. And that's awful 18 minutes. But you've got to fill out certain 18 that you're one year on and this is what you've 19 paperwork that's required. So you fill out the 19 observed -- 20 paperwork. Now I know from looking at the 20 MR. Slit. 21 discovery not every single officer did that. 21 MR. : -- this entire time. 22 Right? 22 MR. FOY: And I only say that because I 23 MR. Sure. 23 feel like - in watching your interaction, 24 MR. FOY: I saw in the discovery that 24 you're kind of talking past each other on your 25 there were people who - there would be blanks 25 focus on if it's the falsification knowing it's EFTA00117699 229 230 1 wrong. And she's like, well yeah, but I'm just 1 a little easier to address. 2 kind of doing. I'm not trying to commit a 2 MR. FO`i iiit. 3 crime. Like it wasn't like - and that's kind 3 MR. : So -. And we can jump 4 of been my pitch the whole time. She wasn't 4 right into that. 5 out to commit a crime. This isn't about hiding 5 FOY: 6 my behavior because )eff Epstein died. 6 MR. : So on August 10th, is 7 MR. : Mm-hmm. 7 that also in front of you? I can't remember at 8 MR. FOY: Right? It's all there. Right? 8 this point what I provided you. The round 9 Even the theory of the case is when asked what 9 sheet for August 10th. 10 happened. We messed up. Right? That's the 10 MR. FOY: The round sheet. 11 like they tell the truth. There's no deceit - 11 MS. Yeah. 12 deception -- 12 MR. : Did you conduct any 13 MR. : Mm-hmm. 13 rounds on Au ust 10th that are -- 14 MR. FOY: -- in frustrating the 14 MS. No I did not. 15 investigation or the response. Now we're here, 15 MR. -- not -. And did you 16 we're trying to clear it up. We understand the 16 also prepo ulate that? 17 job that you have. You know address some of 17 MS. Yes. 18 the specifics here, but it's a much broader 18 MR. Alright. So you knew 19 vision. So we're trying to bring light to that 19 everything you wrote in there - again, I 20 and she's doing the best she can to do it. I 20 understand that you said this is what you 21 think the issue is we're doing this almost two 21 observed. No one told you to do it this way 22 years later. Ri ht? 22 because you saw other people doing it this way. 23 MR. : Sure. 23 But you knew that you didn't conduct any rounds 24 MR. FOY: That's the problem. And -. 24 that you listed on that sheet. 25 MR. : And the next day might be 25 MS. IIII: Yes. 231 232 1 MR. Correct. And what about 1 triple. 2 cell counts? And I'm only trying to move past 2 MR. Okay. So he was doing a 3 because we have a lot more to get through. 3 triple shift? 4 MR. FOY: Mm-hmm. 4 MS. IIII: Yes. He worked three 5 MR. : But if there's something 5 consecutive shifts. 6 else we want to address on there. 6 MR. Okay. 7 MR. FOY: Yeah. No. We're good. 7 MS. : So I conducted the 10:00 by 8 MR. : So the cell counts. When 8 myself. 9 did you conduct cell counts - sorry, inmate 9 MR. : And you actually went 10 counts during your shift in the SHU on August 10 around and counted every inmate? 11 9, 2019? 11 MS. : Yes. 12 MS. : Oh, that's 9th? 12 MR. And we want to show the 13 MR. : August 9th. So we're 13 count sli 14 talking now the 4:00 p.m. and a 10:00 p.m. 14 MR. All of it? 15 MS. : 10:00. 15 MR. We'll start I guess with 16 MR. : Did you conduct those 16 just the August 9th because we don't want to 17 counts? 17 give her too many stuff. Alright. So what I'm 18 MS. : 10:00. 18 going to show you here is this first page is 19 MR. : lust 10:00? Not he 4:00 19 going to be like the institutional count. And 20 p.m.? 20 it's going to show you like ZA. Is ZA correct 21 MS. : Not at 4:00. 21 for the SHU? Do you know that that is what ZA 22 MR. : Now you do recall 22 stands for? 23 actually conducting the 10:00 as you're 23 MS. : I don't remember. 24 supposed to do it? 24 MR. Alright. So ZA is going 25 MS. IIII: No because my partner was on a 25 to be the number that's going to reflect for EFTA00117700 233 234 1 the SHU. And then I'll tell you what the total 1 MS. IIII: Okay. 2 number is in this count. On this page it'll 2 MS. GREGG: They match. This is all of 3 say 75. And it looks like this was beforehand. 3 our counts. Right. And then what they do is - 4 And then at the end, you're going to see that 4 this is at the handwritten outcount from 5 actual count slips and I'm going to ask you - 5 employee. This is what they (Indiscernible 6 you know who was on the count slip that you 6 *02:48:16 entry. 7 filled out and who else was on there with you. 7 MS. Mm-hmm. 8 MS. : Okay. 8 MS. GREGG: This is what's keeping this 9 MR. : In this instance I 9 entry and it reflects on here. These are the 10 believe it's on the second-to-last page. So 10 outcount areas an inmate could be. Right? So 11 that you don't have to flip through all this. 11 5 South's count was 75. Their unit count is 12 But you can let me know if that's accurate. So 12 78, three_2t2ple were in food service. 13 sorry. It looks like that one was the 4:00 13 MS. IIII: Okay. 14 p.m. and I believe this one is the 10:00 p.m. 14 MS. GREGG: So when they actually counted 15 MS. IIII: So let me (Indiscernible 15 living, breathing bodies, they only had 75. 16 *02:47:46). 16 MS. IIII: Right. 17 MS. GREGG: You went (Indiscernible 17 MS. GREGG: So now just apply that to SHU. 18 *02:47:49 12221 __ 18 This is your SHU count. You had a one inmate 19 MR. IIIIIIIIII: This the 10:00 p.m. 19 outcounted to attorney conference. 20 MS. GREGG: Right? 20 MS. IIII: Okay. 21 MS. IIII: Mm-hmm. 21 MS. GREGG: Right? So you come down 22 MS. GREGG: When you call into the 22 here's one. So the actual count - the total 23 control, this is how they determine that your 23 count that's supposed to be there is this 24 count matches their learning base count. 24 number. This is the inmate outcounted. And 25 Right? So ZA is 9 South, ZB is 10 South. 25 this is what whoever counted called in. 235 236 1 MS. Mm-hmm. 1 MS. : Where the is - no. 2 MS. GREGG: Or should have called in. 2 MR. How about your signature? 3 MS. Mm-hmm. 3 MS. : The signature looks like my 4 MS. GREGG: That number is supposed to 4 signature. But where the IIII is - no. But I 5 match ... these are all outcounts. That number S don't recall doing. I may have done the 4:00. 6 is supposed to correspond with these count I don't recall. But I know I did 10:00. 7 slips for our respective housing unit. 7 MR. Alright. So you don't 8 MS. IIII: Okay. 8 recall if ou did the 4:00 p.m. or not? 9 MS. GREGG: Right? And then I guess she's 9 MS. : I don't recall. 10 asking you to review your respective -. Tell 10 MR. You can only recall doing 11 me if 11 the 10:00. And is that because you said you 12 MR. : Yep. 12 did it by ourself? 13 MS. GREGG: Review your respective count 13 MS. : Self. Yes. 14 slip for your unit on your shift. And then I 14 MR. : Do you believe you did 15 guess you wanted to confirm signature on the -? 15 the 4:00 16 MR. : Sure. I just wanted to 16 MS. : I don't remember. 17 see the second. So one page back, that second- 17 MR. You don't recall. 18 to-last page, can you just find if there's a 18 MS. I don't remember. 19 count slip that you created or you signed in 19 MR. Alright. What is the 20 there? 20 number that's listed on there? On that count? 21 MS. IIII: I see here it says -. It has 21 MS. 75. 22 my name on it. And it says 4:00 p.m. count. I 22 MR. And that is your actual 23 don't recall at 4:00. 23 signature? 24 MR. : Does that look like your 24 25 signature or your handwriting? 25 MR. MS. : Alright. And it says 75? EFTA00117701 237 238 1 MS. : Yes. 1 anything you recall, you signed, or you 2 MR. : Okay. What is there on 2 documented. 3 the first page. what does it say that the 3 MR. FOY: Look at (Indiscernible 4 number is? And that's the count for the SHU. 4 *02:51:16 . 5 MS. 75. 5 MS. Here. 6 MR. 75. Okay. So your 6 MR. Okay. Is there somewhere 7 signature. You're claiming you can't recall 7 that you you signed on that? 8 4:00 p.m. 8 MS. Yes. On the bottom. 9 MS. : I don't recall. 9 MR. And who was - and I do 10 MR. Alright. And I'm sure 10 apologize. Let me before I even go to that. 11 that in preparation for this did you discuss at 11 Who else was on the count slip with you on the 12 all or review or kind of - you know at two 12 4:00 p.m.? 13 years now, did I do that 4:00 p.m. count or 13 MS. 14 not? No? 14 MR. Alright. So he 15 MS. 15 signed that one? Or you? 16 MR. Okay. Do you remember 16 MS. : According to the sheet. 17 who called in that number? 17 MR. : Do you know if they were 18 MS. : No. 18 prepopulated? The 4:00 p.m. is that also how 19 MR. : No. Alright. That's 19 you did the rounds? Did you also prepopulate 20 fine. Now the 10:00 p.m. count is next to you. 20 the count slips? 21 MR. Silt here. 21 MS. IIII: On the midnight to 8:00. But 22 MR. : Can you do the same 22 not on -. 23 thing? Co to that last page. it could 23 MR. Not that one? 24 potentially be on the last page or potentially 24 MS. No, not on this one. 25 the second-to-last. You're going to look for 25 MR. Do you know who filled it 239 240 1 out? I know it's your signature. But you said 1 MR. Alright. The 10:00 p.m. 2 it didn't look like your handwriting. But for 2 now we're looking at. Who was on that with 3 the 4:00 p.m. now we're talking about. I'm 3 you? 4 just reverting back. Do you know who actually 4 MS. : Me and 5 completed that count slip? 5 MR. And who - can you tell by 6 MS. IIII: The count slip? Who filled it 6 looking at the handwriting who filled that out? 7 out? I don't recall. 7 MS. IIII: I don't remember. But I 8 MR. No? But it was you and 8 signed. And I know -. 9 that were on it? 9 MR. Does that look like your 10 MS. IIII: Just me and that's on 10 handwritin that filled it out? Can you tell? 11 there. 11 MS. No. 12 MR. And this didn't look like 12 MR. : You're not able to 13 your handwriting? 13 identify our handwriting? 14 MS. IIII: For the - no. For the 14 MS. IIII: No. I'm saying this doesn't 15 signature. 15 look like my handwriting. But that's my 16 MR. : Right. For the - and I 16 signature. 17 think you're looking at the 10:00 right now. 17 MR. : Oh that's your signature. 18 I'm just reverting back to the 4:00. That 18 But it doesn't look like you actually completed 19 doesn't look like your handwriting as far as 19 the slip. I'm asking did you complete that 20 counting out? It just looks like your 20 slip? 21 signature on it? 21 MS. IIII: Yeah. I don't -. And this is 22 MS. : Yes. 22 right here. The 73, I wrote that. But 10:00, 23 MR. And you simply just don't 23 I don't write m numbers like this. 24 recall if ou did or did not do that count? 24 MR. : Okay. 25 MS. IIII: I don't remember. 25 MS. : So. Yeah. I don't put the EFTA00117702 241 242 1 zero-zero in a cross. So I don't. 1 MS. : 73. 2 MR. : Is that the (Indiscernible 2 MR. : 73? Alright. So again, 3 *02:53:11 ? 3 that plus one you're not sure. 4 MR. Is there anything next to 4 MS. : No. 5 73 on that? 5 MR. : And now can you just 6 MS. I ut plus one. 6 explain to me -. You said you do specifically 7 MR. • What is that for? 7 recall conducting that count? 8 MS. I don't remember. 8 MS. : 10:00 yes. 9 MR. You don't know why you 9 MR. : And you actually went 10 put 73 plus one? 10 through and counted all of the inmates? 11 MS. : I don't remember. 11 MS. : Every inmate. 12 MR. : Is that abnormal to write 12 MR. On ever tier? 13 73 plus one? 13 MS. 14 MS. IIII: I don't even know they there's 14 MR. But it was a prepopulated 15 a plus one on there. 15 count sli 16 MR. : But you wrote 73 and 16 MS. •: No. That was for the midnight 17 somebody else may have put the plus one? 17 to 8:00 in the morning. 18 MS. IIII: I don't remember. But the 73 18 MR. . Alright. 19 is mine. 19 MS. We filled it out before. 20 MR. : Okay. And you don't know 20 MR. So 10:00 p.m. wasn't 21 what plus one would mean? 21 prepopulated? 22 MS. : No. 22 MS. : No. 23 MR. : Alright. And then what 23 MR. You did that after you 24 is the first page say - that the institution 24 conducted the count? 25 counts were then for ZA? 25 MS. IIII: Yes. 243 244 1 MR. Alright. But not with 1 long he s122I for? 2 another CO. 2 MS. IIII: Until it was time for him to go 3 MS. 3 home. 4 MR. And who was the CO that 4 MR. So like 10:00 to 12:00? 5 was supposed to have done it with you? 5 MS. roximately. 6 MS. 6 MR. Okay. But you're certain 7 MR. And did sign it 7 you conducted that count? 8 even thou h he didn't? 8 MS. : Absolutely. 9 MS. : Yes. 9 MR. : Okay. And are you 10 MR. • And did you have any 10 confident that that number is correct? 11 discussions with him at that time? 11 MS. : What the 73? 12 MS. IIII: He was tired. He was on a 12 MR. Yep. 13 triple. 13 MS. 14 MR. Okay. And what did he 14 MR. Alright. Now let's show 15 say to you? 15 the 12:00 a.m. Does this go there? 16 MS. : He was tired. 16 MR. : It's (Indiscernible 17 MR. Did he leave then? 17 *02:55:07) 18 MS. 18 MR. Alright. So before we -. 19 MR. : Or did he just stand 19 I guess first, can you go to the back of the 20 there and watch you do it? 20 thing and see the counts? Find the count slip? 21 MS. : No. He was asleep. 21 Can you find if -. Are you on there? 22 MR. : He slept? Alright. So 22 MR. : Check the last page. 23 he was slee ing when that was conducted? 23 MS. : Yes. 24 MS. : Yes. 24 MR. : And is this the one you 25 MR. : Okay. Do you know how 25 said you prepopulated? EFTA00117703 245 246 1 MS. .-. Yes. 1 MR. : Alright. So what 2 MR. : Okay. And did you fill 2 happened with that? 3 that count slip out? 3 MS. 11.1on't remember. 4 MS. 4 MR. : At what point did an 5 MR. did? 5 inmate di122pear? 6 MS. 6 MS. IIII: I don't remember. I called in 7 MR. : And you signed it? 7 73. 8 MS. 8 MR. : If you called in 73, did 9 MR. So is the one that 9 you actuall count 73 people? 10 prepopulated it? 10 MS. Well we didn't count at 12:00. 11 MS. IIII: Yeah. We filled all of them 11 MR. : I know but at 10:00 you 12 out. 12 did you 13 MR. : Oh you filled out all but 13 MS. Did. Yes. 14 three? 14 MR. : So at 10:00 you did. But 15 MS. IIII: Yeah. He wrote and I signed. 15 there's only 72 people there at 10:00. So did 16 All. 16 you actually do the count at 10:00? Did you 17 MR. : Alright. So the 12 and 17 call - dictylm actually count the inmates? 18 the 3 and the 5, you did it all at once? 18 MS. IIII: I actually counted all the 19 MS. 19 inmates at 10:00. Absolutely counted all. 20 MR. : Alright. And then what 20 MR. : And you counted at 73 of 21 number is written on there? 21 them. 22 MS. M. 22 MS. IIII: I actually counted all the 23 MR. : Now look at that first 23 inmates at 10:00. 24 page. What number is written on there? 24 MR. : So where did the one 25 MS. IIII: 72. 25 inmate go? 247 248 1 MS. : I don't know. 1 MS. GREGG: It's in the (Indiscernible 2 MR. : Do you remember any 2 *02:57:402a________ 3 inmate being removed from the SHU after 10:00 3 MR. IIIIIIIIII: And I don't dispute that 4 p.m.? 4 maybe you did a round at 10:00. Are you sure 5 MS. : N 5 you did a count at -? 6 MR. : Alright. Can you show 6 MS. : No. I did a count at 10:00. 7 her this count? Here's the 3:00 a.m. count. 7 MR. : You counted all the 8 Can you see that top sheet right there? Can 8 inmates and it added up to 73. 9 you find ZA? How many - what number is it on 9 MS. IIII: Because that's what on the -. 10 that? 10 I wrote 73. 11 MS. : 72. 11 MR. : Right. And then if you 12 MR. : Alright. So 72 again on 12 notice you wrote 73 a22.1Li2t 12:00. 13 that. That's the institution count. That's 13 MS. : That wrote it at -- 14 how many people are actually in the SHU. What 14 MR. : But there's actually 72. 15 does it sa on the count slip? 15 MS. : 12:00 and then on the front 16 MS. : 72. 16 it says 72. But then the count -. But then if 17 MR. : 72. So what happened 17 the numbers didn't match, the count wouldn't 18 between 10:00 and 3:00? 18 have cleared. 19 MS. IIII: Why the numbers are -? I don't 19 MR. : And that's what I'm going 20 know. 20 to ask you. Did you have any conversations? 21 MR. Why are the number 21 MS. 22 different? 22 MR. : So here's the 5:00 a.m. 23 MS. IIII: I don't remember. 23 and this one also says 72 for the official 24 MS. GREGG: Let me see this again? 24 count. And I believe you guys wrote 72. So 25 MS. IIII: Yeah. 25 did you discuss this with anybody that the EFTA00117704 249 250 1 counts were off? 1 count, how did you get 73? 2 MS. : Uh, no. I think 2 MS. : I don't know. 3 discussed. was on the phone with -. 3 MR. But you're sure you 4 Because the count wouldn't have cleared if it 4 counted 73? 5 said 72 and 73. So I think had a 5 MS. I absolutely counted at 10:00. 6 conversation. But I didn't have a conversation 6 MR. But no inmates left after 7 with anybod 7 10:00. 8 MR. Did you have a 8 MS. IIII: No. I mean, I remember I 9 conversation with with regard to the 9 counted by myself. And I (Indiscernible 10 count bein off? 10 *02:59:23) counted with somebody and we 11 MS. : No. 11 compared the numbers. But I counted at 10:00. 12 MR. So if you did all the 12 MR. • Could have you been 13 prepopulating at 12:00, why does the 12:00 say 13 mistaken during your count? 14 73 and the other two say 72 and 72? 14 MS. Probably. 15 MS. IIII: Because on the -. I remember 15 MR. Do you believe that you 16 at the other one, had the count slips 16 were probabl mistaken? 17 all and I couldn't find - I couldn't find the 17 MS. : Probably. 18 count slip. And I remember I rewrote it. But 18 MR. Okay. So you're certain 19 as far as why the count changed to 72, I don't 19 you conducted the count. 20 remember 20 MS. : Yes. 21 MR. : Well I can tell you why. 21 MR. : But you think you 22 Because the count was off. 22 probably Lilt counted wrong? 23 MS. : Mm. 23 MS. fl: Wrong. Maybe. Because it's 72 24 MR. : So that's what I'm 24 after. 25 asking. If you actually did that 10:00 p.m. 25 MR. Okay. And you went 251 252 1 through and you -. Tell me how a count works. 1 MR. : Do you recall about that? 2 Do you add them up? 2 MS. : Yes. 3 MS. IIII: Yes. Like I write it. Like K 3 MR. : What happened with that? 4 Tier. And then I write it. L Tier and then I 4 MS. : Um.... I'm not really sure 5 write it. And then we add it up. 5 because I remember told me. But I 6 MR. : Alright. Do you want to 6 remember the two inmates didn't go to suicide 7 follow-up with that at all? 7 watch but I don't recall as far as 8 MR. : Do you recall that night that 8 (Indiscernible *03:00:58). 9 during your evening shift? 9 MR. : Did that happen during your 10 MS. Mm-hmm. 10 shift? Or did it happen before your shift? 11 MR. : So let's say from when you 11 MS. iDuring. 12 came on from 4:00 p.m. Or did you come on at 12 MR. : During your shift. Was that 13 2:00 p.m.? Mat you said. 13 after the 4:00 p.m. count? 14 S. 4:00. 14 MS. IIII: I don't -. I think if I would 15 MR. : 4:00 to midnight. Were there 15 have been after 4:00 p.m. because I came in at 16 any inmates removed from the SHU? 16 4:00. 17 MS. : When I came on? 17 MR. : Okay. 18 MR. : Yeah. 18 MR. : If you look at the numbers 19 MS. Not that I know of. 19 on the 4:00 p.m. count, does it - is it 20 MR. : If there were inmates removed 20 correct? 21 from the SHU, would you have been aware of it? 21 MS. • (Indiscernible *03:01:12) 22 MS. I mean if I was there. Yes. 22 MR. It says 75. 23 MR. : Do you recall -? And so you 23 MR. FOY: I don't think that's 4:00 p.m. 24 don't -. Do you recall two inmates -? 24 MS. : No. 25 MS. IIII: Going to suicide watch. Yes. 25 MR. • It's at the bottom of page EFTA00117705 253 254 1 five. 1 number you believe it's supposed to be in 2 MR. It's just -. 2 there. But if you actually conducted the 3 MS. Yes. 3 counts, you would actually know that there was 4 MR. Look at the time on the 4 only 72. Correct? 5 bottom. 5 MS. : I counted. 6 MS. : Yeah. 6 MR. : But you couldn't have 7 MR. : You'll be able to figure 7 counted 73 because - 8 it out. 8 MS. IIII: Well I maybe -. That's what 9 MS. : It says 75. 9 I'm saying. Maybe there's where the error is. 10 MR. : And then two people went 10 But I counted. 11 to suicide 'hatch. Correct? 11 MS. GREGG: No. See at 4:00 count. 12 MS. . Correct. 12 MR. You counted but you 13 MR. Alright. But no one else 13 counted was. Is -. 14 left the SHU. Correct? 14 MS. Yes, that's what I'm saying. 15 MS. : No. 15 Because I absolutely counted. Because I 16 MR. : So that's what we're 16 remember was tired. He was on a 17 saying. Somewhere between 4:00 p.m. and 3:00 17 triple and he was falling asleep. 18 a.m., either an inmate went missing or the 18 MR. : Again, and I'm not saying 19 counts weren't conducted or they were off. 19 you didn't conduct a round -- 20 MS. : The counts was off. 20 MS. : And then I went. 21 MR. : They were off. But if 21 MR. : I'm asking if you 22 your job was actually to count the inmates, how 22 conducted a count. 23 were they off? Usually what you're saying is 23 MS. : And I went and I counted. 24 you're just taking the number. You're 24 MR. Okay. And you're 25 prepopulating this a lot of times saying what 25 positive of that? 255 256 1 MS. : That I counted? 1 MR. So he changed the 3:00 2 MR. Yep. 2 a.m. and the 5:00 a.m. at that time? 3 MS. Yes. 3 MS. IIII: He changed one of the count 4 MR. . Okay. 4 slips and then I was looking of for the other 5 MS. : But the number could have been 5 one and I couldn't find it. And then I did -. 6 off. But I counted. 6 I remember. I filled out one. 7 MR. Okay. And that's why -. 7 MR. : But if you -. So you're 8 MS. : Because if I was counting with 8 saying -. I thought you said at 12:00 a.m. you 9 somebody. If I would have said 73, he would 9 prepopulated all the count slips. 10 have counted and he would have got 72. That's 10 MS. : We did. 11 why you'viiiiiiiiliount with two people. 11 MR. : So - but the 12:00 a.m. 12 MR. : Sure. And at the 12:00 12 says 73. 13 a.m. you said you remember speaking to 13 MS. : Yes. 14 someone -- 14 MR. : And the 3:00 and the 5:00 15 MS. : On the phone. 15 say 72. 16 MR. • -- but you don't know 16 MS. : Ri ht. 17 who? 17 MR. : So is the 72 that was 18 MS. 18 submitted and then he talked to you and then -? 19 MR. • And did you have any 19 MS. IIII: Well I believe that because 20 conversations with at that time? 20 then it would have been - when it got submitted 21 MS. IIII: No. Except for he changed the 21 it would have been that the count wouldn't have 22 count sli and I signed. 22 cleared. It would have been off. So then it 23 MR. : He changed which count 23 would have been (Indiscernible *03:03:45). It 24 slip? 24 would have been had to have been changed. 25 MS. IIII: The one that has 72 on there. 25 MR. Okay. The count slip EFTA00117706 257 258 1 would have had to have changed is what you're 1 MS. : Let me see. 2 saying. 2 MR. : Because I just want to 3 MS. : Yes. 3 make sure because the video shows that no 4 MR. : Is that the time -? 4 counts were done at 10:00. I mean unless 5 MS. : If the count doesn't match 5 you're just -. 6 what's on here, then it would have had to have 6 MS. IIII: I saw that also in the 7 been chaniiiiiiiii 7 indictment. But I did count at 10:00. 8 MR. : If a count is off, like 8 MR. : And this is again part of 9 it was -. 9 that whole under oath thing because there was 10 MS. Mm-hmm. 10 only 72 people on there. So if you're saying 11 MR. : What happens? 11 you did the count, I just want to reconcile 12 MS. You redo the count slip. And 12 that now before we have a potential problem in 13 redo the count. 13 the future. 14 MR. In this case do you 14 MR. : So never assisted 15 recall them telling you to redo the count? 15 you with the 10:00 p.m. count right? 16 MS. : No. 16 MS. : No. 17 MR. : No. And did say 17 MR. : So you wrote 73 plus one. 18 that hey I just spoke to the lieutenant and 18 MS. I wrote 73. 19 they said to redo the count? 19 MR. : So you don't recall the plus 20 MS. : No. 20 one? 21 MR. No? 21 MS. IIII: The plus one, no I don't recall 22 MS. Hm-mm. 22 that. 23 MR. Do you remember redoing 23 MR. Does that look like your 24 that slip that says 73 whereas the institution 24 handwritiiiiiiihe plus one? 25 count says 72? 