1
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4 DIGITALLY RECORDED
5 SWORN STATEMENT
6 OF
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9 OIG CASE #:
10 2019-010614
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18 DEPARTMENT OF JUSTICE
19 OFFICE OF THE INSPECTOR GENERAL
20 DECEMBER 2, 2021
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RESOLUTE DOCUMENTATION SERVICES
28632 Roadside Drive, Suite 285
Agoura Hills, CA 91301
Phone:
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1 APPEARANCES:
2
3 OFFICE OF THE INSPECTOR GENERAL
4 BY:
5 BY:
6
7
8 WITNESS:
9
10
11
12 OTHER APPEARANCES:
13 NONE
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1 MR. : All right. The recorder
2 is on. There is also going to be - I'm just
3 going to go over, like, a list of - it's kind
4 of, like, an introduction, and just kind of a
5 preamble into what we are going to be
6 discussing, and who you are. It's going to
7 sound very scripted, and that's because it
8 pretty much is. But you are there still.
9 Correct?
10 MS. : Yes. Mm-hmm.
11 MR. : Perfect. All right. So,
12 my name is and I am a Senior
13 Special Agent with the U.S. Department of
14 Justice, Office of the Inspector General. New
15 York Field Office. Boston Area Office. This
16 interview with Federal Bureau of Prisons
17 Associate Warden - did I say that
18 correctly?
19 MS. : Yes. Correct. Mm-hmm.
20 MR. : Is being conducted as
21 part of an official U.S. Department of Justice,
22 Office of the Inspector General, or DOJ/OIG,
23 investigation. Today's date is December 2nd,
24 2021, and the time is 10:34 a.m. This
25 interview is being conducted by telephone. I
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1 contacted you, Ms. by telephone number
2 (870) 494-4200, extension 4209. Also present
3 by telephone is DOJ/OIG Special Agent
4 . This interview will be recorded by
5 me, SSA . Could everyone
6 please identify themselves for the record, and
7 spell your last name? To start, again, I am
8 DOJ/OIG Senior Special Agent
9 And my last name is spelled
can you just state your name and
11 spell your name for the recorder?
12 : Yes. I am DOJ/OIG Special
13 Agent Last name is spelled II
■
15 MR. : And Ms.
16 MS. : My name is
17 Associate warden. Last name is spelled E-D-G-
18 E.
19 MR. : Great. Thank you very
20 much. This is an official DOJ/OIG
21 investigation into the death of inmate Jeffrey
22 Epstein and the surrounding circumstances, and
23 you are being asked to voluntarily provide
24 answers to our questions. Will you agree to
25 the interview with the DOJ/OIG?
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1 MS. : Yes. I do.
2 MR. : Perfect. And were you
3 able to review the voluntary interview form
4 that I sent to you via email, the DOJ/OIG form
5 11I-226/2?
6 MS. : Yes, I was. Yes, I did.
7 MR. : Perfect. And thank you
8 for sending it back to me a few minutes ago. I
9 see that you signed and dated it.
10 MS. : Mm-hmm.
11 MR. : And do you understand the
12 OIG form?
13 MS. : Yes, I do.
14 MR. : Perfect. And just, I'm
15 going to just going to read it for the record,
16 so that that's something that we have to do.
17 It says, United States Department of Justice,
18 Office of the Inspector General, Warnings and
19 Assurances to Employee Requested to Provide
20 Information on a Voluntary Basis. It says,
21 "You are being asked to provide information as
22 part of an investigation being conducted by the
23 Office of the Inspector General. This
24 investigation is being conducted pursuant to
25 the Inspector General Act of 1978, as amended.
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1 This investigation pertains job performance
2 failure and security failure. This is a
3 voluntary interview. Accordingly, you do not
4 have to answer questions. No disciplinary
5 action will be taken against you if you choose
6 not to answer questions. Any statements you
7 furnish may be used as evidence in any future
8 criminal proceedings, or agency disciplinary
9 proceedings, or both." And there is a waiver
10 section. It says, "I understand the Warnings
11 and Assurances stated above, and I am willing
12 to make statements and answer questions. No
13 promises or threats have been made to me, and
14 no pressure or coercion of any kind has been
15 used against me." And I see that you signed
16 your signature. You printed your name,
17 And you dated and time
18 12/02/21, at 9:00 a.m. So, I assume that is
19 the time that you reviewed the form?
20 MS. : Yes.
21 MR. : Perfect. And that is
22 your signature on this form?
23 MS. : Yes, it is.
24 MR. : Awesome. And is there
25 any questions you have with regard to the
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1 interview, or this form?
2 MS. : No. I don't.
3 MR. : Awesome. So, I will be
4 signing my name as the Special Agent. And
5 then, I will print my name under that as the
6 Special Agent. , do you mind - since this
7 is a telephone interview, you're not present -
8 do you mind if I sign for you, and place that
9 it was me that signed for you, and print your
10 name as the witness?
11 : I don't mind.
12 MR. : Perfect. All right. So,
13 I will sign for you, and then print your name,
14 and I will add the telephone number that we
15 are, as the place. Great. Let me get back to
16 this. Before starting the interview, I would
17 like to place you under oath. Ms. , can
18 you please raise your right hand? Do you swear
19 to tell the truth and nothing but the truth
20 during this interview?
21 MS. : Yes, I do.
22 MR. : Perfect. Thank you. And
23 then, because we are not in person, I'm just
24 going to have to ask you a couple questions to
25 verify your identity. What is your current
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1 home address?
2 MS.
4 MR. : Thank you. And what is
5 your date of birth?
6 MS.
7 MR. : And what is your social
8 security number?
9 MS. : Do I have to give it?
10 MR. : You can give me your last
11 four, if that's okay.
12 MS. : Okay. The last four.
13 MR. : Perfect. Thank you. And
14 how long have you worked for the BOP?
15 MS. : For 21 years.
16 MR. : Do you remember,
17 approximately, when your enter on duty date
18 was?
19 MS. : Yes. September 10 of 2000.
20 MR. : Perfect. And what is
21 your current position with the BOP?
22 MS. : I'm an Associate Warden.
23 MR. : And where is that?
24 MS. : I'm stationed at FCC Forrest
25 City in Forrest City, Arkansas.
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1 MR. : And how long have you
2 held that position?
3 MS. : I've been - well, I've been at
4 this present duty station since officially
5 September, but physically here in October. Bu-
6 I've been an associate warden for, prior to
7 that.
8 MR. : Okay. So, you've been
9 basically you were remote in September, and
10 then physically present in October of this
11 current year, 2021?
12 MS. : Correct.
13 MR. : Perfect. And you - I'm
14 sorry - you said you've been an associate
15 warden since when?
16 MS. : I've been an associate warden
17 since - we're in 2021 - I think 2017.
18 MR. : Since 2017?
19 MS. : Uh-huh.
20 MR. : Okay. Great. And what
21 are your duties and responsibilities as an
22 associate warden?
23 MS. : As an associate warden, I
24 provide advice and counsel to the warden, and I
25 have oversight of specific disciplines as
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1 decided by the warden.
2 MR. : Okay.
3 MS. : And I made decisions on policy,
4 and security (Indiscernible *00:06:34) concerns
5 of the institution.
6 MR. : Okay. And were you ever
7 interviewed by either the DOJ/OIG or FBI
8 regarding the Epstein matter?
9 MS. : No. I was not.
10 MR. : Okay. So, this is the
11 first time?
12 MS. : Yes.
13 MR. : Okay. Great. And are
14 you familiar with inmate Jeffrey Epstein, who
15 was housed within the MCC in July and August
16 2019, until his death on August 10th, 2019?
17 MS. : Yes.
18 MR. : And what was your
19 involvement with the matter?
20 MS. : Well, I have limited
21 involvement. I arrived at MCC New York July
22 4th, I believe, of 2019. And Epstein expired
23 August 10th, I believe. So, I actually, I saw
24 him, like, when he was in the visiting room.
25 And I was part of - there has been some
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1 meetings, exec staff meetings. But as far as
2 extensive contact, or extensive involvement,
3 really nothing extensive due to my short time
4 being at the institution.
5 MR. : Okay. So, you did arrive
6 on July 4th? So, I guess you were there, then,
7 the entire time during his stay, though.
8 Correct?
9 MS. : Well, not the entire -. I
10 don't know when he arrived. So, I believe it
11 wasn't the entire time. But it was -. I think
12 he arrived some time in June, if I'm not
13 mistaken. I don't recall.
14 MR. : He arrived in July.
15 Right around the same time. So --
16 MS. : In July?
17 MR. : -- there might be, like,
18 a day or two difference, but yeah, it was --
19 MS. : Okay.
20 MR. : -- it was July and August
21 was when he was there.
22 MS. : Okay. Yeah.
23 MR. : Awesome. So, if you were
24 there in July, I'm just going to briefly touch
25 on the July 23rd, 2019 incident. Do you recall
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1 an incident involving Jeffrey Epstein and
2 inmate Tartaglione on July 23rd, 2019?
3 MS. : When you say an incident, what
4 do you mean?
5 MR. : So, there was an incident
6 that happened in the SHU, where Tartaglione was
7 Epstein's celimate, and Epstein was removed
8 from the SHU and placed on suicide watch, and
9 then psychological observation. Are you
10 familiar with that?
11 MS. : Oh, yes. I'm familiar with it.
12 MR. : And what is your
13 understanding of what transpired?
14 MS. : My understanding is that
15 Tartaglione, I believe he requested, or he
16 called somehow for assistance because I believe
17 he indicated that Epstein was trying to commit
18 suicide.
19 MR. : Okay. And do you know by
20 what manner Epstein was attempting to commit
21 suicide?
22 MS. : I believe he was trying to, by
23 use of either strings, or some kind of
24 clothing, or something as a ligature.
25 MR. : Okay. And is it your
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1 understanding that Epstein attempted to harm
2 himself?
3 MS. : Yes. That was my
4 understanding.
5 MR. : And did you hear anything
6 with regard to Tartaglione attempting to harm
7 Epstein?
8 MS. : I know there was, there was
9 speculation, not from Epstein, but there was
10 speculation that, perhaps, you know, there
11 could have been something involved, but
12 Epstein, I believe, made statements that his
13 cellmate did not try to harm him, as well as
14 Tartaglione himself indicated that he did not
15 try to harm him.
16 MR. : Okay. So, your belief is
17 that they are, they were not correct
18 statements, and then in fact it was Epstein
19 that attempted to harm himself, and not
20 Tartaglione?
21 MS. : That is correct.
22 MR. : Okay. And did you have
23 any involvement with selecting Tartaglione as
24 Epstein's cellmate?
25 MS. : No. I did not.
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1 MR. : And do you know how
2 Tartaglione was selected to be Epstein's
3 cellmate?
4 MS. : I don't know. I don't, I don't
5 know exactly how he was selected. I do know,
6 after the fact, it was indicated that, because
7 he was former law enforcement, and he didn't
8 seem like he, I guess he didn't - he didn't
9 have anything that, it didn't appear that he
10 would hurt Epstein, that he was suitable to be
11 Epstein's cellmate. But I don't know exactly
12 what the vetting process was for that decision.
13 MR. : Okay. And do you believe
14 that Tartaglione was an appropriate choice for
15 a cellmate?
16 MS. : I'm not going to speculate
17 about that. I do know, at the time that he was
18 a cellmate, that he did not try to harm him.
19 Epstein never voiced any concerns about - that
20 I am aware of - about Tartaglione being his
21 cellmate. But as far as looking at
22 Tartaglione's charges, or anything to see if he
23 had any risk factors that would indicate that
24 he would harm Epstein, that would be
25 speculation after the fact. So, that, I don't
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1 believe I'm in a position to make that decision
2 at this time.
3 MR. : Sure. Okay. And then,
4 what is your understanding of, after this
5 incident occurred, where was Epstein placed?
6 MS. : He was placed on suicide watch,
7 is my understanding.
8 MR. : Okay. Great. And that
9 was immediately following, or on July 23rd,
10 2019. Do you have any involvement with Epstein
11 while he was on suicide watch? And then,
12 psychological observation?
13 MS. : No.
14 MR. : And where is that
15 conducted? Or where was that conducted?
16 MS. : Where, in the suicide watch
17 cells, you mean?
18 MR. : Correct. Where would
19 have he been housed at the time?
20 MS. : Oh, yeah. The suicide watch
21 cells are on the, they are on the second -.
22 They are on the second floor. On the same
23 floor as the health services department. So,
24 around the corner, and it's down the hall from
25 psychology. From the psychology department
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1 themselves.
2 MR. : Great. And where was the
3 SHU located in the MCC?
4 MS. : The Special Housing Unit is
5 located on the ninth floor.
6 MR. : Great. And while Epstein
7 was on suicide watch, and then psychological
8 observation, do you know if he was allowed any
9 visits, specifically any attorney visits, or
10 anything like that?
11 MS. : I do believe that he was
12 allowed to see his attorney.
13 MR. : And do you know if he did
14 see his attorney while he was on psychological
15 observation?
16 MS. : I don't know for certain if,
17 like, watch was - if it was the same day, but
18 am not for certain, 100 percent certain, but I
19 do believe that it did occur. It did occur. I
20 know he was He saw his attorneys very
21 often. Almost daily. And I don't believe that
22 there was any break in visits. So, I would,
23 would say that it probably did happen on the
24 same day that he was on suicide watch.
25 MR. : And how would that work?
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1 If someone is on suicide watch, and then
2 psychological observation, how would they meet
3 with their attorneys?
4 MS. : Typically, if someone is on
5 suicide watch, they do not have visits, and
6 they don't - because they're on watch - they
7 would be under constant, whether it was an
8 inmate companion, or a staff watch. So,
9 typically, a person on suicide watch would not
10 have visits. So, if a visit did happen during
11 suicide watch, I would gather that that person
12 will still be under the same observation
13 protocol. Obviously, another inmate would not
14 be able to watch them because of the privacy
15 factor with the visit, but I would, I would
16 assume that a staff member would be present.
17 MR. : Okay. Now, would they be
18 present on that second floor suicide watch
19 area, psychological observation area? Or would
20 that be conducted in the attorney visit rooms
21 of the MCC?
22 MS. : So, again, typically, visits
23 don't happen when a person is on suicide watch.
24 And because of the placement where suicide
25 watch is, there is no visits that happen in
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1 that area. So, all of the attorney conference
2 visits, they happen in the attorney conference
3 area, which is on the third floor. So, any
4 visit, attorney related, would happen on the
5 third floor, in the attorney conference area.
6 MR. : And to make sure I'm
7 understanding you correctly. So, that means
8 you believe that when Epstein was on
9 psychological observation or suicide watch, he
10 would have been, then, transported to that
11 third floor visiting area where he would
12 conduct his visits with his attorney? His
13 attorneys.
14 MS. : That is correct.
15 MR. : Okay. Now, were there
16 any specific - and oh, sorry, before I move on,
17 I guess I should say. So, that is not typical,
18 though? That would have been, like, a kind of
19 something that was a special circumstance for
20 Epstein?
21 MS. : Yeah. Yeah. That is not
22 typical.
23 MR. : Okay. And do you know if
24 there is any prohibition up against that, or
25 not?
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1 MS. : I know There are
2 guidelines, I believe, that when a person is on
3 suicide watch, that is where they would remain
4 under constant supervision, and there would be
5 no visits.
6 MR. : Okay. So, I am assuming
7 that answer would be, then, yes, there are
8 prohibitions?
9 MS. : When you say prohibitions, you
10 mean that the agency has guidelines in place
11 that says absolutely not?
12 MR. : Yeah. So, I guess what
13 I'm asking is, should Epstein have been
14 visiting with his attorneys while he was on
15 suicide watch, or psychological observation?
16 MS. : If there was a determination,
17 which I am not aware of, that deemed that it
18 would be okay or appropriate, as far as a
19 psychologist, or someone from the psychology
20 department, indicating that it would be okay,
21 then that would be, you know, that would be a
22 consent.
23 MR. : Sure.
24 MS. : But other than that, I don't
25 believe anyone else would make that
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1 determination to say that he would then be
2 taken off of suicide watch, and then placed in
3 the attorney conference area.
4 MR. : Okay. Great. So, I take
5 it, then, is it that MCC psychology department,
6 are they the ones who determined that Epstein
7 should be on suicide watch, and then
8 psychological observation?
9 MS. : Well, anyone can actually place
10 someone on suicide watch, if that person voices
11 - and when I say "anyone," for instance, if I
12 call, a psychologist is not there after hours,
13 someone voices an intent to harm themselves,
14 the lieutenant can make that decision to place
15 the person on suicide watch. But psychology
16 typically is the one that would determine
17 whether someone is taken off of suicide watch
18 because they would have to do a suicide risk
19 assessment, and any other clinical assessment.
20 So, placing someone on suicide watch
21 again - depending on the time, it can be
22 psychology, or it can be a correctional
23 services staff member. And then, the removal
24 would be someone from psychology, to say that
25 this person is not deemed suicidal, or, you
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1 know, they are safe to be in general
2 population.
3 MR. : Okay. And then, but it
4 would also - and correct me if I'm wrong - but
5 it did sound like you said that it would have
6 been psychology's decision to allow Epstein to
7 visit with his attorneys while he was on
8 suicide watch or psychological observation?
9 MS. : No. I don't know if that was
10 what actually occurred. But to remove someone
11 from suicide watch, that would be a psychology
12 decision.
13 MR. : So, when you say "remove
14 someone," do you mean, like, just for those
15 hours that he was visiting, or are you talking
16 about when he was removed and placed back in
17 the SHU?
18 MS. : Typically, when you remove
19 someone, it's not for an hour or two. It's
20 typically, you are saying that that person
21 poses no more risk to themselves, so they are
22 off. Basically, they are going back to general
23 population. So, I am not aware of any
24 situation where you remove a person for an hour
25 or two, or for a short timeframe, and then
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1 place them back.
2 MR. : Sure. So, that is kind
3 of I guess what I'm asking is, who makes the
4 determinations? Because you said that your
5 understanding was that he did conduct his
6 attorney visits during that time period that he
7 was on suicide watch.
8 MS. : Mm-hmm.
9 MR. : Or psychological
10 observation. So, who made the, you know, who
11 had the authority to allow him to conduct those
12 attorney visits?
13 MS. : Yes. I don't know. Again, I
14 don't know who made the ultimate decision for
15 that to happen. But I know the process for
16 removal of suicide watch, and what that process
17 entails. And that is why I'm saying, to remove
18 someone off of suicide watch, it would have to
19 be someone in psychology, to say that that is
20 appropriate. But in this instance, I don't
21 know, I don't know if that was communicated.
22 If that actually occurred. So, I hope,
23 hopefully that answers the question.
24 MR. : Sure. Yeah.
25 MS. : But (Indiscernible *00:19:29).
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1 MR. : We can move on to the
2 SHU, then, when he got removed. So, do you
3 know if there were any specific instructions,
4 by either you, the warden, or other MCC
5 executive staff, with regard to Epstein being
6 placed back in the SHU from psychological
7 observation?
8 MS. : When he was - you are saying
9 when he was removed?
10 MR. : So, when a determination
11 was made that he - for Epstein to be removed,
12 which was on or about July 30th, 2019.
13 MS. : Mm-hmm.
14 MR. : Were there any specific
15 instructions provided by you, the warden, or
16 other MCC executive staff, with regard to
17 Epstein being placed back in the SHU?
18 MS. : Well, I didn't, I didn't have
19 any specific direction, or instructions to a
20 particular staff member. But I do, I do know
21 that there was a determination made, and who
22 exactly made that determination, typically,
23 when you - high-profile individuals, and you
24 are saying to place them in Special Housing for
25 their care, it is typically the CEO, the
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1 warden, in consultation with correctional
2 services, because it falls under custody care
3 and control. And so, that decision was made to
4 place him in Special Housing.
5 MR. : Okay. Do you know, did
6 you, MCC executive staff, or anyone, including
7 the warden, receive any calls, or was anyone
8 contacted by lawyers, or a judge, asking for
9 Epstein to be removed from suicide watch or
10 psychological observation?
11 MS. : That, I am not aware of any
12 communication about that.
13 MR. : Okay. And just to circle
14 back. Were you, or executive staff, involved
15 with any decisions to have Epstein removed from
16 suicide watch or psychological observation?
17 MS. : Say that one more time. Say
18 that one more time.
19 MR. : So, that actually having
20 him removed. So, back on July, you know, 30th,
21 when he was removed. Would yourself or
22 executive staff, would you have been a part of
23 the process of actually taking him off of
24 suicide watch or psychological observation?
25 MS. : No.
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1 MR. : So, that is solely a
2 psychology decision?
