EFTA00114184.pdf

1 DIGITALLY RECORDED SWORN STATEMENT OF OIG CASE #: 2019-010614 DEPARTMENT OF JUSTICE OFFICE OF THE INSPECTOR GENERAL JUNE 14, 2021 RESOLUTE DOCUMENTATION SERVICES 28632 Roadside Drive, Suite 285 Agoura Hills, CA 91301 Phone: EFTA00114184 2 APPEARANCES: OFFICE OF THE INSPECTOR GENERAL BY: BY: WITNESS: OTHER APPEARANCES: NONE EFTA00114185 3 1 MR. : The recorder is on and 2 it's currently June 14, 2021 at approximately 3 9:37 a.m. 4 MR. : My name is 5 I'm a Special Agent with the U.S. Department of 6 Justice Office of the Inspector General New 7 York Field Office. And these are my 8 credentials. I'll show it to you again. 9 MS. : Thank you. 10 MR. : This interview with Federal 11 Bureau of Prisons Correctional Officer 12 . Did I get 13 that right? 14 MS. : That's correct. 15 MR. : And she is being interviewed 16 as part of an official U.S. Department of 17 Justice Office of the Inspector General 18 investigation. Today is June 14th and the time 19 is approximately 9:35 a.m. The interview is 20 being conducted on the third-floor telephone 21 monitor room of the Metropolitan Correction 22 Center. Also present is DOJ OIG Senior Special 23 Agent Can you pronounce your last name 24 please? 25 MR. . And EFTA00114186 4 1 these are my credentials. 2 MS. : Thank you. 3 MR. : And Lieutenant 4 . This interview will be 5 recorded by me, Special Agent 6 Can everyone please identify themselves for the 7 record and spell their last name. To start 8 again, I am DOJ OIG Special Agent 9 10 MR. : Senior Special Agent 11 12 MS. : Lieutenant 13 14 1. 15 MR. : This is official DOJ OIG 16 investigation into the death of inmate Jeffrey 17 Epstein and everything in response that time 18 period. And you're being asked to voluntarily 19 provide some answers to our questions. Will 20 you agree to a voluntary interview with the DOJ 21 OIG? 22 MS. : Yes. 23 MR. : I'm going to provide you with 24 a form, DOJ OIG Form 3-226-2. The title of the 25 form is Warnings and Assurances to Employee EFTA00114187 5 1 Requested to Provide Information on a Voluntary 2 Basis. I'm going to read it out to you first. 3 And then I'll let you review it also. You are 4 being asked to provide information as part of 5 an investigation being conducted by the Office 6 of the Inspector General. This investigation 7 is being conducted pursuant to the Inspector 8 General Act of 1978 as amended. This 9 investigation pertains to job performance 10 failure and security failure. This is a 11 voluntary interview. Accordingly, you do not 12 have to answer any questions. No disciplinary 13 action will be taken against you if you choose 14 not to answer any questions. Any statement you 15 furnish may be used as evidence in any future 16 criminal proceedings, or agency disciplinary 17 proceedings, and/or both. Now this is the 18 waiver part. This is for you. I understand 19 the Warnings and Assurances stated above and I 20 am willing to make a statement and answer 21 questions. No promises or threats have been 22 made to me and no pressure or coercion of any 23 kind has been used against me. Do you 24 understand? 25 MS. : I understand. EFTA00114188 6 1 MR. : Do you want to move forward 2 with the interview? 3 MS. : Yes. 4 MR. : Please sign your name and 5 print your name. 6 MR. : Let's just say thank you 7 for signing and (Indiscernible *00:03:37). 8 MR. : Thank you for signing the 9 form. I myself am signing the form. I'm going 10 to print my name on it. And Agent is 11 also going to do it. 12 MR. : Thank you SA for 13 signing and dating 6/14/2021 at 9:38 a.m. This 14 is SSA and I am now signing as the 15 witness and printing my name as a witness. 16 MR. : Again, thank you, 17 Before starting the interview, I would like to 18 place you under oath. Lieutenant , can 19 you please raise your right hand? Do you swear 20 to tell the truth and nothing but the truth 21 during this interview? 22 MS. : I do to the best of 23 my knowledge and belief. 24 MR. : Thank you. Please let me 25 know if you do not understand any questions and EFTA00114189 7 1 I will repeat it or try to rephrase it. I ask 2 that you do not try to guess answers. If you 3 don't know, just say you don't know. 4 MS. : Okay. 5 MR. : Thank you. So we'll go 6 through a little bit of your background before 7 we get in. What is your current home address? 