25 MR. : I don't know. 259 260 1 MR. : You don't know. And when 1 MR. Okay. And you just have 2 did sign that? Would it have been 2 no explanation for why the count is off? 3 before he went to sleep? 3 MS. IIII: You can miscount. So I'm not 4 MS. : Yes. 4 saying that the number couldn't have been off. 5 MR. : Would it have been much 5 But as far as the count, like I counted. It 6 before 10:00? 6 could have been a miscount but I counted. 7 MS. IIII: I don't remember the exact 7 MR. : Alright. I've got a follow- 8 timeframe. 8 up. Do you recall an inmate being moved to dry 9 MR. When you wrote that count 9 cell thatilight? 10 slip, was the time accurate to when you 10 MS. IIII: Dry cell. No. 11 conducted the count? 11 MR. FOY: Do you know what that is? 12 MS. IIII: Yeah because you count at 12 MS. IIII: Yes. 13 10:00. 13 MR. FOY: Okay. 14 MR. : Okay. So the time that - 14 MR. : Do you remember an inmate 15 is there a time reflected on -- 15 named Fernandez? 16 MS. : But -. 16 MS. No. 17 MR. • -- the actual count slip? 17 MR. : You don't recall. During 18 MS. Yes. It says 10:00. 18 your shift. The inmate wasn't moved? 19 MR. : Alright. So if around 19 MS. B i No. I don't -. 20 that time, he would have just signed it and you 20 MR. : If an inmate was moved to 21 went up. 21 another cell. Let's just say dry cell. Where 22 MS. : And I went up. 22 is dry cell located? 23 MR. : And you actually did the 23 MS. : I don't know. 24 count. Not a round. But you did a count. 24 MR. : Is it in - you know where R&D 25 MS. IIII: I counted. 25 is ? EFTA00117707 261 262 1 MS. : Yes. 1 MR. Yeah. I'm more concerned 2 MR. : Is it in R&D? 2 with the 73 when there was only 72 people. Now 3 MS. I don't know. 3 I'm not going to doubt that you counted at 4 MR. : Have you -? Okay. If an 4 least one tier. You counted all six tiers? 5 inmate was moved to R&D, would you still 5 MS. : Yes. 6 include the inmate as part of your count? 6 MR. : And you added those up 7 MS. IIII: If the inmate was moved, I 7 and it equaled 73? 8 would think they'd be on the outcount. I'm not 8 MS. : That's what I have on here. 9 sure. 9 MR. : Do you remember? I mean 10 MR. : But you wouldn't include 10 I know you have that on there. But that's what 11 because you can't see the inmate. 11 I'm saying. That's inaccurate. So I'm trying 12 MS. IIII: Right. They'd be on the 12 to - 13 outcount. 13 MS. : But I don't -. 14 MR. : Yeah. You only count the 14 MR. : I'm trying to reconcile 15 people that are physically present. 15 that. 16 MR. IIIIIIiiihresent. 16 MS. IIII: But see I don't remember that 17 MR. : Right. And that's what 17 at this point. Like I mean I wrote 73. I 18 number goes on that count slip. 18 counted. I remember having a 19 MS. • Count slip. 19 conversation. the number was switched to 72 20 MR. Right. 20 but I don't remember like physically like 21 MR. : Do you recall any instances 21 adding it up like I don't remember that. And 22 of why anyone would write plus one? What was 22 again, maybe I miscounted because I counted by 23 that plus one? We've been trying to figure out 23 myself. This was before. But at 12:00 -. 24 what the LI one is. 24 MR. : And being that 25 MS. IIII: Plus one. I don't know. 25 signed before you did the count, do you think 263 264 1 you prepopi212ted that? And then counted? 1 MS. : Ri ht. 2 MS. IIII: I could have been. I don't 2 MR. : And the 4:00 p.m. you're 3 remember. 3 just saying_you don't remember. 4 MR. : So you may have written 4 MS. IIII: The 4:00 yes. 5 the slip first and then counted? 5 MS. GREGG: Can I see the 10:00? 6 MS. : I don't remember at this point. 6 MR. : So you don't remember if 7 MR. : Okay. But at the 12:00 7 it was conducted or if it wasn't conducted. 8 a.m. count when you guys were told this count 8 MS. IIII: Well the 4:00 would have been 9 is off, you didn't then go as you should have 9 conducted because we feed at that time. 10 recount. 10 MR. Well that's not a count 11 MS. 11 though. Again, I'm talking -. I don't want to 12 MR. : And you do understand 12 say - 13 that if a count's off you're supposed to do a 13 MS. : Like a -. 14 recount? Correct? 14 MR. : I want to make sure that 15 MS. : Recount. 15 we're - 16 MR. : Alright. So the 12:00 16 MR. Right but I don't 17 a.m. there's not dispute. The 12:00 a.m., the 17 remember physically at 4:00 counting. I don't 18 3:00 a.m., and the 5:00 a.m. you guys didn't do 18 remember. 19 it. 19 MR. : Okay. So you don't 20 MS. : Correct. 20 recall counting. You know that you did people 21 MR. : And you both signed those 21 at 4:00. 22 slips knowing that the counts weren't done. 22 MS. : Ri ht. 23 10:00 you're claiming that you did. You don't 23 MR. : So that would be what you 24 know when you filled out the slip and you don't 24 call a round. 25 know why it's inaccurate. 25 MS. IIII: Right EFTA00117708 265 266 1 MR. : What you classify your 1 MR. FOY: Let me do this real quick. I 2 understandin of a round. But the count. 2 just want to try to clarify this. Let me 3 MS. Ri ht. I don't recall. 3 because this is something we haven't discussed 4 MR. : You don't recall 4 in advance. 5 conductin the 4:00 p.m.? 5 MR. : Of course. 6 MS. No. I counted -. 6 MR. FOY: Because I didn't know there was 7 MR. : Do you believe that you 7 an off on the number. 8 did conduct a count at 4:00 p.m.? 8 MS. IIII: I didn't even remember that. 9 MS. I don't know. 9 MR. FOY: Alright. So we can take this 10 MR. : So you just can't recall. 10 out with plailLjaak on it real quick? 11 MS. I don't remember. 11 MR. IIIIIIIIII: Ah... 12 MR. : Okay. 12 MR. FOY: want to keep it in here? 13 MS. I counted at 3:00 and 5:00 13 MR. : How about we leave and 14 upstairs. 14 let you discuss it in here? 15 MS. GREGG: That's incorrect at 10:00. 15 MR. That's fine. 16 MR. : In 10 South? 16 MR. : Does that work? 17 MS. : Yes. 17 MR. FOY: Yeah. That's fine. 18 MR. : Alright. 18 MR. : Just because I don't 19 MS. GREGG: Right? So this -. 19 really want to have documents removed. 20 MR. : So you - is it safe to 20 MR. FOY: Yeah-yeah, okay. 21 say that you did the feed, which you classified 21 MR. : Alright. So it's 1:38 22 as a round but you didn't count at 4:00 p.m.? 22 m. This is Senior Special Agent 23 MS. know. 23 and I am pausing the recording. 24 MR. : You don't know. Okay. 24 [Whereupon, the above-entitled matter went off 25 We're going to just move on. 25 the record and went back on the record.] The 267 268 1 recorder is back on. It is currentl 1:46 .m. 1 writing the numbers and it's supposed to be -. 2 This is Senior Special Agent 2 I mean when 3 I'm just reminding you Ms. you are under 3 MS. IIII: No. I'm talking about for the 4 oath and this is a voluntary interview. Thank 4 73 and then how it changed to 72. As far as 5 you again for your cooperation. So when we 5 the plus one, I don't know about the plus one. 6 took a break, is there anything that you wanted 6 I'm talkiiiiiiiiiiihe 73. 7 to add from the last thing we were talking 7 MR. : But when you do a count, 8 about? The difference between the 4:00, the 8 that you list on it, isn't it the physical 9 10:00, and the 12:00, and the different 9 inmates that are there? 10 numbers. 10 MS. : Yes. 11 MS. IIII: On the plus one. I don't know 11 MR. : You can't ever say that - 12 where the plus one came from. I absolutely 12 you can't list somebody that is not there on 13 counted at 10:00. I don't know why is there a 13 that count. Correct? 14 plus one. And then when the number changed, 14 MS. : Correct. 15 like there's something that's sometimes it's 15 MR. : Right. So you see? 16 called like a ghost count. I don't know. I 16 MS. : No but what I'm saying. Okay. 17 don't remember if that's what happened. So 17 Like I'm like I said, I really don't remember, 18 whereas, control will call you and say, put it 18 but let's say if I counted 72. And they said 19 as a ghost count. So the inmate is not 19 ghost count John. And I put 73. As far as the 20 physically there but they know there the inmate 20 plus one, I don't know. And I put 73 because 21 is. Because they didn't redo the count sheet. 21 they know where the inmate is. And then after 22 So that's the only thing I can think of - the 22 for the next count they fixed the roster. 23 ghost count. 23 Because that's why it's called a ghost count 24 MR. : I could think it may be a 24 because they didn't move to where the person is 25 ghost count for the plus one. But if you're 25 supposed to be. And then they fix it on the EFTA00117709 269 270 1 next one. That could have been how the count 1 from the 72 to the 72 at that time. 2 went down in 72. But as far as the plus one, I 2 MR. : Right. So no inmate was 3 don't know where the plus one went. 3 removed from the SHU after 10:00 p.m.? 4 MR. Alright. So who was in 4 MS. : No. 5 the SHU at 10:00 p.m. when you conduct this 5 MR. : There's only 72 inmates 6 count? 6 in the SHU at 10:00 p.m. 7 MS. Me and 7 MS. IIII: I don't - as far as the numbers 8 MR. Just the two of you? 8 go, I don't remember accurately the numbers, 9 MS. Yes. 9 but no inmate moved. 10 MR. He's sleeping. 10 MR. Right. 11 MS. Yes. 11 MS. There was no movement. 12 MR. What conversations did 12 MR. And that's just where 13 you have with anybody about that count? 13 we're just trying to get to this. If you're 14 MS. IIII: That's what I'm saying. I 14 swearing up and down, you know under oath, I 15 don't recall. That's the only thing that could 15 conducted this count. 16 have happened. But I don't recall. 16 MS. : I did. 17 MR. : But if they told you to 17 MR. : But there's only 72 18 do that at 10:00 p.m. as you just noticed, at 18 people there. At 12:00 a.m., that's when the 19 12:00 a.m., the count - that's when they catch 19 lieutenant catches. Hey guys, there's only 72 20 that the counts are wrong. 20 people in there. You've got to redo this count 21 MS. : Ri ht. 21 and give me a new count slip. When did - when 22 MR. : So if I told you that -. 22 did this happen? 23 MS. : Well not at that time at the 12 23 MR. FOY: Let me just say something on 24 time. I'm saying like when it changed from - 24 here it says that at 10:00. I'm looking at the 25 I'm not looking at the time but when it changed 25 10:00 that it was 73 on the outside. 271 272 1 MR. Correct. 1 MR. So you're right. The 2 MR. FOY: Right, so the control and her 2 master list is off but so is the count slip. 3 slip matches. 3 The count slip is provided first. 4 MR. Right. So she calls in 4 MS. GREGG: But they're not off, right? 5 the number -- 5 Technically, at 10:00, the master list is that 6 MR. FOY: Ri ht. 6 front page. 7 MR. : -- and right. So she's 7 MR. : The master list is wrong. 8 calling in because somewhere before 10:00 p.m., 8 MS. GREGG: It said 73. 9 an inmate wasn't removed from the list. 9 MR. : Correct. 10 MR. FOY: Ri ht. 10 MS. GREGG: So there may be something you 11 MR. : Although they were not 11 know that vie don't. 12 present in the SHU. So if they're doing a 12 MR. : Oh we've already talked 13 count -- 13 to hundreds of people about this. 14 MR. FOY: Mm-hmm. 14 MS. GREGG: I'm sure. 15 MR. : -- that's where it's 15 MR. : So that's where - I mean 16 supposed to say that's the actual number that's 16 not hundreds - by you know what I mean. 17 in here. 17 MS. GREGG: A few people. 18 MR. Sit. 18 MR. : A lot of people. So this 19 MR. : And at that point, 19 is where we're just asking the only person that 20 control would say we have 73. Where is the 20 was there that was actually. You know the 21 problem here? But she called in 73 -. 21 other guy was sleeping. There's only one 22 MR. FOY: Ri ht. 22 person physically present in there. 23 MR. : Or yeah instead of the 23 MS. GREGG: Mm-hmm. 24 72. 24 MR. And that was you Ms. 25 MR. FOY: Right. 25 EFTA00117710 273 274 1 MS. : Yes. 1 have four bodies on Unit A and you say to me, 2 MR. : So that's why we're 2 Ms. Gregg.L_IllatIll. good count. Right? 3 asking you. Everyone else clear as day says 3 MR. IIIIIIIIII: Mm-hmm. 4 well it just shows - it's just proof that the 4 MS. GREGG: That's what these documents 5 count wasn't conducted. That's what everybody 5 imply took place. Because the front page is 6 else says all the way up to the highest of 6 prepared by a completely different person in a 7 levels. So that's why if you're saying that 7 completely different area. 8 the count was conducted, you're just saying -- 8 MR. : Exactly. So what these 9 MS. : I did do the count. 9 documents actually imply is that the 10 MR. : -- you just counted 10 institution count showed that there were 73 11 wrong. 11 people in there. 12 MS. IIII: I did do the count. 12 MS. GREGG: Yes. 13 MS. GREGG: So I get -. And I'm asking 13 MR. : There were only 72 people 14 this because I think if we're confused, Ms. 14 in there. So what they imply is that the count 15 is - might be confused. Correct me if I'm 15 wasn't conducted. Because there were only 72 16 wrong. 16 people in there and it was just based on the 17 MS. IIII: Right. Like because I didn't 17 number that should have been based upon the 18 even -. 18 system. The system showed there were 73, so 19 MS. GREGG: If she - if the employee - 19 they wrote 73 on the slip. That's what the 20 let's use a simple number for the sake of it. 20 documentation implies. 21 Right. I'm an employee. I count 4 living 21 MS. GREGG: I get that (Indiscernible 22 breathing bodies on Unit A. 22 *03:16:28 wron . 23 MR. : Mm-hmm. 23 MR. : However, there were only 24 MS. GREGG: And then I call you who is 24 72 people in there. 25 located eight floors downstairs and I say I 25 MS. GREGG: Now I understand what you're 275 276 1 saying. 1 MR. So just give me a little 2 MR. So that's why I'm asking. 2 more information on what you're just saying. 3 It's hard for me to get past this question if 3 You know ya_counted but what? 4 you're sa in yes I counted 73 -- 4 MS. IIII: No. I'm saying I know I 5 MS. : I did. 5 absolutely counted. And that always stood out 6 MR. : -- bodies when there were 6 to me because I remember he was on a triple and 7 only 72 bodies in there. 7 he was tired. 8 MS. IIII: No. I absolutely counted. As 8 MR. : Sure. 9 far as the number, like I said, in remembering 9 MS. : And I counted by myself which 10 how much bodies I counted, but I counted. 10 I'm not supposed to. So I remember that. But 11 MR. So you counted, you just 11 as far as the numbers go, I don't remember this 12 didn't -. 12 because I didn't even remember something about 13 MS. : The count may have been off. 13 a plus one until I seen the count slip. Like I 14 MR. : You didn't maybe have the 14 don't recall nothing about a plus one. 15 numbers u 15 MR. : Right. 16 MS. Ri ht or it was -. 16 MS. : So as far as the numbers, I'm 17 MR. : And that's why I wanted 17 not sure. But as far as counting, I absolutely 18 to make sure the difference between a round and 18 counted. 19 a count. 19 MR. Are you sure you counted 20 MS. : No. I counted. 20 73? 21 MR. : You counted but -? 21 MS. IIII: That's what I'm saying. As far 22 MS. : And the reason why that always 22 as the numbers go, I don't remember. But I 23 stood out to me because I remember he was on a 23 counted. 24 triple and he said he was tired. And I 24 MR. : Let's see. You counted 25 counted. 25 what? So I mean what did you do with the EFTA00117711 277 278 1 numbers that you counted? 1 MR. So someone who you 2 MS. IIII: What I'm saying is, the count 2 relieved would have told you that there were 3 could have been off. But I'm just letting you 3 73? 4 know that I actually did count. As far as the 4 MS. : Correct. 5 actual number, that's where the discrepancy -- 5 MR. : Alright. And do you know 6 MR. So -- 6 who would have told you that there were 73? 7 MS. -- comes in. 7 MS. : I don't know. 8 MR. So did you count and then 8 MR. : Would it have been 9 look at the - what the system showed was in 9 before he fell asleep? 10 there. And ou just decided -- 10 MS. • I don't remember. 11 MS. : I didn't -. 11 MR. : Alright. So again, just 12 MR. : -- to put what the system 12 help me try to understand if there's only 72 13 showed? 13 people in there, how you wrote 73 if you 14 MS. IIII: Because I don't know how to 14 counted? 15 look for that. 15 MS. IIII: Again, that's what I'm saying. 16 MR. You don't even know how 16 I could have miscounted. I don't remember what 17 to find -? 17 happened. As far as the actual number of the 18 MS. IIII: Look for the count in the 18 count. I can only just tell you that I 19 system. No. 19 counted. As far as the numbers go, I don't 20 MR. So where would you -? If 20 remember. 21 you're prepopulating things, where do you get 21 MR. Right. So you counted 22 the numbers from in order to -? 22 each tier. 23 MS. IIII: When you come in, the person 23 MS. : Yes. 24 that you're relieving will be like I got 72 or 24 MR. And then you added each 25 I got 75. 25 of those counts up? 279 280 1 MS. IIII: Yes. I counted each tier. I 1 MR. Correct. Because that's 2 don't know if I added them up. But usually 2 the - the institution count it off. 3 when I'm counting, that's what I do. I write 3 MS. : Ri ht but at -. 4 it down, K Tier with the number, L Tier I put 4 MR. : So -. 5 the number, and I add them up. 5 MS. : So - but I'm confused because 6 MR. : Okay. 6 at 10 it says it's 73. 7 MS. : But if I miscounted, remember I 7 MR. FOY: But they're saying this is 8 counted by myself. So if I miscounted, I would 8 wrong. This a er is wrong. 9 have called control and I would have said 73. 9 MR. : And it was caught at 10 They would have been like no, your count is 10 midnight. 11 wrong. 11 MS. IIII: Okay. But this is -. Well 12 MR. • Well that's the -. 12 then I don't know. I don't know. 13 MS. But on -. 13 MR. Do we want to continue on 14 MR. : It's weird that your 14 this or kee wing? 15 miscount just happened to show what the system 15 MR. : Oh keep going. 16 said that was what the system thought was in 16 MR. : Alright. So prior to 17 there. 17 6:33 a.m. on August 10, 2019, when was the last 18 MS. : But at -. 18 time that you conducted a round within the SHU? 19 MR. : That's where I'm having 19 Now we're talking about a round. 20 difficulty because it's like the system says 20 MS. IIII: I don't remember the time, but 21 73. So if you miscounted 73, and the system 21 I didn't conduct no round between 12:00 and the 22 said 73, but there's only 72, how are you 22 12:00 to 8:00 shift. 23 saying you actually counted? 23 MR. : So this - what we're 24 MS. IIII: Bu there at 10:00, it's 73 on 24 talking about - what you're calling a count 25 here and it's 73 on here. 25 that you're saying would then that the last EFTA00117712 281 282 1 time be that you conducted either a round or a 1 MS. IIII: On the count slip, it says 2 count? 2 10:00. It's always going to say that. Like 3 MS. : After 10:00. 3 even if -. Like on the count slip, let's say 4 MR. : Would that -? When we're 4 if I counted at 10:15, it's still going to say 5 discussing at the 10:00 p.m.? Would have you 5 10:00 because -- 6 done something between then and 12:00? 6 MR. : Alright. 7 MS. IIII: I don't remember. This is the 7 MS. -- it's the 10:00 count. 8 last that I remember with the count at 10:00. 8 MR. : So -. 9 MR. : So the last one that you 9 MS. So that's what I'm saying. A 10 can recall is the one that we're discussing -- 10 round. 11 MS. Yes. 11 MR. : So this one -. I just 12 MR. -- on the 10:00 p.m. 12 want you to try to kind of -. Because this 13 count? 13 would have been if you actually conducted the 14 MS. Yes. 14 count and you actually looked at the people, 15 MR. : Okay. So probably around 15 this would have been the last time you saw 16 10:00 p.m. would have been the last. 16 Epstein. Correct? 17 MS. You can say that. 17 MS. : Correct. 18 MR. : What time does that count 18 MR. : Alright. So I just want 19 slip show? 19 you to consider that with all that's 20 MS. IIII: The count slips shows 10:00. On 20 surrounding this, you've got to kind of in your 21 here is sa s 10:30 p.m. 21 mind think, "When is the las time that I saw 22 MR. : 10:30 p.m.? 22 him?" 23 MS. Mm-hmm. 23 MS. : Mm-hmm. 24 MR. : Do you - no-no-no. 24 MR. : Is this the last time you 25 That's the institutional count. 25 can remember seeing him? 283 284 1 MS. 1 actually go down range until 10:30. You don't 2 MR. : Alright. So do you 2 actually put 10:30. It's a 10:00 count. So 3 remember -? 3 it's alwa s oin to say 10:00. 4 MS. : Until the incident. 4 MR. : Okay. 5 MR. • Right. 5 MS. : So that's what I'm saying. 6 MS. Mm-hmm. 6 Just ball ark it. 7 MR. • So would that - do you 7 MR. : So approximately 10:00 8 remember if that would have been at 10:00? A 8 p.m. 9 little after? A little bit before? And again, 9 MS. : Yes. Or after 10:00. 10 this is the last time you saw this big guy 10 MR. : Okay. So on the round 11 whose caused your life to flip upside down. 11 sheet. Does that also say 10:00 p.m.? I mean 12 MS. IIII: But I can't -. That's what I'm 12 I know you said you prepopulated that one. But 13 saying. 13 what does that one say? And that's for August 14 MR. : But would he -. 14 9th. You already said August 10th, none of the 15 MR. : You just got to ballpark 15 rounds were conducted. On August 9th, I guess 16 it. 16 around the 10:00, you know that nothing after 17 MR. : Okay. 17 10:00 was actually conducted on the round 18 MS. : It's somewhere around after 18 sheet? 19 10:00. 19 MS. : It has after 10:00 on here. 20 MR. : So you just always write 20 MR. Okay. So those ones. 21 the time of the count. 21 Those ones from then on you know those weren't 22 MS. IIII: Yeah. With the counts, even if 22 conducted. 23 -. Because remember, on the unit, you're 23 MS. IIII: Right. Remember I didn't fill 24 waiting to count. So let's say you fill out 24 this out. 25 the 10:00 slip. But let's say we didn't 25 MR. You prepopulated it. EFTA00117713 285 286 1 Right. So I'm just - want to make sure we know 1 MR. Were any supervisors 2 that -- 2 present for any cell counts or rounds in the 3 MS. • Yeah. 3 SHU on either August 9th or August 10, 2019? 4 MR. . -- you said some of them 4 MS. : No. 5 you conducted. 5 MR. • No? Should any 6 MS. : Right. 6 supervisors have been present for any cell 7 MR. • You don't remember which 7 counts or rounds in the SHU on August 9th or 8 ones you did. 8 August 10 2019? 9 MS. Right. 9 MS. : No. 10 MR. • But I just know that 10 MR. : Is there a requirement -? 11 those ones weren't conducted. 11 Or was there at that time that a supervisor - 12 MR. : Right. 12 every supervisor at least one per shift should 13 MR. • After 10:00 p.m. 13 have conducted a round or a count with you guys 14 MS. Ri ht. 14 in the SHU? Not of you staff members, but of 15 MR. Okay. Alright. So that 15 the inmates? 16 last -. You're saying the last round and the 16 MS. IIII: You're saying if the supervisor 17 count were one and the same. And was that an I 17 should have did -? 18 authorized practice? Is a round and a count if 18 MR. : Should a supervisor, you 19 you're doing a 10:00 p.m. count, does that also 19 know like a lieutenant -- 20 what you can document on the round sheet as 20 MS. : Mm-hmm. 21 something ou did at 10:00 p.m.? 21 MR. : -- observed or 22 MS. : Yes. 22 participated in a round or a count of the 23 MR. : Okay. So they can 23 inmates during their shift? At least once? Do 24 overlap for that. 24 you know of that? 25 MS. IIII: Yes. 25 MS. IIII: I think so. 287 288 1 MR. You think that they're 1 MS. IIII: No. She didn't do anything 2 supposed to do that? 2 with us. 3 MS. : Yes. 3 MR. So she did it by herself? 4 MR. : And during your time in 4 MS. Correct. 5 the SHU, did a lieutenant ever participate or 5 MR. She walked up and down 6 observe a count or round while you were in the 6 each of the six tiers? 7 SHU? 7 MS. : She went down the tiers. 8 MS. did. 8 MR. : Do you know if that is a 9 MR. did. 9 requirement that a lieutenant does that in the 10 MS. did because she went 10 SHU? 11 down on the tiers. But on the midnight to 11 MS. . I don't know. 12 8:00, Lieutenant didn't walk the 12 MR. : Had you ever observed 13 tiers. 