3 MS. : Yeah. Because they are the
4 subject matter experts, and again, and whether
5 someone is off of suicide, or displaying
6 suicide risk factors, typically, it is a
7 psychology thing, to remove the individual.
8 MR. : Okay. And that, that's
9 not in consultation with MCC executive staff?
10 MS. : No. To remove someone from
11 suicide watch? No.
12 MR. : Okay. Now, it is our
13 understanding that, after Epstein was placed
14 back in the SHU, or the Special Housing Unit,
15 psychology recommended that Epstein be housed
16 with a cellmate. Do you know if that is
17 accurate?
18 MS. : That, I do know that is
19 accurate.
20 MR. : You do know that it is
21 accurate?
22 MS. : Yes. That, I do believe that
23 that was - Mm-hmm - that is accurate. That it
24 was indicated that he should have a cellmate.
25 MR. : Okay. And do you know
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1 how that information was disseminated within
2 MCC?
3 MS. : And again, there was several,
4 you know, there was meetings, and I don't know
5 what particular meeting it occurred, but I do
6 recall, during one of the meetings, that it was
7 indicated. I don't know if it was during close
8 out, or open up, that it was important that he
9 did have a cellmate.
10 MR. : Okay. So, it was an
11 actual requirement that Epstein have a cellmate
12 while he was assigned to the SHU?
13 MS. : Yes.
14 MR. : Okay. And do you know
15 who made -? Do you know who he was celled
16 with? Do you know what the name of his
17 cellmate was when he came back off of suicide
18 watch, on July 30th, 2019?
19 MS. : Oh, who was his cellmate? i
20 don't know if it was I don't know what the
21 (Indiscernible *00:23:19). But I do know, at
22 one point, he had a cellmate named - the last
23 name was Reyes. And the first name was Efrain.
24 E-F-R-A-I-N. But I don't recall if that was
25 his consistent cellmate. But I do recall,
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1 besides Tartaglione, Reyes was another
2 cellmate.
3 MR. : And thank you. I have
4 actually been saying Efrain. So, it's Efrain?
5 MS. : That's what I think you
6 pronounce it as. It could be my New York
7 accent, but I'm saying Efrain.
8 MR. : Okay. Hey. That's - _
9 guess -. Yeah. I'm looking at it, and it's -.
10 I'm going to start saying Efrain now.
11 MS. : Mm-hmm.
12 MR. : Do you know who made the
13 decision that Reyes would be Epstein's
14 cellmate?
15 MS. : That, I am not aware of. I
16 don't know if it was an actual, like, meeting,
17 as far as a placement decision. So, I don't
18 know if it was actually a vetting process, to
19 determine who should be the cellmate. I know
20 it was indicated that he should have a
21 cellmate. But what that process was, to get to
22 Reyes, I am not aware of it.
23 MR. : Okay. So, that means
24 that you were not involved with that decision?
25 MS. : No.
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1 MR. : Okay. And did you work
2 at the MCC on August 9th - which was a Friday -
3 or August 10th - which was a Saturday - that he
4 was found in 2019?
5 MS. : Well, I worked on Friday. My
6 work hours, because of my position, I work
7 Monday through Friday, 7:30 to 4:00. But I did
8 report to the institution the morning of, when
9 I received the call indicating that I needed to
10 report to the institution on that day that
11 Epstein was found.
12 MR. : Okay. So, on Friday,
13 August 9th, you worked from 7:30 a.m. to 4:00
14 p.m.?
15 MS. : Correct.
16 MR. : And then, on August 10th
17 - so, you did depart at 4:00 p.m. - and then
18 you returned after Epstein was found on August
19 10th?
20 MS. : And then, I returned back to
21 the institution -. Okay. I'm trying to
22 remember what -. I received a call around
23 maybe 8:00 or something. I received a call,
24 and then, I arrived at the institution maybe
25 around 9:00 or so.
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1 MR. : Okay. 9:00 a.m.?
2 MS. : Mm-hmm.
3 MR. : Okay. So, since Epstein
4 was required to have a cellmate, who was
5 ultimately responsible to make sure that all
6 SHU staff were aware of his cellmate
7 requirement?
8 MS. : Oh. Okay. And because - I'm
9 just going to say this - because it's Special
10 Housing, Special Housing is governed under
11 correctional services. It would be the captain
12 is typically in charge of correctional
13 services. And there is a SHU lieutenant that
14 is assigned to the Special Housing on a daily
15 basis. That that is that person's daily
16 assignment. And they are responsible for
17 ensuring that everything is in compliance in
18 Special Housing. And so, there should be some
19 communication, if then, like I said, psychology
20 made a decision that he had to have a cellmate.
21 Everyone was aware of it, but that, like,
22 verbal communication, or insurance, it should
23 have happened in the correctional services.
24 The captain. The lieutenant. And then, that
25 information communicated down to the staff that
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1 actually work in the Special Housing Unit.
2 MR. : Okay. And do you know,
3 at the time, in August 9th and 10th, who the
4 captain at the MCC was?
5 MS. : It was
6 MR. : Okay. And do you know
7 who the SHU lieutenant at the time was?
8 MS. : That, I am not aware of. That,
9 I am not aware of.
10 MR. : Does Lieutenant
11 sound familiar to you?
12 MS. : I know Lieutenant . But I
13 don't know if that was his post at that
14 quarter.
15 MR. : Okay.
16 MS. : I am not sure.
17 MR. : Okay. So, that was his
18 post for the quarter. So, ultimately, the
19 information should have come from Captain
20 and SHU Lieutenant They should
21 have provided to the SHU staff that Epstein was
22 required to have a cellmate at all times?
23 MS. : Mm-hmm.
24 MR. : Okay. And that is a yes?
25 MS. : Yes. That is a yes.
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1 MR. : Okay. Great. And how
2 should have they communicated that? Should
3 have that been verbally, in writing? How
4 should have they made sure everyone knew?
5 MS. : Now, to ensure that, you could
6 have a record of it if you put it in an email.
7 That's blatant, and that can never be
8 contradicted. You could also have verbal
9 notification, in addition to written
10 notification. So, that it could be both.
11 Honestly. It could be both. But if you have
12 it in - you have something that, a bulletin or
13 some kind of an email that went out, that's
14 definitely, you know, something that - that's a
15 record. That's a permanent record.
16 MR. : So, it sounds --
17 MS. (Indiscernible *00:28:24)
18 MR. : -- like you're saying, it
19 really should have been both verbal and in
20 writing, but writing would basically make sure
21 that you are, it's documented?
22 MS. : Correct.
23 MR. : Is that a correct
24 understanding?
25 MS. : That is a correct
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1 understanding.
2 MR. : Okay.
3 MS. : And in addition to that, I do
4 know that the SHU staff did know that he should
5 have had a cellmate.
6 MR. : You do know that they
7 knew that?
8 MS. : I do know that the SHU staff
9 knew that. Mm-hmm.
10 MR. : And how do you know that?
11 MS. : Because the staff are required
12 to make weekly rounds, and I don't -. Now,
13 because of, after the - excuse me - after the
14 fact, you know, he was kind of, like, you are
15 playing a - I'm just trying to recall the facts
16 - but I do recall instances of making rounds in
17 the Special Housing, where staff, it was said,
18 make sure that he had a cellmate, and when we
19 make rounds, that that was - I can - I verbally
20 heard folks say it myself.
21 MR. : And do you remember who
22 was engaged in those conversations, or who you
23 know specifically that knew?
24 MS. : That, I can't recall, because
25 in Special Housing, there is, like, four -.
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1 There is -. You have the SHU number one, SHU
2 number two, the three, and the four. So, you
3 at least have four staff, and you have staff
4 that are SHU rec staff. So, there is several
5 staff assigned to the Special Housing Unit.
6 So, and at that -. So, I can't say with
7 certainty who was engaging in a conversation.
8 And then, like I said, and then you have the
9 SHU lieutenant. So, it was several folks that
10 were assigned to the Special Housing. And
11 again, I don't know specifically who said what,
12 but I do know that it was known because I
13 verbally, I heard it, it was audible. I heard
14 it.
15 MR. : While you were in the
16 SHU?
17 MS. : While I was in the SHU.
18 MR. : And do you know around
19 what time of day that would have been?
20 MS. : No.
21 MR. : No?
22 MS. : Hmm-mm.
23 MR. : And did you hear it more
24 than one time?
25 MS. : Yes. Mm-hmm.
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1 MR. : So, it was something that
2 you had heard on multiple occasions?
3 MS. : Mm-hmm.
4 MR. : Okay.
5 MS. : Mm-hmm.
6 MR. : And is that something
7 that, because you were engaged in a
8 conversation, or you just overheard people
9 saying it?
10 MS. : I wasn't engaging in the
11 conversation about Epstein per se, but just in
12 a conversation about what was going on in SHU,
13 while making rounds.
14 MR. : Okay.
15 MS. : So, you discuss -. So,
16 typically, when you make SHU rounds, you can do
17 both. You can have, like, a SHU roster that
18 kind of lists all of the inmates that are
19 housed in the SHU. You can, like, look at the
20 board to see who has cellmates. So, sometimes,
21 the conversation is prompted from multiple
22 things, or sometimes inmates stop you at the
23 door, and ask questions, and then you talk
24 about who it is that asked you questions. So,
25 I'm just saying, because of all those
EFTA00127238
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1 instances, I don't know why it was said about
2 that particular thing, but that was, that was
3 just one of some comments during that day.
4 MR. : But it was a comment
5 specific --
6 MS. : Yeah.
7 MR. : -- to Epstein's cellmate.
8 Correct?
9 MS. : Yes. Exactly.
10 MR. : Okay. And do you know if
11 there were any plan -. Or sorry. Before I
12 move on, I guess I should specifically ask you.
13 So, you mentioned there was SHU one, two,
14 three, four, but Epstein was found when, you
15 know, during the overnight, I guess the morning
16 watch, which is, you know, I think midnight to
17 8:00 a.m.
18 MS. : Mm-hmm.
19 MR. : He was found at
20 approximately 6:33 a.m. on August 10th, and
21 then, at that time, there were only two SHU
22 staff in there.
23 MS. : Mm-hmm.
24 MR. : Specifically, a
25 and a . Do you know those two
EFTA00127239
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1 staff members?
2 MS. : I know of them.
3 MR. : Do you know if either of
4 those two specific staff members were aware of
5 Epstein's cellmate requirement?
6 MS. : No. I don't -. That, I don't
7 know because they are assigned to work other
8 departments, and they were working overtime.
9 But what I do know - because I also, when i
10 first started working in the Bureau, I was a
11 correctional officer - I do know that you
12 should engage in conversation with whomever it
13 is that you are relieving, to find out, is
14 there any special precautions, or you pass on
15 your equipment, you talk about what your base
16 count is. So, there, there should be some
17 communication between you and the staff member
18 that you are relieving.
19 MR. : Now, do you believe, if
20 the person's quarterly assignment was the SHU,
21 they would have known, and should have known?
22 MS. : Yeah. Yes.
23 MR. : Okay. So, if you know
24 that Tova Nova was actually assigned to the SHU
25 for that quarterly post, does that change
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1 anything for you?
2 MS. : Hmm. Well, you said
3 Was she an officer, or she was --
4 MR. : She was an officer.
5 MS. was she -?
6 MR. : But she was assigned --
7 MS. : Okay.
8 MR. : -- as her quarterly --
9 MS. : Mm-hmm.
10 MR. : -- post was in the SHU.
11
12 MS. : Okay.
13 MR. : -- was on overtime,
14 working in the SHU. He was a materials
15 handler.
16 MS. : Okay.
17 MR. : But was
18 actually --
19 MS. : Okay.
20 MR. : -- assigned to the SHU.
21 MS. : Okay. Well then, she should
22 have known. And then, she - and again, I
23 didn't delve into that - she was on overtime,
24 but was she responding to what shift? Like,
25 evening watch? Was that her permanent
EFTA00127241
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1 assignment?
2 MR. : I would have to check if
3 that was her --
4 MS. : Okay.
5 MR. : -- she may have been, you
6 know, you might, you may be right.
7 MS. : Mm-hmm.
8 MR. : She may have been working
9 overtime in the SHU, but she was, in fact,
10 assigned to the SHU --
11 MS. : Okay.
12 MR. : -- for that quarter.
13 MS. : Then she should have known.
14 MR. : And do you believe
15 MS. : She should have.
16 MR. : -- that there is any
17 excuse for her to say that she didn't know?
18 MS. : I can't see how, if that is
19 your post for the quarter, that you would not
20 know, because you have to make decisions based
21 on, like, recreation. You have to do rounds.
22 You have to actually physically walk down the
23 range. There are name tags on the door. There
24 is the hot list. There is information that
25 psychology, at times, even sends out to SHU
EFTA00127242
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1 staff, indicating these inmates are on the hot
2 list, or these are some important factors about
3 specific inmates.
4 So, there is, there is information, and
5 there is things that you are required to do, as
6 part of your assignment in SHU, that you would
7 have to know who can even go in recreation, in
8 the recreation cage, with whom. It's because
9 of separation. So, there is information that
10 you have to be able to, you have to know, in
11 order for you to make safe decisions during
12 your eight hours of having oversight over the
13 inmates.
14 MR. : So - great - so, you
15 touched on the hot list. Can you just very
16 briefly explain what the hot list is?
17 MS. : Well, the hot list is, it's,
18 like a list that kind of, that psychology puts
19 together, and it has information about, at
20 times, who is on suicide alert, or of any kind
21 of risk factors, or something that requires
22 special care for just specific inmates. So, it
23 is, your base count, or the SHU can help maybe
24 have the capacity to hold maybe 80 inmates,
25 right? And if - not everyone is on the hot
EFTA00127243
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1 list.
2 MR. : Okay.
3 MS. : So, again, the hot list is just
4 specifically designed to highlight specific
5 inmates, and what is needed, or something
6 special about that specific inmate.
7 MR. : So, if an inmate comes
8 off of suicide watch, or psychological
9 observation, and is placed in the SHU, would he
10 be - he or she, yeah - would he be listed on
11 the hot list?
12 MS. : I don't know if that would be
13 on the hot list, but I know that that should be
14 - that is something that would probably be on
15 the SHU roster, or the SHU report.
16 MR. : Okay.
17 MS. : The SHU report, it lists all of
18 the inmates. It has pictures of all of the
19 inmates. And it also sections for health
20 services, for psychology, for correctional
21 services, and for unit teams. And in those
22 comment sections, they typically will say this
23 inmate may need a cellmate. This inmate is on
24 the hot list. This inmate should be kept away
25 from inmate X, Y, and Z. It provides specific
EFTA00127244
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1 information. So, even if it was not on the hot
2 list, it probably would also be on the SHU
3 report, which is BOPWARE. That's an electronic
4 report that you can pull from a program, a BOP
5 program.
6 MR. : Okay. Now, do you know,
7 though, if Epstein specifically was on the hot
8 list in August of 2019?
9 MS. : You know what? I don't know
10 that.
11 MR. : Okay. So, if he was,
12 though, would it have listed that he was
13 required to have a cellmate?
14 MS. : I'm trying to think if that
15 information would be on the hot list. I'm not
16 sure if that information would be on the hot
17 list.
18 MR. : But it would be on this
19 other report that you were just speaking of,
20 that's in BOPWARE?
21 MS. : I was - mm-hmm - that should,
22 that is something that would be important, that
23 psychology would definitely put on there.
24 MR. : And would be -
25 would have she had been required to review that
EFTA00127245
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1 list, and see that Epstein was required to have
2 a cellmate?
3 MS. : Well, you are not required to
4 review the list, but in order to know what's
5 going on with the inmate, I mean, you have to
6 have a SHU roster. You would have to know
7 what's going on with the inmates.
8 MR. : So --
9 MS. : So -.
10 MR. : -- so, she should have
11 reviewed the list, is what you are saying?
12 MS. : If you want to know what's
13 going on with the inmates, I would say that you
14 would review your SHU report.
15 MR. : Is there any other ways
16 that , being that it was her quarterly
17 post, would have and should have known that
18 Epstein was required to have a cellmate?
19 MS. : I do also know that we have
20 TruScope. So, there is also an electronic
21 program called TruScope, and psychology lists
22 things, and that psych, it's called a
23 psychology advisory list. And so, again, there
24 is multiple electronic formats. And paper
25 formats and things that information is listed.
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1 MR. : Okay.
2 MS. : So -.
3 MR. : And do you know, were
4 there any plans made on how to address the
5 situation if Reyes was removed as Epstein's
6 cellmate?
7 MS. : I do - hmm - I don't recall
8 there being a meeting to say specifically if
9 Reyes was removed, but -. So, I can't say that
10 there was a meeting that I am aware of, to talk
11 about.
12 MR. : So, being that Epstein
13 was --
14 MS. : Actually, (Indiscernible
15 *00:39:13).
16 MR. : -- so, being that Epstein
17 was required to have a cellmate, and being that
18 MCC is, you know, a jail versus a prison, where
19 prisoners are constantly moved in and out.
20 MS. : Mm-hmm.
21 MR. : Was there anything in
22 place to address that situation, if Epstein is
23 required to have a cellmate, his cellmate is
24 then removed. What should have happened?
25 MS. : I don't recall of a
EFTA00127247
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1 conversation specific to that. But I do know,
2 as part of, not just Epstein, but any inmate,
3 if they are required to have cellmates, if you
4 are doing your rounds, and the cellmate is not
5 in there, it could be because that cellmate is
6 inside of the recreation cage, but if it is a
7 prolonged thing --
8 MR. : Mm-hmm.
9 MS. : -- that is something that
10 should be brought to the attention of,
11 obviously, your first line supervisor first,
12 and then that supervisor would then call,
13 depending on if it is after hours, they can
14 call the on-call psychologist, or if it during
15 duty hours, you call - then the lieutenant
16 would then contact someone in psychology.
17 MR. : Okay. So, the supervisor
18
19 MS. : Mm-hmm.
20 MR. : -- you're saying is the
21 SHU lieutenant. So, SHU staff should have
22 notified the SHU lieutenant?
23 MS. : Yes.
24 MR. : Now, what --
25 MS. : Mm-hmm.
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1 MR. : -- what about if the SHU
2 lieutenant is off? So, on the 9th, Lieutenant
3 is off that day. There is no SHU
4 lieutenant. What should have happened with SHU
5 staff? Who should have they contacted?
6 MS. : There is always a lieutenant.
7 So, even if , who is the SHU lieutenant, is
8 not physically there, there is always a
9 lieutenant in the building, 24 hours.
10 MR. : Sure.
11 MS. : That person is -. So, there is
12 the management official, after hours. And so,
13 when there is any kind of emergency, or an
14 inmate situation that rises to the level of
15 contact, there is a management official there.
16 And they have received calls. And they then
17 call the captain, and then, the captain can
18 determine whether or not he wants some, you
19 know, to increase the level and call the AW,
20 but there is always a lieutenant in the
21 institution.
22 MR. : Okay. And so, they
23 should have contacted one of the lieutenants,
24 and you are referring to the two lieutenants
25 that are usually there during the day. Can you
EFTA00127249
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1 refresh my memory of what the two are called?
2 MS. : One is the operations, and one
3 is the activities lieutenant.
4 MR. : Right. So, is there one
5 or the other that the SHU staff, during the
6 day, should have called?
7 MS. : Well, during the day, now,
8 okay, Monday through Friday, during the day,
9 there is the SHU lieutenant.
10 MR. : No. I'm saying on the
11 9th --
12 MS. : After -.
13 MR. : -- with the fact that the
14 SHU lieutenant is not there.
15 MS. : That you can call, you can
16 either call the activities or operations.
17 MR. : So, it is either or.
18 There is not --
19 MS. : But one --
20 MR. : -- one or the other?
21 MS. : -- hey, you can call Hmm-
22 mm. You can call either or.
23 MR. : Okay. Great. And do you
24 know what happened to inmate Reyes on August
25 9th, 2019?
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1 MS. : I know, I know because of after
2 the fact, that he was, I believe he was bonded,
3 or somehow, he was released from court. He was
4 at court, and he never came back because of
5 either a bond, receiving a bond or a bail.
6 MR. : Okay. So, your
7 understanding is that he actually went to
8 court, and then was released?
9 MS. : Yes. That is my understanding.
10 MR. : And where did you receive
11 that information?
12 MS. : That is after the fact. After,
13 you know, trying to gather what happened, and
14 to his cellmate. And so, if the information
15 was not, I was not aware of the information on
16 the day. It's because of this incident that
17 am aware of the information.
18 MR. : Okay. So, and that is
19 your belief to this day?
20 MS. : Yes. That is my belief to this
21 day.
22 MR. : Okay. And what does WAB
23 mean?