8 MS. 9 , Brooklyn, New York 10 11209. 11 MR. : Thank you. What is your date 12 of birth? 13 MS. 14 MR. : And your Social Security 15 Number. 16 MS. 17 MR. : What is your current cell 18 phone number? 19 MS. 20 MR. : What is your highest level of 21 education? 22 MS. : I have some college. 23 MR. : What did you do prior to 24 working for the bop? 25 MS. : I was in the EFTA00114190 8 1 military. 2 MR. : Thank you for your service. 3 What branch? 4 MS. : The Navy. 5 MR. : How many years? 6 MS. : Eight. 7 MR. : Alright. And how long have 8 you served with the Federal Bureau of Prisons? 9 MS. : Twenty-six years. 10 MR. : Do you remember when you 11 started? What year you started? 12 MS. : December 11, 1994. 13 MR. : When did you graduate from 14 bop training? It was soon after? 15 MS. : No. I went to 16 Glencoe. I know it was probably six months to 17 a year after I started. 18 MR. : Okay. 19 MS. : I don't' remember the 20 exact date. But it was in `95. 21 MR. : '95? 22 MS. : Yeah, it was in 1995. 23 I don't remember the month. 24 MR. : That's fine. When and where 25 was your first office assignment with the BOP? EFTA00114191 9 1 MS. : FCI Terminal Island. 2 MR. : And after that, how long were 3 you at Terminal Island for? 4 MS. : For probably around 5 six to seven months. I resigned and took a 6 position in San 7 MR. : You resigned the position 8 altogether? Or did you get a transfer? 9 MS. : The way that they did 10 it was they had me resign and then they picked 11 me up in San 12 MR. : Okay. So -. 13 MS. : It's the way that 14 they had me do it. 15 MR. : Was there a break in 16 service? 17 MS. : No. There was no 18 break in service. No. 19 MR. : At Terminal Island, what was 20 your position? 21 MS. : I was a correctional 22 officer. 23 MR. : Okay. And then six months 24 alter you went over to San 25 MS. : As a correctional EFTA00114192 10 1 officer. 2 MR. : Okay. How long were you 3 there for? 4 MS. : A little over ten 5 years. 6 MR. : Ten years. 7 MS. : Yes. 8 MR. : San . Okay. And what 9 other positions have you held with the BOP? 10 MS. : Correctional 11 Counselor and currently as a lieutenant. 12 MR. : When did you get promoted as 13 a counselor? 14 MS. : In I believe it was - 15 I started in I believe it was July of 2005. 16 MR. : July 2005. 17 MS. : Mm-hmm. 18 MR. : Alright. And then after 19 counselor, you got promoted as -. 20 MS. : A lieutenant. 21 MR. : Lieutenant. And when was 22 that? 23 MS. : That was in 2010. I 24 believe it was December 2010 that I 25 transferred. EFTA00114193 11 1 MR. : Where did you transfer? 2 MS. : FCI Jessup. 3 MR. : Jessant? 4 MS. : Jessup. 5 MR. : Jessup. 6 MS. : Jessup. In Georgia. 7 MR. : Georgia. Okay. In 2010 you 8 transferred and that was a promotion to 9 lieutenant? 10 MS. : Yeah. Well as a 11 counselor I was already a 9. So I just I guess 12 lateral over in a sense to a GS9 lieutenant. 13 MR. : Okay. In Jessup. Okay. 14 MS. : Right. 15 MR. : And how long were you in 16 Jessup for? 17 MS. : Up until I came here 18 in November of 2014. 19 MR. : November 2014. Have you been 20 here ever since or did you have any transfers? 21 MS. : Not without trying to 22 leave. But yes, I've been here since 2014. 23 Yes. 24 MR. : And were you transferred over 25 as a lieutenant? EFTA00114194 12 1 MS. : I was a lieutenant 2 when I was at Jessup. I went there as a 9. I 3 got my 11 and I just lateral over here as an 4 11. 5 MR. : And have you been in that 6 position ever since? 7 MS. : That depends on what 8 you mean by ever since. Have I been working in 9 the position or have I held that position? 10 I've held that position. I'm currently still a 11 lieutenant. 12 MR. : Okay. And - bear with me. 13 On August 9th and 10th of 2019, what was your 14 position at the MCC? 15 MS. : I was a lieutenant. 16 MR. : Okay. And what shift did you 17 work on August 9th and 10th? 18 MS. : I believe it was the 19 morning watch shift. 20 MR. : What time does the morning 21 watch shift start? 22 MS. : At that time, we were 23 coming in I believe it was from 10:00 to 6:00. 24 I think that's it. We would leave around 10:00 25 and then we got off - we got relieved at around EFTA00114195 13 1 6:00. 2 MR. ■ 3 a.m. and -? 