13 anyone prior to August 9th - doing that? 14 MR. Okay. So when did 14 MS. IIII: Observe a lieutenant going down 15 on August 9th, she actually walked the tiers 15 the tier? 16 and checked -- 16 MR. : Either do it themselves 17 MS. . Yes she did. 17 the lieutenant do the round themselves - or 18 MR. -- out the inmates? 18 watch the staff members do it? 19 MS. She did. 19 MS. IIII: Oh no, they never No they 20 MR. She did? Okay. And 20 never watch us do -. 21 around would have that been? Do you remember? 21 MR. Never watched? Never 22 MS. : I don't remember the time. 22 observed? 23 MR. : Did she do it by herself? 23 MS. 24 Or did she go with you guys while you were 24 MR. Did they ever conduct it 25 conducting a round or a count? 25 with you? EFTA00117714 289 290 1 MS. : No. 1 the tiers? 2 MR. : But they would 2 MR. Correct. 3 occasional) it themselves? 3 MS. Some of them do. Not all. 4 MS. IIII: They'll make -. The 4 MR. Which ones would do it? 5 lieutenants will make a round. Yes. 5 MS. . Lieutenant IIII was the SHU 6 MR. So not just pop into the 6 lieutenant so he walks the tiers all the time. 7 SHU, but the '11 actually go up and down the -? 7 MR. : Okay. 8 MS. Yes. Some. Not all. 8 MS. : And then the other lieutenants 9 MR. Some? Alright. And 9 that's on, when they come, they sign the round 10 that's what I'm asking. Do you know if it's a 10 sheets. 11 requirement that -? 11 MR. : But do they actually do 12 MS. IIII: That I don't know if it's 12 rounds themselves? Or they just sign your 13 required. 13 sheet and check in with you? 14 MR. So you don't know what 14 MS. IIII: They don't do it all the time. 15 policy or -- 15 They sign the sheet. And they check in with 16 MS. IIII: I don't know what the 16 me. And they'll say like is there anything 17 lieutenant -. 17 going on. But they don't physically actually 18 MR. -- rule or what they're 18 walk it all the time. 19 supposed to or not do? 19 MR. : Okay. So it's 20 MS. : What's supposed to do. 20 occasional) 21 MR. : Alright. But that didn't 21 MS. : Mm-hmm. 22 happen. Did that happen more often than not? 22 MR. = : Alright. But you don't - 23 Or -? When they were actually doing a round 23 . Okay. 24 with the inmates. Lieutenants. 24 MS. IIII: I don't know if it's a 25 MS. IIII: If it happened that they walked 25 requirement. 291 292 1 MR. Alright. You're saying 1 MR. And you didn't have a 2 you don't recall the 4:00 p.m. You may have. 2 conversation about filling them out at 12:00? 3 You might not have. 3 MS. IIII: No because we do that all the 4 MS. : I don't recall. 4 time. Like when he came in, we filled them 5 MR. : You just don't recall. 5 out. And then, I think when the phone rang, he 6 Alright. So 12:00 a.m., 3:00 a.m., 5:00 a.m. 6 had the conversation. And then there was 7 We don't need to go into these specific things. 7 another time when I was looking of for the 8 You said none of them were conducted. They 8 counts slip, he had it and I couldn't find it. 9 were false. You both signed them and submitted 9 So I had to like wake him up to resign the 10 them. Correct? 10 count sli 11 MS. : Correct. For the -. 11 MR. . : Now give me - can you 12 MR. : And you knew that you - 12 walk me through that? So he gets a call. You 13 and you knew that you had to do the count. You 13 already filled out the count slips. Was one 14 just -. 14 submitted? You put it through the door and 15 MS. Yes. 15 internal came and got it? 16 MR. What conversations did 16 MS. : Yes. 17 you have with about doing that? 17 MR. : And that's when they 18 MS. IIII: We didn't have a conversation. 18 called him back? 19 He was exhausted and he was sleeping. 19 MS. IIII: And he spoke to whoever. And 20 MR. 20 then he wrote on the count slip. And we filled 21 MS. Yes. 21 it out. Ai ,,ic t it back through the door. 22 MR. So at 12:00 a.m. until -. 22 MR. : For the corrected one 23 Because you said you filled them all out at 23 that said 73? Then you made it 72? 24 about 12:00? 24 MS. IIII: I don't remember. But I know I 25 MS. IIII: Yes. 25 filled out a new one. EFTA00117715 293 294 1 MR. At 12:00 a.m.? 1 MR. Because that's just 2 MS. Yes. 2 common practice there? 3 MR. : And did you have to at 3 MS. IIII: What? To fill out the count 4 that time fill out a new 3:00 a.m. and 5:00 4 slips before? 5 a.m.? 5 MR. To prepopulated count 6 MS. IIII: Yeah. Because I couldn't find 6 slips. You're supposed to count inmates to 7 the count slips that he had and I filled it 7 make sure that they're there. And write the 8 out. And I woke him up and he filled it. I 8 number of what you counted. 9 remember that. 9 MS. : Yes. 10 MR. : So this was later? So he 10 MR. : You just -. Common 11 gets a call. He falls asleep. And then later 11 practice is you just fill that out first. And 12 you have to wake him up to resign? 12 you said that you don't have access to what the 13 MS. IIII: No. He gets the call, he does 13 count number is supposed to be. It's just -- 14 it. And then he falls asleep. When he gets 14 MS. IIII: I never said I don't have 15 the call to change whatever, we change it. And 15 access. I don't know how to. I don't know if 16 then he falls asleep. 16 I have access. I don't know how to find what 17 MR. : So you only changed the 17 it's supposed to be. 18 12:00 a.m. He falls asleep and then you have 18 MR. : So how do you get the 19 to wake him up to change the 3:00 a.m. and the 19 number that write on the slip? 20 5:00 a.m.? 20 MS. IIII: We're not -. The number that I 21 MS. : Yes. 21 wrote on the sli the officer gave it to me. 22 MR. : Okay. And you just never 22 MR. : So whoever you replace, 23 talked about what you were doing? 23 they tell ou what number to write? 24 MS. IIII: No we didn't talk about it. As 24 MS. : They -. 25 far as like -. 25 MR. : You prepopulated that 295 296 1 number. Is that correct? 1 there, I counted, so I know that's what it is. 2 MS. IIII: Correct. And you fill it out. 2 So it doesn't sound crazy that I fill it out. 3 Even on a regular housing unit, I fill it all 3 MR. : Well in this instance it 4 out. And then I count. Because even if it's 4 does because your count was wrong - the one you 5 wrong, you can ust rewrite it. 5 said that ou counted. 6 MR. : Right. 6 MS. IIII: Okay. But that's that case. 7 MS. : Because even if I come in and 7 But I'm saying like it's not -. If I worked a 8 you say it's 72. And I fill it out and I put 8 double on 11 North and I've been there the 9 72 on all of them. I know nobody there's no 9 shift before and the shift after, and I filled 10 movement between 12 and 8. So even if I did 10 it out. I know there's no movement. So no, 11 that and I put 72, and I counted and it's 11 it's not craz that I filled it out. 12 wrong, I could just change it. So that's the 12 MR. : Right. So. Had you 13 way I've it. 13 worked with prior to this instance? 14 MR. : Does that sound weird to 14 MS. : Never. 15 you? Or List me? 15 MR. You never did? 16 MS. : What? 16 MS. 17 MR. : That that's the way it's 17 MR. And there was no 18 done. That you prepopulated all these numbers 18 conversation with him about these not doing the 19 and then you just change them later if they end 19 counts or rgopulating these count slips? 20 up being off? 20 MS. IIII: No. About prepopulating the 21 MS. IIII: No. Because they're usually 21 count slips, he came in, he filled it out and I 22 not off. 22 signed it. It wasn't a conversation about 23 MR. • Um. 23 that. When it was time to do the - when it was 24 MS. : And then like if I'm working a 24 time to conduct the count, I tried to wake him 25 unit -. If I work that unit and I did a double 25 up and he was really tired. He was like I'm EFTA00117716 297 298 1 tired. And I didn't - we didn't conduct the 1 MS. : 3:00 and 5:00. 2 count. 2 MR. You did the 3:00 and the 3 MR. : Alright. And that was at 3 5:00 with 4 - what time was that? At 12:00? 4 MS. Yes. 5 MS. : I don't remember what time. 5 MR. You just didn't do the 6 MR. : What count would have 6 1:00 in your unit? 7 that been for that you tried to wake him up he 7 MS. : Ri ht. 8 said he was tired? 8 MR. Okay. Um. Um. I'm just 9 MS. : I don't know. 9 -. The only problem I -. I'm trying to 10 MR. : You don't know? 10 reconcile the fact that you've never worked 11 MS. 11 with before. You didn't have any 12 MR. • Would have it been the 12 conversation with him about it. 13 12:00? Because you're already -- 13 MS. : No. 14 MS. IIII: It could have been the 12:00, 14 MR. : He didn't -. That's why 15 it could have been the 3:00, I don't know. 15 I'm saying it sounds like it must be just 16 MR. Alright. 16 common practice. 17 MS. was tired. 17 MS. : Yes. 18 MR. So that was the one 18 MR. : You just don't conduct 19 conversation -- 19 counts. You just fill out eh forms. 20 MS. IIII: Because I counted upstairs. 20 MS. IIII: We didn't have a conversation 21 Like why would I go upstairs and count a unit 21 about filling it out. No because that's common 22 and leave my unit? So I woke him up. He was 22 in there. 23 tired. So I went upstairs and I counted with 23 MR. : Alright. So it's very 24 24 common. Is it very common from like 12:00 a.m. 25 MR. And what time was that? 25 to the 5:00 a.m. count? Those three? Not to 299 300 1 conduct the counts and just write them? 1 worked in the SHU we fill -. 2 MS. : No. 2 MR. : So you're saying you've 3 MR. : No it's not common or is 3 never worked in the SHU and we got the schedule 4 it common? 4 in front of you if you want to take a look to 5 MS. IIII: You're saying if it's not 5 just help refresh your memory. Um. When you 6 common to conduct the count or if it's common 6 were in the SHU, was it common to fill out 7 to (Indiscernible 03:33:51) it? 7 count slipl_that weren't conducted? 8 MR. : Is it common not to 8 MS. IIII: Count slips, we fill them out 9 conduct the counts at night or the early 9 and the counts were done. The rounds, it was 10 morning hours? 10 common to fill them out and the rounds weren't 11 MS. IIII: I don't know because that's my 11 all conducted. 12 first time ever not doing it. So I don't know 12 MR. : So you're saying it's 13 if it's common not to conduct the count. But 13 common to fill them out ahead of time, but it's 14 it is common to fill it out before. 14 not common not to conduct the counts? 15 MR. FOY: You need to make that more 15 MS. : The counts. Correct. 16 clear. Did you ever work midnight to 8:00 a.m. 16 MR. Okay. How often were 17 to have an experience to say what happens? 17 they - when you 'worked in the SHU, how often 18 MS. : No. Not in the SHU. 18 were the counts not conducted? 19 MR. IIIIIIIIII: So you've never worked 19 MS. : They were done. 20 midnight to 8:00 a.m. prior to this instance? 20 MR. : They were always done 21 MS. : In the SHU? No. 21 when you were in there before? 22 MR. : Okay. On the other times 22 MS. : Yes. 23 you were in the SHU, was it common to fill out 23 MR. : And this is again one of 24 count slipl_that weren't conducted? 24 those things if we go back to video from the 25 MS. IIII: In the other times that I've 25 days prior, because we had to get video from EFTA00117717 301 302 1 these days. If we review that, are we going to 1 MR. : I'm sorry, what was that? 2 - it's going_to show you conducting the counts? 2 MS. : The rounds sheets I did. The 3 MS. IIII: Yeah. I don't have to conduct 3 count 4 the count because if I'm working with two more 4 MR. : The rounds sheets you did 5 people, they could have did the count. So it 5 what? 6 doesn't necessarily have to be you're going to 6 MS. IIII: On the 9th, when I filled out 7 see me on the video, but you will see the 7 the entire count slips, I didn't conduct every 8 counts bein done. If you get what I'm saying. 8 single round. 9 MR. : No I understand what 9 MR. You didn't conduct every 10 you're saying. 10 single round. 11 MS. IIII: If three of us are working, 11 MS. : N 12 those two could have did it. It doesn't have 12 MR. So what about on previous 13 to be me. 13 incidents? We can switch over to rounds, 14 MR. So when you were in the 14 that's fine. In previous instances when you 15 SHU, did -. If you didn't do it, did the two 15 worked in the SHU, were the rounds conducted as 16 other peo le always do it? 16 displayed on the count sheets? 17 MS. : Yes. 17 MS. : No. 18 MR. Alright. Were you ever 18 MR. : But the counts you're 19 on count slips - your assigned count slips - 19 saying they were always conducted when you 20 that you ersonally didn't conduct? 20 worked in the SHU? 21 MS. : The - no. 21 MS. : Yes. 22 MR. : So you never signed 22 MR. So this was just a rare 23 MS. : But they're -. If I ever 23 instance. 24 signed the count slips but that the night 24 MS. IIII: It wasn't a rare. It was 25 before the round sheet, I did. 25 because he was exhausted. And he was tired and 303 304 1 he didn't want to count. So we didn't count. 1 MS. : No because I usually -. 2 MR. But then you also say 2 MR. : Or the counts - not 3 at 10:00 p.m. also was exhausted? 3 rounds. Counts. 4 MS. : Yes. 4 MS. IIII: Because I usually come in on 5 MR. So -- 5 the shift prior. I don't work that so I don't 6 MS. And -. 6 know what goes one. Because that's the tired 7 MR. -- that's -- 7 time. 8 MS. And -. 8 MR. Right. 9 MR. -- not a -. 9 MS. • So I usually come in before so 10 MS. : And -. Yes and I know because 10 I don't have to deal with that. 11 I did it and I wasn't supposed to do it. 11 MR. Alright. But it was just 12 That's why I didn't continue to do it. Because 12 13 I'm really not supposed to count - to go down 13 MS. : It was just that one day. 14 range by myself. So I didn't continue to do 14 MR. : It's the one day. No 15 it. 15 conversations were had. You try to wake him 16 MR. You didn't continue to do 16 up. He didn't wake up. So you just didn't do 17 what? 17 them. And then you didn't even have to say 18 MS. : The count by myself. 18 like hey man, we need to do these things. Or 19 MR. : Alright. But you did the 19 like there was just an unspoken thing that he 20 entire count at 10:00 p.m.? 20 was tired. So you weren't just going to do 21 MS. : Yes. 21 them? 22 MR. : Were there other 22 MS. : Sa that again. 23 instances that you worked in the SHU where 23 MR. : I'm just trying to like 24 other people were too tired to conduct their 24 it sounds like it would be common practice to 25 rounds? 25 do this if there's no conversations that were EFTA00117718 305 306 1 had. Usually, it would be like hey if this is 1 because remember I'm going upstairs to count. 2 the first time I'm not going to do something. 2 So I wake him up to count. And he was like I'm 3 I would say like, hey is it cool that we're not 3 tired. He was like we have the count slip. 4 going to do this? Or some kind of a 4 I'm tired. He went back to sleep. When the 5 conversation. Unless it was something that you 5 lieutenant came, I woke him up because the 6 had learned or experienced in the past. That 6 lieutenant was coming. He fell back to sleep 7 like we don't do counts at this time. 7 in front of the lieutenant. She said hey, you 8 MS. IIII: But I never worked the SHU at 8 need to stay awake. He couldn't' stay awake. 9 that time. 9 I went upstairs and I counted again. 10 MR. FOY: This is calling for to 10 MR. FOY: Go back to the lieutenant. 11 explain your interaction with 11 Explain that in more detail. There's details 12 MS. IIII: Mm-hmm. 12 leaving out of the interaction between 13 MR. FOY: As it relates to the count in 13 and the lieutenant with respect to him 14 particulaL__EigbI2 14 sleeping. 15 MR. IIIIIIIIII: Correct. 15 MS. IIII: Oh. I woke him up. The 16 MR. FOY: He asleep. What's the 16 lieutenant came. She came, she found the round 17 interaction? What did you say? What did he 17 sheet. He fell back asleep in front of her. 18 say? Did you ask one time? Did you ask 18 She said, hey you need to wake up. She had 19 multiple times? Did he affirmatively say no? 19 papers and she hit him. She says, hey you need 20 Or did he just continue to sleep? That's the 20 to wake up. 21 level of detail they're asking for. 21 MR. FOY: That's what I'm talking about. 22 MR. : Yeah. We're asking, 22 MS. IIII: She hit him with a stack of 23 to explain all of your interactions with 23 papers. So saying that to say like everybody 24 with regard to these counts. 24 knows like because we're understaffed and 25 MS. IIII: Well when it was time to count, 25 overworked. So let's say if I was to tell on 307 308 1 that's who I would have told it to. 1 tried to wake him up for the 5:00. Because by 2 She was there. And she saw it. 2 that time he went ugltiirs. I remember he went 3 MR. : So she knew. So you 3 upstairs to relive IIIII. And I don't remember 4 didn't as far as like if you were going to 4 what happened between there as far as waking 5 report someone sleeping on duty, she's -. You 5 him up. 6 didn't' need to report it because she saw it 6 MR. : Alright. And as far as 7 with her own eyes. 7 the inaccuracy of the one count, specifically 8 MS. : Exactly. 8 now we're talking about the 12:00 a.m. that it 9 MR. And he was literally - 9 was actually - it's off. He got a call but he 10 fell aslee in front of her? 10 didn't talk to you about what was said on the 11 MS. : In front of her. Yes. 11 other line? 12 MR. How long was she there? 12 MS. IIII: No. He just said we got to 13 MS. be like five, then minutes. 13 change the count slip. And he wrote it. And 14 MR. And that little brief 14 he changed it. And I signed. 15 interaction he actually went to sleep in front 15 MR. : Alright. 16 of her? 16 MS. : But he didn't say like oh the 17 MS. Yes. 17 lieutenaniiiiiiiiiipened or that happened. No. 18 MR. Okay. So no discussions 18 MR. : Alright. And have you 19 with . Just when you would wake him up 19 ever experienced previous instances where the 20 he just said he was tired. 20 count was off from when it was called in? Like 21 MS. Yes. 21 if you give the number and they say no that's 22 MR. Did you try to wake him 22 not right? 23 up for each count? 23 MS. : Yes. 24 MS. IIII: I tried to wake him up for the 24 MR. And what happened in 25 12:00 and the 3:00. I don't remember if I 25 those instances? EFTA00117719 309 310 1 MS. : You recount. 1 that? 2 MR. : You actually did a 2 MS. : No. 3 recount? 3 MR. : Okay. So you didn't 4 MS. IIII: On - not in the SHU. In other 4 really get into detail about what he said. 5 units. 5 MS. : No. 6 MR. In other units though. 6 MR. : Okay. But you do believe 7 But do you know that that's what is supposed to 7 at 12:00 a.m. a new slip was created. Just not 8 be done? You need to do - if you call in a 8 that one. That's not attached to that. The 9 wrong number, you're supposed to do a recount? 9 one that actually says 72. 10 MS. IIII: Right. But I don't think that 10 MS. IIII: (Indiscernible *03:42:12) Is 11 was the case with that. Like they called in 11 that a 12? At 12 here it says 73. 12 and gave -. Okay. That was a case where like 12 MR. : Correct. But that was 13 if I counted wrong, and then they'll say no 13 actually - the top page says 72 and I thought 14 it's wrong. And then I recount and I get the 14 that's the one that you said they made you 15 right number. But in this case, they gave him 15 recreate a count slip. 16 the number because of whatever I guess they 16 MS. : Ri ht. 17 knew where the inmate was or was supposed to be 17 MR. And that's not -. You 18 or wasn't moved. That's what I'm saying. I 18 don't see that -- 19 don't know what happened between the 73 an the 19 MS. That count slip. 20 72. But when he changed the number, he said 20 MR. : -- new count slip on 21 the lieutenant said so I just signed it. 21 there. Correct? Alright. And I know -. 22 MR. : But he didn't tell you 22 Did they have the conversation with 23 the lieutenant said do a new count? 23 because at 12:00 a.m. he called that count 24 MS. : No. 24 number in and they said he was wrong? Is that 25 MR. He never informed you of 25 when he had that conversation with the 311 312 1 lieutenant? 1 but all the other counts you had conducted that 2 MS. No the phone rang. 2 you've documented from previous. 3 MR. Alright. So who called 3 MS. : Yes. 4 the count 12:00 a.m.? 4 MR. : Documented. You're 5 MS. Me. 5 saying you may have worked with three other 6 MR. And did you call - also 6 people and two of them may have done the 7 call the 3:00 a.m. and the 5:00 a.m. in? 7 counts, but there are - when you've been 8 MS. : Yes. 8 present in the SHU, all the counts have been 9 MR. : Alright. And obviously 9 conducted. 10 you called it in without actually conducting 10 MS. : Yes. 11 the counts. Correct? 11 MR. : Okay. And do you know of 12 MS. : Yes. 12 any other COs or employees that have falsified 13 MR. : Alright. Now it sounds 13 count sli s? 14 like your attorney has - and you have had this 14 MS. : Count? No. 15 conversation but what was the reason you didn't 15 MR. No. SO you don't know 16 conduct the counts? 16 any other. I know you said you prepopulated 17 MS. IIII: I didn't conduct the count in 17 them in a sense. But like as far as -- 18 my area because he was tired and we're supposed 18 MS. : As far as other units. 19 to do theiliiiiiiii. So I just didn't do them. 19 MR. : -- not conducting the 20 MR. : Okay. So would have you 20 counts and actually writing a number when a 21 done them if he was awake? 21 count -. Do you know? 22 MS. IIII: Yeah. Because I did them 22 MS. : Oh. No. 23 upstairs. 23 MR. : So all counts that have 24 MR. : Okay. And you're saying 24 been submitted to this point when you're in the 25 that you never worked that night shift before, 25 SHU - someone conducted them. EFTA00117720 313 314 1 MS. : Yes. 1 Senior Special Agent and I am 2 MR. : And you said you've never 2 pausing the recording. [Whereupon, the above- 3 actually had a conversation with anyone about 3 entitled matter went off the record and went 4 counts and how they're documented. You just 4 back on the record.] Okay. The recorder is 5 observed as well like on the round sheets? 5 back on. It is 2:28 p.m. Again Ms. MI you 6 MS. IIII: As far as having a 6 are under oath and this is a voluntary 7 conversation? 7 interview. Thank you for your cooperation. 8 MR. : Did anyone ever train you 8 Alright. So if you don't mind, just all the 9 on how to write count slips? 9 documents I have in front of you, can you just 10 MS. No. 10 initial and date those just again so that we -- 11 MR. : No. 11 MR. FOY: Yeah. Just on the first page. 12 MS. Hm-mm. 12 MR. : -- know what it is that 13 MR. : So you just from watching 13 you were looking at during this interview. 14 other people fill them out - that's how you 14 Thank you very much for initialing and dating 15 learned? 15 all of those. 16 MS. IIII: Yeah because it's just your 16 MS. : Mm-hmm. 17 name and the number of the count. 17 MR. : Alright. We're just 18 MR. : Sure. 18 going to talk briefly about the SHU layout. 19 MS. Mm-hmm. 19 These are papers that have the SHU layout. Now 20 MR. : Okay. You want to take a 20 are the - just for your reference if you need 21 break now? 21 to look at them. Are the COs assigned to the 22 MR. FOY: Mm-hmm. 22 SHU located together on one social - one 23 MR. : Okay. 23 centralized location? Sorry, so the officers 24 MR. FOY: We've got to eat. 24 that are working in the SHU. Are you all 25 MR. : It is 2:21 p.m. This is 25 together? You mentioned there's a desk in the 315 316 1 shape of an L. 1 MR. Three? And you said no 2 MS. : Yes. 2 one had like an assigned computer like the -- 3 MR. : Is everybody together at 3 MS. : No. 4 that location when you're not doing rounds and 4 MR. OIC doesn't have one 5 counts? 5 computer? 6 MS. IIII: I mean no not really. Somebody 6 MS. : You -. 7 could go ita. sto the bathroom. 7 MR. : Everyone just uses one 8 MR. : Okay. During your shift 8 computer? 9 on the 10th. 9 MS. : Mm-hmm. 10 MS. : Mm-hmm. 10 MR. : What can you see from 11 MR. : Is that where ou and - 11 that desk in the SHU? Can you just mark on 12 aside from when you said you hel ed out. 12 there where is the actual L desk setup located? 