24 MS. : Oh, that means With All
25 Belongings.
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1 MR. : So, if a person is
2 transported down to Receiving and Discharge,
3 with the status WAB next to their name --
4 MS. : Mm-hmm.
5 MR. : -- what does that mean is
6 happening?
7 MS. : That means that the inmate is
8 leaving, and he's not coming back.
9 MR. : So, it does mean that
10 they are actually - that that is known as that
11 inmate is not coming back to the MCC?
12 MS. : Correct.
13 MR. : And what is --
14 MS. : Mm-hmm.
15 MR. : -- what is the document
16 that would say WAB on it?
17 MS. : Normally, there is a court
18 roster that lets the unit officer know that the
19 inmate is leaving. So, you would know who to
20 send down to R&D. And typically, it has an
21 approximate time. And/or, sometimes R&D may
22 then call up to the specific location, or the
23 housing unit, to say, send inmate so and so
24 down with all belongings.
25 MR. : Okay. So, but there is
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1 a, it sounds like a court list, or a
2 production, an inmate production list that is
3 created by R&D?
4 MS. : That is correct.
5 MR. : And that is what would
6 say -? That is how -? What staff members
7 would utilize in order to produce the inmates
8 to R&D?
9 MS. : That is - yeah - that is my
10 understanding.
11 MR. : And what happens with
12 that document? Like, so, the staff members
13 utilize it, then where does the document go?
14 Is it saved somewhere, like BOPWARE, or
15 TruScope, or is it something that they print
16 out, and then they destroy, or do they keep it?
17 MS. : Well, I know that R&D
18 definitely should have a copy of the court
19 roster. They should. Now, as far as what the
20 housing unit would do with it, I would believe
21 that they probably would shred it because it
22 serves no purpose to that specific housing
23 unit. But R&D would maintain copies of the
24 court roster.
25 MR. : Now, if R&D is saying
EFTA00127253
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1 that they actually don't keep a copy, it's like
2 a template that they revise every day, based
3 upon what inmates need to be produced. So,
4 they actually don't have any records from past,
5 you know, production lists. Does that sound
6 accurate to you?
7 MS. : Hmm. From my understanding, I
8 would think that a copy would be maintained.
9 And that there would also possibly be a
10 logbook. Because I - again - at the time, I'm,
11 you know, an associate warden, but, and I never
12 specifically worked in Receiving and Discharge.
13 But from my understanding of being in Receiving
14 and Discharge, and from our early, my early
15 years of being a correctional officer, I am
16 aware of, like, if a receipt is being
17 maintained, because someone keys in inmates in,
18 and keys inmates out in Sentry. And there, at
19 times, control even annotates things in their
20 daily, their daily log.
21 MR. : Yeah.
22 MS. : So, of, like, of movement.
23 Depending on the control room officer, that
24 officer may even take the time to list the
25 names, to actually write out names and register
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1 numbers. Or they just might write out the
2 numerical value of how many inmates departed
3 for court, versus how many departed, like, with
4 all belongings. Because that means that the
5 inmate is not returning, and he would
6 definitely have to be taken off your base
7 count, in order to get an accurate count.
8 MR. : Okay. So, and I know
9 we're not in person, so I'm going to have to
10 just explain to you what I'm looking at. i
11 have two emails that were sent to the MCC. One
12 was to - both from the U.S. Marshals Service -
13 one was to just Receiving and Discharge
14 personnel, and another one was sent, it looks
15 like to, like to a large amount of custody
16 personnel, including lieutenants, it looks like
17 Tijuana , who I believe was the SIS
18 lieutenant. It looks like
, who was an AW, is on there. As well as
20 a number of other people. Quite a large number
21 of people. I do not see your name on here.
22 But it does say the subject, "Prisoner
23 Production 8/9/2019," the date is Thursday,
24 August 8th, 2019, at 3:36 p.m.
25 MS. : Mm-hmm.
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1 MR. : Now, within the
2 attachments, it shows NYM 8/9/2019. Do you
3 know what that would stand for?
4 MS. : You said NYM 8/9?
5 MR. : Yeah. So, N-Y-M.
6 MS. : Mm-hmm.
7 MR. : Yeah. And then, when you
8 open it up, it just says - it's the U.S.
9 Marshals report - and it says, "Prisoners
10 Schedule Report." It says --
11 MS. : Mm-hmm.
12 MR. : -- MCC New York.
13 MS. : Mm-hmm.
14 MR. : Do you know if that would
15 be who was being produced to the U.S. Marshals
16 the following day?
17 MS. : Yeah. That is what it is.
18 It's a court list.
19 MR. : Okay.
20 MS. : Yeah. Basically, it's a court
21 list.
22 MR. : Okay. So, when I open
23 this up, on the first page there, it starts
24 with two inmates. The second inmate down, it
25 says, "Reyes, Efrain." Or Efrain. E-F-R-A-I-
EFTA00127256
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1 N.
2 MS. Mm-hmm.
3 MR. : It shows a date of birth.
4 A time. A time. The time says 8:53, and then,
5 it says, 8/9/2019. Underneath production
6 reason, it says, "TF," and the description
7 says, "Transfer within." And then --
8 MS. : Mm-hmm.
9 MR. : -- it says, "MCC New
10 York." And then, it does say, next to that,
11 typed court. Now, under that, it says, "Judge.
12 MCC TOT GEO." Do you know what that would
13 stand for?
14 MS. : No. I'm not. Hmm-mm.
15 MR. : So, the MCC to GEO. You
16 wouldn't understand that that --
17 MS. : Oh.
18 MR. -: -- meant -?
19 MS. : Oh. GEO. MCC to GEO. That
20 means that GEO is a private prison.
21 MR. : Correct.
22 MS. : So, I would think that GEO,
23 that's, like - yeah - that's a mnemonic for a
24 private prison.
25 MR. : Okay. And then, when it
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1 says, "Destination description," it says,
2 "WAB/MED summary." Does that tell you
3 anything?
4 MS. : Yeah. Well, WAB. WAB means
5 With All Belongings. Now, /MED summary means
6 medical summary. So, when I'm first hearing
7 you say WAB, that lets me know that the person
8 is leaving. That means with all belongings.
9 So, typically, when someone is scheduled for
10 transfer, you have the time to pack them out,
11 and so, they would come down, you know, prior
12 to the date. But with WAB, that means that the
13 person is leaving that day, and then they
14 should come down with all of their belongings.
15 Everything that they have because for whatever
16 reason, they're not coming back, they're going
17 somewhere else.
18 MR. : Right. So --
19 MS. : And then -.
20 MR. : -- so, it looks like --
21 MS. : Mm-hmm.
22 MR. : -- these first two
23 people, the first two people both say,
24 "Transfer within." Both of them say MCC to
25 GEO. And then --
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1 MS. : Mm-hmm.
2 MR. : -- they both say WAB,
3 with the destination in the description. Now,
4 the other inmates that are listed on here, they
5 have various things --
6 MS. : Mm-hmm.
7 MR. : -- from the reason being
8 status hearing, to sentencing, to a change of
9 plea, to all things that look like they are
10 court related, but would you believe that these
11 first two, since it would say, "Transfer Within
12 MCC to GEO," and WAB, that means that they are
13 actually being transferred and not going to
14 court?
15 MS. : Yeah. I would - if I had an
16 opportunity to see that - I would understand
17 that that means that, exactly what you said,
18 that they are transferring.
19 MR. : Okay.
20 MS. : Somewhere other than -.
21 MR. : So, being that the MCC
22 was sent, actually, the one that was sent to
23 Receiving and Discharge was much earlier in the
24 day. But the one that was sent to the custody
25 was on August 8th, 2019 at 3:36 p.m. What
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1 should have been known from that information?
2 MS. : That those inmates listed for
3 departing and were not coming back.
4 MR. : Okay.
5 MS. : Yeah.
6 MR. : So then, it was known by
7 the MCC, at least, or at least should have been
8 known by the MCC, that on August 8th, 2019,
9 that Reyes, who happens to be Epstein's
10 cellmate, was actually transferring from the
11 MCC to another institution. And specifically,
12 to GEO.
13 MS. : That part is accurate. The
14 only thing that is not included in that is, if
15 it was sent to R&D, and R&D may not have known
16 that Reyes was Epstein's cellmate. So, it may
17 not have alerted them that Reyes was
18 (Indiscernible *00:52:03) for them to then have
19 to discuss, to say, oh, he's not, you know, it
20 wouldn't have rang alarms for whomever that R&D
21 staff member was.
22 MR. : Right. And that's why
23 focused on the email to custody, because all of
24 custody, including all the lieutenants --
25 MS. : Yeah.
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1 MR. : -- as well as Shirley, or
2 AW , and Captain
3 were actually sent --
4 MS. : Yeah. That --
5 MR. : -- that email.
6 MS. okay. Then that is - yeah
7 that is different. That is different.
8 MR. : So, the fact that custody
9 received it, is there someone that should have
10 been alerted to the fact, or reviewed that
11 document, to know, huh, we got these two
12 inmates, one of them is Epstein's cellmate.
13 You know, we now know that Reyes is leaving
14 from the institution. Is there someone that
15 should have been responsible for catching that?
16 MS. : The one thing I will say is
17 that, unless you are actually looking at the
18 court production list, to vet it, a person may
19 have just seen that as another court production
20 list. If it wasn't actually read, to see, you
21 know, for - to determine, okay, this inmate is
22 leaving, and who is he associated with?
23 MR. : Absolutely.
24 MS. : So --
25 MR. : And that's kind of - and
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1 I apologize if I
2 MS. : -- no.
3 MR. : I apologize if I
4 wasn't clear. What I'm saying is --
5 MS. : Mm-hmm.
6 MR. : -- should someone have
7 reviewed it? Is there someone that should have
8 - being that it was sent to all these people in
9 custody - is there someone that really should
10 have looked at it --
11 MS. : Mm-hmm.
12 MR. : -- as opposed to could
13 have looked at it?
14 MS. : Yeah. No. That's not
15 necessarily the responsibility of custody to
16 view -. There is -. I will say this. There
17 is no procedures in place, or their
18 responsibility that exists, that would say that
19 custody had to review a court production list.
20 Typically, they don't -. They may have
21 received a list as a courtesy. But okay. It's
22 a courtesy. It wasn't necessarily something
23 that they may or may not have to have some, you
24 know, to do something with the list. It's not
25
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1 MR. : Okay.
2 MS. : -- it's just a courtesy. It's
3 nothing more than that.
4 MR. : Okay. Now, I have an
5 email here, it's from you to
6 Do you know who that is?
7 MS. . Yes. He was
8 the former warden.
9 MR. : Okay. Great. And the
10 subject, it says, "Epstein, Jeffrey Edward,"
11 and then it gives his reg number. It was sent
12 Saturday, August 10th, 2019, at 4:35 p.m., and
13 in the body of the message, it says, "So far,
14 this is the documentation I have in my
15 possession." And it's signed your name,
16 Associate Warden, MCC New York."
17 So, do you recall if you were tasked with
18 obtaining documentation on Warden
19 behalf?
20 MS. : He didn't specifically task me
21 with anything. I just know that, when
22 something happens, that part of your
23 responsibility as an AW is to try to gather
24 documents. Now, I didn't have a specific
25 responsibility of securing the scenes. If
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1 that's correctional services, and that is what
2 they do. But I, certain things, I just
3 inherently, or instinctively, knew that I
4 should try to assist with. But I wasn't given,
5 you know, the instruction that Warden
6 did, relayed to me was to report to the
7 institution because of, you know, the death.
8 And from that, I already knew, or in my head,
9 on the way there was planning of what I wanted
10 - one of the things that I needed to do to
11 assist with the matter.
12 MR. : Okay. So, you
13 independently took this task on, to collect all
14 these documents?
15 MS. : I did.
16 MR. : Okay.
17 MS. : I must admit I did.
18 MR. : Okay. Great. So, I have
19 the document opened that you provided to him.
20 It's an attachment to your email saying what it
21 was that you collected.
22 MS. : Mm-hmm.
23 MR. : It starts with,
24 "Documentation re: Epstein, Jeffrey --
25 MS. : Mm-hmm.
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1 MR. : -- Jeffrey Edward,
2 Deceased." And then, it talks about Sentry
3 reports. Like, the PPE-44, or PPE-37, and all
4 the way down to a PR-15. And then, it talks
5 about BOPWARE, label, administrative detention
6 order. And then, a few down, which is directly
7 in the middle of the first page, or slightly
8 below the middle, it shows, "Court
9 documentation regarding WAB." And this is
10 under --
11 MS. : Okay.
12 MS. : -- under the heading,
13 "Documentation --
14 MS. : Okay.
15 MR. : -- re: Efrain, Reyes.
16 Reg number 85993-054." And then, it says,
17 "Cellmate." It says, "Court documentation
18 regarding WAB, 8/9/19." Do you know what court
19 documentation is you were referring to?
20 MS. : Well, it had to be the court
21 list, then. Is it the same thing that -? Are
22 you able to open the attachment?
23 MR. : That is the attachment.
24 So, it doesn't -. You didn't include in that
25 email the electronic versions of this. You
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1 said, this is what I have collected.
2 MS. : Oh.
3 MR. : And within it, it says --
4 MS. : Okay.
5 MR. : -- "Court documentation
6 regarding WAB, 8/9/19," and specific to Efrain
7 Reyes. So, I am just wondering, what
8 MS. : Okay.
9 MR. : -- what document were you
10 referring to?
11 MS. : What document? It had to -.
12 Hmm. I don't know. Unless I'm able to
13 actually look at my email. But if you are
14 saying WAB, that means I had to have seen
15 something --
16 MR. : If you are actually
17 MS. : -- that says that -.
18 MR. if you are in front of
19 your email, you can find this. Just go to your
20 sent emails.
21 MS. : Yeah. I have to go - hold on.
22 That's what I'm doing - but I have to go in my
23 archives.
24 MR. : Right.
25 MS. : You know?
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1 MR. : Okay. So, yeah.
2 MS. : But when I open --
3 MR. : This might help refresh
4 your memory, so we can actually, you can
5 actually look at what it is that I am talking
6 about.
7 MS. : Okay.
8 MR. : So --
9 MS. : Yeah.
10 MR. : -- again, it would be, it
11 will probably take a little while --
12 MS. : Okay.
13 MR. : -- because it was a long
14 time ago.
15 MS. : Yeah.
16 MR. : But August 10th, 2019 --
17 MS. : Mm-hmm.
18 MR. : -- and again, the email
19 was sent at exactly 4:35 p.m.
20 MS. : Okay. Give me one second,
21 because like I said, I have to go in the
22 archives.
23 MR. : Sure.
24 MS. : Okay. Okay. To
25 MR. : And did you happen to get
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1 to that email yet?
2 MS. : No. Hmm-mm.
3 MR. : Okay.
4 MS. : But the way that this -. Okay.
5 Hold on. Just wait. I got this. Okay. You
6 said -. Hmm. Not -. I'm doing an advanced
7 search. And because it's the archives, it's a
8 little slow. It's not -. It's not on my
9 present Google Drive.
10 MR. : Yeah. No. I understand.
11 Same thing when I look for my own emails. If
12 it's, like, more than six months to a year old
13
14 MS. : No.
15 MR. : =- it takes a while.
16 MS. : Okay. Now - okay - I'm in old
17 stuff now. Okay. You said 8/9, 8/10/19. Oh.
18 MR. : 11.
19 MS. : Okay. I'm in nine. That's why
20 I had to do with it. Okay. Okay. Okay. I
21 see. I see the Word attachment that is there.
22 Okay.
23 MR. : Okay. You did find the
24 email?
25 MS. : I - yes - I was able to find
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1 the email.
2 MR. : Great.
3 MS. : Mm-hmm.
4 MR. : So then, yeah. So, you
5 see where the Word attachment. Do you see,
6 again, middle of the page, where it says,
7 "Documentation, Re: Reyes, Efrain."
8 MS. : Yeah.
9 MR. : And that - yeah - that
10 first document is the one I was wondering
11 about. This court documentation regarding WAB,
12 8/9/19.
13 MS. : Mm-hmm.
14 MR. : And I'm just trying to
15 refresh, see if you can remember what document
16 you would have --
17 MS. : What --
18 MR. : -- been talking about.
19 MS. : -- what I could do is, hold on,
20 because I'm trying to -. I'm trying to over
21 document that I have. Okay. So, what -. Let
22 me first forward this to my present email, so I
23 won't lose it. And then, I'm going to go,
24 because I had a folder of documents that I did
25 maintain because of that, I kept receiving,
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1 like, inquiries after as to what documents I
2 had. And so, let me see what I -. See if I
3 have anything that shows that. Okay. Hold on.
4 I'm going to have go out Okay. So, I have
5 -. Okay. One thing I had, that I have a title
6 for Efrain was just, like, was his
7 (Indiscernible *01:04:43) and Sentry
8 information. Special Housing review. Okay.
9 That's not showing me the court date. R&D.
10 Okay. Hold on one second. Let me see which
11 drop file. No. The drop file. (Indiscernible
12 *01:05:16). Let me see. Man, I don't -.
13 That, as an attachment. I don't have that as
14 an attachment. I do -. I am able to look at
15 other things. But a court list. I don't have
16 that as a court list. I don't have the court
17 list.
18 MR. : Now, you're talking about
19 electronically, or are you referring to --
20 MS. : Mm-hmm.
21 MR. : -- okay.
22 MS. : Yeah. Because I saw - there
23 were things that I saved. That's how I was
24 able to send them, you know, to other
25 individuals. Meaning, in the agency. When
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1 there was a request. But that, I don't see,
2 for whatever reason. I don't see that file. I
3 mean, I don't see that.
4 MR. : Now, it sounds like this
5 specifically was, they were documents that you
6 obtained physically.
7 MS. : Mm-hmm.
8 MR. : Do you know, do you still
9 have any of those documents? When you say you
10 kept the file --
11 MS. : No.
12 MR. : -- are they hard copy --
13 MS. : No.
14 MR. : -- files?
15 MS. : No. It's not a hard copy file.
16 Any hard copy files, they were turned over.
17 Items that I have were turned over. And then,
18 there was some things that were still in my
19 possession. I have the emails where it shows
20 who it is that I turned them over. It was
21 myself and Lieutenant that was actually
22 working together. She was assigned to SIS.
23 Working together to gather the documents. And
24 then, there was some documents that were turned
25 over to the FBI. And that could, in fact, have
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1 been one of the documents that was turned over
2 to the FBI. There should be a list of what was
3 turned over to them.
4 MR. : Okay. And do you know if
5 it was the FBI versus the OIG?
6 MS. : No.
7 MR. : You don't know who it
8 was?
9 MS. : I don't know because I - like I
10 said - any documents that Lieutenant
11 would have turned over, it should have been
12 There should be something, some kind of
13 document indicating what was turned over to
14 them.
15 MR. : And do you know -. So,
16 there should be some kind of a receipt with the
17 documents --
18 MS. : There should be.
19 MR. : -- that were provided?
20 MS. : Yeah. Mm-hmm.
21 MR. : And that would be
22 something that Lieutenant would have?
23 MS. : If she, in fact, turned those
24 documents over, she worked in SIS.
25 MR. : Okay. So, it wouldn't -.
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1 You didn't turn it over to the FBI. She --
2 MS. : No. Yeah. I didn't have any
3 contact with the FBI agents directly. At all.
4 MR. : Okay. And then, as far
5 as - what is your understanding of what it
6 means, though, when it says, "Court
7 documentation regarding WAB." Do you know what
8 court --
9 MS. : That was --
10 MR. : -- documentation you
11 would be referring to?
12 MS. that was (Indiscernible
13 *01:08:04). I don't know specifically, but
14 obviously, it would have to have been something
15 that said for, in order for me to write WAB,
16 without being able to look at it right now, it
17 obviously had to be something that said WAB on
18 it, and listed that inmate's name. Other than
19 that, I would not have wrote that.
20 MR. : And do you think that
21 that would have been that Receiving and
22 Discharge document that the SHU staff would
23 have utilized when they transported Reyes to
24 R&D?
25 MS. : It wouldn't have been his -
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1 that document from SHU. Because I didn't even,
2 I didn't go to SHU that day. So --
3 MR. : Sorry. But --
4 MS. (Indiscernible *01:08:42).
5 MR. : -- the court production
6 list that, I'm just saying that, because my
7 understanding is, R&D, you know, prints out all
8 the same court production lists, and they
9 provide it to the different housing units, and
10 to the ops lieutenant, and to, you know, the
11 different various people that need to be in the
12 know with who is being produced. So, that is
13 all --
14 MS. : Mm-hmm.
15 MR. : -- all I'm saying, is,
16 like --
17 MS. : Uh-huh.
18 MR. : -- would it be the --
19 MS. : A copy of it. You're saying a
20 copy. It could have -. It had to be a copy of
21 something. But I don't know if it was, if it
22 was the court production list, or some kind of
23 Sentry roster. That, because you could print a
24 Sentry roster also, that shows, like you said,
25 everybody, you know, movement. So, it had to
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1 be a copy of something listing information as
2 to who was going out of the institution on that
3 particular day.