4 MS. • So you would come in at 10:00 : 10:00 p.m. 5 MR. : 10:00 p.m. And leave at 6:00 6 a.m.? 7 MS. : Well it depends on 8 what time our relief came. But those were the 9 hours that we were working around. Around that 10 time. 11 MR. : Officially that's the 12 schedule? 13 MS. : Officially, our hours 14 were midnight to 8:00. But we would come in 15 and relieve around, you know, between the hours 16 of 10:00 and 6:00. I'll put it like that. 17 MR. : Understood. Okay. And who 18 was your supervisor when you worked at the MCC 19 on August 9th and 10th? Who did you report to? 20 MS. : Then I think it was 21 Captain . Yeah. I think it was Captain 22 We've had so many captains in and out 23 since I've been here, it's hard to keep track 24 sometimes. But yeah, it's Captain 25 MR. : As a lieutenant, where were EFTA00114196 14 1 you assigned during August 9th and 10th where 2 were you assigned? 3 MS. : I was operations 4 lieutenant. 5 MR. : Okay. And as an operations 6 lieutenant, what are your daily duties? 7 MS. : We supervise staff 8 and of course the inmate population. We're 9 responsible for the safety and security of the 10 inmate staff and the institution. We do - we 11 hire overtime. We make runs throughout the 12 institution. And do various other duties. We 13 have checks and balances that we have to do 14 throughout the night. 15 MR. : Okay. As a supervisor, who 16 did you supervise? 17 MS. : I supervised the 18 inmate population and of course the staff that 19 worked for me during that shift. 20 MR. : Do you remember who you r 21 staff was during that shift? 22 MS. : Ooh, all of them? 23 No. No I do not. 24 MR. : Any key people you 25 communicated with? EFTA00114197 15 1 MS. : I mean I communicate 2 with all my staff. 3 MR. : Okay. 4 MS. : There is not one 5 person during the course of a shift that I 6 don't communicate with. Especially when I'm 7 making rounds. And especially during that 8 time, I communicated with them even more 9 because we were below the bottom of the barrel 10 then when it came to staffing. So we really 11 didn't have a lot of -. We didn't have anybody 12 back then. We didn't even have enough staff at 13 that time to even respond to body alarms. Or 14 to do uses or forces. You know. Especially on 15 morning watch. It's already tight. But we was 16 even tighter. So that was one of those nights 17 when as much as -. Well that night as like 18 every other night. As much as possible I tried 19 to talk to staff because staff were doing back- 20 to-back mandations then. And you had staff 21 that were being mandated every day of the week 22 Monday through Sunday. Or Sunday through 23 Saturday as we say in Bureau. Because that's 24 when our week officially starts - Sunday. 25 MR. : When you say mandated what do EFTA00114198 16 1 you mean by that? 2 MS. : Mandations are 3 mandatory overtime. That's when you've 4 exhausted your overtime roster. That's the 5 people that sign up for overtime. You've gone 6 through that. There's no one available. Or 7 you get everybody from that list that wants to 8 do overtime or that's available. Then you 9 announce it over the intercom system. That's 10 voluntary. Whoever wants overtime outside of 11 that, you can assign them overtime from there. 12 And then we go to mandatory overtime. That's 13 when we have nothing else left. And we have to 14 utilize the staff that we have currently on 15 duty that's not officially on a double-shift. 16 That's not officially on 16 hours. 17 MR. : So I'm going to ask a couple 18 more questions. How many hours where COs 19 working during that time period? ON average? 20 MS. : Sixteen plus because 21 -. 22 MR. : Per day? 23 MS. : Per day. Yes. 24 Because there were days when staff would be 25 late. There were days when there wasn't EFTA00114199 17 1 anybody even after we mandated everybody on the 2 shift. We didn't have anybody to fill a bunch 3 of posts. We had vacated posts. We had a lot 4 of stuff. It was grueling during that time. 5 And I think we had been doing that for at least 6 a year if not more than a year. 7 MR. : Okay. 8 MS. : Mm-hmm. 9 MR. : Did you previously meet with 10 agents regarding the Epstein investigation? 11 MS. : I did. 12 MR. : Do you recall meeting with 13 them on August 14, 2019 in regard to the 14 matter? 