13 Is that were the two - you and were 13 So it's the two floors - the two layers. I 14 located at that -- 14 don't know if you're able to look at the L Tier 15 MS. : Yes. 15 where Epstein was. That might give you like a 16 MR. -- one central area? 16 what's the first and what's the second. Is it 17 There's not another officer station though, 17 correct that he was on the second level? 18 correct? 18 MS. : Yes. 19 MS. : N 19 MR. : And was he in L Tier? So 20 MR. There's just one 20 that might help you out to be able to 21 officer's station? 21 differentiate between - you see where the cells 22 MS. : There's one. 22 start with like a letter and then the numbers? 23 MR. : Okay. And approximately 23 MS. : Yes. 24 how many corn uters are there at that station? 24 MR. : So that will probably 25 MS. IIII: About three. 25 help you to be able to decipher what's the EFTA00117721 317 318 1 first level and what's the second level. 1 sitting. You've got to go down and you've got 2 MS. GREGG: Do you know what you're 2 to go up iiiiiiiiiithe cell. 3 looking at? 3 MR. : Okay. So on that looking 4 MR. : So each of the cells have a 4 at like the first level of inmates, can you 5 letter in front of it. 5 just kind of identify where it is that that L 6 MR. : That's to identify the 6 shape setu is? 7 tier. That will be the letter. And then the 7 MS. : Over here. 8 numbers will be the cell numbers. 8 MR. : Can you just mark it? 9 MS. : Uh-huh. Okay. 9 Maybe like an X or a circle or something. 10 MR. : So by - can you figure 10 Okay. Thank you. And from where you're 11 out by looking at that? So if the one that 11 sitting can you see all the cell doors from 12 begins with L that would be the second level. 12 there? 13 Do you follow that? 13 MS. : Not all. 14 MS. : Yes. 14 MR. : Not all. 15 MR. : And then there's the 15 MS. Hm-mm. 16 first level. Is there actually almost like 16 MR. Could you see the door to 17 third level where the officers sit? It is like 17 Epstein's cell from there? 18 two different - the way it's tiered. 18 MS. : Yes. 19 MS. : No. It's on the main level. 19 MR. : Alright. Can you mark on 20 MR. : Okay. So where the first 20 there where you recall Epstein to have been? 21 set of inmates are. 21 Alright. Thank you. And does that have a cell 22 MS. IIII: See it's stairs. You've got to 22 number on it? 23 go down and ou've got to go up. 23 MR. : I think those numbers 24 MR. : Right. Okay. 24 correspond with this. 25 MS. : So it's not where we're 25 MR. That's fine. 319 320 1 MS. IIII: Um. 1 in - was that L988? 2 MR. FOY: Because I'm thinking is it? 2 MS. IIII: I don't remember the number 3 Because you have to be able to see in here. 3 that he was in. I just know when you go up the 4 MS. GREGG: This is your unit entrance. 4 stairs, it's the first one on the right. 5 This is where you enter. This is L Tier. 5 MR. : Let me just so that we're 6 Right. The - you walk in. L, M, 3, K. So if 6 not. I just want to make sure that we're not - 7 this is 3, this is you walking into your 7 . Huh. Okay. So they don't actually 8 housing unit. 8 correspond with the numbers. 9 MS. IIII: (Indiscernible *03:51:16) by 9 MS. : No (Indiscernible *03:52:08). 10 turning left. 10 MR. We have that. 11 MS. GREGG: Yes. So. 11 MR. : Do you remember what room he 12 MR. : And maybe put X and a 12 was in? 13 circle just so I know what it is that you just 13 MS. On L Tier? 14 changed. 14 MR. : Yeah. L Tier. 15 MR. FOY: Put a circle around that X and 15 MS. The first cell on the right. 16 that will be the desk. 16 MR. : The room number by any 17 MR. : Perfect. 17 chance? 18 MR. FOY: Alright? 18 MS. Oh I don't know the room 19 MR. : Alright. And then you - 19 number. 20 is it correct where you identify where -? 20 MR. Okay. 21 MS. E stein 21 MR. : Um. Okay. But you could 22 MR. Epstein. What number was 22 see his actual door from where you were 23 that? 23 sitting? 24 MS. : 988. 24 MS. : Yes. 25 MR. : You believe that he was 25 MR. : Yes. Okay. And could EFTA00117722 321 322 1 you see inside his cell from where you were 1 -. Or let's talk from you said 10:00 p.m. is 2 sitting? 2 the last time - around 10:00 p.m. is the last 3 MS. 3 time you saw him. 4 MR. No. Approximately again 4 MS. : Yes. 5 we're talking about like that's where the 5 MR. : From 10:00 p.m. until 6 shower was - what you were talking about. 6 approximately 6:33 a.m., what times did you - 7 Approximately how far was Epstein's cell from 7 when did you leave the SHU? I know one time 8 where you were seated? 8 you said you helped with the counts up in 10 9 MS. IIII: Mm. To like where that chair 9 South. And you may have said you were gone in 10 is. 10 the bathroom around. 11 MR. . Ten to 15 feet? 11 MS. : Indiscernible *03:53:38) 12 MS. Probably. 12 MR. : When would have those 13 MR. Okay. Alright. So the 13 times have occurred? 14 reason why I'm asking that. Did you or anyone 14 MS. IIII: Um 3:00 or right after 3:00, 15 else ever go in or out of Epstein's cell on 15 5:00 or around after 5:00, going to the 16 August 10, 2019? 16 bathroom I don't remember the times. 17 MS. . No. 17 MR. : Okay. So around 3:00 18 MR. And would have you known 18 a.m., around S:00 a.m., and then one other time 19 if someone did? 19 to use the restroom? 20 MS. : Yes. 20 MS. : Yeah. 21 MR. Okay. While you were 21 MR. : And where is the restroom 22 physicall resent in the SHU of course. 22 located in the SHU? 23 MS. : Yes. 23 MS. : U stairs where I iiiiiicount. 24 MR. And you said the only 24 MR. : Okay. But was 25 times you weren't present in the SHU on August 25 present any time you were not there? 323 324 1 MS. : Yes. 1 MS. IIII: Oh you're talking about the 2 MR. : Although he may have been 2 people that's working there? 3 sleeping. 3 MR. : Everybody that's been in 4 MS. : Mm-hmm. 4 the SHU. So there's you, there's . Who 5 MR. : Okay. And are you - of 5 else was actually in the SHU from 10:00 p.m. - 6 the people that we've talked about, you said 6 the last time you saw Epstein - up until about 7 that the lieutenant visited the SHU 7 6:30 when he was discovered? 8 atel , 4:00 a.m. That was Lieutenant 8 MS. , Lieutenant 9 10 iiiiiiiii MS. Yes. 9 and 10 MR. • And ? 11 MR. Who else from 10:00 p.m. 11 MS. He left at 10:00. 12 until 6:33 a.m. were in the SHU? 12 MR. At 10:00. So at 10:00 he 13 MS. (Indiscernible 13 left. The 're the only other people there? 14 MR. Well so -. 14 MS. : That's It. 15 MS. 15 MR. Okay. No one else? 16 MR. left at around 16 MS. No one else. 17 10:00. 17 MR. And you're confident 18 MS. : Mm-hmm. 18 positive about that? 19 MR. left around 19 MS. : Yes. 20 12:00 a.m. Anyone else? 20 MR. : Alright. And did any of 21 MS. : No. 21 those individuals that visited the SHU go near 22 MR. : What about when 22 Epstein's cell? 23 came thought the SHU? So I just want to make 23 MS. : No. 24 sure you're -. I know we've kind of discussed 24 MR. So no one even went near 25 some of this stuff. 25 it? EFTA00117723 325 326 1 MS. 1 upon you having the keys the whole time? 2 MR. Let alone go in it. 2 MS. : Yes. 3 MS. 3 MR. : And did you have the keys 4 MR. No one went in it? 4 because you were SHU officer number one? 5 MS. 5 MS. IIII: I guess. I mean I just had 6 MR. : Okay. That's all we need 6 them. 7 to talk about with the SHU. Do you mind just 7 MR. Okay. There wasn't a 8 initialing and dating that? And are you aware 8 discussion -- 9 -? I guess the one other thing I'll ask. I 9 MS. 10 know I asked when you were there. But when you 10 MR. -- like I'm SHU one, I 11 were gone to do the counts in 10 South as well 11 get the ke 12 as use the restroom, are you aware of anyone 12 MS. 13 visiting the SHU during those times? 13 MR. Do you know that SHU one 14 MS. : No. 14 is supposed to be the one who has the keys? Do 15 MR. : No? Okay. 15 you know that (Indiscernible *03:56:05)? 16 MR. I have a follow-up question. 16 MS. : I think so. 17 MR. Go ahead. 17 MR. : Okay. Do know if you 18 MR. : When you left to go assist, 18 have any conversations with about if you 19 did you take the keys with you? 19 had the ke s or he had the keys? 20 MS. ies. 20 MS. : No. 21 MR. : So could Mr. have let 21 MR. : Okay. Anyone that 22 anyone in and out? 22 entered or exited the SHU that day, are you the 23 MS. : No. 23 one that let them in or out? 24 MR. Oh so he wouldn't have 24 MS. : Yes. 25 even had the ability to let anyone in based 25 MR. didn't let anybody 327 328 1 in or out? 1 MS. : No. 2 MS. : No. 2 MR. : Are there any like - do 3 MR. : Okay. Are you aware of 3 you have the ability to monitor cameras from 4 any cameras were not recording within the SHU 4 the SHU? 5 on August 9th or 10th 2019? 5 MS. : No. 6 MS. : No. 6 MR. So if you're sitting in 7 MR. : You're not aware? Are 7 there, there's not like camera down range that 8 you aware at this point? Not just at the time. 8 you can like - you can see what's going on in 9 But are you aware now if any cameras were or 9 each range? 10 were not recording? 10 MS. • No. 11 MS. : I mean I'm aware now. 11 MR. No? Do you know if 12 MR. : That's what I mean. What 12 someone is live monitoring either - anywhere in 13 is your - what are you aware of now? 13 the SHU during operations? 14 MS. IIII: Oh I don't know like what 14 MS. : I don't know. 15 specifically. I just heard that some of the 15 MR. : You don't know if you're 16 cameras were not working. As far as which ones 16 being monitored or the inmates are being 17 17 monitored? 18 MR. But you don't know which 18 MS. IIII: I don't know. I know there is 19 ones? 19 cameras on the tiers. 20 MS. : -- or no. 20 MR. : Right. Do you know if 21 MR. : Okay. And at the time 21 anybody's live monitoring them? 22 you didn't know? 22 MS. : Oh. I don't know. 23 MS. : No. 23 MR. : You don't? And do you 24 MR. So you don't know if they 24 know if there's any cameras pointed at you in 25 weren't working when they stopped working? 25 the desk area? EFTA00117724 329 330 1 MS. : Oh, I don't know. 1 MR. To relieve M .? 2 MR. : And you don't know if 2 Alright. I might be getting_gpfused. I 3 anybody is monitoring those either? 3 thought you were relieved IIIII. 4 MS. : I don't know. 4 MR. She went up there to do the 5 MR. : (Indiscernible *03:57:54) 5 count. T% Then reached out to her to ask 6 MR. : I think it will be fine. 6 her to relieve him. She called the lieutenant. 7 So you are not - we can just skip the rest of 7 Verified with the lieutenant and then Mr. 8 those questions. You're not aware of any 8 weiiiiiiiiiieliye him. 9 cameras at the time not working? 9 MR. : Okay. And around what 10 MS. : No. 10 time was that? 11 MR. : So no one reported that 11 MS. : After S:00. 12 to you aniLy2u didn't report it to anyone else? 12 MR. : Okay. So basically from 13 MS. IIII: No. I didn't know anything 13 12:00 to about 5:00 he was sleeping? 14 about cameras. 14 MS. IIII: I mean in intervals. Like I 15 MR. : Alright. And we talked a 15 tapped him. He kind of woke up. 16 little bit about sleeping on duty. So it 16 MR. Right. 17 sounds like was asleep pretty much the 17 MS. he went back to sleep. 18 entire shift then? 18 MR. Okay. But he wasn't 19 MS. : Yes. 19 doing his duties. He was sleeping. 20 MR. From pretty much 12:00 20 MS. : Correct. 21 a.m. until he -. 21 MR. Did you sleep during the 22 MS. : Until he went upstairs. 22 shift? 23 MR. • Until he went upstairs? 23 MS. : No. 24 Went upstairs to do what? To feed? 24 MR. : You didn't sleep at all? 25 MS. IIII: To relieve 25 MS. : No. 331 332 1 MR. For the period that you 1 MCC? 2 were sitting at the desk for like two hours 2 MS. : Not in the SHU. 3 without moving were you awake? 3 MR. : Not in the SHU but other 4 MS. : Yeah on my computer. 4 places? 5 MR. : You were on the computer? 5 MS. Yes. 6 Were you and seated next to one another? 6 MR. Where would you - where 7 MS. : No. We were seated next to 7 did you slee at other places? 8 each other but not facing each other. Like he 8 MS. : Where did I fall asleep? 9 was facediiiiiiwa iiii I was faced the other way. 9 MR. Mm-hmm. 10 MR. : Okay. Close proximity to 10 MS. a regular housing unit. 11 one another? 11 MR. The regular housing unit? 12 MS. IIII: Yeah. Like he's there and I'm 12 MS. 13 here. 13 MR. Can you just give me a 14 MR. : So about three or four 14 little more information on that? What do you 15 feet from each other? 15 mean? Were ou allowed to sleep there? 16 MS. IIII: Yeah. But the back is turned 16 MS. : No. 17 because he's that way and I was that way. 17 MR. : And where were 18 MR. Okay. But you were not 18 (Indiscernible *04:00:15)? 19 sleeping? 19 MS. IIII: Like I worked consecutively 20 MS. 20 like five days of overtime. And I would like 21 MR. : Now are you guys 21 doze off - caught myself like that. But not 22 authorized to sleep in the SHU? 22 sleep. 23 MS. : No. 23 MR. : Okay. So you've fallen 24 MR. : No? And have you ever 24 asleep in other housing units. 25 fallen asleep previously while on duty at the 25 MS. IIII: Like dozed off. EFTA00117725 333 334 1 MR. Right. Because you were 1 didn't fall asleep that night and never before 2 overworked? 2 in the SHU? 3 MS. IIII: Yeah when I work like three or 3 MS. IIII: In the SHU no because it's 4 four days of 16 hours, yes. 4 daytime I'm on. 5 MR. And how often would that 5 MR. You said that was your 6 happen? 6 first time working with =? 7 MS. IIII: Every - how often would I fall 7 MS. : Yes. 8 asleep -- 8 MR. : Was that ever with 9 MR. Yeah. 9 or ust in the SHU? Did you ever work with 10 MS. -- or the overtime? 10 outside of the SHU? 11 MR. How often would you fall 11 MS. : No. 12 asleep? 12 MR. : Would you ever like - met 13 MS. IIII: Oh that was like for one or two 13 with him or interacted with him -- 14 times. But I don't -. 14 MS. : Yes. 15 MR. : I understand. But in the 15 MR. -- prior to this? Just 16 SHU you had never fallen asleep before? 16 socially or -. 17 MS. IIII: No because I don't work that 17 MS. IIII: He brings inmates to the units 18 graveyard shift. 18 to give out stuff. So we've spoke and said 19 MR. : Well I just mean even 19 hello. 20 during your regular shifts -- 20 MR. : Okay. Do .oi cnow if 21 MS. : Ri ht. 21 - have you ever heard of sleeping 22 MR. : Because it sounds like 22 on the job revious to this incident? 23 you guys were working a lot. 23 MS. : I don't know. 24 MS. . Yes. 24 MR. : No? And you said you did 25 MR. Um so but in the SHU, you 25 try to wake him up a couple times? 335 336 1 MS. : Yes. 1 like that to him. She was saying that to me. 2 MR. : But he said he was just 2 That's the problem in MCC. Everybody's 3 tired? 3 overworked and understaffed. 4 MS. : Yes. 4 MR. : Okay. After she left did 5 MR. : And you said you didn't 5 he fall back asleep? 6 report the matter to a lieutenant because he 6 MS. : Yes. 7 actually fell asleep in front of the 7 MR. : Have you ever witnessed 8 lieutenant? 8 any other staff member fall asleep at the MCC? 9 MS. • Yes. 9 MS. IIII: No because you're in a unit by 10 MR. • And at that time, she hit 10 yourself. 11 him with a iece of paper and said wake up. 11 MR. : You're in what - the 12 MS. : Yes. 12 housing units or the SHU? 13 MR. : And how did he respond to 13 MS. IIII: Yeah. Like when I'm in the 14 that? 14 housing unit -. Remember I don't work the SHU 15 MS. : He woke up. 15 that time, so I wouldn't know if people are 16 MR. Was there a conversation 16 sleeping at that time. In the housing unit 17 at all? Did he say oh I'm just exhausted? 17 you're by ourself. So I can't witness nobody. 18 MS. IIII: Well he didn't say that. But 18 MR. : Okay. And you have your 19 she said that. She was like that's the problem 19 own little office there -- 20 in here. The overwork and the understaff. 20 MS. : Yeah. 21 MR. : So with him falling 21 MR. : -- when you're in the 22 asleep that's how she responded? 22 housing unit. And that's where you might be 23 MS. Lieutenant 23 able to doze off? 24 MR. Yeah. 24 MS. : Yeah. 25 MS. : Yeah. But she didn't respond 25 MR. As far as in the SHU did EFTA00117726 337 338 1 you ever experience anyone else sleeping aside 1 MR. Did you like Google 2 from 2 things or look things up when you were in 3 MS. : that day before. 3 there? 4 MR. : Okay. And I do 4 MS. : Yeah. 5 apologize. It's just been so long now. How 5 MR. : Well just tell me. What 6 long did he sleep for? 6 did you search for? 7 MS. : Who 7 MS. IIII: Well yeah that's what - I was 8 MR. Yeah. 8 looking at um a benefit page for something. I 9 MS. : From about after 10:00 until it 9 was checking for one of my benefits. And -. 10 was time for him to go. 10 MR. FOY: Continue with it. I've just got 11 MR. : So 10:00 to 12:00? Okay. 11 to - this is call. 12 And did you try to wake him up at all? 12 MR. : Okay. So attorney Foy is 13 MS. : No because he was on a triple. 13 stepping out. However attorney is it Sarraga? 14 MR. : Okay. Alright. Now 14 MR. SARRAGA: Yep. 15 we're going to do -. You said you were on the 15 MR. : Sarraga is still present. 16 internet. Are you authorized to use the 16 MS. : Yes. And then I think I looked 17 internet when you're in the SHU? 17 at I think it's furniture. 18 MS. IIII: I don't know if I'm authorized 18 MR. : Okay. Did you do any -? 19 to use the internet in the SHU but I did. I 19 Do you remember conducting any internet queries 20 don't know if I'm authorized. 20 related tp_Epstein? 21 MR. : Alright. And did you 21 MS. IIII: No. I don't remember doing 22 conduct internet queries when you were assigned 22 that. 23 to the SHU on August 10, 2019? 23 MR. : So you don't remember 24 MS. IIII: What do you mean? Like 24 actually conducting queries on Epstein around 25 internet searches. 25 4:00 or 5:00 a.m.? 339 340 1 MS. : Hm-mm. 1 somebody else was looking him up and it just 2 MR. : On August 10th? No? 2 prepopulated when you turned on the computer? 3 Okay. Does that surprise you for me to ask 3 MS. IIII: I don't think it does that. 4 that question? 4 Like on the searches, like the current news 5 MS. : If I don't remember doing that? 5 will be there. So he's in the current news, so 6 MR. : I don't know. Had you 6 he'll be there. 7 queried him before? Had you looked up Epstein 7 MR. : Oh. Alright. 8 previousl ? 8 MS. : It won't like load the page. 9 MS. : I don't recall looking him up. 9 Like when you click on like Internet Explorer 10 MR. : No? 10 or you click on like Firefox or whatever. When 11 MS. : No. because when you open the 11 the page loads the news is there, weather. 12 computer, and when you click on it, like he's 12 MR. IIIIIIIIII: Okay. So if you 13 there in the - in the Google search. Like he's 13 prepopulated something and then you searched on 14 there. 14 that day, Epstein at the MCC, that possibly 15 MR. Epstein is? 15 could have been something that was like on a 16 MS. : Like when you click on the 16 news feed? 17 browser. You know like if you open it Emerson 17 MS. IIII: When you say prepopulated, like 18 or Google, like how it has that little news 18 that as soon as you click it like it was there. 19 piece. Like one time he was there. 19 Not like roi. ida search. 20 MR. : And was that on August 20 MR. : So you weren't. Yeah. 21 10th? 21 Like a search. Like you were actually looking 22 MS. IIII: No. I don't recall that being 22 at it. Or if like a news feed. 23 on August 10th. I don't remember. But I don't 23 MS. IIII: Oh yeah. Like I'm looking at 24 recall itiiiiiiiiilAugust 10th. 24 it because it's there. But not like typing it 25 MR. : So as in like maybe 25 in. EFTA00117727 341 342 1 MR. So you're not like 1 no. and they was like he's always in the news. 2 actually going to Google or Yahoo or some kind 2 So when I saw it, I just briefly like skimmed 3 of a search engine and -- 3 to see like what he was in the news for but -. 4 MS. : No. 4 MR. : Okay. And do you recall 5 MR. -- saying Epstein? 5 at 5:42 to 5:52 on August 10, 2019 looking at 6 MS. 6 articles related to Epstein? 7 MR. • Alright. Do you remember 7 MS. 8 reviewing news articles on Epstein -- 8 MR. You do not recall that? 9 MS. : Yeah. 9 MS. 10 MR. : -- on August 10th? 10 MR. Do you remember searching 11 MS. : On August 10th? I don't recall 11 for him? 12 if it was August 10th but I remember when I saw 12 MS. 13 it I like scrolled and read it. 13 MR. Or having anything to do 14 MR. : Okay. And what was the 14 with when ou're on the internet? 15 purpose of that? 15 MS. : No. 16 MS. : What was the purpose of that? 16 MR. With Epstein in 17 MR. Yep. 17 (Indiscernible *04:07:02)? 18 MS. : Because he's in there. I just 18 MS. : No. 19 scrolled and -. 19 MR. : S:52? 20 MR. Sure. So you're trying 20 MS. 21 to learn about the inmate that was -. 21 MR. • No? Does it surprise you 22 MS. : And read it. 22 to hear that you know internet searches would 23 MR. • Okay. 23 show that that's what you were doing from 5:42 24 MS. : Because remember, I was asked 24 to 5:52 a.m. on August 10, 2019? 25 like do I know who that was. And I was like 25 MS. IIII: Yeah. 343 344 1 MR. That does surprise you? 1 call cont." that door. 2 MS. Mm-hmm. 2 MR. : So he has to call 3 MR. So do you think that 3 control? 4 would not accurate then? 4 MS. IIII: Because there's a door that 5 MS. Yes. 5 lets you into 10. You have to call control. 6 MR. You think it would be 6 MR. : And then is it like the 7 accurate or not be accurate? 7 entrance? Is there also a second door that you 8 MS. IIII: Oh no. It wouldn't be 8 have to use a key for? 9 accurate. 9 MS. : Yeah. 10 MR. It wouldn't be accurate? 10 MR. So there's also two into 11 You do not believe that you actually conducted 11 10 South? 12 those searches? 12 MS. 13 MS. : N 13 MR. And that second door is 14 MR. : Okay. And since you had 14 that the one 15 the keys, no one could have visited the SHU 15 MS. don't have the key for. 16 without you knowing. Correct? 16 MR. So he would also have a 17 MS. : Correct. 17 key? Or is it just 18 MR. And the individual on 10 18 MS. IIII: No I don't have the key for 19 South - - or anyone else. Are they able 19 upstairs. 20 to access the SHU without someone in the SHU 20 MR. Alright. So he needs to 21 allowing them in? Can they get out of 10 South 21 open his own? 22 and enter the SHU by themselves? Or does 22 MS. : Ri ht. 23 someone from the SHU like you and need 23 MR. • And then control pops it 24 to authorize them entry? 24 25 MS. IIII: He needs to call like I have to 25 MS. IIII: Pops it. EFTA00117728 345 346 1 MR. -- to then allow him into 1 knowledge? 2 the SHU? 2 MS. IIII: Yes. Because he could go and 3 MS. Yes. 3 pop the door. 4 MR. . So he could theoretically 4 MR. : Right. But he would have 5 get into the SHU without your knowledge? 5 had to call control in order to do so. 6 MS. IIII: No. I have to call control to 6 MS. : Yes. 7 pop me into the SHU. 7 MR. : Alright. And does 8 MR. : Yeah-yeah. I'm saying 8 anything allow control to know if that door was 9 ' ability to get into the SHU where you 9 never locked or closed or anything behind him? 10 and were. 10 MS. : I don't know. 11 MS. : Be he can't do that because he 11 MR. : You're not sure? Would 12 can't leave unless -. Because remember 12 an alarm sound if a door wasn't closed or 13 has to go up to relive him. So is 13 anything? 14 getting the door popped. But he can't just 14 MS. I don't know. 15 come out and get the door popped because he 15 MR. You're not sure. Who was 16 would leave the unit with nobody up there. 16 the last person to see Epstein alive prior to 17 MR. : Right. What I'm saying 17 August 10, 2019 at 6:33 a.m.? 18 is like could he? Does he have the ability to? 18 MS. IIII: The last person to see him 19 Not policy dictates that he can't do it. I'm 19 alive? I would uess me. Because I got -. 20 saying would he be able to if he wanted to? 20 MR. You were? 21 Take polic out of the way. 21 MS. Because I counted at 10:00 - or 22 MS. : Call for them to pop the door? 22 after 10:00. 23 MR. : Right. So like point 23 MR. And on that occasion, you 24 being, could have he accessed the SHU 24 didn't actually enter his cell you said? 25 theoretically without you and 25 MS. IIII: No. 347 348 1 MR. Who was that last person 1 guess you already did. You said when you saw 2 to have ph sical contact with Epstein? 