4 MR. : Okay.
5 MS. : That is the only thing I could
6 have - that I could surmise why I would have
7 wrote WAB.
8 MR. : Okay. Can I ask you just
9 to see if, you know, after the interview, if
10 you can, if you can track that down by any
11 means? Or if you may -. I don't know if you
12 can coordinate with Lieutenant - can ask
13 Lieutenant , as well - but if you could
14 just see if you, in fact, did make a copy, or
15 you know what you did with this document, or
16 figure out what that document was. And I don't
17 know how you would do that. So, I don't, you
18 know --
19 MS. : Yeah.
20 MR. : -- you might not be able
21 to, but just, if you could just check.
22 MS. : Mm-hmm. That means all of
23 them, the documents that I listed, those things
24 were turned over. But okay. I will even look
25 at all of my emails I saved. Well, what I -
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1 whom I turned things over to, or what I've
2 turned, what I turned over.
3 MR. : That would be great.
4 Specifically, we would be very interested in
5 that court documentation regarding, you know,
6 Reyes.
7 MS. : Mm-hmm.
8 MR. : And is it surprising to
9 you now, though, since again, like, you thought
10 that he was at court, and then released on, you
11 know, released from there, but now that you see
12 that you actually wrote, "Court documentation
13 regarding WAS," is that surprising?
14 MS. : Well, I won't say it's -. I
15 won't use the word "surprising." But it would
16 jog my memory to say, okay, you - like I Said -
17 if he left on WAB, I have something that says
18 WAB, that is what it was. WAB. But did I know
19 at the time, or was I in the know? No. This
20 is after the fact.
21 MR. : Right, right, right. No.
22 I'm just saying the, you know, it seems like a
23 lot of people seemed to think that he was, you
24 know, sent to court and released, whereas, you
25 know, as we just discussed, he was actually
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1 transferred. So, I was just wondering if that
2 surprised you to find out that, oh, wow, I
3 actually did know he was WAB after the, you
4 know, on --
5 MS. : Yeah, well --
6 MR. : -- August 10th.
7 MS. : -- yeah, that part, because
8 that is, like you said, that has been, that has
9 been the discussion all along, that Reyes went
10 to court, and he was released from court. So,
11 I'm hoping that my information is accurate, but
12 typically, when you - because it's now, it
13 seems like, it conflicts, obviously, with what
14 everyone's recollection is - but typically,
15 when you see WAB, that means With All
16 Belongings, that the person is leaving, they
17 are transferring. Now, how the whole court got
18 into play, maybe, I don't know. And I don't
19 want to speculate, because it is just going to,
20 you know, further confuse everything.
21 MR. : Okay. Yeah. No. I
22 think we've definitely cleared up the fact that
23 he was WAB, and he transferred, just upon the
24 emails that we, you know, I talked to you about
25 with the U.S. Marshals Service, as well as this
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1 one. But I was just, you know, for you being
2 that you are the one who gathered that
3 document, I'm just hoping that we can figure
4 out where that document went, because
5 MS. : Sure.
6 MR. : -- you know, it's really
7 the R&D document, and I'm hoping that that's
8 what it is, that we can track down, is whatever
9 they --
10 MS. : Well --
11 MR. : -- generated.
12 MS. : I want to clarify. It may
13 not be their specific document. If it's a
14 document that says WAB.
15 MR. : Absolutely.
16 MS. : It doesn't necessarily have to
17 be their, you know --
18 MR. : No, no. Absolutely. I'm
19 just hoping that it is. And that we can track
20 it down --
21 MS. : Okay.
22 MR. : -- is what I'm saying.
23 Like, I don't know what it is, because again,
24 it's not --
25 MS. : Yeah.
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1 MR. : -- specific. But yeah, I
2 was just hoping that you would be able to, you
3 know, provide some clarification on that
4 document.
5 MS. : Yeah.
6 MR. : Now, just to back up a
7 little bit. Now, what was your responsibility,
8 like, the AWs are kind of split. Right?
9 There's two AWs, and one is in charge of one
10 thing, and another is in charge of another.
11 What - when you were at the MCC - what were you
12 in charge of on August 9th and 10th?
13 MS. : What? I was in - I had
14 oversight of correctional services.
15 MR. : Okay. So, you actually
16 did have oversight over this incident?
17 MS. : Mm-hmm.
18 MR. : And is that --
19 MS. : Well --
20 MR. : -- is that why you would
21 have --
22 MS. : I think what --
23 MR. : -- gathered all those
24 documents?
25 MS. : -- not specifically only
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1 because of that. But because I just know there
2 is an incident that happened, because I've been
3 an exec staff, and there is certain things that
4 you should gather. But it wasn't because I was
5 the AW of correctional services. Now, as an
6 AW, or someone in exec staff, you should just
7 know kind of what to gather anyway.
8 MR. : Okay.
9 MS. : What information to gather.
10 MR. : Okay. Great. And on
11 that note, would that have been something that
12 you would have gathered, specifically the R&D
13 court production list?
14 MS. : No. Hmm-mm.
15 MR. : No?
16 MS. : No. Mm-hmm.
17 MR. : But it's just something
18 that had -. Something that was court
19 production for Reyes with WAB, you just don't
20 know what it was.
21 MS. : I gathered all of the
22 information that I knew logically was
23 associated with Epstein.
24 MR. : Okay.
25 MS. : That was, it's just logical
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1 connections, if you wanted - if you know you
2 have an incident, and you know something
3 happened, in the Special Housing, and there is
4 only two inmates that are in the cell, you know
5 you are not only going to focus on, quote
6 unquote, "The victim." You have to then also
7 turn your attention to who was in the cell at
8 the time. So, to me, anything that I gathered,
9 as far as Sentry information for Epstein, or
10 his Special Housing Unit record, I gathered the
11 same for his cellmate because that's just a
12 logical thing to do.
13 MR. : Sure. And that is what
14 I'm asking for my question. Being that you
15 logically gathered these documents, and you can
16 see that you wrote the document, I'm asking,
17 like, can you recall what would be - what would
18 have been the logical document that you would
19 have gathered, that would have showed that he
20 was --
21 MS. : Oh, I understand what you mean.
22 MR. : WAB?
23 MS. : Mm-hmm. I don't, I don't know
24 if I would have gone in R&D to see, or if I ran
25 - or if it was a Sentry roster, like, a log, a
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1 PP-37 log that showed something. But I don't
2 thinking about it now - I honestly, I can't say
3 that, because I do have other R&D documents,
4 but I don't know if that was that R&D court
5 roster.
6 MR. : If you don't mind, and if
7 it's not too much trouble, can you just send me
8 an email with the documents that you do have,
9 and then I can go through them to figure out
10 what it is we have and don't have, and what we
11 need, and don't need?
12 MS. : Sure.
13 MR. : With regards to this
14 incident.
15 MS. : Okay.
16 MR. : You can just, like, and
17 not right now. After, after we're done.
18 MS. : Okay. Not right now.
19 MR. : Yeah, yeah.
20 MS. : Okay.
21 MR. : No, no, not right now.
22 MS. : Okay. Mm-hmm.
23 MR. : All right. So --
24 MS. : And I will also look at other
25 emails that I sent out, because it's been, like
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1 I said, it's been, it's been several requests
2 to show what I had and what I didn't have. So,
3 any other emails, I will be more than happy to
4 share with you.
5 MR. : Yeah. If you can just,
6 if that's possible, just to forward me those
7 emails that you have provided --
8 MS. : Mm-hmm.
9 MR. : -- that had documents
10 with regarding, with regard to the matter.
11 MS. : Mm-hmm.
12 MR. : That would be great. So,
13 being that you were the AW in charge of
14 custody, you would probably be perfect to
15 answer some of these questions. So, since
16 Epstein was required to have a cellmate, what
17 should have happened once the notification wa -
18 made that Reyes was being transferred?
19 MS. : He should have received another
20 cellmate.
21 MR. : And obviously, we
22 probably did just cover this, and just because
23 we got sidetracked, and you said that SHU
24 staff, once they found out that Reyes was
25 transferred, they should have notified,
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1 Lieutenant wasn't there, so they should
2 have notified either the activities lieutenant,
3 or the operations lieutenant. Is that what you
4 said?
5 MS. : I'm saying that someone of a
6 supervisory nature, yeah, should have been
7 notified.
8 MR. : But who was it that
9 should have notified them? Would it be the OIC
10 of the SHU? Would it be the person that
11 transferred Reyes to R&D? You know it, when I
12 say transferred, I mean escorted him to R&D.
13 Should it have been R&D themselves? Who should
14 have made the notification to the lieutenant?
15 MS. : And without me spinning the
16 tale, and pointing a finger, because lack of,
17 it didn't, it all depends. For instance, if
18 the SHU staff knew that Reyes - and that's why
19 it's just kind of, I don't know, a question
20 mark - if the SHU staff knew that Reyes was not
21 coming back, then that would mean that they
22 would know that he wasn't, he was not going to
23 have a cellmate. So, without knowing what
24 everybody knew, I
25 MR. : Okay. So, I'll --
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1 MS. : -- (Indiscernible *01:17:59)
2 MR. -- fill you in on that.
3 MS. : Right.
4 MR. : So --
5 MS. : Yeah.
6 MR. . Do you know
7 who Roberto is?
8 MS. : Yes.
9 MR. : So, he was the SHU OIC at
10 the time. He's the one who escorted Epstein to
11 attorney conference that morning. And --
12 MS. : Mm-hmm.
13 MR. : -- at the same time, they
14 were jointly escorted with, I believe it was
15 Monge, but one of the, one of the SHU, one of
16 the internal staff who provided, produced Reyes
17 to R&D. They both did the --
18 MS. : Mm-hmm.
19 MR. : -- they both escorted
20 their inmates together. And during their
21 conversation, it was discussed that Reyes was,
22 in fact, WAB, and --
23 MS. : Okay.
24 MR. : -- would be getting a new
25 cellmate.
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1 MS. : Mm-hmm.
2 MR. : So, knowing that
3 was present, and there was an internal employee
4 that was present, and they both had this
5 discussion, and both said that they --
6 MS. : Mm-hmm.
7 MR. : -- knew that he was WAB,
8 does that clue you in a little bit more of what
9
10 MS. : Yeah.
11 MR. : -- actions should have
12 taken at that time?
13 MS. : Yes. Either one of them should
14 Now, either one of them. So, you said
15 was was the OIC?
16 MR. -: was the OIC. He
17 was the one that was --
18 MS. : Okay.
19 MR. : -- bringing Epstein, and
20 the conversation was had with both Epstein and
21 Reyes, saying, Reyes, we know you're leaving,
22 you're WAB. Epstein, you'll get a new cellmate
23 by the end of the day.
24 MS. : Now, as the OIC,
25 should have then contacted the lieutenant.
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1 MR. : Okay. So, being the AW
2 in charge of custody, do you believe that
3 MS. : Mm-hmm.
4 MR. : -- it was really
5 that should have made that notification?
6 MS. : Because as the OIC, that means
7 that you are, if you look at the post orders,
8 you are basically have oversight of SHU, for
9 lack of a better term. You should make sure
10 that the rounds are being conducted. If
11 inmates needs to be pulled out for whatever
12 reason. That the appropriate inmates are going
13 in their appropriate cages, so that, you know,
14 separate tees are adhered to. That inmates are
15 being fed. That sanitation is being conducted.
16 And if, and because you are now telling me
17 that this individual, whomever the individual
18 is, is saying that they were aware that Epstein
19 needed a cellmate, and that his cellmate was
20 leaving, they knew, so when you know something,
21 then you should, either you're going to - if
22 you didn't want to make the determination to
23 make another decision about who the cellmate
24 would be, then you need to contact your
25 supervisor.
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1 If you, yourself, can't make a decision,
2 you contact your supervisor who is authorized
3 to make that decision. But you must make the
4 contact in order for your supervisor to know.
5 And as an OIC, you are aware of who you can
6 contact.
7 MR. : Yeah.
8 MS. : That's plainly known that you
9 can contact the lieutenant when something is
10 going on, especially for something that, it's
11 not, it's the Special Housing Unit, that you
12 must be able to get a decision maker.
13 MR. : Okay. So, he should have
14 notified a lieutenant, is basically the long
15 and short of it?
16 MS. : Yes. Yes. The long and short
17 of it, he should have notified a lieutenant.
18 MR. : Okay. And are you aware
19 if - we are going to just touch on counts and
20 rounds that were conducted in the SHU - are you
21 aware if the SHU counts and rounds were not
22 conducted by the SHU staff on August 9th and
23 10th of 2019?
24 MS. : I was aware after the fact that
25 the staff members indicated that they did not
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1 make rounds.
2 MR. : And what did you become
3 aware of? Can you just give me a little bit
4 more clarity on that?
5 MS. : Well, I became aware of it just
6 like everybody else, you know, that the staff
7 members are saying that they didn't make
8 rounds. But was I aware of it on the day? No.
9 MR. : No, no, no. I'm sorry --
10 MS. (Indiscernible *01:21:57).
11 MR. : -- so, what I mean is,
12 like, what did you became aware of? What staff
13 members, and what did you learn?
14 MS. : Oh. Oh, oh. Okay. The two
15 staff members that were assigned on the morning
16 watch shift, that they have said that they did
17 not make rounds.
18 MR. : And is that and
19
20 MS. : Yes. Those were the two staff
21 members that worked that shift.
22 MR. : And do you remember who
23 you learned that information from?
24 MS. : No. Hmm-mm.
25 MR. : Okay. Did either
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1 or say that that, you know, tell you that
2 information directly?
3 MS. : No. I didn't I haven't
4 even, from the day of the incident, I have not
5 laid eyes on either one of them.
6 MR. : Okay.
7 MS. : Besides on TV. So, I have not
8 spoken to either one of them. Well, no, and
9 I'm not going to say I haven't spoken to either
10 one of them. I did call to make welfare checks
11 on staff members, to see if they were okay, and
12 that was weeks after, because they haven't been
13 at work, and that's what we were told to do, to
14 call the staff members, just to say, you know,
15 if you're okay. Because they physically were
16 not in the institution. But as far as
17 discussing the incident, and what they did and
18 did not do, I did not engage in that.
19 MR. : Okay. And did you learn
20 anything, you know, during your time on this,
21 did you learn anything about the accuracy of
22 the MCC SHU counts and rounds on August 9th and
23 10th of 2019?
24 MS. : You said did I run anything as
25 far as the -.
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1 MR. : Did you learn if they
2 were accurate or not? Like, the counts that
3 they conducted, and the rounds they conducted.
4 Did you find out through your, you know, what
5 you were doing, did you learn if they were
6 accurate counts and accurate rounds?
7 MS. : The date, the date, you're
8 saying the date of when I was gathering the
9 information, or the documentation?
10 MR. : Or at any point. Did you
11 ever find out if the counts were either
12 accurate or not? And the rounds were accurate
13 or not.
14 MS. : Not specifically about the
15 counts and the rounds, but just like, like I
16 said, and like everybody else, of what has come
17 out, that they said that they did not do
18 counts. I mean, do rounds.
19 MR. : But had you heard
20 anything about, like, the counts being wrong?
21 Like, they're actually reporting the wrong
22 numbers, or anything like that?
23 MS. : In the SHU. I'm trying to
24 remember. I know that there was, there was
25 discussion about whether or not the count was
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1 done because, and I can't remember exactly what
2 happened to make that come up, but I know there
3 - we couldn't find certain count slips. And I
4 think somebody, and I can't remember if it was
5 Epstein, or Reyes, or somebody was not keyed
6 out. One of the inmates was not keyed out, and
7 if that, and my memory is serving me properly,
8 and the count should have been affected by --
9 MR. : Right. And did --
10 MS. : -- you know, inaccurate Sentry.
11 Inaccurate Sentry information.
12 MR. : -- okay. So, you are
13 aware of that then. Yeah. So, do you know,
14 it's, I think the inmate's name was Fernandes.
15 Does that ring a bell? Someone that
16 MS. : I --
17 MR. : -- was found to have
18 been, passed contraband, and then, they were
19 removed from the SHU and placed in R&D holding
20 cell, but they were not actually keyed out of
21 the SHU?
22 MS. : No. I don't - hmm-mm - I don't
23 remember that specific. Hmm-mm.
24 MR. : Okay. But you remember
25 someone wasn't keyed out, which messed up the
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1 counts?
2 MS. : If you, it was something to
3 that effect. That there was somebody not keyed
4 out. I don't know if it was about SHU or about
5 the institution itself. But I know that there
6 was something about, there was some Sentry
7 inaccuracies that should have affected the
8 count.
9 MR. : Okay. And do you know if
10 that was documented anywhere, or you, you know,
11 provided information to anyone on that, that
12 you might be able to retrieve, to help, you
13 know, help us?
14 MS. : I'm going to try.
15 MR. : You know, you don't have
16 to do it now.
17 MS. : Yeah.
18 MR. : But this is another one
19 of those --
20 MS. : Okay.
21 MR. : -- things that if --
22 MS. : All right.
23 MR. : -- you can put that to
24 your --
25 MS. : Let me do Fernandes.
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1 MR. : -- yeah.
2 MS. : Okay.
3 MR. : Yeah. So --
4 MS. : Yeah.
5 MR. : -- if you can --
6 MS. : Mm-hmm.
7 MR. : -- those two things.
8 One, whatever documents --
9 MS. : What's his -?
10 MR. : -- (Indiscernible
11 *01:25:53).
12 MS. : What is Fernandes's register
13 number?
14 MR. : Let me pull that up.
15 That wasn't something I was going to touch on
16 with you, but since you brought it up, that's
17 the only reason I did. Let's see. All right.
18 And this one, I just have inmate Fernandes.
19 Let me -. Hold on. All right. So, it's
20 Leonardo. L-E-O-N-A-R-D-O.
21 MS. : Mm-hmm.
22 MR. : Fernandes. F-E-R-N-A-N-
23 D-E-S.
24 MS. : Mm-hmm.
25 MR. : Register number-
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1
2 MS. : Okay. And you said he was -.
3 MR. : And there is, you
4 actually have an -. Actually, what I pulled up
5 was an email from to both you
6 and So, and it talks
7 MS. : And it said, it talks about
8 that?
9 MR. : No. It talks about the
10 incident, where it just talks about, the date
11 was Friday, August 9th, 2019, at 3:52 p.m., and
12 it just says, "On August 9th, 2019, at
13 approximately 1:37 p.m., while conducting
14 routine duties, the 9 South visiting officer
15 observed a female visitor produce an unknown
16 object from her waistband and hand it to inmate
17 Fernandez." And then, it just talks about, you
18 know, a little bit more of it. But this is the
19 individual --
20 MS. : Okay.
21 MR. : -- that was not keyed out
22 of the SHU. And he was placed in R&D --
23 MS. : Okay.
24 MR. : -- the R&D holding cell,
25 which caused the count numbers to be
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1 inaccurately reported. Because the SHU staff
2 was still adding him on their count slips.
3 MS. : Yeah. Mm-hmm. Okay. Okay.
4 MR. : And does that --
5 MS. : Okay.
6 MR. : -- does that --
7 MS. : Okay.
8 MR. : -- does that refresh your
9 memory at all?
10 MS. : Hmm-mm. But you're saying, so,
11 but email doesn't talk about that. It
12 just talks about --
13 MR. : No, no, no.
14 MS. : -- (Indiscernible *01:28:02).
15 MR. : It just talks about the
16 incident.
17 MS. : Okay.
18 MR. : It doesn't --
19 MS. : Okay.
20 MR. : -- it doesn't talk about
21 the fact that it -. That's something that our
22 investigation has revealed.
23 MS. : Oh, okay.
24 MR. : Because we had to figure
25 out why are, you know, are the counts accurate
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1 or not, how do we find out if they --
2 MS. : Mm-hmm.
3 MR. : -- actually conducted the
4 counts, or didn't conduct the counts.
5 MS. : Okay.
6 MR. : So, when we went through
7 everything, we found that there was some
8 discrepancies based upon what was on the
9 lieutenant's log versus what was on
10 institutional count, which was on the, you
11 know, count slips. There are different things.