15 MS. : I don't remember what 16 day it was. But yes, I recall meeting with 17 them. 18 MR. : I have a summary of the 19 report. What I'm going to do is I'm going to 20 read it out to you. And once I read it out to 21 you, we're going to have some follow-up 22 questions because there's some holes in there 23 that we would like to fill. This is like the 24 summary part. informed that she 25 had been employed with the Bureau of Prisons EFTA00114200 18 1 since December 11, 1994 and promoted to 2 lieutenant around 2010 and has spent her entire 3 career working at the Metropolitan Correctional 4 Facility. During the interview, 5 described the duties -. 6 MR. : Let her correct that. 7 It's not correct. So if you hear something 8 that's not correct -- 9 MR. : Yes, please. 10 MR. : -- just say that that's 11 not correct. 12 MS. : Okay. 13 MR. : If you hear anything, please 14 interrupt me and I'll -. 15 MS. : Okay. I was a 16 lieutenant prior to coming here. I had - as a 17 matter of fact, I was promoted. I was given a 18 temporary position not to exceed a year as a 19 lieutenant back in I think it was 2000, 2001 20 when I was at MCC San in California. And 21 I did - even after that year expired, I 22 remained in the lieutenant's office for the 23 next three or four years after that until I 24 transferred. And so when I came here, when I 25 left there, I went to be a counselor. And then EFTA00114201 19 1 I picked up my lieutenant position again in 2 Jessup. When I came here, I was already a 3 lieutenant. I didn't get promoted to the 4 lieutenant rank coming here. 5 MR. : Okay. 6 MS. : And I haven't spent 7 my whole career here at MCC New York. This is 8 my fifth institution. 9 MR. : Okay. 10 MR. : You said you've been here 11 since 2014. 12 MS. : I've been here since 13 November of 2014. 14 MR. : Okay. I'm going to keep 15 going. If you hear anything wrong, please -. 16 MS. : Okay. 17 MR. : During the interview, 18 described the duties and 19 responsibilities of the position as well as the 20 guards she supervises at the MCC. 21 is assigned to the midnight shift to 8:00 22 a.m. shift, but routinely arrives at 10:00 a.m. 23 MS. : 10:00 p.m. 24 MR. : 10:00 p.m. Sorry, I read 25 that wrong. In addition to describing her EFTA00114202 20 1 administrative duties, how 2 account at the MCC works and that the 3 lieutenants are responsible for supervising one 4 count per shift. described that 5 during the count, two guards assigned to the 6 area are to unlock the main gate that separates 7 the cells from the open and common area where 8 the guards are. One guard will walk down range 9 and actually look into each cell and count the 10 number of prisoners inside. Once the count is 11 complete, the guard will return to the key and 12 exchange places with the guard that was left to 13 secure the gate. That guard will then walk 14 down range and count the number of prisoners in 15 the cells. Upon completion, the guard will 16 return to the gate, secure it from the outside, 17 and record the numbers that came from their 18 count. Those numbers will be compared to the 19 master list of prisoners on record for being 20 assigned to the south. In addition to the 21 numbers being recorded and compared to the 22 master list or the E-1 sheet, the guards will 23 call in or receive a call from internal and 24 give a verbal record of their count. And 25 internal. EFTA00114203 21 1 MS. : Wait a minute. What 2 is that again? 3 MR. : I'll repeat that back. In 4 addition to the numbers being recorded and 5 compared to the master list or E-1 sheet, the 6 guards will call in or receive a call from 7 internal. 8 MS. : That's not true. 9 MR. : Go ahead. You can tell me. 10 MS. : When the officers 11 take the count, once they have gone around to 12 each range and both of them had counted each 13 range, before they leave that range, they will 14 compare their count for that particular range. 