2 him he just ut his hand up. 3 MS. 3 MS. : Mm-hmm. 4 MR. would have? And 4 MR. And then he - you said he 5 when would have that been? 5 also asked for -. 6 MS. : When he was feeding. 6 MS. : CPAP machine to be plugged in. 7 MR. No-no-no. 7 MR. : And that is something 8 MS. You mean like a time? 8 that he has every night? 9 MR. had physical 9 MS. : Yes. 10 contact with Epstein during his shift on August 10 MR. : Yep? Did he seem - did 11 10th prior to 6:30? 11 anything seem unusual with him? 12 MS. IIII: Oh no. Not prior to the 6:30 12 MS. IIII: No. See there's exceptions 13 a.m. I'mliiiiiiiiibout at the 6:30. 13 being made for Epstein because it's Epstein. 14 MR. : Right. So you're the 14 You're not supposed to have -. A CPAP machine 15 last person to see him. 15 has a long cord. So other inmates don't have a 16 MS. : Mm-hmm. 16 CPAP machine in the SHU. Like you're not 17 MR. : Who was the last person 17 supposed to have that. Who authorized it, who 18 to have phylical contact with him? 18 gave it t2hills_igon't know. 19 MS. IIII: Oh! Whoever put him in the 19 MR. IIIIIIIIII: Okay. And that's kind of 20 cell. When I went to the bathroom. 20 what I was asking earlier - and this was much 21 MR. Okay. So you're not 21 earlier - about like where like did Epstein was 22 sure? 22 he treated differently than others? 23 MS. 23 MS. : I mean -. 24 MR. Alright. When you saw 24 MR. : Were there other 25 him, please explain in detail like -? Or I 25 instances that you can think of like people EFTA00117729 349 350 1 said pay him special attention because he's 1 MS. IIII: Yeah. The cord has to be 2 different from eh other inmates? 2 plugged in. 3 MS. IIII: No. Just the CPAP machine and 3 MR. : Now do you consider that 4 one time he wanted two mattresses. 4 like a safer issue or anything like that? 5 MR. : He wanted two mattresses? 5 MS. IIII: But see that's the thing. I 6 MS. 6 don't authorize those things. 7 MR. Was he provided two 7 MR. : Sure. 8 mattresses? 8 MS. : That's why I said when a person 9 MS. No. 9 -. You see how the question was asked when 10 MR. : So he just had the one 10 somebody comes back from suicide watch. Like 11 mattress? 11 is there like something like special being 12 MS. : Mm-hmm. 12 said. Like no because he's cleared. Because 13 MR. : So the only thing you can 13 if there was then why would he be allowed to 14 think of is that? 14 have that in his room? So once you're cleared 15 MS. : Is that. 15 and you come back, you're back. 16 MR. Is it like C-P-A-C? 16 MR. : Okay. Were there any 17 MS. What the CPAP? C-P-A-P. 17 other issues with any inmates on August 10th 18 MR. CPAP. 18 from 12:00 a.m. to 6:33 a.m.? 19 MS. Yes. 19 MS. : No. 20 MR. Okay. 20 MR. No? So there was no 21 MR. : Is it the one with like a 21 disturbances? 22 mask that's attached to your face? 22 MS. 23 MS. : Yeah. 23 MR. • Were there any inmates 24 MR. : And there's actually like 24 complaining about the lights being left on or 25 a cord that goes with that? 25 anything like that? Do you recall? 351 352 1 MS. : Not that I know of. 1 each tier? 2 MR. : No? And do you recall if 2 MS. : Oh yeah. It stays on. 3 any other inmates were on - came from suicide 3 MR. Were they on 24/7? 4 watch? 4 MS. Yeah. 5 MS. 5 MR. Do they ever turn those 6 MR. So you don't remember any 6 lights off? 7 other inmates being handled differently than 7 MS. 8 others? 8 MR. No? Okay. Now we're 9 MS. 9 going to get into a little into more of the 10 MR. • No? Or like special 10 specific stuff. Was there a medical emergency 11 instructions with regard to this inmate or that 11 in the SHU in the morning of August 10, 2019? 12 inmate. 12 MS. : Yes. 13 MS. : I don't know. 13 MR. : Why was the medial 14 MR. : And you don't remember 14 emergency called? 15 inmates con laining about the lights you said. 15 MS. : Because when I opened the grill 16 MS. : No. 16 and went to go feed, he knocked on the 17 MR. How do the lights work? 17 door. He got no response. And he opened the 18 Do they stay on in the range all times - uh 18 door. And then he started saying get the 19 24/7? 19 cutter. And I heard -. I was on the grill. I 20 MS. : The -. 20 heard when he ripped something and he started 21 MR. • In each tier? 21 CPR. 22 MS. : I don't know. But the light is 22 MR. Okay. When was the 23 in the hallway room. 23 medical emer ency called? 24 MR. : So for an interior room. 24 MS. : At that time. 25 What about the down the hallway to each for 25 MR. : How soon after um EFTA00117730 353 354 1 entering -- 1 MS. : Yeah. 2 MS. IIII: When he opened the door, he 2 MR. -- one minute or -? 3 yelled get the cutter. 3 MS. A second. As soon as he said 4 MR. -- the cell? 4 it I did it. 5 MS. I had the audio on. 5 MR. Oh so like there's just 6 MR. . Was he already in the 6 button that ou hit? 7 cell at that time? Or had he not yet gone in? 7 MS. : Yeah. 8 MS. : He was in the cell. 8 MR. : So you -. 9 MR. : So he walked into the 9 MS. : Because the button is on my 10 cell and he yelled out? Did he come back out 10 radio. 11 of the cell and yell to you? 11 MR. And did you call it in at 12 MS. : No. 12 that time? 13 MR. He yelled from within? 13 MS. IIII: No once you hit it, everybody's 14 MS. Yes. 14 coming. 15 MR. Could you see him at that 15 MR. : Alright. So there's 16 time? 16 nothing that you call in. You just push a 17 MS. Could I see him? No. 17 button. 18 MR. . No? And from eh time 18 MS. : Yes. 19 that he was discovered to the time of your 19 MR. : Alright. So at the 20 call, about how much time passed from him 20 second he told you get the cutter, you hit the 21 saying - entering the cell - and the time that 21 medical emer ency? 22 the medical emergency was called by you. 22 MS. : Yes. 23 MS. : A- 23 MR. : Did he say anything about 24 MR. Are we talking about like 24 what he saw? 25 five seconds -- 25 MS. IIII: When he got - when he entered 355 356 1 the room, and he said get the cutter, before I 1 MS. 2 got the cutter, I heard him tear something. 2 MR. : Okay. So you didn't 3 And then when he lowered him to the floor, 3 actually have to call anything over the radio. 4 that's when I saw him and he started CPR. 4 It was just a simple push of a button. 5 MR. : Alright. So he never 5 MS. : A button. 6 said like Epstein hung himself or what he saw. 6 MR. And around what time did 7 He just said get the cutter. 7 you say E was last fed? 8 MS. IIII: He said get the cutter. And 8 MS. After 10:00. 9 then he started CPR. And he kept saying, 9 MR. : After 10:00 p.m.? 10 "Breathe, Epstein, breathe!" And he was like, 10 MS. : I mean - not after 10:00. When 11 "We're goiiiiiiiiiiin so much trouble." 11 they fed him in the cell around - I guess after 12 MR. : And where were you when 12 8:00 or 9:00. 13 he was doin that? 13 MR. Sometime between 8:00 and 14 MS. : On the grill. 14 9:00 p.m.? 15 MR. . Were you in a position to 15 MS. IIII: When I came back from the 16 be able to see anything in there? 16 bathroom. 17 MS. : No. 17 MR. And who was it that fed 18 MR. . At any time did you see 18 him? 19 anything in there? 19 MS. 20 MS. : No. 20 MR. You fed him. 21 MR. Did you ever see Epstein 21 MS. 22 in the cell? 22 MR. And did you say at that 23 MS. 23 point did ou actually talk with him? 24 MR. So you never even went 24 MS. : No. 25 over to like look in? 25 MR. : Okay. And did you or EFTA00117731 357 358 1 anyone else recover his food tray? 1 10:30 or whatever that was. Anything unusual? 2 MS. IIII: I don't know if somebody did. 2 MS. No. 3 Not me. 3 MR. : Nothing that caught - 4 MR. : Okay. But you didn't do 4 raised sus 5 it? 5 MS. 6 MS. : No. 6 MR. : No like distress or 7 MR. : Who else could have done 7 anything like that with him? 8 it if it wasn't you? 8 MS. : No. 9 MS. IIII: I don't know because after the 9 MR. : And you're sure when you 10 medical emergency, nobody's allowed to go in 10 saw him at 10:00 - 10:30 he was alive? 11 the room. So. 11 MS. Yes. (Indiscernible *04:17:41) 12 MR. : So you're just not sure 12 MR. : I'm sorry what? 13 if by the time you fed him, in that medical 13 MS. Yes. He put his hand up. 14 emergency if it was ever recovered? 14 MR. : He put his hand up. 15 MS. : Ri ht. 15 MS. Mm-hmm. 16 MR. : Okay. Alright. So when 16 MR. : And he wasn't like 17 you fed him - can you just again refresh my 17 hanging a ainst the bed when he put it up? 18 memory - what is it that you saw with Epstein 18 MS. No. 19 when you ave him the food? 19 MR. : Where was he located? 20 MS. IIII: He gets like microwaveable 20 MS. on the floor. On a mattress. 21 food. So I just handed it to him. Through the 21 MR. : So he was like sleeping? 22 slot. And he took it. 22 MS. He was laying on the floor on 23 MR. : Okay. And any instances 23 the mattress and he had the machine. 24 where you saw him from the shower to the last 24 MR. : And he had the machine on 25 time you said you saw him between 10:00 and 25 him? 359 360 1 MS. : Mm-hmm. 1 floor. 2 MR. : Okay. 2 MR. : Yep. 3 MR. : When you looked through his 3 MS. : Well he shoves it to the 4 window. 4 corner. 5 MS. Mm-hmm. 5 MR. : And he was laying on - 6 MR. : Right. What of his body 6 was he laying on it like the direction of the 7 could you see? 7 mattress lines? 8 MS. IIII: Um his head, his hand, and like 8 MS. IIII: That the mattress is going. 9 maybe to mid-there. 9 Yeah. 10 MR. : The best of the body was -? 10 MR. : Alright. So he wasn't 11 MS. Like under his head. Mm-hmm. 11 like L or a T shape -- 12 MR. : So he was laying facing the 12 MS. No. 13 wall? 13 MR. • -- with the -. 14 MS. IIII: Yeah. He was facing like this 14 MS. 15 big (Indiscernible *04:18:24) is this way. The 15 MR. Alright. So he was like 16 mattress was here on the floor. Like in front 16 17 of the bunk on the floor. 17 MS. : Direction of the mattress. 18 MR. : And the CPAP machine was it 18 MR. : Okay. You want to ask 19 already attached to him? 19 more on that? 20 MS. : Yeah. He had it on. 20 MR. M.o. lust had that quick. 21 MR. : I'm not following what 21 MR. : And you said to your 22 you're saying about that. So the mattress was 22 knowledge, no one else saw him between the time 23 laying like -. 23 you last saw him and when discovered 24 MS. IIII: The mattress was like how you 24 him. 25 just take it off the bunk and you put it on the 25 MS. IIII: Right. EFTA00117732 361 362 1 MR. Did you hear anything 1 is that a door that is closed? Was it closed 2 from Epstein's cell between 10:30 p.m. and 6:33 2 or was it_aptn? 3 a.m.? 3 MS. IIII: I opened it. And then 4 MS. : No. 4 goes in. 5 MR. : No like movement, 5 MR. Okay. So was it open 6 talking, or a crash? 6 when entered Epstein's cell? 7 MS. No. 7 MS. I opened it. I opened the 8 MR. Anything like that? And 8 grill for him in. 9 about how far were you from Epstein's cell when 9 MR. : Right. And did it remain 10 went in? 10 open? 11 MS. IIII: I don't know. The grill is 11 MS. but I'm -. 12 right here and the door is right here. 12 MR. Or did you close it 13 MR. So I mean is it like - so 13 behind you? 14 this is a foot, this is two feet, this three 14 MS. IIII: No. I'm standing there so it's 15 feet. 15 open. 16 MS. : A foot. 16 MR. So you're only a foot 17 MR. A foot? 17 away from E stein's cell door though? 18 MS. : From the grill to the door 18 MS. Yes. 19 right here. But he's inside. So. 19 MR. And you never looked in? 20 MR. Right. 20 MS. 21 MS. . I'm not in there. So from the 21 MR. Was it because - why 22 grill to the actual door about a foot. 22 didn't you look in? 23 MR. • Only about a foot? 23 MS. IIII: Because usually the door is not 24 MS. Yes. 24 open. His intentions is to feed. So he would 25 MR. Now was the grill door - 25 just open the slot and put the food in. When 363 364 1 he knocked, he didn't get no answer. So that's 1 away from E stein's door? 2 when opened the door and went in. I 2 MS. : Ma be like two three minutes. 3 stood on the grill. And as soon as he opened 3 MR. So you were there for two 4 the door and he went in, he started screaming, 4 or three minutes while he was conducting CPR? 5 "Get the cutter!" So I hit the body alarm 5 MS. Yes. 6 because I have to - when everybody's coming, I 6 MR. And at that time, never 7 have to let them in. I never went in. 7 once did you actually look in to see what he 8 MR. : Okay. So after he made 8 was doing? 9 the call, did you go get the cutter and bring 9 MS. : No. 10 it back to him? 10 MR. : Even though it was just a 11 MS. IIII: No. I didn't get the cutter 11 foot away? 12 because he didn't need it. 12 MS. Ri ht. 13 MR. Because he ripped 13 MR. And that's what I'm 14 something? 14 asking you. 15 MS. : Yes. 15 MS. IIII: No by that time, when he's 16 MR. : And you actually heard it 16 conducting CPR, I can see because he lowered 17 rip? 17 him to the floor and I could -. 18 MS. : I heard the rip. 18 MR. : And that's what I'm 19 MR. : Okay. And the reason why 19 asking. So you could see him lower him to the 20 - and then you left the grill to go let people 20 floor? 21 in? 21 MS. IIII: Yeah. I could see when he 22 MS. : Yes. 22 lowered him to the floor. 23 MR. : Alright. So how long 23 MR. : This is where I want to 24 after Mike went into the room did you 24 make sure that we're -. I'm asking you what 25 leave the grill station door that was a foot 25 could you see inside? EFTA00117733 365 366 1 MS. IIII: Oh no. I can't see inside the 1 MS. IIII: I only see -. It's just like 2 cell. I could onl just see doing CPR. 2 this. He's holding him like this. And he puts 3 MR. : But you saw him lower him 3 him to the floor to start CPR. 4 to the floor? 4 MR. : Did he put his arms 5 MS. IIII: Yes. He lowered him to the 5 underneath_Lestein's arms? 6 floor and I -. 6 MS. IIII: I don't remember how he held 7 MR. : So this is what I want to 7 him directly. But he just lowered him to the 8 know. What did you see? So what you could see 8 floor. I don't remember how he - the details 9 from where you were standing? What could you 9 of how he lowered him to the floor. 10 see? Everything. Because I'm getting confused 10 MR. : So he - somewhere on his 11 with what you're telling me. I thought you 11 upper body then lowered him to his like butt to 12 said you never looked in. You never saw 12 the floor? 13 anything. What did you see? From the moment 13 MS. : Yes. 14 the medical emergency occurred. So he walked 14 MR. : And then he then allowed 15 to the door -. 15 him to dri2p?_ Or did he place him -? 16 MS. : When he -- 16 MS. IIII: No. He didn't allow him to 17 MR. : -- what do you see? 17 drop. He had him all the way. 18 MS. : -- goes in the door first, I 18 MR. : So at all times he 19 don't see anything. I hear the rip and then he 19 maintained control of Epstein's body and brough 20 lowers him to the floor -- 20 him to the floor? 21 MR. : Okay. So just back up -. 21 MS. : Yes. 22 What do you mean by lowering him to the floor? 22 MR. : And you witnessed all of 23 Did you watch him rip or just heard? 23 this? 24 MS. : I heard the rip. 24 MS. IIII: I just only witnessed when the 25 MR. Okay. 25 top part of his body went to the floor. 367 368 1 MR. Okay. And at any time 1 his upper body is up. And that's when you 2 did like - and we have to ask this just because 2 witnessed him now bringing him down to the 3 of you know, the autopsy and things like that. 3 floor? 4 Did his head smash against the floor? 4 MS. IIII: He brought him down to the 5 MS. • No. 5 floor. I can't see that other half of his 6 MR. Alright. So everything 6 body. So I don't know. lust -. 7 was like a entle like -- 7 MR. : What part of his body do 8 MS. • Yes. 8 you see? 9 MR. -- fluid movement? 9 MS. IIII: Just the top part like torso up 10 MS. Yeah. 10 and he's brio in him down. 11 MR. . From you heard it rip. 11 MR. : Alright. And then did 12 Did you ever hear like [sound)? Hear him like 12 you see him -? When you say CPR, what kind of 13 land on the floor? 13 CPR was he iving him? 14 MS. • No. 14 MS. : Chest compression. 15 MR. . So you didn't hear like 15 MR. Any kind of mouth-to- 16 alright, he ripped this thing. So you think he 16 mouth of breath? 17 ripped it and then maintained control of him? 17 MS. • No. 18 MS. IIII: Probably. I didn't see that 18 MR. Did he ever check for his 19 part. I iiiiiiiiiiheard the rip. 19 vitals? Did he ever check to see if he was 20 MR. : Alright. But you did see 20 alive first? 21 -. Did you see his body after the rip hit the 21 MS. I don't know. 22 floor? 22 MR. . You don't know. Did you 23 MS. No. 23 witness him check for breath or check for a 24 MR. Alright. So he's on the 24 pulse? 25 floor. Maybe like his butt's on the floor and 25 MS. IIII: I didn't see that. EFTA00117734 369 370 1 MR. You didn't see either? 1 MS. IIII: Get the cutter. And then I 2 MS. : No. I just seen him giving 2 heard the rip. He lowered him to the floor. 3 compressions. 3 He was doing CPR. He said, "breathe Epstein 4 MR. Alright. Did you see him 4 breathe" and he said we're going to be in so 5 like try to wake him up or hit him or anything 5 much trouble. But I never said anything. 6 like that? 6 MR. You didn't respond to 7 MS. No. lust compressions. 7 "we're goin to be in so much trouble"? 8 MR. Did you have any 8 MS. : No. 9 communication with while he was doing 9 MR. Do you know why he said 10 this? 10 you're goin to be in so much trouble? 11 MS. : No 11 MS. Because we didn't the count. 12 MR. What were you saying 12 MR. Okay. 13 about we're going to be in so trouble. When 13 MS. GREGG: I think it's important though 14 was that -? 14 that you convey to him like - that you didn't 15 MS. Eir said that. 15 understand the magnitude of what had just taken 16 MR. That's what I'm asking. 16 place. Right? Because that's something that 17 Did you have a conversation - did you have any 17 you had expressed. So like not knowing what a 18 communication with -? 18 cutter was. And maybe that gives insight into 19 MS. Oh no. No. 19 why there wasn't a more in-depth conversation. 20 MR. Well you did have that 20 I think it's important that -. 21 right? 21 MS. IIII: Yeah. When he said to get the 22 MS. IIII: No he said we're going to be in 22 cutter, like I would have to go try to look for 23 so much trouble. I didn't say anything. 23 where a cutter was. But he didn't need it 24 MR. Okay. So what statements 24 because I heard the rip. And then when he said 25 did he make to you? 25 we was going to be in so much trouble, like I 371 372 1 still wasn't thinking like the trouble that 1 open? 2 we're in now. I was just probably thinking 2 MS. : The grills. 3 because I know we didn't do the count. But I 3 MR. : That's it? 4 never responded because all the inmates by this 4 MS. : There's other keys. The grill, 5 time are on the door. 5 the front door, that middle door, but not the 6 MR. Because they're all 6 inside cell door key. 7 watching? 7 MR. : That's with 8 MS. Yeah. 8 MS. Yes. 9 MR. This all take place? 9 MR. : Now when you look inside the 10 MR. : I've got a question. 10 cell, you said you could see only Epstein's 11 MR. Yeah. Go ahead. 11 upper body__Where was he hanging? 12 MR. : You said you opened the -- 12 MS. IIII: I don't know. I didn't see 13 MS. The grill. 13 that part. 14 MR. -- the grill. Did he have 14 MR. : And when you heard the thud, 15 keys to o en Epstein's cell? 15 or you know, the rip and then the body landing. 16 MS. Who 16 Did you look inside to see what he was doing? 17 MR. 17 MS. IIII: When he - when the body -. 18 MS. : Yeah. He as the door keys. So 18 Because when he lowered the body, he stepped 19 there's two separate set of keys? 19 back like to come like it's almost like he was 20 MS. Yes. 20 backing up because you're bringing him down. 21 MR. : So he - that's the keys that 21 So that's how come I was able to just see that 22 stayed with him the whole time? 22 part. But I didn't like to go look in the 23 MS. Yes. 23 cell. I was still on the grill. 24 MR. : But those door keys -. So on 24 MR. : So that's what I was trying 25 the keychain that you have. What does that 25 to understand. Where exactly was he hanging? EFTA00117735 373 374 1 MS. IIII: I don't know that because I 1 MR. So not even like a ripped 2 don't know where he took him down from. I just 2 shirt? Nothing was on? 3 only heard the rip and then when he was walking 3 MS. : He didn't have a shirt on. 4 the body like down. 4 MR. : Okay. At that time when 5 MR. : So he was - basically his 5 you saw him, did you see anything around his 6 arms were behind Epstein? 6 neck? 7 MS. IIII: Right. And he was bringing 7 MS. : N 8 him -. 8 MR. And when you say no, are 9 MR. : And he was pulling him up? 9 you saying_/here was nothing around his neck? 10 MS. -- bringing him down. 10 MS. fl: No. There was nothing around 11 MR. : Was there a mattress on the 11 his neck. 12 floor? 12 MR. : So there was nothing 13 MS. IIII: Well I'm assuming because the 13 around his neck? Okay. What did he look like? 14 mattress was on the floor earlier. But I don't 14 MS. : Blue. 15 know. 15 MR. : He looked blue? Did he 16 MR. So from where you were 16 look like bloated or puffy or anything? 17 standing, ou couldn't see the actual mattress? 17 MS. No. 18 MS. : Mattress? No. 18 MR. Did he look like he was 19 MR. SO he wasn't doing CPR 19 deceased? 20 like on to of the mattress? 20 MS. : His face looked blue. But. 21 MS. : No. Not that I can remember. 21 MR. Any reason for you to 22 MR. Do you remember what 22 believe that he was alive? 23 Epstein was wearing? From what you could see 23 MS. 24 from his -? 24 MR. No? Did you see any kind 25 MS. IIII: He didn't have a shirt on. 25 of breath or anything? 375 376 1 MS. : No. 1 MR. : And you said you don't 2 MR. : No? What did his cell 2 know if actually checked to see if he 3 look like from what you could see? 3 was alive? 4 MS. IIII: I wasn't really looking at his 4 MS. : Yeah. I don't know. 5 cell. By that point I was just looking at 5 MR. : You just know he went 6 doing CPR. I didn't look in there to 6 straight into compressions. And did you say 7 see what was oin on. 7 you were two or three minutes that you stood 8 MR. : Okay. So you didn't 8 there? How long were you actually at the grill 9 notice an thing like unusual in his cell? 9 when they walked into the door? 10 MS. : No. 10 MS. IIII: When I went to go get them to 11 MR. : When went to his 11 come in the door? Between the time - 12 door, did you notice if he actually had to use 12 MR. : So you let -. 13 his key to open it? Or was it - do you know if 13 goes in. He goes into the room. He's making 14 it was actually already -? 14 these - you know you're watching him do some 15 MS. : He used a key to open it. 15 compressions. He makes the statement, "we're 16 MR. : So are you confident that 16 going to be in so much trouble." How long are 17 that door was locked? 17 you standiag_there while you're observing this? 18 MS. IIII: Yes. Because he knocked. And 18 MS. IIII: About one to two minutes. 19 then he used the key to open it. He knocked. 19 Because I'm waiting for - the radio is going to 20 He knocked. He didn't get a response. And 20 tell me when everybody's -. Because remember, 21 then he used the key to open. 21 once I hit that button, everybody's coming. So 22 MR. : Was there any indication 22 the radio is going to tell me when everybody's 23 that any of the other inmates could have gotten 23 at - when they're at the door. And then when I 24 out of their cells? 24 pop the door and let them in. So I go to the 25 MS. IIII: No. 25 door. EFTA00117736 377 378 1 MR. And you never entered 1 MR. Okay. What did you 2 Epstein's cell? 2 observe from the bottom of the stairs? When 3 MS. . No. 3 people arrived? 4 MR. : Who was the second person 4 MS. IIII: They got a stretcher. And they 5 to enter E stein's cell? 5 put him on the stretcher. And brought him out. 6 MS. IIII: That I don't remember because 6 MR. Did anyone take over for 7 everybody came right at the time I don't 7 the CPR efforts that was doing? 8 remember. 