12 And then, you know, looking through the
13 lieutenants log, we see that, on August 10th,
14 during the night, at around 12:30 a.m., it has
15 a note in there, saying that they keyed
16 Fernandez out of the SHU, or out of the SHU,
17 and into wherever, R&D. And that's how we were
18 able to figure out, okay, these count slips are
19 actually all off.
20 MS. : Oh.
21 MR. : They are saying that they
22 were counting this many bodies, whereas, in
23 fact, there was one less because he wasn't
24 there.
25 MS. : Okay. Yeah. That doesn't jog,
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1 that doesn't jog my memory for that, though.
2 MR. : Okay.
3 MS. : Yeah.
4 MR. : This is kind of the first
5 you're hearing of that, then?
6 MS. : Yeah. I don't, I don't -. If
7 for whatever reason, this is, I don't recall
8 anything about that.
9 MR. : There was something you
10 recalled about the counts being off, but it
11 wasn't that?
12 MS. : Yeah. But it wasn't that.
13 Hmm-mm.
14 MR. : But you did know that
15 someone wasn't keyed out?
16 MS. : I, perhaps out of the
17 institution, and again, if something came up
18 about the count, but I don't recall there being
19 - and because it's --
20 MR. : Well, I think --
21 MS. : -- (Indiscernible *01:29:35)
22 MR. : -- well, there was a
23 question that - and maybe this is something
24 that the warden asked you - but Ray Ormond, who
25 I'm assuming you know - correct? - the regional
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1 director at the time.
2 MS. : Yeah. Mm-hmm.
3 MR. : He sent an email to
4 Warden , on the, I believe the 10th,
5 asking, "Why are the counts off? Why does one
6 say 72, and one say 73?" Maybe.
7 MS. : For Special Housing?
8 MR. : For Special Housing.
9 Correct. So, maybe --
10 MS. : Mm-hmm.
11 MR. : -- that's where they
12 asked you. Do you recall?
13 MS. : And you said, when did, that
14 happened on the day of 8/10?
15 MS. : Yeah. That would have been
16 Ray, Mr. Ormond asking on 8/10 because
17
18 MS. : Mm-hmm.
19 MR. : -- he was provided all
20 the count documentation, and asking him --
21 MS. : Mm-hmm.
22 MR. : -- why are these counts -
23 ? Why did the count - oh, no. He said, "Why
24 did the count change?" That's what it was.
25 MS. : Okay.
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1 MR. : He was, like, from the
2 10:00 p.m.
3 MS. : That's probably --
4 MR. : -- count to midnight, it
5 changed from 73 down to 72, and our
6 investigation has revealed it's because this
7 person was never keyed out of the SHU --
8 MS. : Mm-hmm.
9 MR. : -- until --
10 MS. : That is maybe that is what
11 prompted it, but like I said, I knew something
12 happened with the count, and from that, I -
13 myself and Lieutenant were trying to
14 gather the count slips, and it should be a 30-
15 day file maintained in control, and we were not
16 able to find the count slips. So, I didn't
17 know it. Well, now that you're telling me, I
18 didn't know it was because of that. And there
19 is some things that I was in the know about,
20 that I - or I wasn't - but I knew it had
21 something to do, like, is that with the counts,
22 and we were told to get some of the count
23 slips.
24 MR. : Okay. But just, you
25 don't have anything to add to that. This is
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1 all kind of --
2 MS. : Mm-hmm.
3 MR. : -- more new information
4 for you?
5 MS. : Yes. Mm-hmm.
6 MR. : Okay. We can move on,
7 then.
8 MS. : Okay.
9 MR. : What is a lieutenant - or
10 sorry - a SHU lieutenant round? So, sorry.
11 So, when a lieutenant conducts a round in the
12 SHU, what should that consist of?
13 MS. : So, when you're the SHU
14 lieutenant, you --
15 MR. : And I don't mean
16 specifically the SHU lieutenant. I said that
17 wrong.
18 MS. : Okay.
19 MR. : In the first.
20 MS. : Okay.
21 MR. : Just when a lieutenant,
22 whether it's an activities, a SHU lieutenant --
23 MS. : Okay.
24 MR. : -- an activities
25 lieutenant, an operation lieutenant. When
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1 lieutenant goes to the SHU and conducts a
2 round, what should they be doing when they
3 conduct a round?
4 MS. : They should be walking around
5 and talking to the inmates.
6 MR. : So, is there, is the SHU
7 Is a lieutenant round the same thing as a
8 staff round, where you are supposed to go up
9 and actually check on the inmates?
10 MS. : Hmm. I'm not going to say it's
11 the exact same thing because the staff in SHU,
12 they actually have to record that they have
13 done rounds. And by them recording that, they
14 are indicating that they recorded timely
15 rounds, and that they actually are able to say
16 with certainty that they looked, you know, that
17 they verified that all the inmates are there,
18 and that they are alive. Versus a lieutenant,
19 what your responsibility is, you are just
20 making, you are generally making sure that you
21 go around and ensure that everything is okay.
22 But are you specifically and stopping at every
23 single cell? I wouldn't say necessarily that
24 that is exactly, but it mimics the same
25 requirement as the staff.
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1 MR. : Okay. So, if Reyes is
2 gone at 8:30, approximately 8:30 a.m. on August
3 9th --
4 MS. : Mm-hmm.
5 MR. : -- and there is
6 obviously, I think there is supposed to be at
7 least, what? One lieutenant round conducted in
8 the SHU per shift?
9 MS. : Mm-hmm.
10 MR. : Is that --
11 MS. : Mm-hmm.
12 MR. : -- is that correct?
13 MS. : Mm-hmm.
14 MR. : So, if there is an
15 activity, you know, the SHU lieutenant is out,
16 so there is an activities or an ops lieutenant
17 conducting a round, both the day shift and the
18 night shift, and then, the operations
19 lieutenant conducting one in the morning shift.
20 Should any of those lieutenants realized, when
21 they were doing their rounds, that Epstein, you
22 know, Reyes was gone, and/or Epstein was by
23 himself?
24 MS. : Yeah. If - now, that's a -. I
25 would say yes. I would say yes.
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1 MR. : And how should have they
2 known that? What should have the -. What
3 should have clued them in on the fact that
4 Reyes is gone, and Epstein is by himself? Or
5 if Epstein is in attorney conference, there is
6 just no one in the cell in general.
7 MS. : Well --
8 MR. : Since they have names on
9 the door tags, like you said.
10 MS. : -- that's what I was going to -
11 yeah - that's what I was going to say. But the
12 names on the -. The names on the door tag.
13 When someone leaves, you should remove the door
14 tags, so then, in fact, there should have only
15 just been one tag on the door. You wouldn't
16 have, you wouldn't have two tags on the door if
17 there is only supposed to be one person in
18 there. So, the tag should have been removed.
19 And -.
20 MR. : Do you know if the tag
21 was removed for Reyes?
22 MS. : That, I don't know if Reyes'
23 tag was removed, because I didn't go in the
24 Special Housing Unit. So, I don't know if his
25 tag was removed. But you - by us talking - you
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1 indicated that the SHU staff was aware that he
2 was leaving. So, they put the tags up, they
3 should remove the tags. And there would be no
4 reason to keep a tag on the door, indicating
5 that there is two inmates. One, when you are
6 aware that he is no longer going to be there.
7 MR. : But should
8 MS. : Yeah.
9 MR. : -- should those
10 lieutenants have conducted a round on basically
11 Epstein's cell?
12 MS. : I would -. You would conduct a
13 I would say yes. Because especially if you
14 have a highlighted inmate, or an inmate of
15 great concern. Or someone that you know you
16 need to check on. If you are not going to look
17 at anybody else's cell, you would definitely
18 look at, or check on, the inmates that are of
19 concern, to even say, hey, you okay? Or, you
20 know, just to talk with them, or physically see
21 them. So, I would say that you would - yeah -
22 that you would have looked in his cell to see
23 something, that something is going on.
24 MR. : Now, what about --
25 MS. : And then -.
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1 MR. if Epstein -. So, if
2 they are conducting their rounds when Epstein
3 is in attorney visits, should they still be
4 checking in on his cell itself, like, to make
5 sure everything is okay with his cellmate, or
6 anything like that?
7 MS. : Well, if he was, if he was
8 physically inside of his, he physically was not
9 inside the cell at the time, but the only way
10 for you to know, because why would the
11 lieutenant automatically know that he's in
12 attorney conference? So, you still would have
13 looked in his cell.
14 MR. : So, they - regardless, in
15 this specific, you know, Epstein is your
16 highest profile inmate at the time --
17 MS. : Mm-hmm.
18 MR. : -- any time a lieutenant
19 basically goes into that SHU, they should
20 really check on him? And check on that cell?
21 MS. : I would say so.
22 MR. : Okay. But that is more
23 of a, you know, it sounds like it's not
24 necessarily a policy, but just, that's good
25 practice. Is that what you are saying?
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1 MS. : Yeah. Yeah. That's what I'm
2 saying. And because it was known, as you and I
3 discussed, that he should have a cellmate. So,
4 there's certain things that you would be
5 checking for, you would be checking for his
6 welfare, and you would also be checking to make
7 sure that those recommendations were adhered to
8 because you want to make sure, with certainty,
9 if you are saying that you made the round, you
10 are annotating it in the book that you made the
11 round. And you would want to say that you
12 actually went around to them, and you checked
13 on these things.
14 MR. : But is there any kind of
15 BOP or MCC policy or directive that, you know,
16 they would have violated, if they didn't in
17 fact check on Epstein's cell?
18 MS. : I can't say that it would be a
19 I don't know about the lieutenant, that
20 they would say that, because they didn't look
21 in one cell or two cells. But I do know, if
22 you are indicating, and then, that's another
23 thing. If you are, when you come inside of the
24 Special Housing Unit, there is a logbook. If
25 you are annotating in the logbook that you are
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1 visiting, or if you are indicating in the
2 logbook that you are doing a round, you -. So,
3 I'm going to backtrack what I said before.
4 MR. : Well, there is an actual
5 log sheet that they sign. So, the lieutenants
6 actually have to sign that they conducted their
7 round.
8 MS. : So then, that's why I'm going
9 to backtrack then. If you are saying that you
10 did rounds, that means that you should have
11 looked in all of the cells.
12 MR. : Okay. And so, for a
13 lieutenant, that - and that, so, this is where
14 we've been getting kind of different
15 information - some lieutenants are saying,
16 absolutely, you need to go down each range,
17 check on every cell door. Other lieutenants
18 are saying, no, no, no, no, we're just supposed
19 to check in with the staff member that are in
20 there, and make sure that they don't have any
21 problems. Our rounds are really conducted on
22 the staff members, not on the inmates. So,
23 that is where I am - and there is nothing that
24 I can find, specifically in policy, that really
25 specifies that information.
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1 MS. : Yeah. So, I - and that's where
2 I was kind of weaving back and forth. A
3 lieutenants' purpose, let's just say in the
4 general housing, like, general, you know, GP.
5 You are making rounds on the unit, you're
6 checking on, generally, you're checking on the
7 unit itself. And you don't, you would not go
8 down, and checking every cell, because that's
9 general population. You don't anticipate being
10 in SHU. And you are making yourself available
11 in the event that the staff member needs
12 something. So, you are physically supposed to
13 go. But if it's the Special Housing Unit, and
14 then, also 10 South, which MCC also has.
15 MR. : Correct.
16 MS. : Your responsibility level,
17 because of the practices, or just you knowing,
18 inherently, what you should be doing, it's a
19 little different than the just making yourself
20 available to the staff. You are not just there
21 for the staff. You are also there for the
22 inmates because they can't come to you. You
23 have to go to them.
24 MR. : Okay. So --
25 MS. : So -.
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1 MR. : -- so, basically, I'm
2 understanding that general population, no, a
3 SHU - or a lieutenant wouldn't have to - with
4 their rounds - don't have to be with the
5 specific inmates, but in the SHU, because they
6 have limited movement, and they are only in
7 their cells, a lieutenant really should be
8 checking on each cell, during their rounds?
9 MS. : For - like you said - for good
10 correctional judgment, sound correctional
11 practices, you - yeah - you would.
12 MR. : But to your knowledge,
13 there is no requirement? It's just sound
14 judgment and sound practice?
15 MS. : Yeah. And because that, but
16 that's why I was going back, because I don't
17 think there is anything written that says when
18 a lieutenant makes his rounds, they should go
19 to every single cell. I know their requirement
20 is, like you said, for you to, for a lieutenant
21 to be present, and to, on every shift, as well
22 as if there is also, also different departments
23 that are required to make rounds. Weekly. And
24 with that in mind, you typically know that that
25 means that you are stopping at every door, and
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1 you are talking to the inmates, because again,
2 your purpose in SHU is to provide information,
3 and again, it's not like they can come out to
4 you. So, you have to go to them.
5 MR. : So, just to wrap this
6 thing up, if a lieutenant is saying that they
7 did not conduct any rounds of cells, they just
8 stopped in and talked to staff members. Do you
9 believe that they did something wrong?
10 MS. : I would say that I don't think
11 that they acted responsibly. I don't want to
12 say it's wrong or right because, you know, then
13 that person could say this, it's not written,
14 but I would say that that's not a responsible
15 decision.
16 MR. : So, when they certify
17 their round sheets that they conducted a round,
18 what do you believe that they are certifying?
19 MS. : That they have visited SHU, and
20 that they visited the inmates.
21 MR. : Okay. So, you do believe
22 that certification that they are signing, that
23 they conducted a round in the SHU, is that they
24 actually did conduct a round with the inmates?
25 MS. : That is what I believe.
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1 MR. : Okay. But that is more
2 of a belief and opinion versus a knowledge.
3 Correct?
4 MS. : Yes.
5 MR. : Okay. Great. We can
6 move on. Next thing we are going to talk
7 about, and I apologize this has taken a little
8 long, is the cameras. Do you know if the SHU
9 cameras were recording on August 9th and 10th
10 of 2019?
11 MS. : I know there was some -. And
12 again, this is information that has become
13 available after the fact. I know it has become
14 known after the fact that there was some
15 cameras that were not working. And that were
16 not recorded. But did I know the day of the
17 incident? No. I did not know on the day of
18 the incident.
19 MR. : Did you know why they
20 weren't recording? Do you know what happened
21 with the cameras?
22 MS. : I know that, I don't know why
23 they were not working on that day, but I know
24 that, following Epstein, that there have been
25 issues with MCC's cameras. The recorder, that
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1 there was supposed to be a backup camera, and
2 that, when the primary camera failed to record,
3 that there was supposed to be another camera
4 that kind of acts, or kind of, you know,
5 interfaces, so that there is always some
6 recording going on. That has been going on,
7 and again, that was after the fact, but as far
8 as the day of, I don't know.
9 MR. : So, you don't know what
10 caused the cameras to stop recording?
11 MS. : No. I don't know.
12 MR. : Okay. And do you
13 remember the - so, on August 8th, which would
14 have been a Thursday - do you remember, if on
15 August 8th, if you and SIS Lieutenant
16 were attempting to review video footage, and
17 you learned that you were not able to rewind
18 the cameras, and review the footage that you
19 were looking for?
20 MS. : You said on August 8th?
21 MR. : Right. And to help
22 further jog your memory. So, the information
23 we received from Lieutenant was that the
24 two of you were attempting to review video
25 footage, you weren't able to, so you called the
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1 comtech, Hughwon and asked him to
2 review the matter, and fix the issue. Does
3 that ring a bell to you?
4 MS. : If she's saying that that's
5 happened, and I know, Lieutenant and I
6 have had conversations, and about that, I would
7 say that that's - that if she is saying that
8 she and I had a conversation, I would say that
9 that probably did occur.
10 MR. : But you don't recall it?
11 MS. : I don't know if it was August
12 8th, or if it happened prior to. But I do
13 recall. I, again, I recall her and I trying to
14 look at something, but I don't recall the date
15 or the timeframe.
16 MR. : So, I guess, when you
17 arrived on the 10th, and learned that the
18 cameras weren't recording, which is, I'm
19 assuming, you would have learned on that day,
20 the 10th, that Epstein was found. Is that --
21 MS. : Mm-hmm.
22 MR. : -- is that accurate?
23 MS. : No. No. That is not accurate.
24 MR. : Okay. When did you learn
25 that the cameras actually weren't, or didn't
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1 record, or weren't recording?
2 MS. : I don't recall exactly when I
3 learned that --
4 MR. : Oh, okay.
5 MS. : -- but mm-hmm.
6 MR. : Okay. So, when we spoke
7 with Lieutenant , she said, when she
8 found out on the 10th that the cameras weren't
9 recording, she went to and said, hey,
10 what happened? You were to supposed fix this.
11 So, I didn't know if you
12 MS. : Oh.
13 MR. : -- you would have, you
14 know, had a similar reaction, or a similar take
15 on the matter.
16 MS. : Mm-hmm. And she is saying that
17 it was the SHU cameras that were not recording?
18 That --
19 MR. : Well, she --
20 MS. (Indiscernible *01:45:44).
21 MR. : -- well, she just said
22 that she knows that there were problems with
23 the cameras. I would have to look back at her
24 transcript to find out exactly if we were
25 talking about the SHU, but she says that --
EFTA00127315
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1 MS. : Mm-hmm.
2 MR. : -- the two of you were
3 trying, were attempting to review video, and
4 you were unable to review it because there was,
5 you couldn't find the recording, or you
6 couldn't rewind. So, the, you know, the
7 determination was made between the two of you,
8 and I can actually, let me pull up the actual
9 specific part of what she, of what she said
10 here. To see if you think it's accurate. So,
11 it says, "I remember stepping into his office."
12 Oh, okay.
13 So, "I remember stepping into his office,
14 which was right next door to mine, and
15 notifying him that the camera was down, and I'm
16 trying to get back to look at footage, and I
17 can't. Actually, I had one of the associate
18 wardens with me, as well, who happens to be his
19 supervisor." "So," I said, "Who was that?"
20 "Associate Warden ." " was there?"
21 "Yes." "Okay." "It was me and her together,
22 looking at the camera."
23 "Okay. So, it wasn't ? It
24 was actually ?" "No. It was me and AW
25 • " "And that was with Captain ?"
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1 "Yes." "Okay. So then, the two of them knew
2 that the cameras were down?" "Yes." "All
3 right. And do you know if they had any
4 conversation with about a need to get
5 them back up?"
6 She says, "I don't know if they had a
7 separate conversation, but when I called Mr.
8 over the radio, Ms. was still
9 standing there with me in the office, and she
10 was there with me when he came up to check,
11 because we thought it was something that maybe
12 he could just go in, and it allow us to go to
13 look at the camera, and look for what we were
14 looking for." So, does that ring a bell to you
15 at all?
16 MS. : Yeah. That does. Mm-hmm.
17 MR. : Does that sound accurate?
18 MS. : It does. Mm-hmm.
19 MR. : Okay. So, and this was
20 what she was saying, was on August 8th, that
21 she went in. So, do you know if, were you
22 there and present when was brought into
23 the office and told to fix the issue?
24 MS. : I don't recall. I don't recall
25 - hmm-mm - I don't recall having that
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1 conversation. And then, and I could have had
2 that conversation, but I don't recall having a
3 conversation with
4 MR. : Okay. So, you don't
5 recall But you do recall
6 MS. : Mm-hmm.
7 MR. : -- this interaction --
8 MS. : I remember --
9 MR. : -- with both you,
10 Lieutenant , and --
11 MS. : Yeah.
12 MR. : -- Captain
13 MS. : Mm-hmm. I do remember that.
14 And speaking of, I don't remember if it was, if
15 it was, because I'm trying to understand if it
16 was because you were saying we just couldn't
17 rewind, or if it was known that it was not, or
18 if it was that the cameras were not recording.
19 I'm hoping that you understand what I'm saying.
20 MR. : Yeah. So, the way that -
21 all right - the question was asked, so I said,
22 "Okay. So then, the two of them knew the
23 cameras were down?" She said, "Yes." And I
24 said, "Oh, all right. And do you know if they
25 had any conversations with about a need
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1 to get them back up?" She said, "I don't know
2 if they had a separate conversation, but when I
3 called Mr. over to radio, Ms. was
4 still standing there with me in the office, and
5 she was there with me when he came up to check
6 because we thought it was something that may be
7 he could just go in and it allow us to go to
8 the camera, and look for what we were looking
9 for."
10 I then said, "And when he mentioned the
11 whole -". So then, we started talking about
12 overtime, and when he could fix it, I said,
13 "And when he mentioned the whole, I'll stay
14 overtime, was she there when - was there -
15 when he mentioned that he would stay to work
16 overtime?" And she said, "I can't remember."
17 MS. : Well, and I know that, if I had
18 a conversation with , or anybody, about
19 the cameras not recording, versus you not being
20 able to rewind on your, on the Nice Vision.
21 That that would have been something that would,
22 that I would have known that was important.
23 And I'm trying to differentiate because there
24 are there, and I have had the experience that I
25 have access to Nice. And I was not able to
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1 actually rewind on one of the cameras.
2 But it's not because the camera was not
3 recording. It's because it was, the camera was
4 not programmed correctly or something. I don't
5 even know if I'm using the proper word. But
6 it's not that the camera was not recording. It
7 had something to do more with you're not being
8 able to pull it up and rewind it on the Nice
9 Vision application. But it's not the same as
10 it not being recorded. So, that's why I was
11 asking you, is she saying that we knew that it
12 was not recording? Because that's not my
13 knowledge, or my understanding, that the
14 cameras were not recording.
15 MR. : Okay. Yeah. No. Her
16 specific words were, "I remember stepping into
17 his office, which was right next door to mine,
18 and notifying him that the camera was down.
19 And I'm trying to go back and look at the
20 footage, and I can't. Actually, I had one of
21 the associate wardens with me
22 MS. : Yeah.
23 MR. : -- as well."
24 MS. : That - I wouldn't say that that
25 means that the camera is not recording. Hmm-
EFTA00127320
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1 mm.
2 MR. : So --
3 MS. : And that -.
4 MR. : -- so, saying the camera
5 was down, that would, what would you think that
6 that was saying?
7 MS. : And that's not -. When you say
8 that a camera is down, that's different than
9 the whole system not recording. That's not the
10 same thing. That might be that one particular
11 camera, and whatever area that she was talking
12 about, that I believe they had to be a fight,
13 or something happening for her and I to look at
14 a camera. That particular camera may, again,
15 something might have not been programmed
16 correctly, that we were not able to rewind.
17 But that is not the same thing as a whole
18 system not being operational.
19 MR. : Okay.
20 MS. : It's two totally different
21 things.
22 MR. : Okay. So, my question on
23 this really is --
24 MS. : And it's still fine.
25 MR. : -- my question on this is
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1 really is
2 MS. : Mm-hmm.
3 MR. : -- regarding
4 because it sounds like was told to fix
5 the issue, and that's really why I'm asking
6 this question. Do you know if was
7 instructed that you need to fix this issue?
8 MS. : You said in SHU?
9 MR. : Well, no. This is just
10 the cameras in general.
11 MS. (Indiscernible *01:52:06).
12 MR. : Well, we learned that the
13 cameras in SHU weren't recording.
14 MS. : Okay.
15 MR. : Through the
16 investigation. And to find --
17 MS. : Mm-hmm.
18 MR. : -- and determining, well,
19 when was this first found out? This is
20 MS. : Okay.
21 MR. : -- you know, that there
22 was a problem with the cameras. You know, we
23 obviously had to talk to a lot of people,
24 including, you know, , and , and,
25 you know --
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1 MS. : Now, that, now, I would like to
2 ask you to, did ever say that he knew
3 that the whole camera system was not working,
4 and when he knew, and who he had a conversation
5 with?
6 MR. : No, no, no.
7 MS. : About it.
8 MR. : So, that --
9 MS. : Oh.
10 MR. : -- so, the understanding
11 that I am of, is that - and again, I know at
12 least spoke with , and she
13 believed that you were with her when the
14 conversation took place. So, that is where I
15 was asking if you recall having a conversation
16 with and
17 MS. : I recall that, but not about
18 the camera system. The whole Nice system. And
19 all of the cameras in SHU not recording.
20 MR. : Yeah. Right. And I'm
21 not saying that that would have been the
22 conversation. I would think that the
23 conversation would more be along the lines of,
24 hey, we are trying to review this video. We
25 are not able to do it. Can you figure out
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1 what's going on with the cameras?
2 MS. : If that, if we had a
3 conversation about that, then I could see,
4 logically, that, yeah, I would say,
5 hey, why we can't rewind?
6 MR. : Sure.
7 MS. : Can you fix a camera, X, Y, and
8 Z, or see why it's not focused, or something to
9 that effect.
10 MR. : Right. And so, my
11 question --
12 MS. : Yeah. Yeah.
13 MR. is to you
14 MS. : Yeah.
15 MR. : -- do you remember what
16 the conversation entailed?
17 MS. : I can't remember the
18 conversation, but I know, if we were talking
19 about a particular image, or a particular
20 camera, and again, I'm not saying that it's not
21 recording, we are saying that we can't rewind,
22 that is what it would have been about.
23 why can't we rewind? Why can't we pull up
24 camera X, Y, and Z? But not about the whole
25 system. Especially if the whole system was not
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1 in question. Or there was no talk about the
2 system not recording, or even SHU not
3 recording. There was never any conversation
4 about SHU, or anything. So, that's the
5 conversation would have been limited to that
6 particular camera, and why we can't rewind.
7 MR. : Absolutely. And then --
8 MS. : And -.
9 MR. : -- that is kind of my
10 understanding --
11 MS. : Yeah.
12 MR. : -- is what your part of
13 this conversation was, is we are having an
14 issue trying to record, can you figure it out?
15 And my question to isn't, like, you know, this
16 isn't an I gotcha type of question, even in the
17 slightest. It's just, if you can --
18 MS. : Yeah.
19 MR. : -- recall what
20 conversation you had with
21 MS. : I can only recall about that,
22 like you said, about the interaction with
23 and I talking about why we were not able
24 to rewind to see what happened. Because we
25 were able to pull the image up. We were just
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1 not able to rewind. So, that is what I'm
2 saying. There is, and it might sound like I'm
3 trying to be very specific and deliberate,
4 because I am, because there is a difference
5 with you accessing the Nice system, and I'm not
6 an electronic - an electrician - or, you know,
7 an electronics person, and I could physically
8 see it, I could see it, but I am not able to
9 rewind. That doesn't let me know that, oh, the
10 system is not recording. So, that would not
11 have ever been part of the conversation. The
12 conversation would have been limited to, why is
13 it that I am able to look at it, but I can't
14 rewind?
15 MR. : Sure. Now, do you know
16 anything about --
17 MS. : So, figure that out.
18 MR. and do you know if, do
19 you know if Lieutenant created a memo,
20 and provided it to , regarding the camera
21 issue on the 8th?
22 MS. : No. Now, if she included me in
23 it, then I would say, oh, okay --
24 MR. : But you --
25 MS. : -- but I don't --
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1 MR. : -- yeah. And I don't
2 know that she would have included. She said
3 that she wrote a memo, based upon the issue
4 with the camera, and provided it to Captain
5
6 MS. : No.
7 MR. : But --
8 MS. : Hmm-mm.
9 MR. : -- but when you -. But
10 you do remember when, you know, in her, like I
11 just read to you, she said that the
12 conversation with the problem with rewinding
13 actually was with you and , though? Do
14 you remember being present for that, you
15 know -?
16 MS. : Now, I don't know if was
17 present for that. But I do, I know, because of
18 you reciting about the conversation, I do know,
19 definitely, that was there, and if she
20 is saying that was there, it is -.
21 Gosh, I don't know see why she would say he was
22 or he wasn't. It didn't have great importance
23 to me, that conversation, because it wasn't -.
24 So, that is why I am not, I am not - I can't
25 recall this to say that, oh, this person was
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1 there, that person was there, because it
2 wasn't, it wasn't, in my mind, highlighted that
3 the camera system was down. So --
4 MR. : Okay. So, what we have
5 learned is that, that is when checked on
6 the system, and he realized that - and this,
7 there is nothing that we learned that, you
8 know, have any knowledge of this, so I will
9 just, you know, put that out front - is that
10 said he checked on the system, and he
11 realized that two of the drives were down, and
12 when two drives go down, it stops the system
13 from recording. So, half of the cameras in the
14 institution stopped, were not recording at the
15 time. And this was basically learned on August
16 8th and August 9th, when he was trying to fix
17 the system. Were you ever made aware of that
18 information?
19 MS. : No. I was not.
20 MR. : Okay. Is this the first
21 time you are even hearing of that information?
22 MS. : Absolutely.
23 MR. : And is there someone that
24 he should have told about that information, the
25 fact that --
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1 MS. : Yeah.
2 MR. : -- no, no, no, that half
3 the cameras in the institution are actually
4 down and not recording? I mean, there is
5 live feed, but there is no recording.
6 MS. : Yeah. So, he should have
7 definitely told his first line supervisor, who
8 would have known to then tell his supervisor,
9 and if I am the common denominator, because I
10 am, I was the AW, and I probably was
11 supervising facilities at the time, that
12 information, at some point, would have made it
13 to me.
14 MR. : All right. So, this is
15 another one of those everyone seemed to be out
16 on the 9th, at least. Mr. was the
17 facilities manager, and he was actually out
18 that entire week. So, he wasn't in the know
19 that the cameras were down. So, it was just
20 MS. : There is a, there is a -.
21 Okay. So, there is his -. So, first
22 line supervisor is not actually
23 was his second line supervisor.
24 MR. : Okay.
25 MS. : His first line supervisor was
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1 another person. (Phonetic Sp.
2 *01:58:34). I don't know if was working
3 at the institution at the time, but , who
4 is the facility manager, is the second line
5 supervisor.
6 MR. : Would --
7 MS. : So, I don't -.
8 MR. : -- would be, you
9 are talking about the general foreman?
10 MS. : Yeah. The general foreman.
11 MR. : If there was no one --
12 MS. : Yeah.
13 MR. : -- filing the general
14 foreman at the time --
15 MS. : No.
16 MR. : -- is our understanding.
17 MS. : So, there was not even an
18 acting in place?
19 MR. : Yeah. From out
20 of office response, to the people that acted in
21 his stead, where , and I think her
22 name was
23 MS. : Oh. Oh.
24 MR. : But --
25 MS. : Acting in his place.
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1 MR. : -- right. So, but there
2 wasn't an acting for the general foreman. From
3 our understanding is that there was just no one
4 in the general foreman role at the time, and
5 that's, unfortunately, on the 9th, there is a
6 lot of people that were out of the institution,
7 and a lot of people that were not there, that
8 would have --
9 MS. : Then --
10 MR. : -- potentially been in
11 the know in these situations.
12 MS. : -- then he could have
13 contacted, he should have contacted somebody.
14 I mean, if you are all - and I'm just going to
15 say line staff, but they are all peers, they
16 are all subordinates, and no one is a
17 supervisor. If there is something that, that'
18 a security issue, you would raise it to
19 someone, of a supervisory nature. And if your
20 supervisor is not there, you would raise that
21 to the next level, who was, in the absence of
22 your supervisor, your supervisor's supervisor.
23 MR. : And do you know, so,
24 according to , this is something that
25 happened quite regularly.
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1 MS. : Mm-hmm.
2 MR. : That these things would
3 go down, he would have to rebuild the system,
4 and then the cameras would be down for, you
5 know, a period of 24 hours, while the system
6 rebuilt. Were you aware of that?
7 MS. : Hmm. No. I know, after the
8 fact, there have been issues that we were aware
9 of with the camera. But prior to, and again,
10 arrived at the institution in July
11 MR. : Sure.
12 MS. so, this is one-month in.
13 So, if there were historical issues with the
14 camera, I have no way of knowing what existed
15 because I was not present then. But at the
16 time that I was present, there is no mention of
17 those cameras being down. And again, because
18 of that incident, there was obviously
19 heightened attention to the cameras, and who
20 you should notify when you are aware that a
21 camera is down. But at the time, when I was,
22 you know, like I said, a recent arrival, there
23 was no mention or a discussion that I was aware
24 of about any issues with the camera.
25 MR. : Okay. So, leading up to
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1 this issue, you didn't know that the cameras,
2 they are a big problem at the institution?
3 MS. : You said leading up, or
4 following the incident?
5 MR. : No. Leading up to the
6 incident.
7 MS. : You said, did I have any
8 knowledge of it?
9 MR. : Right.
10 MS. : Yes. Leading up to the
11 incident, there was no knowledge that there was
12 issues with the cameras recording.
13 MR. : Okay. And do you know if
14 - when you and Lieutenant were speaking
15 with - do you know if he was told to fix
16 the camera situation immediately? Or to just
17 look into it and figure out what's going on.
18 Do you recall?
19 MS. : I don't -. I don't want to -.
20 I don't want to -. I don't recall my exact
21 words to him. But again, if there was no
22 mention that the camera was not recording,
23 there is a difference when instruction, based
24 on knowledge that the cameras are not working,
25 versus knowledge that the camera that I can see
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1 it, but I can't rewind it:
2 MR. : Sure.
3 MS. : And not --
4 MR. : So, you
5 MS. : -- knowing --
6 MR. : -- so, you knew that
7 there was an issue with the camera. You just
8 didn't know what the issue was.
9 MS. : I knew that we could not
10 rewind. Yes.
11 MR. : Okay.
12 MS. : Yes.
13 MR. : And do you remember if
14 you ever followed up, after that conversation,
15 with anyone, to say, hey, did that ever get
16 resolved?
17 MS. : I don't. I don't recall.
18 MR. : Okay. Is there a reason
19 why you should have, or did you believe someone
20 else was on top of it, and that was fixing it,
21 and looking into it?
22 MS. : I don't (Indiscernible
23 *02:02:48). I don't -. I actually, I don't
24 recall because, again, at the time, when we
25 were looking at the camera, you can see it.
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1 So, there was, there was never any discussion,
2 or there was never even no information to say
3 that the camera was not working. There was
4 never any discussion about that. So, to follow
5 up on an issue that you don't know is present,
6 I would say that that's, if I didn't have a
7 further discussion about it, it's because of
8 that, that there was no discussion that the
9 camera was not recording.
10 MR. : Okay. So, from the
11 knowledge that you do have, that, you know, you
12 know, according to , she was saying she
13 knew that the cameras weren't recording, and
14 they were down. And then, saying that
15 he was going to fix them, and he clearly knew
16 the cameras weren't recording. What should
17 have happened?
18 MS. : Well, first, I want to clarify,
19 you are saying that said that she knew
20 the cameras were not recording.
21 MR. : She - yeah - her -. That
22 is what i read you before - that she said, her
23 words, "Notifying him that the camera was down,
24 and trying to go back and look at the footage,
25 and I can't." And then, later on --
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1 MS. : But that's not saying that --
2 MR. : -- saying, you know,
3 saying --
4 MS. : -- (Indiscernible *02:04:10).
5 MR. : -- so, okay --
6 MS. : Yeah.
7 MR. : -- the two of them knew
8 the cameras were down. Yes. And then, she
9 said that she actually wrote a memo to the
10 captain, saying that, you know, the cameras
11 were down, and that was fixing the
12 issue. And then, when he came in on the 10th,
13 to find out the cameras still hadn't recorded,
14 she had a conversation with and said,
15 hey, you told me you were going to fix the
16 cameras. Why didn't you fix them? So, I'm not
17 saying that you have any part of this. What
18 I'm saying
19 MS. : Oh.
20 MR. : -- you, is --
21 MS. : No. I know --
22 MR. : -- being that Lieutenant
23 seems to have known that the cameras
24 were down, and definitely knew the
25 cameras were down, what should have happened?
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1 MS. : Then someone should have
2 followed up to say were the cameras, if saying
3 down means not recording.
4 MR. : Right. And that's what
5 they --
6 MS. : That's (Indiscernible
7 *02:04:57).
8 MR. : -- and that was clear.
9 went into, you know, great detail of,
10 the cameras, you could watch live, it's only
11 when you try to rewind, because they weren't
12 recording. And he said
13 MS. : That's --
14 MR. : -- this is what happened
15
16 MS. (Indiscernible *02:05:11).
17 MR. : -- and he --
18 MS. (Indiscernible *02:05:11).
19 MR. sorry. Go ahead.
20 MS. : I don't know if knew
21 that what, the explanation that you said,
22 provided, that, I have never had a
23 conversation to say that the reason why you
24 can't rewind is because the cameras are not
25 recording. I don't know. I can't say what
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1 knew. If she understood that that's
2 what that meant. I know that I know that
3 that's -. I did not know that that's what that
4 meant. So, if never came back, and
5 said, oh, the cameras are not recording, that
6 is a difference with then just saying that, oh,
7 you could see the camera, you are thinking that
8 the camera is working. If you pull up a camera
9 on the Nice Vision (Phonetic Sp. *02:05:52),
10 and you could actually see the image and
11 everything, you are thinking that the camera is
12 recording. So, how else would -? Why else
13 would you think that it's not recording?
14 MR. : Well, that's why --
15 MS. (Indiscernible *02:06:02)
16 MR. : -- that's why I'm trying
17 to explain to you --
18 MS. (Indiscernible *02:06:04).
19 MR. : -- like, said that
20 she knew that they weren't. That's why she
21 wrote the memo to the captain, and that's why -
22
23 MS. : Yeah.
24 MR. : -- on the 10th, when she
25 found out that the cameras were still down, she
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1 confronted and said, you were supposed
2 to fix this, why didn't you fix the cameras?
3 MS. : Hmm.
4 MR. : So, those two things is
5 what I'm trying to -. I've been trying to
6 explain to you --
7 MS. : Oh.
8 MR. : -- is that she did know,
9 is because that is why she wrote the memo to
10 the captain, and that is why she confronted
11 on the 10th, saying why didn't you fix
12 this?
13 MS. : And my response then would be:
14 maybe she thought - and I'm not, I don't even
15 want to -. I don't know. Maybe --
16 MR. : And she didn't point the
17
18 MS. : -- (Indiscernible *02:06:42).
19 MR. : -- she didn't point the
20 finger at you in the slightest. I'm not even
21 trying to insinuate that.
22 MS. : Mm-hmm.
23 MR. : I'm saying, because you
24 are the AW in charge of --
25 MS. : Yeah.
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1 MR. : -- you know, this
2 situation, what should have happened? And this
3
4 MS. : Mm-hmm.
5 MR. : -- and again, isn't
6 gotcha. I'm asking you --
7 MS. : Mm-hmm.
8 MR. : -- as a genuine question.
9 Like, you're the boss. What should have they
10 done?
11 MS. : Yeah. Someone should have
12 specifically said the cameras are not
13 recording. And I'm not going to say it's
14 responsibility, but she reported it.
15 If she reported it to her supervisor, she did
16 what she was supposed to do. So, I'm going to
17 kind of -. Like you said, I'm going to try to
18 come back and be, like, really assess it. If
19 she reported it to her supervisor, that's her
20 responsibility.
21 That's what she did. But from there, it -
22 I wish had said to me, hey, I
23 received this memo from , saying that the
24 cameras are not working. And that I spoke with
25 , and the cameras are not working, they
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1 are not recording. And that is something that
2 I could have definitely said, okay, f you
3 have to do overtime, in the absence of your
4 supervisor, I am authorizing you to do
5 overtime, to then fix the cameras, and then,
6 when something like that happens, obviously,
7 you know you have to make security related
8 decisions.
9 Then you could have recalled all the
10 inmates, so that if there is any incidents that
11 happened, at least the inmates are confined to
12 their cells. And then, you say, well, there is
13 no cameras inside of the cells. But you make
14 rounds. You have to make rounds in Special
15 Housing anyway. You know? So, you wouldn't be
16 able to capture what's happening inside of the
17 cell itself. But you would have a general idea
18 about, you know, with the cameras, what's going
19 on.
20 But there would have been decisions that
21 would have been made, to ensure security. But
22 there should have been notification, and
23 clarification, and specificity about -
24 specificity - about actually what was the
25 issue.
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1 MR. : Okay. So, in your
2 opinion, though, it's, should have
3 reported it to should have made
4 the appropriate - like, this is, I'm not saying
5 that this did or didn't happen. I'm just
6 saying, under, from what you know --
7 MS. : Mm-hmm.
8 MR. should have
9 told should have made whatever
10 appropriate, you know
11 MS. : He should have told --
12 MR. : -- taken whatever actions
13 needed to be taken.
14 MS. : -- he should have -. Yeah.
15 Then, if I was his supervisor, then he should
16 have told me.
17 MR. : Okay. And again, it
18 sounds like this is how - you already answered,
19 but to be clear - you knew there was a problem
20 with that one specific incident, trying to
21 rewind, but you had no idea what the problem
22 was. You just knew you weren't able to rewind.
23 MS. : And - yeah - if you simplify
24 it. Yeah.
25 MR. : Right. So, you didn't
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1 know that the --
2 MS. : Mm-hmm.
3 MR. : -- point being, you
4 didn't know the cameras were down.
5 MS. : Yeah.
6 MR. : You didn't know that they
7 were not recording.
8 MS. : Exactly.
9 MR. : Great. So, were you
10 aware that MCC cameras were scheduled to be
11 replaced?