8 MS. : I don't remember. 9 MR. Okay. So you don't 9 MR. You don't remember seeing 10 remember the first person on the scene? 10 this? So this isn't something that's vivid in 11 MS. : No. 11 your memory? You know like this whole big 12 MR. Did you assist at all 12 occurrence. You're not almost like you're 13 with the medical emergency? 13 playing it in slow motion? 14 MS. 14 MS. : No. 15 MR. . No? So what actions did 15 MR. The details of it? 16 you take after people arrived? What did you 16 MS. : No because when was 17 do? 17 doing CPR. Then when they came, they took the 18 MS. IIII: Nothing. They told me to get 18 stretcher and put him on the stretcher and 19 out the wa . 19 left. As far as when they're -. Remember it's 20 MR. : So did you like leave the 20 a lot of people. So I'm not really seeing like 21 tier? 21 who's twoliiiiiiiiihey're coming out with him. 22 MS. IIII: I was on the bottom of the 22 MR. : About how many people 23 stairs. Mm-hmm. 23 responded? 24 MR. Like observing? 24 MS. IIII: Mm. I don't know. Maybe 10, 25 MS. : Mm-hmm. Yes. 25 15. 379 380 1 MR. And they didn't know what 1 between an inmate altercation versus a medical 2 they were responding to? They just knew it was 2 emergency? 3 a medical emergency. It wasn't announced that 3 MS. IIII: I mean the person that's 4 it was Epstein. 4 hitting the body alarm can say it. But there's 5 MS. IIII: No. There ain't nobody that 5 no differentiation. So either way the response 6 (Indiscernible *04:31:48). 6 is the same. 7 MR. : And is that typical for 7 MR. : So you could have said 8 10 to 15 people to respond? To a medical 8 it. You ,Ls didn't say anything. 9 emergency? 9 MS. IIII: Like when I hit the button, I 10 MS. IIII: It - there's no number. It's 10 could have said a medical emergency on the 11 when - whoever is in the building and the body 11 radio. Yeah I could have said that. 12 alarm goes off once you're not in a post - 12 MR. But you didn't. 13 because when you're on a post you can't leave 13 MS. No because it's the same 14 your post. But everybody else in the building 14 response. 15 responds. 15 MR. Right. 16 MR. And they just leave 16 MS. Mm-hmm. 17 wherever the were? To respond? 17 MR. Has anybody ever hit it 18 MS. : Yes. 18 accidentall 19 MR. Okay. 19 MS. Yes. And same thing. 20 MR. I've got a question. 20 MR. And people just rush? 21 MR. Go ahead. 21 MS. Everybody comes. Yes. 22 MR. : When a body alarm is hit, who 22 MR. Okay. Alright. You said 23 gets notified? 23 you stood there for a little while on the 24 MS. : Control. 24 bottom of the steps. You observed some people 25 MR. : And how do they differentiate 25 going in. You don't know who took over CPR. EFTA00117737 381 382 1 You just saw 1 MS. IIII: After they took him out on the 2 MS. : I don't know. 2 stretcherj_tg_l_tL 3 MR. -- who put up. Do you 3 MR. IIIIIIIIII: So not after the 4 remember who put him on a stretcher? 4 stretcher. Once at least one person showed up. 5 MS. : I don't know. 5 Do you know what did? 6 MR. Did you see the body like 6 MS. IIII: No because I'm at the bottom of 7 fall or an thing going on the stretcher? 7 the stairs. So I don't know. Because they're 8 MS. : No. 8 - remember they're on the top. I'm at the 9 MR. Did he ever fall off of 9 bottom. So I don't know. 10 the stretcher? 10 MR. : So could you even see in 11 MS. : 11 at all at that point? 12 MR. Did anyone drop the 12 MS. IIII: No. I could only see when they 13 stretcher? 13 coming down with him on the stretcher. Because 14 MS. 14 I'm at the bottom. I can't see up there now. 15 MR. . When they were moving 15 MR. : Okay. So after you were 16 him, did you see him like get knocked or 16 standing there when you let people in, you 17 anything like that? 17 really couldn't see in the door anymore? 18 MS. : No. 18 MS. : No. 19 MR. : No? Anything then - did 19 MR. Okay. What happened 20 you notice anything that could have caused 20 after the came out with the stretcher? 21 additional injuries to his body aside from what 21 MS. They left out of SHU with him. 22 the hangin would have caused? 22 MR. Did you go with them? 23 MS. : No. 23 MS. I had to stay. 24 MR. : No? What did do 24 MR. You stayed in SHU? Did 25 after people responded? 25 anyone stay with you? 383 384 1 MS. 1 MS. IIII: Yeah. But I don't remember who 2 MR. . So you were there alone? 2 came in first. But he was there. When 3 MS. Alone. 3 was there I remember 4 MR. And what did you do at 4 MR. 5 that time? 5 MS. Yes. 6 MS. IIII: I kept calling control. Like 6 MR. Do you know how to spell 7 what's going on? And they was like somebody's 7 that last 8 going to come like to help you. Because 8 MS. 9 remember we were supposed to feed. 9 MR. Okay. And did you say 10 MR. Who was it -? How long 10 anything to the people that arrived? 11 were you in the SHU by yourself after they 11 MS. : No. 12 left? 12 MR. : You didn't say like it's 13 MS. Um... Maybe like 20 - 15 or 20 13 Epstein of_&2stein hung himself or anything? 14 minutes. 14 MS. IIII: No. The only thing they asked 15 MR. So just -. Do you 15 -. Because when they come on, they want to 16 remember if -? Now I want to say these names 16 know where the emergency is. So I just pointed 17 to make sure that they were actually there. Do 17 up the stairs. 18 you remember if the fir2I22Lon to arrive in 18 MR. : Okay. Did you make any 19 the SHU was Lieutenant =I M? Does that 19 statements to anybody about saying we didn't do 20 help spark a recollection of who arrived first 20 rounds at 3:00 a.m. and 5:00 a.m.? 21 since you were the one that let them in? 21 MS. IIII: No. After Lieutenant IIII 22 MS. IIII: When the medical -. I don't 22 asked me what happened. When I was getting 23 know who arrived first. But he was in there. 23 ready to answer him, came off the 24 MR. : Because you're the one 24 elevator and was like, "Oh it's not her fault. 25 that had to let them in. Right? 25 We fucked up." EFTA00117738 385 386 1 MR. So at first did you say, 1 came back from bringing Epstein down? 2 "We didn't do rounds at 3:00 a.m. -- 2 MS. IIII: Well he went down with them. 3 MS. No. 3 Yes. 4 MR. -- and then he responded 4 MR. : And then he came back? 5 it's not your fault we didn't do the rounds we 5 So when you say by the elevator where was the 6 messed up? 6 elevator? 7 MS. : No. I didn't say that. 7 MS. : In the hallway. 8 MR. So that's not your 8 MR. Outside the SHU? In the 9 recollection that you saying we didn't do the 9 SHU? 10 3:00 a.m. and 5:00 a.m. rounds? 10 MS. IIII: Like right the door the first 11 MS. : No. 11 door. 12 MR. : Okay. So they're saying 12 MR. : The first door of what? 13 that you said that. Do you think that they're 13 MS. CThe: SHU. 14 mistaking? That you told them that? 14 MR. : So is that outside of the 15 MS. : I don't recall saying that. 15 SHU? 16 MR. : Okay. So you don't 16 MS. IIII: Like right outside the door. 17 recall. But is it possible that you could have 17 The SHU door. 18 said that? 18 MR. Outside of the second 19 MS. IIII: Probably but I don't recall 19 outer door? 20 saying that. I remember Lieutenant asked 20 MS. : Yes. 21 me what happened. And I was getting ready to 21 MR. So right outside of the 22 tell him what happened. And came off 22 outer door? This is where you had a 23 the elevator and said that. But I don't recall 23 conversation with who? 24 saying that. 24 MS. : Lieutenant IIII. 25 MR. And this is after 25 MR. Who else was present? 387 388 1 MS. IIII: Nobody else. Just me, him, and 1 MR. From 12:00 a.m. to 6:33 2 2 a.m. That's not actually my question. From 3 MR. Okay. And he asked you 3 12:30 to 6:30 a.m., none of the rounds or 4 what happened? 4 counts were completed. Correct? 5 MS. IIII: He asked me whatt!pkened. And 5 MS. : Correct. 6 the elevator door opened. And came off 6 MR. : Alright. Is it true that 7 the elevator. I was getting ready to answer 7 end of the shift the supervising lieutenant 8 him. And said, "It's not her fault. We 8 signs and sends the completed log of the inmate 9 fucked up." 9 movements from the day? Do you know if that's 10 MR. And do you know why he 10 true? 11 made that statement? 11 MS. IIII: I don't know what they sign, 12 MS. IIII: I think because we didn't do 12 but they sign something. I don't know what it 13 the counts. Or he -. 13 is. 14 MR. : But why did he say it 14 MR. Do they sign like for 15 wasn't your fault? 15 instance the round sheets? Do the lieutenants 16 MS. IIII: Because I kept waking him up. 16 sign that? 17 So maybe that's why he said that. 17 MS. : Yes. They sign that. 18 MR. : Was he trying to take 18 MR. But they don't sign the 19 more of the responsibility? 19 count sli s do they? 20 MS.'Suess so. 20 MS. : No. 21 MR. : Would that be? Um. 21 MR. lust the round sheets? 22 Alright. Is it true that if the count is not 22 MS. 23 done and the round sheet which is filled out 23 MR. Okay. And what is your 24 after 30 minutes also cannot be completed? 24 belief or understanding of how Epstein died? 25 MS. IIII: If the -? 25 MS. IIII: Mm. He hung himself. EFTA00117739 389 390 1 MR. So you believe he was 1 MS. : No. 2 dead upon entering into the cell? 2 MR. : Did you have any part in 3 MS. : I don't know. Because I just 3 Epstein's death? 4 assumed he hung himself. Because I read the 4 MS. : No. 5 (Indiscernible *04:38:24). 5 MR. Prior to Epstein dying, 6 MR. So do you believe Epstein 6 did you have any communications - verbal, 7 took his own life? 7 electronic, handwritten, or otherwise - with 8 MS. : Yes. 8 anyone - BOP staff members or otherwise, about 9 MR. Did someone else take 9 the safet and wellbeing of Epstein? 10 Epstein's life? 10 MS. : No. 11 MS. : N 11 MR. : Alright. Do you need me 12 MR. • Did anyone assist Epstein 12 to -? That was pretty long. Did you catch 13 with takin his life? 13 everythin I just asked you there? 14 MS. : No. 14 MS. : Yes. 15 MR. = : Did take Epstein's 15 MR. : This is going to be 16 life? 16 another long one. Prior to Epstein dying, did 17 MS. : N 17 you have any communications - verbal, 18 MR. . Did assist Epstein 18 electronic, handwritten, or otherwise - with 19 with takin his life? 19 anyone - BOP staff members or otherwise -. And 20 MS. : Na. 20 when I say otherwise I mean like civilians, 21 MR. : Did you assist Epstein 21 inmates, ou know anybody on the streets. 22 with takin his life? 22 MS. : Okay. 23 MS. : No. 23 MR. : About the death of 24 MR. = : Did you take Epstein's 24 Epstein or taking Epstein's life? 25 life? 25 MS. IIII: No. 391 392 1 MR. Did anyone ever offer you 1 MR. Did you - but it kind of 2 anything such as something of value or favors 2 doesn't surprise me because you said that you 3 with regard to harming Epstein or taking his 3 didn't even know who was in what cell. You 4 life? 4 just looked to see if people -. So Epstein is 5 MS. : No. 5 assigned to the cell across the hall. He 6 MR. : Did anyone ever threaten 6 wasn't in the cell that he was actually 7 you in exchange for harming Epstein or taking 7 assigned to. Do you -? 8 Epstein's life? 8 MS. IIII: Wait. You said across the 9 MS. : No. 9 hall? So like not in SHU? 10 MR. Do you know anyone else 10 MR. The same tier. But you 11 that those uestions would have applied to? 11 know -- 12 MS. : No. 12 MS. 0 13 MR. Do you know of anyone 13 MR. -- they do inmate cell 14 else being offered anything to hurt Epstein or 14 rotations? 15 taking his life? 15 MS. 16 MS. : No. 16 MR. • So you do not know that 17 MR. No? Why wasn't Epstein 17 inmates are moved from different cells? 18 in his assi ned cell on August 10, 2019? 18 MS. IIII: Yeah. I know that. They move 19 MS. That was his cell. 19 you said if I know how they do that? I don't 20 MR. It wasn't. This is the 20 know that. 21 first you're hearing of that? 21 MR. • Do you know how often? 22 MS. 22 MS. : Often they do that? I'm not 23 MR. So he wasn't in his 23 sure. 24 assigned cell. 24 MR. Are you responsible for 25 MS. IIII: What? I never knew that. 25 reviewing - as your assignment, duties, and EFTA00117740 393 394 1 responsibilities within the SHU - of verifying 1 MS. IIII: So you said he was assigned to 2 that the inmates are in the cells that they're 2 the cell across from him? Because that had 3 assigned to? 3 people in it. 4 MS. IIII: I don't know if I'm responsible 4 MR. : He was - yeah. Because 5 for but there is -. Their ID cards are on the 5 of cell rotations. It doesn't mean that -- 6 door. 6 MS. : Oh okay. 7 MR. : Was Epstein's ID card on 7 MR. : I think as far as you 8 his door? 8 were concerned, he was in that cell. You 9 MS. No. Not all of them. 9 didn't move him to a different one. But 10 MR. : Okay. Was there anything 10 administratively, he was in a different cell 11 else on the door? 11 and was moved and the assignment didn't follow 12 MS. No. 12 him. 13 MR. : Was there anything on the 13 MS. Oh, okay. 14 door that said something about him being 14 MR. : So on paper, he was 15 required to have a cellmate? 15 supposed to be in one cell. In reality he was 16 MS. : No. 16 in another. 17 MR. : So you don't know 17 MS. : Okay. 18 anything about him not being in his assigned 18 MR. : So if you look in the 19 cell? 19 system and find out hey where was Epstein 20 MS. : I never knew that. 20 supposed to be? He was supposed to be over 21 MR. : Okay. So this is the 21 here from the paperwork in the book. 22 first you're even hearing about it even since 22 MS. Oh okay. 23 the incident? 23 MR. : He was physically located 24 MS. Ri ht. 24 over here. 25 MR. : So you -? 25 MS. IIII: Okay. 395 396 1 MR. Did you ever have any 1 different cells? 2 dealings with that? 2 MS. : One time. 3 MS. I never even knew that. 3 MR. : One time? And how was 4 MR. so is this the one he was 4 that - how does that playpjf__ 5 s actuall 5 MS. Il think - the day when 6 MR. : Yeah. 6 I saw it, was doing it. Like I don't 7 MR. : So he was in cell 220. 7 know. They told them to pack up. They pack up 8 He was assi ned to cell 206. 8 they stuff, two people move them, and they go 9 MS. : Mm. 9 to the cell that they supposed to go. 10 MR. : But that's not something 10 MR. : And then do you know what 11 you dealt with? 11 they're supposed to do at that point with - in 12 MS. . No. 12 order to make sure the paperwork follows them - 13 MR. Did you ever deal with 13 14 rotating the inmates into different cells? 14 MS. : Oh. I don't know -- 15 MS. . No. 15 MR. -- to that cell? 16 MR. Do you know who deals 16 MS. • -- about the paperwork. 17 with that? 17 MR. Do you know who is 18 MS. : No. 18 responsible for that? 19 MR. : Do you ever see them get 19 MS. : No. 20 rotated? 20 MR. : Would it be the 21 MS. : On the 8:00 to 4:00. 21 lieutenant in your opinion? Or you just don't 22 MR. : While - yeah. That's 22 know. 23 what I'm asking. I'm not saying just for 23 MS. I ust don't know. 24 Epstein. I'm saying like in general, have you 24 MR. Okay. And is that 25 ever witnessed inmates being rotated to 25 anything you've ever dealt with as far as like EFTA00117741 397 398 1 training or that you recall? 1 MR. : Downstairs? 2 MS. : The cell rotation? No. 2 MS. On I think M tier with 3 MR. : Do you know if it's 3 . Because that was his cellmate 4 supposed to be every certain amount of days? 4 first. 5 MS. IIII: I know it's supposed to be 5 MR. : Alright. So what about 6 every certain amount of days, but I don't know. 6 on L Tier? You ever remember him being in a 7 MR. : Do you remember Epstein 7 different cell up there? 8 ever bein2_21signed to cell 206? 8 MS. No. 9 MS. IIII: I don't know where cell 206 is. 9 MR. : No? 10 That's the one across from where he was at? 10 MS. 11 MR. : They're both on L Tier, 11 MR. : Alright. So. So the 12 so I'm just assuming. 12 incident happened on July the 23rd. 13 MS. : Oh. 13 He comes back on July 30th. From your 14 MR. : Because there's the 14 recollection from eh time that he came back and 15 paperwork that shows that's not even the 15 he was with , he was always in that same 16 number. 16 cell? 17 MS. IIII: Yeah. The number is not on 17 MS. IIII: And in that (Indiscernible 18 here. I don't know what cell is 206. But -. 18 *04:44:20 cell? 19 MR. : So when you're in the SHU 19 MR. : Alright. So maybe he 20 in July and August when he was - when Epstein 20 wasn't rotated but on paper it was rotated? 21 was assigned to the SHU. Do you recall him 21 MS. : Ma be. 22 ever being in a different cell than the cell 22 MR. : But you don't know 23 you found him in - or round him in on 23 anything about it? 24 August 10th? 24 MS. I don't know anything. No. 25 MS. IIII: Yes. He was downstairs. 25 MR. : Okay. Do you know what 399 400 1 BOP database tracks that? 1 medication? 2 MS. : No. 2 MS. : I don't know. 3 MR. : Why were there pill 3 MR. Do you ever provide 4 bottles found on the top bunk of Epstein's 4 inmates prescription medication when you're 5 cell? 5 working in the SHU? 6 MS. : I don't know. 6 MS. : No. The nurse does. 7 MR. : Do you know anything 7 MR. The nurse comes around? 8 about like medication or what was found in 8 MS. Yeah. 9 there? 9 MR. So is that surprising to 10 MS. : No. 10 hear that there were medication in his cell? 11 MR. : Do you have any idea what 11 MS. : Yes. 12 was even -? Did you ever go in Epstein's cell 12 MR. : And you knew nothing 13 prior to this incident? 13 about that being in there? 14 MS. : No. 14 MS. : No. 15 MR. : Do you know if Epstein 15 MR. : Is it SHU policy for 16 was authorized to have pills in his cell on the 16 things like medication - is it different than 17 SHU? 17 the other housing units? 18 MS. : I don't know. 18 MS. IIII: Yes because I think on housing 19 MR. : Do you know if that's 19 units they can have prescription medication in 20 like abnormal or are inmates allowed to have 20 their cell. 21 medications in the SHU? 21 MR. Okay. 22 MS. : No. 22 MS. But in SHU they can't. 23 MR. • They're not allowed to? 23 MR. And do you know that to 24 MS. : They're not allowed. 24 be a fact? Or is that just your belief? 25 MR. Even if it's prescription 25 MS. IIII: I don't know it to be fact. EFTA00117742 401 402 1 MR. Okay. Do you know if any 1 MS. IIII: I never gave out linen. Ever. 2 other inmates in the SHU are allowed to have 2 Because that's done on the shift prior. 3 medications in their cell? 3 MR. : What shift is that? 4 MS. : I don't know. 4 MS. : 8:00 to 4:00. 5 MR. : How many changes of 5 MR. : And did you ever work the 6 clothing and linens are inmates allowed to have 6 8:00 to 4:00 shift? 7 in the SHU? 7 MS. IIII: Yes. But I worked the 8:00 to 8 MS. : I think one. 8 4:00. When I come in to do overtime before. 9 MR. It's supposed to be a 9 But it's nc naya in SHU. 10 one-for-one exchange? 10 MR. IIIIIIIIII: Okay. So have you ever 11 MS. : Yes. 11 worked 8:00 to 4:00 in the SHU? 12 MR. for both linens and 12 MS. : I think I have. 13 clothing? 13 MR. : And do you remember doing 14 MS. IIII: For linen. I'm not sure with 14 giving - doing the linens? 15 clothing. 15 MS. : I never gave linen. 16 MR. Okay. Why did Epstein 16 MR. : You never gave linens. 17 have extra clothing and extra linens in his 17 MS. Never. 18 cell -- 18 MR. What about the clothing? 19 MS. I don't know. 19 MS. e. Never. 20 MR. -- on August 10th? 20 MR. When is that done? 21 MS. I don't know. 21 MS. I give toilet paper. Say that 22 MR. : You don't know. But you 22 again? 23 said that was something that you did though? 23 MR. When is the clothing 24 As far as your duties? Is to be able to 24 done? 25 provide people with linens and clothes? 25 MS. I don't know. 403 404 1 MR. No? And did you ever 1 MS. : Because I never saw it. No. 2 provide Epstein with additional clothing or 2 MR. : Okay. And when you're 3 linens? 3 looking in doing your counts and your rounds, 4 MS. : Never. 4 are you looking for things like that? Of like 5 MR. : Do you know of anyone 5 6 that has? 6 MS. : Not really. 7 MS. 7 MR. : You're just looking for 8 MR. You never witnessed 8 the person? You're not looking to see what's 9 anyone provide him anything extra? 9 going on in their cell? 10 MS. : No. 10 MS. IIII: Correct. Sometimes they don't 11 MR. : Do you know if providing 11 even let you see their cell. They're like 12 inmates with extra clothing and linens is a 12 standing in the window blocking the window. 13 security risk? 13 MR. : But it's your 14 MS. : I don't know. 14 understanding though it's supposed to be a one- 15 MR. : No? If you saw that an 15 for-one exchange? 16 inmate had extra clothing or linens, would you 16 MS. : Yes. 17 do anythin about it? 17 MR. Do you know what material 18 MS. : I mean I'd ask. 18 was used to take Epstein's life in August of 19 MR. : Who would you ask? 19 2019? 20 MS. The officer I'm working with. 20 MS. : I don't know. 21 MR. : And did you ever have to 21 MR. • Do you know if Epstein 22 do that? 22 was given any special privileges to have extra 23 MS. : No. 23 clothing? 24 MR. : So you never witnessed 24 MS. : I don't know. 25 anybody? 25 MR. : If he was, do you know EFTA00117743 405 406 1 who would rovide that? 1 MR. Do you want to - have 2 MS. • I don't know. 2 any? We're almost there. Well while I'm going 3 MR. : Do you know if there was 3 thought the uestions can you just find that? 4 anything else that was in Epstein's cell that 4 MR. : Yeah. 5 should not have been here? 5 MR. : Have you ever heard that 6 MS. : Only the CPAP machine. 6 during your shift you're supposed to conduct 7 MR. : Okay. Tell me about cell 7 five cell searches? 8 searches. What are the requirements for when - 8 MS. : No. 9 you said your typical shift is I guess the 9 MR. Random cell searches? 10 afternoon shift? Right? Or do you call it 10 MS. 11 evening shift I guess? 11 MR. . Did you ever witness 12 MS. Yes. 12 anybody conducting cell searches when you -- 13 MR. Is that the 4:00 to 13 MS. • No. 14 10:00? 14 MR. -- were working the SHU? 15 MS. : 4:00 to midnight. 15 MS. 16 MR. : 4:00 to midnight. Sorry. 16 MR. No. Do you know if any 17 What are the cell search requirements during 17 cell searches were conducted on August 9th or 18 that shift? 18 August 10th? 19 MS. I don't know. 19 MS. 20 MR. Did you ever read the 20 MR. Do you know what a cell 21 post orders with regard to that? 21 search is? 22 MS. : No. 22 MS. IIII: When you go in there and search 23 MR. : But they're in the SHU? 23 their cell. 24 You just didn't read them? 24 MR. Right. Of an inmate. 25 MS. IIII: Right. 25 And you never observed that in the SHU? 407 408 1 MS. : No. 1 L Tier as we're referring to? And is the outer 2 MR. : Did they ever teach you 2 gate that you were standing at that you were 3 that during training that you're supposed to do 3 talking about? 4 that? 4 MS. : Yes. 5 MS. : Mm. I don't recall. 5 MR. : Alright. And then when 6 MR. : You don't recall? It's 6 you say you're staying at the lower part of the 7 just something that you never-ever witnessed? 7 steps, is it about right there that you were 8 MS. : Never. Never saw it. 8 standing? 9 MR. : Even when you were 9 MS. : I was standing over here. 10 working that like earlier shift? You know when 10 MR. : Over there? Do you have 11 you're doing your OT or your regular shift? 11 a pen? Do you just mind marking it? So that's 12 Never once witnessed a cell search. 12 where you were standing? Alright. And in that 13 MS. : Never. 13 picture, can you see where Epstein was? 14 MR. : And do you know - of 14 MS. : From down here? 15 things that you do know in there, would any of 15 MR. : No-no-no. I'm sorry. Is 16 that be considered contraband? That was in 16 his -? I'm assuming -. 17 there? Now that you know that medication was 17 MS. IIII: Oh! No-no-no. Because he's on 18 in there. The CPAP machine. Or the extra 18 this side. 19 linens. Or the extra clothing. 