12 MS. : Hmm. No. I didn't know that
13 they were scheduled to be replaced. I know -
14 again - there is information that you -. I
15 don't know if they were scheduled to be
16 replaced. I know that they have been, they
17 were upgraded after. And then, I know there
18 was certain projects. But I don't -. I,
19 again, I don't know what I -. That, if they
20 were scheduled to be replaced at the time of
21 the incident.
22 MR. : So, I guess what I'm
23 saying is, do you know if they were, you had
24 new cameras on site at the MCC, and there was
25 currently a camera project underway, of
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1 replacing the old cameras? Did you know that?
2 MS. : No. Not at the time.
3 MR. : Okay.
4 MS. : Not -. Not at the time.
5 MR. : So, based on the work
6 orders and email communications that we
7 received --
8 MS. : Mm-hmm.
9 MR. : -- the MCC ordered new
10 cameras, DVRs, and other system parts, and had
11 them delivered to the MCC in approximately
12 October of 2018.
13 MS. : Mm-hmm.
14 MR. : These were the cameras
15 that were installed immediately after Epstein's
16 death in August of 2019.
17 MS. : Hmm.
18 MR. : Did you know that to be
19 accurate?
20 MS. : I know that there were cameras
21 that were installed after, and afterward, but
22 again, I don't know when those cameras arrived
23 because I didn't work there in 2018.
24 MR. : Sure. Sure.
25 MS. : No.
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1 MR. : But I guess what I'm
2 saying, though, is --
3 MS. : Oh.
4 MR. : -- did you know that
5 those cameras were on site, and they were, you
6 know --
7 MS. : No.
8 MR. : -- you didn't even know
9 that?
10 MS. : No. There's a lot of things
11 that have, obviously that folks have knowledge
12 of after the fact because of the incident, and
13 there have been actions after, but there was
14 no, I was not knowledgeable about cameras being
15 on site, and about the installation prior to.
16 MR. : And just to be clear.
17 So, , you know, the facilities manager --
18 MS. : Mm-hmm.
19 MR. : -- you know, Warden
20 , and, you know, , they have all
21 said, yup, this is accurate. So, the follow up
22 on that is, when should the new camera system,
23 that was already on site at the MCC, have been
24 installed? Do you have even a -? Or do you
25 just not have knowledge on that because you
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1 weren't there at the time?
2 MS. : Yeah. So, I don't have
3 knowledge of that.
4 MR. : Okay. Do you know who
5 would have been ultimately responsible for
6 ensuring -? Because it sounds - and again, you
7 weren't there at the time, but there was a lot
8 of problems, the same problem happened time and
9 time again, at the MCC, where these cameras
10 would -. Two hard drives would crash, and then
11 take out the system. And then, would
12 have to go and rebuild the system, and it was,
13 like, a 24 hour process to rebuild it.
14 MS. : Mm-hmm.
15 MR. : Who should have made sure
16 that new camera system was installed? That was
17 on site. Who should have, like, said, like,
18 this is an urgent matter? And I am assuming it
19 was. Was that an urgent matter, if the cameras
20 are down?
21 MS. : Mm-hmm. Yeah.
22 MR. : And they are not
23 recording? I would think that that's a pretty
24 big deal. Correct?
25 MS. : Mm-hmm. Correct.
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1 MR. : So, who should have made
2 sure that that new system was installed? That
3 had been on site, all the way back to October
4 2018.
5 MS. : It's multi-layered. And when
6 it's a multi -. This is multi-layered. Because
7 if you are saying that, who actually does the
8 work for the installation, or who the primary
9 person is the electronics technician. But
10 ultimately, they have a supervisor, and that
11 supervisor tracks the completion of projects.
12 The progress of projects. So, it's - that's
13 what I'm saying - it's multi-layered. That,
14 and if the cameras were present, I don't know
15 what would have happened to make them not be
16 installed.
17 MR. : And just for more --
18 MS. (Indiscernible *02:13:50)
19 MR. : -- information, the
20 reason why they were on site, the reason why
21 you guys were able to get your cameras
22 immediately back up and running, with a whole
23 new system, was because they were already on
24 site. So, knowing that information, what is
25 your thought on the matter? Like, the fact,
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1 now that you are hearing, and again, this is,
2 I'm looking at you as a subject matter expert.
3 I am not looking for any type -.
4 I'm not accusing you of anything. I'm
5 just looking at you as you are a boss there.
6 You are in charge of custody. So, I am just
7 kind of giving you this information, so you can
8 give me your professional feedback. So, the
9 fact that they were able to immediately install
10 this, have SigNet come in, who was the
11 contracted company, and install these new
12 cameras that had been on site since October of
13 2018 --
14 MS. : Mm-hmm.
15 MR. : -- what is your opinion
16 on that?
17 MS. : Hmm.
18 MR. : Do you think that they
19 were, you know, the MCC, or, you know, really
20 dropped the ball with having this faulty camera
21 system, and actually having the parts that they
22 needed on site, to be able to be replaced?
23 MS. : I'm careful with saying about
24 this, who dropped the ball. I know if you know
25 that there is cameras present. And there is no
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1 logical reason why the cameras can't be
2 installed. And if it is your department that
3 is responsible for installing the cameras, then
4 you should ultimately ensure that the cameras
5 are installed. And -.
6 MR. : Now, should - would it
7 fall on the facilities manager to make sure
8 that that's happening?
9 MS. : The Comtech works for the
10 facility manager. So, the facility manager is
11 responsible for the department that that staff
12 member works in.
13 MR. : So --
14 MS. : You know?
15 MR. : -- according to
16 he said that his job was basically to fix it.
17 His job, you know, fix things when they're
18 broken. And he had been screaming that there
19 was a problem with these camera systems for a
20 long time, and he's basically the reason why
21 they got the new cameras, but he said, you
22 know, it wasn't his job to get SigNet there, to
23 be able to actually get these installed.
24 You know, so, that is where, to me,
25 hearing that explanation, it sounds like oh,
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1 well, it's really probably the facilities
2 manager that is, you know, supposed to manage
3 that task, and make sure that they get in
4 there. But I don't -. I want to make sure
5 that that would be an accurate, you know,
6 assessment, or if I'm off.
7 MS. : Now, would have -. I don't know
8 if, like you said, if it's the facility manager
9 that actually calls SigNet, or if it is the
10 Comtech that would call and coordinate SigNet's
11 visit. It's between the two.
12 MR. : So, you believe they
13 have, both have part responsible ---
14 MS. : Mm-hmm.
15 MR. : -- you know --
16 MS. : Mm-hmm.
17 MR. : -- their part exposure to
18 this thing?
19 MS. : Yeah.
20 MR. : And anything --
21 MS. : Yeah.
22 MR. anyone outside of the
23 facilities manager? I mean, did this go up to
24 the executive, you know, level, to the captain,
25 AWs, or warden?
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1 MS. : If they were aware that the
2 cameras were there, and that the cameras should
3 have been installed. Now, and that's what I'm
4 saying, I don't know if, who knew that the
5 cameras were there.
6 MR. : Yeah. I mean, certainly,
7 the warden did.
8 MS. : Or that --
9 MR. : But -.
10 MS. : -- that it shipped. Mm-hmm.
11 MR. : So, if the --
12 MS. : Mm-hmm,
13 MR. : -- warden knew that, is
14 that something you think that he has exposure
15 to, then, as well?
16 MS. : Hmm. Oh my gosh. If - again,
17 without knowing who knew what, I don't, I don't
18 know who -. This is -. Yeah.
19 MR. : Sure.
20 MS. : No.
21 MR. : No. And that's fine.
22 And point being, though, you didn't know that
23 the cameras were even there. It sounds like
24 you are saying?
25 MS. : I would have no knowledge to
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1 know about the cameras were there, because this
2 all happened prior to me.
3 MR. : Right. No. I'm just
4 saying --
5 MS. (Indiscernible *02:17:39).
6 MR. : -- like, you know, you
7 were --
8 MS. : Yeah. No.
9 MR. : -- you were --
10 MS. : No.
11 MR. : -- you were, I know it
12 was only a month and a half, but you were
13 there, leading up to this point. I just didn't
14 know if that was a conversation that would be
15 happening within executive staff meetings,
16 that, hey, this is where we are on the camera
17 project. You know, and --
18 MS. : Well, now --
19 MR. : -- we'll be -.
20 MS. conversations about the
21 camera project, and again, I'm going to
22 reiterate what I've kind of said before,
23 because of this incident, there have been
24 discussions about things that happened within
25 this incident, but that's after the fact.
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1 MR. : And so, prior
2 MS. you're asking --
3 MR. : -- prior to August 10th,
4 that you weren't involved in the conversations
5 at all with the camera project?
6 MS. : I do not recall anything
7 specifically about discussing about camera
8 project.
9 MR. : Great.
10 MS. : Now, if you can, if you can
11 show me something, or anything to that effect,
12 then I can say, okay, yes.
13 MR. : No, no, no, and again,
14 this is not an I gotcha interview. This is
15 just to ask --
16 MS. : No. I know.
17 MR. : -- you know -.
18 MS. : I know. But I'm being
19 forthcoming, so that's why I'm trying to tell
20 you. In your investigation, I know you are
21 aware, you've had conversations with folks that
22 are giving you information, but this is
23 information after the fact.
24 MR. : Right. And then --
25 MS. : So -.
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1 MR. : -- and point being is you
2 don't recall anything prior to, about --
3 MS. : No.
4 MR. : -- a camera project. You
5 are not -. You weren't aware that there was a
6 - at least at this moment in time - you don't
7 recall there ever being a camera project
8 leading up to the incident?
9 MS. : I do not recall. Hmm-mm.
10 MR. : Okay.
11 MS. : I did -. Yeah. I don't
12 recall. Mm-hmm.
13 MR. : Okay. So, now, we are
14 going to touch on cell assignments. Then we're
15 going to just try to fly through the rest,
16 because that was the primary things I wanted to
17 talk to you about, were the cameras and Reyes.
18 MS. : Mm-hmm.
19 MR. : So, these are more just
20 to touch on some things.
21 MS. : Mm-hmm.
22 MR. : Now, are you aware that,
23 on August 9th and 10th, 2019, Epstein was not
24 in his assigned cell, as documented within the
25 BOP cell assignment history, and the BOP
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1 database?
2 MS. : Can you say that one more time?
3 I'm sorry.
4 MR. : So, were you aware, are
5 you aware of anything with a cell discrepancy,
6 with Epstein, that he was, he was physically in
7 a cell that didn't correspond with the BOP
8 system?
9 MS. : Yes. And this information
10 after, after the fact.
11 MR. : And do you know why
12 Epstein wasn't in his assigned cell, according
13 to the BOP database?
14 MS. : Sheer error.
15 MR. : And do you know who made
16 that error?
17 MS. : Not - no - not specifically. I
18 don't know who made the error.
19 MR. : So, what do you know
20 about it?
21 MS. : I know that there were keying
22 errors. And so, Sentry reflected one cell
23 assignment, but he was physically in another
24 cell.
25 MR. : And do you -? So, he was
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1 in that cell from the time he, you know,
2 assigned to that cell in Sentry, from July
3 30th, all the way to August 10th.
4 MS. : Mm-hmm.
5 MR. : So, being that he was
6 there for, you know, ten or 11 days --
7 MS. : Mm-hmm.
8 MR. : -- should that have been
9 caught in that period of time?
10 MS. : Yes.
11 MR. : And who should have
12 caught that?
13 MS. : The folks that are doing the
14 rounds.
15 MR. : So, is that, that falls
16 onto the SHU staff?
17 MS. : If - yeah - if it happened in
18 GP, it would have fallen on the person that is
19 actually doing the rounds in GP. So, yes. Mm-
20 hmm
21 MR. : Okay. And then, would
22 any lieutenants, whether it be the SHU
23 lieutenant, or the captain, or, you know, ops,
24 activities lieutenant, should any of them
25 caught this?
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1 MS. : Well, they would have only
2 known that if they actually looked at a roster,
3 and physically walked with a roster, to know
4 which cell he was in. But I'm thinking about
5 the 292s, whether or not it would have the cell
6 on it. I'm not sure if the 292 -. Do you know
7 what I'm talking about when I say 292?
8 MR. : Yeah. His file that is
9 kept in the housing unit.
10 MS. : Does it have this -? I'm not
11 even sure if it has the cell number on it. But
12 the long and short of it, you are making
13 rounds, you're pulling the inmate in and out of
14 his cell, you're keying, because
15 MR. : Now, are you talking
16 about bed book count, or are you talking about,
17 like, actual rounds?
18 MS. : No. You're making rounds. Not
19 a bed count. If you actually did it, if a bed
20 book was done, between those days, then whoever
21 did the bed book would most definitely know
22 that there was an error. Because you have to
23 have the roster with you. But without, if a
24 I don't know if a bed book count was during
25 that time. I know that the counts were done
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1 after the fact.
2 MR. : And is there a --
3 MS. : (Indiscernible *02:22:36).
4 MR. -- requirement to do,
5 like, a bed book count, like once a week, or
6 any certain amount of days, or -?
7 MS. : There is no, there is no
8 requirement that says a bed book count has to
9 be done once a week. That was -. There was
10 some procedures put in place after the fact.
11 MR. : Okay. And is, and how do
12 we determine if a bed book count was in fact
13 conducted?
14 MS. : Without there being some
15 documentation, or to say, or, because I know
16 after the fact, like I said, when that was a
17 procedure put in place, it was indicated that
18 that should be documented in the log.
19 MR. : But that was an after the
20 fact thing? So, it wasn't
21 MS. : After.
22 MR. : -- being documented prior
23 to?
24 MS. : No. It wasn't. It wasn't done
25 prior to. Now, if you are making, TruScope,
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1 the officers have a log that they do. Any
2 activity is part of whatever is going on in
3 your unit. That should have That could
4 have been logged. But is there a requirement
5 that said that you have to log that, that you
6 did the bed book count? You would be doing it,
7 you know, for documentation purposes. But a
8 lieutenant or a staff member can do a bed book
9 count, just to make sure that things are done
10 accurate. So, that's not -. It's not
11 something that was a requirement prior to.
12 MR. : Okay. So --
13 MS. : Mm-hmm.
14 MR. : -- aside from the bed
15 book count, though, is there any other way,
16 though, and you said when they were conducting
17 rounds. I mean, when a staff member is
18 conducting rounds, are they supposed to be
19 walking around with the, you know, Sentry
20 report, or BOP roster, or whatever it is, the
21 housing roster that indicates what cell he is
22 assigned to in the system?
23 MS. : No. They don't have to have
24 the roster. However, once the inmate is
25 introduced into SHU, typically, the OIC does a
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1 lot of the data entry. So, someone, even if
2 it's not the OIC, if someone in SHU, if someone
3 is doing the data entry, they are the ones that
4 is physically recording where the inmates is.
5 No one else would know where that inmate was
6 assigned unless they actually go in the system
7 and do the Sentry assignment. So --
8 MR. : Okay.
9 MS. : -- the person that is saying,
10 okay, if I am saying put inmate X, Y, and Z in
11 cell ten, I have to change him from wherever he
12 was before, and make sure that I update, I
13 update it. And not only that, there is a
14 physical board in SHU that you have the cards.
15 You have name tags or whatever. And it shows
16 where everyone is.
17 MR. : And does it say where
18 they are based upon them writing it down from
19 knowing that they are in there, or is that
20 showing where they are based upon what the BOP
21 system says?
22 MS. : From knowing where - from
23 knowing where they are.
24 MR. : Okay.
25 MS. : So, the system, and everything
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1 should be the same. So, if I'm changing, if
2 I'm changing an inmate's Sentry assignment,
3 then I know I - I automatically know there is
4 not just one thing I have to do, there is a
5 couple of things I have to do.
6 MR. : Mm-hmm.
7 MS. : I have to physically move the
8 body from one place to another.
9 MR. : Okay.
10 MS. : I have to put the card, you
11 know, the card off of one door, put it on the
12 new door, and I know I have to update Sentry
13 because Sentry should be accurate. I
14 physically have to do a PP - I can't remember -
15 34, and then update the Sentry assignment. And
16 then, I should physically update the board, so,
17 the door and the board would have cards on
18 them, or, you know --
19 MR. : And this is where, so, _
20 know what happened. I know what happened when
21 this all happened on the 30th. On the - I know
22 what happened, how it was done, where the
23 discrepancy came in place. So, I guess my
24 question, though, is: between - and so, I know
25 that the person who dropped, you know,
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1 basically dropped the ball by not making the
2 correct entry on the 30th, but the fact that
3 from the 30th all the way to the 10th --
4 MS. : Mm-hmm.
5 MR. : -- this, you know,
6 discrepancy continued, my question to you is,
7 is there any point, aside from when he was
8 physically placed in the wrong cell, and the
9 key entry wasn't, you know, updated, or not in
10 the wrong cell, but they key entry wasn't
11 updated. Was there any way that that would
12 have been caught in those approximately ten
13 days? After that initial mistake happened.
14 So, like, an audit of the system --
15 MR. : Yeah.
16 MS. : -- or, like, hey, let's,
17 you know, aside from a bed book count, how do
18 we know that these inmates are actually in the
19 cells that they are supposed to be assigned,
20 you know, or they are in the cells that they
21 are assigned in, in the system? Is there a
22 checks and balance to that? Are they -? Is
23 there -? Is the staff supposed to be checking
24 those sheets, or is it -? Is there an audit
25 that is done by the lieutenant or the OIC?
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1 MS. : I wouldn't say that there is an
2 audit done, but you -. That's (Indiscernible
3 *02:27:56). That's 7/30 to 8/10. That -.
4 There is not a specific audit that is done on a
5 daily basis. There is not an audit that is
6 done besides, like I said, you making rounds --
7 MR. : Mm-hmm.
8 MS. and you -. Yeah. I can't
9 think of a specific, like you said, a procedure
10 in place that you would check, where you would
11 audit on a daily basis, besides if you were
12 actually required to do a bed book count.
13 Which, she was not required to do a bed book
14 count daily.
15 MR. : Right. And at the time,
16 they weren't required to do them at all?
17 MS. : There was no procedure - and
18 when you say they were not required - there i.-
19 times when --
20 MR. : I mean, based upon a time
21 period.
22 MS. : -- yeah.
23 MR. : versus, like, a, you
24 know, an incorrect count.
25 MS. : Yeah. Not that I am - not that
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1 I am aware of.
2 MR. : Okay. Now, just to touch
3 on cell searches. On August 9th and 10th,
4 2019, do you know how often the SHU staff were
5 supposed to conduct cell searches?
6 MS. : Oh, you are supposed to do cell
7 searches daily.
8 MR. : Okay. And is it, like,
9 supposed to be at least five per shift --
10 MS. : Mm-hmm.
11 MR. : -- aside from the
12 morning?
13 MS. : It's five.
14 MR. : Five.
15 MS. : Yeah. Yeah. And then, you
16 annotate it in, I believe it's TruScope, so
17 that you are ensuring, and that kind of, it
18 tracks, so that there is a, so that you can
19 ensure that all of the cells have been done.
20 MR. : Okay. So, is it
21 acceptable that only one cell was entered as
22 being searched in TruScope, on August 9th,
23 2019?
24 MS. : No. You should do at least
25 five.
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1 MR. : Now, do you believe that
2 if only one was entered, does that mean only
3 one was actually conducted?
4 MS. : Hmm. I wouldn't say that. But
5 because I don't -. Hmm. That would be -. I
6 would question why one was only entered. But
7 you should do five. And you should recall,
8 record all five.
9 MR. : Now, being, you know, day
10 and night watch --
11 MS. : Mm-hmm.
12 MR. : -- are required to do
13 five, who is responsible for, one) conducting
14 them; and two) entering them into TruScope? Is
15 it the OIC that is ultimately responsible to
16 make sure that they are done, and then enter
17 them, or is it, there is no rhyme or reason to
18 who is actually responsible? Everybody is --
19 MS. : I wouldn't --
20 MR. : -- responsible.
21 MS. no. I wouldn't say who,
22 because the folks that actually do the, that do
23 the rounds, they are physically, you know,
24 doing the manual labor. And typically, the SHU
25 OIC, because there is not, like, five computers
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1 up in SHU. There may be one or two computers
2 in SHU. And typically, the OIC is the one that
3 is logged in. And that person is doing all the
4 administrative work. So, they would ensure
5 that, okay, rounds are done. And if there were
6 bar taps, or like you said, if there were cell
7 searches done, that information is then
8 communicated from one officer to the OIC, and
9 then that person goes in and records that it's
10 done.
11 MR. : Okay. Do you know
12 anything about Epstein placing a telephone call
13 on August 9th, 2019, from the SHU?