19 MR. : Right. So we can see 20 MS. : In his cell? 20 part of the two when it's crossed. But does 21 MR. Mm-hmm. 21 this look like Epstein's door? 22 MS. 22 MS. IIII: This is the first door on the 23 MR. • Do you want to show her 23 right. Yeah. 24 some of these pictures just so she can get a - 24 MR. And from what you can see 25 know what we're talking about here? So is this 25 from where you were standing, did that look EFTA00117744 409 410 1 like what ou saw? 1 would usuall lay on his bed? 2 MS. IIII: I didn't see all of this. I 2 MS. Yes. 3 saw like here. Because I'm on the door. So 3 MR. : Was he the top bunk guy 4 he's doing CPR like here. So I didn't see all 4 then? And do you know where would 5 that. 5 usually slee 6 MR. : Alright. So you couldn't 6 MS. I don't know. 7 see all that extra clothing and linens right 7 MR. : Is it only like -? 8 there? 8 MS. Because he's always on the 9 MS. No. 9 floor. 10 MR. : Does that look like a lot 10 MR. : Okay. But I see that the 11 of clothin and linen to you? 11 top one doesn't actually have it. It doesn't 12 MS. • Yes. 12 look like it has a -- 13 MR. : Here's a couple extra 13 MS. Right. A mattress. 14 pictures of some different like advantage 14 MR. -- mattress. So do you 15 point. Does that all look like extra clothing 15 know if would sleep like right next to 16 to you? 16 him? 17 MS. IIII: Yes. And there's the machine 17 MS. I don't know. 18 right here. 18 MR. • You don't? Did you ever 19 MR. : That's the CPAC machine? 19 check in on them when you were - or that was 20 CPAP? 20 the first ni ht you said you -? 21 MS. Yes. 21 MS. • That was it. 22 MR. : Okay. Again though, you 22 MR. : So did you ever observe 23 don't know what he actually hung himself with? 23 him in a sleep state before? 24 MS. I don't know. 24 MS. IIII: Because he's never really 25 MR. : Is this the way that he 25 there. Epstein 411 412 1 MR. Yeah-yeah-yeah. I'm 1 could have been on top. I don't know. 2 saying during sleeping hours. Did you ever see 2 MR. Okay. So if this is 3 Epstein prior to this instance? Prior to 3 where took him off of, is that what you 4 August 9th have you ever seen Epstein sleeping 4 couldn't see that from the door form that 5 in his cell? 5 vantage point? 6 MS. IIII: When he comes back he lays 6 MS. : Yeah. I can't see that. 7 there on the floor. On the mattress on the 7 MR. : You couldn't see that. 8 floor. 8 Okay. So did you ever notice that type of 9 MR. SO wiiiliou would observe 9 medication in there before? 10 that, would you see where 'has? Prior to 10 MS. : No. 11 this incident? 11 MR. : And that's something you 12 MS. IIII: Oh be up. So I never 12 believe that shouldn't have been in there 13 seen like where is. Like is always 13 though? 14 up. 14 MS. • Yes. 15 MR. Is there only one bunk in 15 MR. Does anything here look 16 that room? 16 out of the ordinary to you? With what -? 17 MS. : It was these two. 17 MS. IIII: What's in the (Indiscernible 18 MR. Yeah. So the one 18 *04:54:17 ri ht here? 19 bunkbed? 19 MR. : I don't know. I'm asking 20 MS. : Yeah. One. 20 you. Does any of that look out of the ordinary 21 MR. : So if I'm assuming if 21 to you? 22 he's sleeping on the floor then would be 22 MS. IIII: Yeah. There's couple. 23 sleeping next to him. 23 Whatever's in the bag. 24 MS. IIII: There. But I don't know if 24 MR. : Okay. But you never went 25 this was because wasn't there. Or he 25 in there. You never saw any of this? EFTA00117745 413 414 1 MS. : No. 1 your attorneys. Just have her do the top one. 2 MR. : And cell searches were 2 Unless you prefer to -. 3 never conducted. So no one even went in to 3 MR. FOY: No. That's fine. Initial that 4 ever check to see what was in these cells. 4 one. 5 MS. : Correct. 5 MR. Here. Keep these away 6 MR. : Here's three additional 6 from that. I'll just keep everything next to 7 pictures if you want to look. Does any of this 7 her anywa 8 stuff look abnormal to you? 8 MR. : And the -. 9 MS. • All these. 9 MR. That's fine. 10 MR. Everything? Looks 10 (Indiscernible *04:56:07) she didn't know about 11 abnormal? 11 it anyway. How were Epstein's interactions 12 MS. The medication. 12 with other inmates? 13 MR. the medication? And it 13 MS. : I don't know. 14 was never discussed with anyone about cell 14 MR. Did you ever see him 15 searches? Ever. In the three - you know two 15 interact with other inmates? 16 and a half months that you were in there? 16 MS. : He's never there. No. 17 MS. IIII: That (Indiscernible *04:55:35) 17 MR. Did you ever see him 18 in there. 18 interact with his cellmates? 19 MR. Okay. And did you ever 19 MS. : No. 20 get to see what it was that Epstein used to 20 MR. No. You said -. But the 21 hang himself? 21 last time you interacted with him was just that 22 MS. 22 one raisin of the hand. 23 MR. • No. Alright. Rather 23 MS. : Yeah. 24 than have you do all those individual, I'm 24 MR. : Was it surprising you to 25 going to just separate this. If it's okay with 25 notice that there was no cellmate in there with 415 416 1 him? 1 MR. Did Epstein ever complain 2 MS. : No. 2 about anything? 3 MR. : So did it even cross your 3 MS. : Not to me. 4 mind that there was always a cellmate with him 4 MR. : Do you know if he 5 prior to that time? 5 complained about anything to anyone else? 6 MS. : No. 6 MS. IIII: lust the time when he asked for 7 MR. : Did you ever -? Were you 7 the mattress. The extra mattress. 8 ever told that was removed from the 8 MR. . That was a request 9 institution? 9 though. 10 MS. 10 MS. Yeah. 11 MR. . And is that something - 11 MR. Was it a complaint? Did 12 being that's the high-profile nature that he is 12 he say anything along with asking for an extra 13 that like -? Is that something that you would 13 one? 14 notice though? That like hey this guy usually 14 MS. IIII: Well how it was relayed that he 15 has a cellmate. He's not in there right now. 15 was complaining that he needed another 16 Where is he? 16 mattress. 17 MS. : N 17 MR. Okay. 18 MR. : Did even cross -? 18 MS. I don't know if you want to 19 MS. Cross my mind? No. 19 take that as 20 MR. Didn't cross your mind. 20 MR. : Did you ever hear him 21 You're just looking at the people in there and 21 complainin about other inmates? 22 you're not worried about who is in there. The 22 MS. : No. 23 people in there are alive. That's all you're 23 MR. No. Never complained 24 worried about? 24 about bei2g_in the SHU versus somewhere else? 25 MS. IIII: Yes. 25 MS. IIII: No. EFTA00117746 417 418 1 MR. : So no complaints other 1 prison? 2 than that mattress. 2 MS. 3 MS. • No. 3 MR. : Did you ever speak about 4 MR. : Do you know if there were 4 Epstein with other inmates? 5 any threats made to Epstein? 5 MS. : No. 6 MS. : I don't know. 6 MR. : In your opinion when the 7 MR. : Do you know at the time 7 medical emergency was discovered, did you and 8 did you know why Epstein was in prison? 8 act appropriately, per BOP policy? Now 9 MS. : Well he -. 9 that you've had time to reflect on it. 10 MR. : You said you did some 10 MS. IIII: Um I know now that when there's 11 internet searches or you saw some things but -. 11 a medical emergency, you're not supposed to 12 MS. IIII: Right. After the fact. But 12 enter the cell until everybody gets there. So 13 initially no. 13 that would be the only thing that I would say 14 MR. : Didn't you say there were 14 like that wasn't done correctly. But as far as 15 things that would populate on the computer? 15 everythin else -. 16 MS. IIII: Yeah. That's why I said after. 16 MR. : Now was that per 17 When he initially first came in there, no. I 17 MS. What I'm saying or -? 18 didn't know. 18 MR. : Yeah. So the one thing 19 MR. : I mean prior to August 19 that you know that was incorrect. What about 20 9th or Au ust lOth. 20 what you did? Was there anything that you did 21 MS. Oh. Yeah. 21 that wasn't correct? 22 MR. : Yeah? 22 MS. : If it was I don't know. 23 MS. Mm-hmm. 23 MR. • No-no-no. I'm asking. 24 MR. : And did you have any 24 MS. Oh now. 25 specific feelings with regard to why he was in 25 MR. : It's a genuine question. 419 420 1 It's not a trick. 1 until peoplfjEL_ And then go in. 2 MS. : Hm-mm. 2 MR. IIIIIIIIII: Okay. And how did you 3 MR. : So you're not aware of 3 learn that? 4 you doing an 4 MS. IIII: After. That's what I heard 5 MS. 5 them sayia9 6 MR. Alright. But you know 6 MR. IIIIIIIIII: That's what people were 7 that went into the cell before he was 7 telling you on August 10th? 8 supposed to. 8 MS. : Yes. 9 MS. : Yes. 9 MR. That you -. 10 MR. • He was supposed to 10 MS. . Not telling me but just in 11 actually wait for someone to come and respond? 11 conversation. Like after. 12 MS. Yes. 12 MR. : What conversations did 13 MR. And why is that? 13 you have with people after? 14 MS. Wh did he go in? 14 MS. IIII: I didn't have no conversations. 15 MR. No. Why does he need to 15 I just heard them saying should have 16 wait for them to respond? 16 never went in there by himself. I don't even 17 MS. IIII: Oh I don't know. That's the 17 remember who said it. But somebody that was in 18 rule. I uess. 18 the SHU. 19 MR. : Okay. And by you 19 MR. : Did anybody say anything 20 standing outside at that gate, he still 20 about your reactions? 21 wouldn't be allowed to go into the room? 21 MS. : No. 22 MS. : Who me? 22 MR. No. Do you know if he 23 MR. • So even the way you did. 23 needed to just wait for one person or a bunch 24 MS. : Oh because I was there. No. 24 of people? How does that - what did you hear 25 From what I understand, you're supposed to wait 25 with regard to that? EFTA00117747 421 422 1 MS. Illiiiiiiiidn't hear nothing else. 1 someone wants to trick you to get in and then 2 MR. : When I said you I mean 2 you - the other person overpowers him. And now 3 3 has a -. 4 MS. : Oh. I don't know. 4 MS. : Ri ht. 5 MR. • Do you believe that 5 MR. : So that's my point. Do 6 acted appropriately? Being that you 6 you know if was aware if anyone else was 7 were there and you observed it. 7 in there? 8 MS. IIII: What the stuff that he did? 8 MS. I don't know. 9 Yes. 9 MR. You don't know. Not 10 MR. : Yeah. Do you think he 10 something ou discussed with though? 11 should have waited for someone or you think 11 MS. : No. 12 it's like - there was a medical emergency and - 12 MR. : Did any supervisors or 13 ? 13 staff talk with you about the incident? 14 MS. IIII: I think it was a medical 14 MS. • No. 15 emergency and he was just trying to get to try 15 MR. Aside from that one when 16 to help him. 16 Lieutenant 17 MR. : Alright. And did you and 17 MS. Lieutenant asked me. 18 know that Epstein was the only person in 18 MR. . Okay. So I just want to 19 the cell then? Or did you not know if 19 - again, when I ask you these questions just 20 was in there or not? 20 make sure we say like aside from this or that. 21 MS. IIII: When I counted, I knew that he 21 So any other things aside from that instance 22 was in there b himself. 22 where they asked you what happened. And you 23 MR. : Okay. lust for 23 said you don't recall saying we didn't do the 24 background, I believe the reason why you're 24 3:00 a.m. and 5:00 a.m. rounds. But you do 25 supposed to wait is in case it's a ruse and 25 recall saying it wasn't her fault. 423 424 1 MS. : Yeah. 1 MR. A little bit after your 2 MR. : We didn't do the rounds. 2 shift? 3 MS. Yeah. 3 MS. Yes. 4 MR. Any other questions other 4 MR. : You didn't have to stick 5 than that? 5 around for anything else? 6 MS. IIII: Um they asked me to go 6 MS. : No. 7 downstairs to the lieutenant's office. And 7 MR. : Did you have to sign any 8 then I waiiiiiiiiiinding down there. 8 paperwork? 9 MR. : But no one spoke with 9 MS. 10 you? 10 MR. You were left right 11 MS. : No 11 around the end of your shift. Did they tell 12 MR. • Did anyone even ask you 12 you to leave? 13 how you were? 13 MS. IIII: My shift was over. They said I 14 MS. IIII: Oh the psychologist asked me 14 could go. 15 how I was. 15 MR. I just mean like did they 16 MR. : Okay. So but did she ask 16 instruct you to go home. You just had a 17 you about the information -? 17 traumatic experience. Or it's just your shift 18 MS. IIII: No. They didn't ask me 18 was ended. And you left. 19 anything about that. 19 MS. IIII: My shift was ended and I asked 20 MR. It was just about your 20 can I go now. And they said go. 21 mental wellbeing? 21 MR. Okay. And who was that 22 MS. : Yeah. 22 who said o 23 MR. : And what time did you 23 MS. : The lieutenant. 24 stay at the institution until on August 10th? 24 MR. Do you remember which 25 MS. IIII: I left like around after 8:00. 25 lieutenant? EFTA00117748 425 426 1 MS. 1 MS. : No. 2 MR. not M? 2 MR. : Like when you feed an 3 MS. 3 inmate or when you give them -. 4 MR. Okay. But you 4 MS. IIII: Oh that's like when you log 5 didn't have any other conversations with 5 into and iiiiiiiiiikay. 6 IIIIIII? 6 MR. : Is there also paperwork 7 MS. 7 that follows that or is it just logging into 8 MR. Okay. Did you ever 8 the BOP sy/fm? 9 handle or touch Epstein's paperwork? Epstein's 9 MS. IIII: That's logging in to the 10 file or paperwork? Prior to your departure 10 system. 11 from the MCC on August 10th? 11 MR. : Okay. When you - during 12 MS. : No. 12 the time that you were on your shift at all on 13 MR. : So in that time from - 13 August 10th did you ever log into that system? 14 you said you were there by yourself for 20 14 MS. : No. 15 minutes. Did you ever go near his file? 15 MR. : So you never had to enter 16 MS. IIII: I don't even know where his 16 than you fed him or you went into -? 17 file is. No. 17 MS. : No. 18 MR. : Alright. Do you know if 18 MR. : And you checked on him or 19 they keep files on inmates? I think they're 19 anything like that? 20 called like - what is it a 292 or something 20 MS. No. 21 like that? 21 MR. : When would that be done? 22 MR. : Yeah. 22 MS. : At the earlier part of the day 23 MS. Eh no. 23 or when you feed. 24 MR. Do you know what's kept 24 MR. So around what time? 25 in a 292? 25 MS. : After 4:00. 427 428 1 MR. After 4:00 a.m.? 1 MS. : No. 2 MS. No 4:00 p.m. 2 MR. : Where those things are 3 MR. : 4:00 p.m. So when you 3 monitored or tracked? 4 say the earlier part of the day, you mean the 4 MS. 5 later part of the day? 5 MR. And you never did that 6 MS. IIII: No like when the shift starts 6 for any inmates? 7 at 4:00 after you feed. That's the time I see 7 MS. : No. 8 them like log in to say okay they've been fed. 8 MR. : You never filled out 9 But I've never really -. One day, I actually 9 paperwork or kept files for inmates? 10 like was in there because was showing me 10 MS. : No. Never. 11 how to do it. But I don't necessarily do that. 11 MR. : So obviously you never 12 Somebody else will do it. 12 handled or touched Epstein's paperwork? 13 MR. : And what was he showing 13 MS. : Never. 14 you how to do? 14 MR. : Or his file? Did you 15 MS. : How to log it. 15 ever remove any of Epstein's paperwork from his 16 MR. : So what is it that you're 16 file? 17 supposed to log? You know in the system? 17 MS. : N 18 MS. IIII: I vaguely remember because I 18 MR. : Did you ever remove or 19 don't did it - he only showed me that one time. 19 destroy an of Epstein's paperwork? 20 I think you're supposed to like log if they 20 MS. : No. 21 showered, log if they were feeding, and I don't 21 MR. : Did you ever remove or 22 know, if you gave out stuff. I guess. I don't 22 destroy - that's a repetitive question. Did 23 know. 23 you ever remove or destroy any signs related to 24 MR. : But you don't - you're 24 Epstein to include signs that said he was 25 not aware of an actual paper file? 25 required to have a cellmate? EFTA00117749 429 430 1 MS. 1 MS. : Yes. 2 MR. . Did you access any BOP 2 MR. : That was the extent of 3 databases such as BOPWARE, SENTRY, TRUVIEW, 3 the conversation? 4 after Epstein was discovered on August -- 4 MS. IIII: And then I said so when do I 5 MS. No. 5 come back? And they was like you'll get a call 6 MR. -- 10, 2019? That was 6 like when or if ou're supposed to come back. 7 no? 7 MR. : Okay. And what did that 8 MS. 8 administrative leave change to a different type 9 MR. Did you report - was that 9 of leave? 10 the last time you reported to work? On August 10 MS. : Suspended without pay. 11 10th? 11 MR. : Indefinite suspension? 12 MS. : Yes. 12 Was that it? Is that what you're on right now? 13 MR. : Were you placed on 13 MS. Yes. 14 administrative leave? 14 MR. Oka.id you 15 MS. : Yes. 15 communicate with after Epstein's 16 MR. : By whom? 16 body was discovered? 17 MS. : Mm. I don't know. I got a 17 MS. No. 18 phone call saying that I was placed on 18 MR. Did you communicate -? 19 administrative leave, but I don't remember by 19 MS. : We communicated never because 20 who. And then the letter. 20 we was not allowed to communicate. Even - well 21 MR. : Did you ever receive an 21 before -. 22 explanation verbally? 22 MR. : What about -? I'm 23 MS. : No. 23 talking about right after the body was 24 MR. : No? So the person told 24 discovered. People respond. And then did you 25 you that you were on administrative leave -? 25 communicate? You talked about the one instance 431 432 1 outside of the elevator. 1 MR. That's kind of like - 2 MS. : Yeah-yeah-yeah. No. 2 when I say EVER, that means ever. Any time 3 MR. : But you guys didn't 3 from then until this moment? 4 actually converse? You were just both talking 4 MS. IIII: From then until the union 5 to the lieutenant? 5 meeting, we never spoke. 6 MS. : Ri ht. 6 MR. : Alright. So what was 7 MR. : And at no point also did 7 discussed at the union meeting? 8 you ever converse? 8 MS. IIII: That we're going to have an 9 MS. : No. 9 investigation and the union is there for us. 10 MR. • Didn't you guys talk 10 They're su ortin us. Stuff like that. 11 somewhere 11 MR. But did you discuss this 12 MS. 12 with 13 MR. Since then? Like outside 13 MS. What? 14 of work? 14 MR. The investigation? 15 MS. 15 MS. 16 MR. You don't recall anytime? 16 MR. Did you ever discuss like 17 So if he says that you guys talked it up, you 17 what you were going to tell us? 18 don't remember that? 18 MS. : No. 19 MS. IIII: We never spoke until we had a 19 MR. Or what you were going to 20 union meeiiiiiiiii, 20 say durin an interview? 21 MR. : That's what I'm asking. 21 MS. : No. 22 Ever. 22 MR. So what did your 23 MR. : Oh never spoke until that 23 communication entail? 24 union meeting. That was just like two weeks 24 MS. IIII: With =.? It wasn't with 25 ago. But we never ever spoke. 25 . But he was present. So basically the EFTA00117750 433 434 1 union was saying you know they're fighting for 1 that we need to clarify. Anything that you can 2 us. They're there for us. They're supporting 2 think about. Like maybe I should provide some 3 us. You know that was along the line. We're 3 additional background information regarding 4 going to have to meet with you guys to be 4 that. 5 investigated. lust tell the truth. That was 5 MR. FOY: No. I don't of know anything. 6 along the line. 6 MR. : Okay. So everything good 7 MR. • Okay. 7 for - because I just want to pass it over to 8 MS. : But my conversation wasn't 8 see if there's anything that Agent wants 9 directly with . It was - we were both 9 to ask. 10 being told. 10 MR. : You mentioned there was an 11 MR. So aside from the union 11 office in the SHU for the lieutenant. 12 and with that interaction with , was 12 MS. Yes. 13 anybody else that you discussed the Epstein 13 MR. : Where is that located? 14 incident with since August 10th? 14 MS. : Upstairs outside of the door 15 MS. : No. 15 for 10 South. 16 MR. • No. Aside from your 16 MR. : Who normally sits there? 17 attorneys? 17 MS. The lieutenant. 18 MS. : More or less. Mm-hmm. 18 MR. : Who would that be? 19 MR. • Is there anything else 19 MS. Lieutenant IIII. 20 that you want to add to anything we've talked 20 MR. : Have you ever been in that 21 about? Being and just keep in mind the - under 21 office? 22 oath. What you just said. The union said just 22 MS. No. 23 tell the truth. The way that you get in 23 MR. : Do you know anyone else that 24 trouble from this point forward is basically if 24 utilizes that office? 25 you don't tell the truth. You know, anything 25 MS. IIII: No. 435 436 1 MR. : After the incident happened, 1 MR. : Yeah. When you were leaving. 2 did you -? After Epstein was removed, did you 2 Where was she? 3 see any lieutenants at the MCC? 3 MS. : In the SHU. 4 MS. Did I see any lieutenants? 4 MR. : Okay. She was in the SHU 5 MR. : Yeah. Which lieutenants did 5 physicall in the SHU? 6 you see at the MCC? 6 MS. : Helping feed. 7 MS. IIII: Lieutenant IIII, but who was 7 MR. : Okay. 8 there? 8 MR. What time are we talking 9 MR. : Yeah whoever's present. Did 9 about? 10 you actuaIly_see. 10 MR. This is after the incident. 11 MS. IIII: Lieutenant Lieutenant 11 MR. : Oh, okay. 12 , Lieutenant getting off 12 MR. : This is just for 13 but she came like to help feed. 13 clarification purposes. 14 MR. : She came back to help feed? 14 MS. Okay. 15 MS. Yes. 15 MR. : I know you mentioned this 16 MR. : Did you have a conversation 16 before, I'm just going to clarify it. A couple 17 with her? 17 of questions. Did you ever assist any inmates 18 MS. : Lieutenant 18 with makin hone calls? 19 MR. : Yeah. 19 MS. : No. 20 MS. No. 20 MR. : Do you know that if an inmate 21 MR. : How did you know she came 21 wanted to make a phone call, how would they go 22 back to hel feed? 22 about it? 23 MS. : I was there. 23 MS. : They use their PIN number. 24 MR. : And where was she when -? 24 MR. : Is every inmate assigned one? 25 MS. : Where was she when? 25 MS. : Yes. EFTA00117751 437 438 1 MR. : Can they call anybody they 1 the legal line is. 2 wanted to? 2 MR. : Okay. You said it was not 3 MS. I don't know. 3 weird Epstein was left alone with the phone. 4 MR. : Is there a restriction on 4 Has this happened before? 5 certain peo le that they are allowed to call? 5 MS. IIII: Where an inmate is in the tier 6 MS. I don't know. 6 using the hone? Yeah. 7 MR. : Okay. Did you know that 7 MR. : Who - to your recollection - 8 inmate calls are monitored? 8 which other inmates were allowed to make phone 9 MS. Yes. 9 calls like that? 10 MR. : Do you know the difference 10 MS. IIII: I don't have a name, but it's 11 between a monitored line and the legal line? 11 not because they're allowed to make a phone 12 MS. Meaning.... 12 call like that. It's only if where their cell 13 MR. : So there was one line that's 13 is located, the jack's not working. So it's 14 used to make legal phone calls that's just for 14 not like they put inmates in the shower to have 15 attorneys. 15 private phone calls. It's just that if where 16 MS. : Okay. 16 your cell is that, the jack's not working, they 17 MR. : So those - that line is not 17 put you -. Because they can't put you with 18 monitored. 18 another - in another inmate's room. And they 19 MS. Oh 19 can't leave you out in the open. So they place 20 MR. : But the other line is any 20 you over there because the jack is closest to 21 calls that they make is recorded. 21 it to make the phone call. 22 MS. IIII: Okay. But I don't know where 22 MR. : So you know who could set up 23 like which line is which. But I am aware that 23 a call like that? Can anyone - any CO just 24 there's the recorded line and the other line. 24 plug it in? Or does it have to be a specific 25 But I don't know which one is which. Or where 25 person who plugs it in? 439 440 1 MS. IIII: That I don't know. If any CO 1 The evening watch officers will conduct a 2 could jusiii it in. I don't know. 2 minimum of five cell searches during their 3 MR. : You don't know. Would you 3 shift." And that's what I was just trying to 4 happen to know if Epstein had a PAC and PIN 4 get (Indiscernible *05:14:13). Just to make 5 assigned to him? 5 sure and that's just to -. If you want to just 6 MS. IIII: I would think he would. But I 6 initial it and date. And also when I do need 7 don't know for sure. 7 to clarify when I said the getting in trouble 8 MR. : Do you recall that night when 8 thing. I was talking about legally. When I 9 set up the phone call. Did he tell you 9 said about that being truthful. 10 who Epstein was supposed to be speaking to? 10 MR. : So these things that you 11 MS. : No. 11 initialed. Can you date them also? Because 12 MR. : That's all I have. 12 this first set doesn't have a date on them. 13 MR. : And then the two final 13 MR. What is that you want her, 14 follow-ups. Just because we discussed it and I 14 -? 15 kind of gave it to you from memory. But this 15 MR. : There's no dates. Next to 16 is the special housing unit post orders 16 her initials. On there. 17 regarding cell rotations and cell searches. It 17 MR. : Do you care if it has a 18 just quickly says, "All SHU staff are expected 18 date? I don't want her to have to go through 19 to conduct searches of the special housing 19 everything again. She just wrote her initials. 20 unit. The morning watch officers will conduct 20 MR. FOY: Yeah. It doesn't matter. 21 searches of the common areas and document their 21 Especiall if e're only meeting one time. 22 findings in the search section of the True 22 MR. : Okay. Sure. So just 23 Scrub Program. (Phonetic Sp. *05:14:00) The 23 next to where you wrote your initials, do you 24 day watch officers will conduct a search of 24 mind just dating? I don't know if there's a 25 every inmate's cell who attends recreation. 25 reason to provide this here. I would just -. EFTA00117752 441 442 1 You might not -. You don't have to provide it 1 MS. : Um yeah. 2 to her. 2 MR. : With All Belongings. 3 MR. Yeah. 3 MS. Belongings. 4 MR. Just read it after she's 4 MR. : If an inmate let's say had to 5 done that. 5 go to court and it was notified that the inmate 6 MR. : Weriii aware -? Maybe 6 is not coming back and was being removed by 7 subsequently that wrote a memo pretty 7 WAB. Does an officer in the SHU have to go in 8 much stating that he was notified -. He was 8 and remove all the belongings? 9 notified 1:50 p.m. that inmate was not 9 MS. IIII: Um I don't know. Because I 10 coming back to MCC. And he actually notified 10 only know in the regular unit when they're 11 Officer , SOS , and Officer 11 going WAB the bring their stuff. 12 that inmate needed - that a cellmate needed to 12 MR. : They don't bring their stuff? 13 be assigned to Epstein. 13 MS. No they do. 14 MS. •• I'm not aware of that. 14 MR. : If they were. But what if 15 MR. : Did you ever get instructions 15 that person - let's say that inmate wasn't 16 like that? 16 notified that they're not coming back until -. 17 MS. : No. 17 MS. IIII: Oh if it wasn't. Then yeah. 18 MR. : When you came on shift, were 18 The officer would have to go in and take it 19 there any instructions that came down about 19 out. 20 going in and removing Inmate ' belongings 20 MR. : And there was no instructions 21 from the cell? 21 for you gu s to go remove it? 22 MS. No. 22 MS. : No. 23 MR. : If an inmate was removed. 23 MR. : And I may have just 24 Let's say someone was going WAB. Do you know 24 missed this, but you do not recall anyone 25 what that is? 25 coming in and retrieving ' belongings? 443 444 1 MS. No. 1 there anything that you can think of that we 2 MR. : No? And would have that 2 should be discussing? Or 0? 3 happened during your shift? Before the 12:00? 3 MS. GREGG: I mean I -. If OIG really 4 MS. : I don't know. 4 wants to know what led up to the death of Mr. 5 MR. : If it was? 5 Epstein. I think that there needs to be a 6 MR. : You just don't know 6 thorough investigation of the Metropolitan 7 anything about leaving or -? 7 Correctional Center and it's pitfalls. I'll 8 MS. I don't know. 8 just you know kind of leave it at that. And 9 MR. Anything? Okay. 9 I'm sure you're getting a little bit of insight 10 MR. : Get all this signed we'll go 10 into what the MCC is. Not just staffing but 11 to initial documents. 11 conditions for inmates as well. It failed a 12 MR. : Yeah. They're all - I 12 new employee. Yes there are some things that 13 just gave them to her. Anything else before we 13 she absolutely should be taking responsibly 14 end this so that hopefully this will be a one- 14 for. But what led up to the unfortunate death 15 and-done? 15 of Mr. Epstein wasn't just August 9th and 16 MR. M.Jothing else. 16 August 10th. 17 MR. : Nothing else that we 17 MR. : Referring to the fact 18 should talk about that we missed? That we can 18 that she was trained on people not conducing 19 handle now rather than having to circle back? 19 rounds and counts? 20 MR. FOY: Uh nothing. I can't think off 20 MS. GREGG: It's a cultural issue at MCC 21 of the toiliiiiiiiiad. 21 New York. Falsifying of documents to pass 22 MR. : We're trying to cover a 22 program reviews. Inadequate training of 23 lot so. 23 employees. Um an employee may go through an IF 24 MR. FOY: I am at the end. 24 training but most of that training is three 25 MR. Yep. From the union is 25 weeks or so. Most of the time, you'll find EFTA00117753 445 446 1 yourself sitting down in the training center I 1 pretty much not conducting the round sheets the 2 believe because they don't have someone to 2 way they did it, as well as the supervisor that 3 actually train you. But they'll tell you sign 3 told you to sign the training that you never 4 the training sheets. So if something like this 4 actually attended. Can you think of anything 5 comes up, it implies that the employee received 5 else that you were asked to do like that from 6 the training. When actually I was present to 6 anyone? Or observed anyone else? As like a 7 receive the training but nobody taught me. The 7 training or an experience that was - now that 8 same thing is you know for annual refresher 8 you're thinking back on it - wrong? 9 training. There's a cultural issue at the 9 MS. IIII: Um.... I mean I haven't really 10 Metropolitan Correctional Center. Is it 10 been there that long. So the only thing I 11 agency-wide? I don't know. I've only been at 11 could recall was Lieutenant III was oh. I 12 MCC New York. But there are some pitfalls. 12 think when I had my probationary year, like I'm 13 There have been inmates that's prior to Mr. 13 supposed to get reviewed like every quarter. 14 Epstein and since Mr. Epstein and I believe the 14 Like to get before I get off probation. I've 15 inadequate managing of the building plays a big 15 only got it one time. I think it's supposed to 16 role in those deaths. Assaults of staff and 16 be done three times. I've only got it one 17 inmates. And you guys, I guarantee you've seen 17 time. 18 it. I'm sure there's something you've seen 18 MR. : And were you asked to 19 that you're like, wow that's a little bit crazy 19 sign on a quarterly basis that you received 20 what just seems very egregious it's because 20 that evaluation? 21 it's not being run the correct way. It's 21 MS. IIII: I know I signed it one time 22 failing staff and inmates every day. 22 that I got it. But I never got the other two. 23 MR. : Well thank you for that. 23 So just biiiiiiiiigust showing how -. 24 On that note, I know we talked about you know 24 MR. : But they didn't actually 25 how you observed other staff members like 25 ask you to sign something? 447 448 1 MS. IIII: No. Ask me to sign for that. 1 MR. -- conducting the 2 No. 2 training? 3 MR. : Is there any instances 3 MS. IIII: Yeah. There were a couple of 4 you can think of that you like needed to sign 4 training that we didn't get because there was 5 for something that you thought oh I shouldn't 5 nobody there to teach the class. 6 sign for that. I didn't take this training. I 6 MR. : And they certified that 7 didn't conduct these rounds. Is there anything 7 they actuall - 8 else like that that you can think of that's 8 MS. IIII: Yeah. I remember when I was in 9 happened while you were at the MCC? 9 IF, they would tell me stuff. But I never 10 MS. IIII: I mean, like for example, like 10 walked. You're supposed to get a tour of the 11 she said in IF training, there's a roster with 11 building for when you sit in training and in 12 a whole bunch of stuff that we're signing next 12 the SHU blah-blah-blah - you have a visual. 13 to. But like let's say, lieutenant so-and-so 13 They never even did that. Like they would 14 is supposed to teach that class and they didn't 14 explain like when they say down range, you have 15 show up. But I already signed that I received 15 to just imagine what's down range because I 16 it. But I didn't get the actual training. So 16 never been in that jail and I didn't know. 17 I'm signing that I'm present and I'm here for 17 I'm saying that to say like the training is not 18 the trainin but I didn't actually get it. 18 -. You guys probably look at oh I signed or 19 MR. : So you're showing up at 19 you're saying this training or that she should 20 training -- 20 know this. But I don't actually necessarily 21 MS. But I can't remember -. 21 have to know it because it wasn't like taught. 22 MR. -- and they're actually 22 And if I kind of learn as you go along, that's 23 not conducting it and they're certifying 23 why I said like it's wrong, but I tried to 24 they're -- 24 mimic or follow what I see. Other people do. 25 MS. IIII: Right. Yeah. 25 And yes I've exercised poor judgment on things, EFTA00117754 449 450 1 but even sometimes you ask people and they tell 1 time I called the lieutenant's office. Like I 2 you the wrong thing. That's MCC. So even if I 2 can't keep my eyes open because that's just the 3 don't know and I call and I say hey how do you 3 reality of it. By the time you go home, it's 4 do this? The like oh just do this. 4 time for you to -. Some people don't even go 5 MR. : And what do you - now 5 home. They try to sleep in the locker room 6 that you've experienced this, what do you blame 6 because the manpower is not there. And it's 7 that on? Do you also blame it on like poor 7 absolutely ridiculous. For me, I started in 8 management or like a lack of manpower? What is 8 June of 2018. The indictment said 2016. 9 your thougils1 on that? 9 That's not true. To December. That's only 6 10 MS. IIII: It's both but every time 10 months. And I made my base pay because of all 11 something happens, the officers get in trouble. 11 that overtime. 12 And the problem is it starts from the top. 12 MR. : Okay. Thank you. That's 13 Because if my supervisor is telling me to 13 all great insight. Anything else we want to 14 falsify documents and I do it, I'm in trouble. 14 add? 15 But Lieutenant got promoted. You 15 MS. IIII: Mm. Nothing else. 16 understand? Like the problem starts from eh 16 MR. FOY: The only thing I can think of, 17 top. And it comes all the way down. It's not 17 which you've kind of alluded to, is what it 18 being managed correctly and the manpower is 18 feels like as a new employee. The culture. 19 also not there. Like you can't take somebody 19 The friendliness or lack thereof. The fact 20 and tell them to work 16 hours. And remember, 20 that in a way, your trust in your colleagues is 21 it's a thing where I'm on probation, so I can't 21 undermined through your colleagues. Right? I 22 say, no I'm not working it. So you asked me to 22 mean which makes it a difficult thing. I mean 23 work 16 hours every day. I'm a human being. 23 if you want to talk about that part of it. 24 I'm not a robot. I fell asleep plenty of times 24 Right. Because it's all related. It's not I 25 going home. I come to work. I remember one 25 just one thing. So I mean if you want to speak 451 452 1 on it, this would be the time to say it. 1 the officer is on the other unit? But there's 2 MS. IIII: I don't know what -. 2 been - and that's all not supposed to happen. 3 MR. FOY: Hm? 3 But like I said, when nothing happens it's okay 4 MS. IIII: (Indiscernible *05:25:37) 4 because nobody died. Nothing happened. But 5 MR. FOY: Your experience of was it a 5 when something happens, then that officer 6 friendly experience? Did you feel supported by 6 working the two units gets in trouble not the 7 your co111222es? Like -. 7 lieutenant that said hey I'm assigning you to 8 MS. IIII: Oh. No. 8 work these two units. And yes, we know we're 9 MR. FOY: Right? Did you like it there? 9 not supposed to work the two units. But again, 10 Did it feel safe? Like -. 10 I don't feel like I can override my lieutenant 11 MS. IIII: Oh. No. Absolutely not. 11 or I can override the senior officer because 12 Absolutely not. 12 the instruction that's being passed on from the 13 MR. FOY: But you've got -. 13 top is not correct. But who am I going to 14 MS. IIII: I was actually trying to - like 14 tell? Because everybody in that building knows 15 from the moment I started there, I didn't like 15 from the warden all the way down knows we don't 16 it there and I was trying to get out of there. 16 have enough people. We don't have enough. 17 But I'm not going to quit a job and go sit at 17 From day one I entered that building, that's 18 home. So. The atmosphere was - like to me, I 18 all I've been hearing. We don't have enough 19 didn't feel safe because if you don't have 19 people. We don't have enough people. People 20 enough people to work the units and something 20 get hurt because there's not enough staff to 21 happens and you hit a body alarm, who's 21 respond to certain. Like when I'm on a unit 22 responding? If there's no nobody there. So 22 and inmates are fighting -. Like if the 23 that's a problem in itself. There's been times 23 inmates really wanted to take over and harm 24 where you got one officer working two units. 24 you, they could have. And then who's 25 So what if somebody died on the other unit and 25 responding fast enough because maybe you hit EFTA00117755 453 454 1 the body alarm sometimes only three people 1 Do you mean like an FCI or a penitentiary? Or 2 come. 2 3 MR. : So with all this in mind, 3 MS. : Yes. 4 is there anything that you can think of as a 4 MR. Or are you talking about? 5 way to rectify these issues? 5 MS. 6 MS. IIII: They need staffing. And I 6 MR. Okay. 7 don't know if people don't stay there because 7 MS. : Yes. Versus a high-rise 8 like the culture of MCC is just -. It needs to 8 building. So it's - the procedures are a 9 start over. Like it needs to be cleaned out 9 little bit different. So that's why I rely on 10 and start over. And people need to follow the 10 the people inside to teach me. And you'll 11 rules and reinforce and show people the correct 11 always hear this being said. There's the BOP 12 things. Then maybe - maybe it could get 12 way and there's the MCC way because at MCC, 13 somewhere. But when you have new people coming 13 they do it their way. 14 in and we're taught bad - and again, I'm not 14 MR. : Okay. Good to know. 15 blaming everything on me being taught bad. 15 MS. : There's been -. And again 16 It's what I see. What I know. And again, yes 16 because I don't know because they probably 17 I could sit and read an employee handbook. 17 don't give you the roster. Every single time 18 Sometimes you ready stuff in the context of -. 18 that I've came to work, I've called to switch 19 Like I'm not in a camp. I'm in a high rise. 19 with somebody else because I don't want to work 20 So the context of what you're reading in an 20 SHU. Because I don't know how to work SHU. 21 employee book refers to like you know those 21 And it's very annoying that you have to keep 22 types of institutions and not MCC. So 22 having to ask somebody. There's plenty of 23 sometimes when you try to put it into 23 times that I called across like somebody 24 perspective -. 24 working 9 North, like hey you want to switch 25 MR. You keep on saying camp. 25 with me? And I switch. Because on a regular 455 456 1 housing unit, I know what I'm doing. In the 1 note that said an inmate wanted to rape me. 2 SHU, I don't know what I'm doing. And I was 2 And I forward the email to the lieutenant and I 3 even told usually they don't put probationary 3 never got a call back. And I called and I said 4 staff to work SHU. But again, because of 4 -. Because that inmate is still on the unit. 5 seniority, that's all that's available. So 5 So if the inmate really wanted to rape me, then 6 that's what I have to get. 6 I guess he would have. So I called and I'm 7 MR. : Okay. Anything on that? 7 like did you get my email? And she was like 8 MR. liro you recall any specific 8 yeah I got it, but that inmate ain't going to 9 instances of policy violations by staff or any 9 do nothing to you. These are the type of 10 actions that you could bring into questions 10 things that happen at MCC. How do you know 11 about other staff members at MCC? Any specific 11 that inmate's not going to do anything to me? 12 instances. 12 What you should have did was remove me from 13 MS. IIII: Um no. 13 that unit or remove that inmate, but that 14 MR. FOY: You're talking about like 14 wasn't done. Inmates have threatened me. And 15 contraband stuff like that? 15 they're supposed to remove them out of the 16 MR. IIIIII: Anything. Overall. 16 building but they don't. Inmates have 17 MR. FOY: (Indiscernible *05:29:50) 17 threatened me and I have sent them to SHU. And 18 MS. : I mean it comes in some -. 18 then they'll release them and then they came 19 MR. : I think what he means 19 right back to my unit. So again, it's like who 20 more along the lines though of like a 20 are you telling or complaining to at MCC? 21 supervisor directing you to falsify a record. 21 Because from the top there's no help. And I'm 22 Like that's pretty big. If they're telling you 22 literally at the bottom. I was the last 23 sign this because you needed to take quarterly 23 officer at the time. 24 SHU train . Anything else like that. 24 MR. : Now do you know of 25 MS. IIII: I mean one time I got a drop 25 (Indiscernible *05:31:04) corrupt officers like EFTA00117756 457 458 1 bringing in contraband? Is that like a problem 1 MS. 1.2. 2 at the MCC? 2 MR. : And you can - you know 3 MS. IIII: It is a problem. But I don't 3 the distinct smell of K2? 4 know who brings it in. I just always wonder 4 MS. Yes. 5 like how did -? As far as smoking. Like 5 MR. : Um. 6 there's smoking all in the building. I get 6 MR. : Was this on the SHU also? 7 headaches daily because of the smoking. So it 7 MS. . Yes. 8 comes in some way. But as far as who or how it 8 MS. GREGG: It's the entire building and 9 comes in, I don't know. 9 you know, I would welcome, right, if OIG said 10 MR. : And I would think it's 10 we want to tour the institution. 11 kind of easy to identify who is smoking. 11 (Indiscernible *05:32:11) and judges do. 12 Correct? 12 Attorneys do. Law clerks do. Right. Because 13 MS. IIII: Oh - the - you'll be sitting in 13 it gives you a little bit of - you can actually 14 your officer's station, and you smell smoke. 14 put a visual besides seeing the photos. You 15 But remember they're inmates. So by the time I 15 can get a visual. You actually get to see what 16 get out, they always have a watch person. So 16 it is to be an employee there or even an inmate 17 by the time I feel like okay I smell it, it's 17 there. And the drug problem is absolutely 18 coming from here. Let me go walk the tier this 18 rampant. The institution has no control over 19 way, they'll be like, she coming. So they 19 it. Right. So it boils down to that employee 20 already done -. 20 saying okay if you guys don't stop smoking, I'm 21 MR. : Now what are you 21 locking everybody behind a door because it's 22 smelling? What kind of smoke? Is it marijuana 22 making me sick. Or it's making me -. It's 23 or is it -? 23 that kind of thing. Like they're not holding 24 MS. : K2. 24 inmates responsible for incident reports. None 25 MR. : K2? 25 of that stuff is happening. And it just makes 459 460 1 it a very bad place to work. And it makes it a 1 investigating this whole thing. Is this 2 poor place for a new employee to work. Right? 2 falling on deaf ears? I don't know. I would 3 And I say that wholeheartedly understanding 3 like to hope that the death of an inmate leads 4 that there is some onus on Ms. There's 4 to some chan e. But we're two years out and -. 5 just some things as an adult you have to say, I 5 MR. : Sure. Well part of that 6 take responsibly for it. I don't think she's 6 has to do with we had to wait to interview. 7 ever come out of taking that res 7 But yeah. 8 that MCC New York failed Ms. IIII, Mr. 8 MS. GREGG: Yeah. 9 and Mr. Epstein regardless of what he was in 9 MR. : Do you have ...? 10 jail for, I don't believe anybody deserves loss 10 MR. : Yes. 11 of life behind the walls of a jail especially 11 MR. : It just made me think of 12 in that manner. Right? And there's just so 12 something. I just want to make sure just going 13 man things so when you ask questions to Ms. 13 back like we were talking about to make sure 14 such as, "Are there any instances of 14 that we've got the like - as truthful a 15 falsifying documents," you're not going to say 15 statement as we possibly can with regard to the 16 to me, but I guarantee you that in reviewing 16 August 9th 10:00 p.m. count. Talking about 17 rosters and training records, I'm sure you guys 17 video and things like that. When you remember 18 have questionable discrepancies. I'm sure 18 doing that count -- 19 you've caught rosters not reflecting what 19 MS. : Mm-hmm. 20 videos show. I'm sure you've caught employees 20 MR. : -- although the count 21 on rosters - not on rosters but attending a 21 number was wrong, did you do the count from the 22 training, but the roster says they're on sick 22 outside grill or did you actually walk down the 23 leave or annual leave. I would bet my next low 23 range? 24 paycheck that that's absolute to what you guys 24 MS. : No. I walked down the range. 25 have probably seen or experienced in 25 MR. : And you're -? EFTA00117757 461 462 1 MS. : And I know like for example, 1 wrong, that's the -. We're going to have to - 2 like in statement, he probably was 2 MS. : Yeah. Like I don't remember -. 3 like, I don't know if she did the count. Or 3 MR. . -- review that video and 4 I'm going to say she didn't do the count 4 5 because it needed to be done with me and I was 5 MS. -- what happened between like 6 sleeping. He was sleeping, so he don't' know 6 the 73 and the 72 and the phone call and what 7 if I did the count or not. 7 was said I did do that count. 8 MR. : Yeah. I'm just trying to 8 MR. : And again, we're not 9 reconcile the review of -- 9 confusing a count with a round. 10 MS. • He signed, but -. 10 MS. : Rounds. No. 11 MR. : -- of the video. 11 MR. : Okay. Anything else? 12 MS. : But no because I saw a lot of 12 Well I just want to thank you all so very much 13 stuff. Even in the indictment. There's a lot 13 for the cooperation. And to the union, I want 14 of things in there that's not true. Like the 14 to kind of apologize for the initial 15 one thing I know I did do was that 10:00 count. 15 interaction. 16 For a fact. 16 MS. GREGG: Mm-hmm. 17 MR. : But you just don't know 17 MR. : I think that now talking 18 how they reconcile the fact that -- 18 with you, I think that you're actually - I was 19 MS. : The numbers no. 19 maybe misunderstanding maybe what you were 20 MR. • -- the numbers are off. 20 doing. I just wanted to make sure that we 21 MS. But the count. I did do that. 21 weren't going to be stopping this interview 22 MR. Was that just - and 22 every time there was a question. But you were 23 again, that's going to be one of those big 23 extremely helpful. So thank you for your 24 things that's like well how do we -? If you're 24 participation. 25 saying you did the count, and the numbers are 25 MS. GREGG: No problem. 463 464 1 MR. And yeah. It is -. CERTIFICATE 2 MS. GREGG: I've got something. Can I I hereby certify that the foregoing pages 3 just get iiiiiiiiiithe document that I signed? represent an accurate transcript of the 4 MR. : Absolutely. electronic sound recording of the proceedings 5 MS. GREGG: Or unless you just want me to before the Department of Justice, Office of the 6 take a picture of it. Whatever's easier. Inspector General in the matter of: 7 MR. : Um yeah. I'll get you a 8 copy. Either a photocopy or a picture. That's Interview of 9 fine. Okay. It is 4:20 p.m. on Tuesday, Lune 10 22 2021. This is Senior Special Agent 11 and I am turning off the recorder. 12 13 Marci Bratton, Transcriber 14 15 16 17 18 19 20 21 22 23 24 25 EFTA00117758