14 MS. : You said from August 9th?
15 MR. : August 9th, 2019. Do you
16 know anything about Epstein placing --
17 MS. : I --
18 MR. : -- a telephone call from
19
20 MS. : -- again --
21 MR. : -- the SHU?
22 MS. : I know, I know information
23 after the fact. Just like everybody else. But
24 the day that it happened, no, I wasn't aware of
25 the phone call the day that it happened. I
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1 know information after the fact.
2 MR. : Okay. And what did you
3 learn after the fact? And just briefly.
4 MS. : Mm-hmm. That there was a staff
5 member that allowed him to place a phone call.
6 MR. : Did you learn that it was
7 a phone call on an unrecorded line?
8 MS. : Mm-hmm.
9 MR. : Is that a yes?
10 MS. : Yes. That is a yes.
11 MR. : Okay. And then, do you
12 is that standard practice, to allow inmates to
13 make personal calls, as had been done, from an
14 unrecorded line?
15 MS. : No. That is not standard
16 practice, and the phone call should be on the
17 ITS - the Inmate Telephone System - line.
18 MR. : Now, if he didn't have
19 his pack and PIN set up --
20 MS. : Oh, yeah.
21 MR. : -- or PIN and pack, or
22 however, which way you say it, what, what could
23 have or should have happened, if you wanted to
24 allow someone to take a - make a telephone
25 call?
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1 MS. : They don't make a phone call.
2 MR. : They just don't make one?
3 MS. : They don't make one. There is
4 allowances for, like, bereavement phone calls.
5 That would be done by the Chaplain, but that,
6 too, is on a recorded line. And that is in the
7 Chaplain area. The other thing is a legal
8 phone call, and that would be on an unmonitored
9 line. But that would only be for legal
10 purposes.
11 MR. : Now, is it true, though,
12 if it was allowed to be done on a legal line,
13 if it was authorized by, you know, the captain
14 or whomever, or the case manager, unit manager,
15 should it be put on speaker phone, and
16 monitored by a staff member?
17 MS. : Policy says - I don't know -
18 but policy says that the inmates should make
19 phone calls, and it should be through the ITS
20 system.
21 MR. : And do you --
22 MS. : But you --
23 MR. : -- is that -?
24 MS. : -- but there is social calls
25 and legal calls.
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1 MR. : Phone calls and legal
2 calls -.
3 MS. : Oh, no. I said there is social
4 calls and there is legal calls.
5 MR. : Okay.
6 MS. : And the only phone call that
7 should be on an unmonitored line would be the
8 legal call.
9 MR. : Okay. So, you don't, you
10 don't believe there is any circumstance where,
11 if it is not a legal call, that a social call
12 should be made?
13 MS. : I know policy, what I know of
14 policy, it indicates social calls, which should
15 be via ITS.
16 MR. : And do you know if there
17 was any kind of recorded line in the SHU, that
18 could have been utilized if an inmate did not
19 have a pack and PIN?
20 MS. : No.
21 MR. : No.
22 MS. : Hmm-mm.
23 MR. : There was no line. There
24 was no such line. Just a legal line?
25 MS. : No. I'm saying, there is an
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1 ITS system in SHU.
2 MR. : No, no, no. What I'm
3 saying is
4 MS. (Indiscernible *02:34:31).
5 MR. : -- if someone doesn't
6 have a pack and PIN, to be able to record it,
7 do you know if there was another type of a
8 line, like you said, I think you said the
9 Chaplain has a line that people can use, that
10 for bereavement purposes, but it's still
11 recorded.
12 MS. : Mm-hmm.
13 MR. : Is there a line that is
14 still recorded, that a staff member can provide
15 to an inmate that doesn't have the ability to
16 make a call from his pack and PIN?
17 MS. : No.
18 MR. : Or -?
19 MS. : No.
20 MR. : And is that no, there is
21 no line, or no, you are not aware?
22 MS. : No, there is no line that you
23 can make a phone call from, that is recorded,
24 that is not hooked up to the ITS.
25 MR. : Okay. And when you say
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1
2 MS. : -- (Indiscernible *02:35:09).
3 MR. -- the ITS, what does
4 that mean?
5 MS. : Inmate Telephone System.
6 MR. : And is that --
7 MS. : Yeah.
8 MR. : -- with reference to the
9 pack and PIN that they receive to be able to
10 put money on their cards and use
11 MS. : Mm-hmm.
12 MR. : -- or -? Yes?
13 MS. : Yeah.
14 MR. : Okay.
15 MS. : Yeah. That is a yes.
16 MR. : Okay. And what is your
17 understanding of what occurred in Epstein's
18 cell on August 9th or 10th, 2019?
19 MS. : Well, what I am aware of,
20 again, after the fact, is that he committed
21 suicide.
22 MR. : Okay. So, you believe
23 that Epstein took his own life?
24 MS. : Yes. He was the only one in
25 the cell.
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1 MR. : And do you have any
2 information, with regard to anyone else taking
3 Epstein's life?
4 MS. : No.
5 MR. : Had you heard anything
6 about Epstein's cell door being left open the
7 night of August 9th, 2019, or 10th, or the
8 morning of August 10th --
9 MS. : No.
10 MR. : -- 2019?
11 MS. : This is the first -. If that
12 happened, this would be the first time that I
13 have, of me even hearing that. I have never
14 heard that.
15 MR. : And have you heard of any
16 other cell mates in the SHU, in the SHU, with
17 their doors being left open the night of August
18 9th, 2019, or the morning of August 10th
19 MS. : No.
20 MR. : -- 2019?
21 MS. : No. I have never heard that.
22 MR. : No? And do you know if -
23
24 MS. : Never heard that.
25 MR. : -- do you know any
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1 information, with regard to anyone harming
2 Epstein on August 9th or 10th, 2019?
3 MS. : No.
4 MR. : Okay. Do you know
5 anything about Epstein changing his will just
6 prior to his death?
7 MS. : Again, that's just in the news,
8 but no, I don't have any knowledge of that.
9 MR. : So, only from what you've
10 heard in the news?
11 MS. : Yeah. I don't have any
12 knowledge of that. We don't -. The BOP has
13 nothing to do with inmates' wills.
14 MR. : Okay. So, and we're just
15 going to now wrap up. It's just specific to
16 the timeline. There was an after action report
17 that was created by the BOP. So, this is
18 specifically where I am getting this
19 information, but --
20 MS. : Mm-hmm.
21 MR. : I'm just going to ask
22 you just a couple more questions, then we will
23 be done.
24 MS. : Okay.
25 MR. : It says, "6:33 a.m., on
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1 August 10th, 2019, a body alarm is activated in
2 the Special Housing Unit. SHU staff reported
3 inmate Epstein was unresponsive in cell," and
4 it says the cell, but it says Sentry does not
5 reflect this accurately. "Staff entered the
6 cell and attempted to wake inmate Epstein.
7 Control center announced a medical emergency,
8 and CPR was initiated." So, the information
9 that we have is that at 6:33, told
10 call in the emergency, and went straight
11 into the cell. Did act appropriately by
12 going straight into the cell, or should he have
13 waited for someone to arrive?
14 MS. : No. There is -. Well, it
15 depends if you feel like you - that is an
16 emergency, and it is a life or death situation.
17 I don't know if he had the -. He could have
18 gone into -. He could have gone into the cell.
19 MR. : Okay. So, policy doesn't
20 dictate that you are supposed to wait for other
21 people to arrive, so that if it was a
22 MS. : Yeah.
23 MR. : -- a ruse, that someone
24 could have overpowered him, and then taken -?
25 MS. : There is no -. When you say
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1 policy, policy does state that you have to be
2 safe, and that you should wait for another
3 staff to arrive. Policy does say that. If
4 felt that he had enough staff on hand, I
5 don't know if he felt that, but policy does say
6 to ensure. And especially if you have more
7 than one inmate in a cell. So, with, I guess
8 realized there was only one inmate in
9 the cell, and if he saw the inmate hanging, he
10 would probably want to act immediately. But
11 policy protects you either way. If you feel
12 that you have enough, because - and that's your
13 - that's what I said - that's your discernment.
14 If you feel that you have enough people on, you
15 know, available, maybe he felt that way.
16 MR. : Okay. And then, it says,
17 "At 7:36 a.m., inmate Epstein pronounced dead
18 by the emergency room physician." Do you know
19 of anything about -? Do you know if Epstein
20 ever showed signs of life, prior to leaving the
21 MCC, or specifically from 6:33 a.m. to 7:36
22 a.m., do you know if he showed any kind of
23 signs of movement or life?
24 MS. : No. I don't. I arrived after.
25 And I have never heard of anything to the
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1 contrary that he exhibited life.
2 MR. : Okay. And here is
3 another thing that was written in there, in the
4 BOP, and again, this is the BOP after-action
5 report. It says, "SHU has multiple cells
6 equipped with video recording capability.
7 Inmate Epstein was not housed in one of these
8 cells, and there appears to be no set guidance
9 on when to utilize these cells." So
10 specifically, I am assuming he is, they are
11 either talking about 10 South or possibly G-
12 tier. I'm not sure. I can't remember if G-
13 tier has cameras or not. But 10 South
14 certainly does.
15 MS. : Mm-hmm.
16 MR. : Do you believe that
17 Epstein should have been placed in one of those
18 cells that were, that had cameras in them?
19 MS. : I'm not going to say that. I'm
20 not going to say that he should have been
21 placed in a cell with a camera. He was an -.
22 He is an inmate, just like another inmate. So,
23 I can't, I can't say that, that he should have
24 definitely been placed in a cell. There
25 obviously was a reason that they felt that he
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1 was safe, since he didn't say that he was going
2 to -. I don't -. Yeah. I can't say that he
3 should have definitely been placed in a cell
4 with a camera.
5 MR. : Okay.
6 MS. : Because those cells are for the
7 SAMs inmates. Those inmates that can't, you
8 know, their communication has to be monitored.
9 So, that is a different vetting process.
10 MR. : Okay.
11 MS. : Mm-hmm.
12 MR. : And do you -. These are
13 going to be the last, like, three or four
14 questions. Oh. What do you believe allowed
15 Epstein to be able to - if he took his own life
16 - what do you believe allowed Epstein to take
17 his own life?
18 MS. : Well, there were, I think his,
19 if that's what he wanted to do, without -
20 because the -. Now, we do know that staff
21 members have to make rounds. They're going
22 to, every, I don't know, 30 minutes, a regular
23 round. But he could have done it right before,
24 or right after the round. So, it doesn't mean
25 that he still - at the end - still wouldn't
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1 have happened. So, I can't say for certain
2 that, we still would not have had the same
3 outcome.
4 So, I can't -. I know there was some
5 things that staff did not do that they were
6 supposed to do. Had they still made their
7 rounds, there is a possibility that a death
8 could have still have occurred, because there
9 are instances where staff make their rounds,
10 and inmates still are able to successfully
11 complete suicide, unfortunately. So, in this
12 instance, staff - we all, again, know - staff
13 did not do what they were, you know, supposed
14 to do by policy, but I can't say with certainty
15 that he still would not have been able to
16 successfully complete suicide.
17 MR. : So, it sounds like rounds
18 would have helped. What about having a
19 cellmate? Do you think that would have helped?
20 MS. : Yes. A cellmate would have
21 been able to alert a staff member, that is, if
22 they were alert and oriented themselves.
23 MR. : Yeah. I would think,
24 though, if a cellmate was in there, and they
25 saw someone hanging themselves, you know,
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1 obviously, there would be no requirement, I
2 guess, for them to do it, but that would
3 certainly indicate to that person that they
4 probably, there was an issue. Right?
5 MS. : Yeah. But when you say that,
6 when you say that, it depends on, see, if the
7 manner in which he committed suicide, he did it
8 because he was in there by himself. Yes.
9 MR. : Right.
10 MS. : But there is instances where
11 you have cellmates, if you are on, you could
12 have - an inmate could have tied a ligature
13 around his neck, if he was in his bed, and just
14 hung himself that way. So, again, there are
15 things that were not done on line with policy,
16 but I can't say for certain because we have, we
17 do have successful suicides, where staff do
18 follow procedure and follow policy.
19 MR. : But in this case, I
20 guess, you know, you know, correct me if I'm
21 wrong, but I would think that the two most
22 glaring things were the fact that he was
23 required to have a cellmate, and he didn't; and
24 that, also, staff were not conducting rounds as
25 they were required. Would you agree with that
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1 assessment?
2 MS. : Yeah. We know that those
3 things did not happen.
4 MR. : And do you believe
5 anything else, you know, basically, if we are
6 looking at what all, you know, what could have
7 helped prevent this from happening in the
8 future? If we are looking at it as, you know,
9 like, well, what can we do better next time?
10 Aside from making sure, you know, cellmates
11 that are required to have cellmates have them,
12 and then, aside from making sure that staff are
13 actually conducting their rounds and counts, is
14 there anything else that should have been done?
15 MS. : Just --
16 MR. : It sounds like you didn't
17 agree with putting him in a cell with a camera.
18 So, I'm just wondering if there is anything
19 else that --
20 MS. : No. I'm not saying necessarily
21 I agree or disagree. I'm saying that there is
22 inmates that are in cells without cameras, and
23 they don't necessarily commit suicide. So,
24 what was the difference? Why did Epstein have
25 to be in a cell with a camera? So, I'm saying,
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1 we don't -. That's not part of our policy,
2 that cameras have to be present. So, that is
3 not the -. That does -. That in and of itself
4 doesn't determine or make a difference whether
5 someone commits suicide or doesn't.
6 MR. : Sure.
7 MS. : Like, that's not a requirement.
8 MR. : So, I guess the - and I
9 probably got you off on track, on the camera
10 thing - I'm just saying, is there anything else
11 we are missing here, aside from, you know, what
12 we just discussed, as far as reasons that
13 allowed for Epstein to be able to take his
14 life?
15 MS. : No.
16 MR. : No.
17 MS. : I don't know.
18 MR. : Okay. What do you
19 believe the failures of the BOP - if you
20 believe there are any - that allowed for
21 Epstein to die?
22 MS. : I don't believe that the BOP is
23 responsible for him committing suicide. I
24 believe that, as you investigate, that there
25 are things that - may not have been with the
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1 policy, but I don't believe that that
2 contributed to the suicide itself. Because,
3 like I said, I know we are looking at it after,
4 like, Monday morning quarterbacking, but there
5 are, there are some instances where there is a
6 successful suicide, where does not follow
7 protocol from top to bottom. And it happens,
8 unfortunately. And in this instance, they
9 didn't do everything that they were supposed to
10 do, or they didn't do a lot, but I don't
11 believe that it contributed to him committing
12 suicide. I don't. I don't really believe
13 that.
14 MR. : So, you don't believe -
15 and we didn't get into staff members sleeping -
16 but you don't believe that a staff member not
17 conducting rounds, a staff member sleeping on
18 the job, staff members not, you know, making
19 proper notifications and getting a new cellmate
20 into them, you don't believe that that is
21 contributed to him taking his own life?
22 MS. : I'm --
23 MR. : The ability to do that?
24 MS. : hmm. Because when you are
25 saying staff members sleeping, yeah, if, even
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1 if a staff member is awake, and that I'm saying
2 that because I'm aware of a successful suicide,
3 staff members can make their rounds every 30
4 minutes. And when they go by, unfortunately,
5 if someone actually is intent on committing
6 suicide, they can wait for you to make your
7 round, and they know that you don't have to
8 come back until another 30 minutes.
9 MR. : Sure. And I didn't say
10 that staff members --
11 MS. (Indiscernible *02:47:32).
12 MR. : -- caused him to die.
13 what I said is, helped contribute, and allowed
14 for him --
15 MS. : Yeah.
16 MR. : -- to take his life. So,
17 what I'm saying is, like, the job --
18 MS. : Okay.
19 MR. : -- performance that
20 wasn't done, and that's why this investigation
21 pertains to security failure and job
22 performance failure, because it seems to me
23 that there was a lot of job performance failure
24 here, at the very least, in the sense that
25 people weren't doing their jobs.
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1 MS. : Mm-hmm.
2 MR. : And that, that helped
3 cause, you know, and again, I think you
4 mentioned it, if a person wants to kill
5 themselves, they're probably going to be able
6 to find a way. But there is also things that,
7 when an inmate is in our custody, it is our job
8 to try to do everything we can to keep them
9 alive, and prevent that from happening.
10 MS. : Mm-hmm.
11 MR. : So, my question to you
12 is, you don't believe that, by though, you
13 know, them not doing those things, that that
14 helped contribute?
15 MS. : And I know this might sound
16 but you sound bewildered by my response, but I
17 believe that it contributed to some failures,
18 but I don't really believe that the failure
19 equals the contribution of the suicide. I
20 really don't believe that.
21 MR. : Okay. Yeah. I don't
22 know that I look at it as a contribution. I'm
23 just saying, the failures that allowed for him
24 to be able to take his own life. And so,
25 again, I'm not saying that they helped assist
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1 him with taking his life, but by not doing --
2 MS. : Mm-hmm.
3 MR. : -- their job, that, you
4 know, provided him ample opportunity to do so.
5 Would you agree with that?
6 MS. : Again, I'm going to - my thing
7 is going to be the same.
8 MR. : Okay. No. You're just
9 the first person I've talked to that said that.
10 MS. : Yeah.
11 MR. : Okay. That's totally
12 fine. Okay. Well, is there anything else that
13 I missed, or that you would like to add to
14 this?
15 MS. : Hmm-mm. No.
16 MR. : And , are you still
17 there? Is there any follow up questions that
18 you have, before we end this thing?
19 : No follow up questions.
20 MR. : All right. Great. Well,
21 you have my information. My cell phone. My
22 email.
23 MS. : Mm-hmm.
24 MR. : If there is anything you
25 need, please feel free to contact me. But
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1 otherwise, I would very much greatly appreciate
2 if you get me that stuff we talked about,
3 specific with regard to the documents that you
4
5 MS. : Okay.
6 MR. : -- that you kept on file,
7 and I think you took - there was something else
8 that we discussed. What was the other thing?
9 Was it -?
10 MS. : You said it was about the bad
11 (Indiscernible *02:49:59). I made some notes
12 about the bad count. And then, about the court
13 document.
14 MR. : Perfect. Yeah. So,
15 there would be those specific things. But
16 again, anything -? I think you said you made
17 records of things that you produced, that would
18 be very much appreciated, as well.
19 MS. : Yeah.
20 MR. : It is 1:24 p.m. on
21 December 2nd, 2021. This is Senior Special
22 Agent and I am going to turn
23 off this recorder.
24 MS. : Okay.
25 (Whereupon, the above-entitled matter went
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1 off the record and back on the record).
2 MR. : This is Senior Special
3 Agent It is currently 1:26
4 p.m., 12/02/2021. Prior to hanging up the
5 call, Associate Warden asked if I could
6 turn back on the recorder so she could make a
7 clarifying statement. So, Ms. , go ahead.
8 I'll just remind you, you are under oath, and
9 this is a voluntary interview.
10 MS. : I wanted to clarify whether I
11 feel that, some of the things helped, I guess
12 helped to, or contributed to, Epstein's ability
13 to commit suicide. While I understand that
14 this is something that no one wanted, there
15 were things that were not done, that were in
16 line with policy. That were required to be
17 done, and had those things been done, maybe we
18 would not be questioning the liability aspect.
19 But I just want to ensure that it's understood
20 that I have - I believe that staff should
21 follow policy, to ensure with certainty that no
22 inmate is able to hurt themselves, or that no
23 other inmate is able to hurt them.
24 So, with that knowledge, again, I really
25 hope that staff would have done everything
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1 within their power to follow policy, so that
2 there would be no question as to what should or
3 should not have been done. And with
4 acknowledgement that there were not things done
5 that should have been done, as it relates to
6 following policy.
7 MR. : All right. Thank you
8 very much. Is there anything else you wanted
9 to add before I turn off the recorder and we
10 end this interview?
11 MS. : No. I think that's it. I just
12 wanted to add that as a sentiment, that I
13 understand that this is a serious matter, and
14 that it required care and attention, and that
15 it requires me to clarify what I believe
16 actually, you know, the staff did or did not
17 do.
18 MR. : Perfect. Thank you so
19 much. Again, if there is anything you need
20 from me, you have my email, and I will greatly
21 look forward to the information you can provide
22 following this interview. It is 1:28 p.m.,
23 12/02/2021. This is Senior Special Agent
24 , and I am turning off the
25 recorder.
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1 CERTIFICATE
2 I hereby certify that the foregoing pages
3 represent an accurate transcript of the
4 electronic sound recording of the proceedings
5 before the Department of Justice, Office of the
6 Inspector General in the matter of:
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8 Interview of
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See,7s 45- --
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12 Brianna Rose Burton, Transcriber
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EFTA00127389