15 And they would do that in each subsequent 16 range. When they've completed, they call the 17 control center. And they will call in their 18 unit. They will call in the count that they 19 got for that particular unit. They will give 20 them their name, who conducted the count, and 21 at that time, the control center will let them 22 know whether they have a good count or a bad 23 count. Internals position is to pick up those 24 count slips after each unit has counted and 25 place those counts slips out into their EFTA00114204 22 1 respective sally port to be picked up by 2 internal. They do not call. Internal has 3 absolutely nothing to do with their count 4 unless they get a bad count. Sometimes 5 internal, or if we have other extra staff, they 6 will go up there and they will assist them with 7 the count. You know just to see maybe if one 8 of them miscounted or something like that. 9 They would just be like an additional person. 10 A new set of eyes, basically, to assist them 11 with the count. 12 MR. : So before I continue, I had a 13 question for you. Can you sat the difference 14 between internal and control? What exactly 15 their duties are? 16 MS. : The internal officer 17 is an officer who mans the elevator. He's 18 responsible for moving inmates around in the 19 institution. He has - they have checks and 20 stuff that they do throughout their shift. But 21 mainly they're responsible for moving inmates 22 up throughout the institution. They respond to 23 body alarms. They pick up the count slips. 24 And they just have general duties throughout 25 the night. They assist with the count EFTA00114205 23 1 throughout the night. But yes, once those 2 officers if they was to get a bad count, they 3 count again. And then if they get another bad 4 count, a subsequent bad count, then internal or 5 whoever else we have available at the time 6 that's not assigned to doing something else 7 will go in and conduct another count. But 8 internal would never just - they never report 9 to internal the results of their count. 10 MR. : I was just going to ask. 11 On this if she's able to identify during her 12 shift who was internal. 13 MR. : Do you remember who was an 14 internal that night? 15 MS. : That night? No. 16 MR. : What about control? 17 MS. : No. I don't. And I 18 don't want to guess. 19 MR. : And that's why I gave him 20 This is the official duty roster from those 21 nights. See I didn't expect you to remember. 22 That's why I was just asking if you were table 23 to look at these 24 MS. : Yeah. 25 MR. : -- things and be able to EFTA00114206 24 1 determine who it is that actually -. I think 2 this is you. you were on the 10th. So -. 3 MR. : So we're going to present you 4 with two rosters. One from August 9th, 2019. 5 MR. : Well I don't think you 6 were on August 9th. Well I guess you were at 7 the 10:00 p.m. So -. 8 MR. : The 10:00 p.m. And she 9 worked an overnight too. Right? So from 10 August 9th and then also from August 10th. So 11 I'm going to mark it Exhibit 1 on August 9th. 12 And Exhibit 2 for August 10th. 13 MS. : Okay. This is August 14 10th. 15 MR. : Can you take a look and let 16 me know who the internal was and who the 17 control was for those nights? 18 MS. : For both nights? 19 MR. : Yes, please. 20 MS. : Okay. I'm currently 21 looking at the assignment roster for Friday, 22 August 9, 2019. 23 MR. : Let's start with that 24 afternoon. And then the evening. 25 MS. : You want day watch? EFTA00114207 25 1 MR. : Yeah. Again, you can go 2 through it. 3 MS. : Okay. On Friday, 4 August 9, 2019, the day watch. You wanted the 5 control room or you wanted -? 6 MR. : Let's do control room first. 7 MS. : The control room 8 number one was Officer 9 MR. : Please spell that. I don't 10 have it. Just for the record. Can you spell 11 the name on that? 12 MS. : Yes. 13 MR. : Okay. Officer 14 MS. : Yes. And his control 15 number two officer was Officer 16 I. For the evening watch shift, 17 would have been the control number one officer. 18 It seems like it appears. Ancl 19 , would have been the control two 20 according to this roster. 21 MR. : And those were the people 22 that they would have called with the numbers. 23 Correct? 24 MS. : They generally would 25 call the control number two. EFTA00114208 26 1 MR. : Okay. Control two. 2 MS. : Control two. Yes. 3 MR. : And who was that again? 4 MS. : On day watch that 5 would have been And on evening watch 6 that would have been 7 MR. : Now as far as the counts, 8 who would have picked up the slips from 9 internal? Who was that? 10 MS. : Internal during day 11 watch was Officer who was overtime. 12 And for the evening watch shift, you had 13 Officer and they had an internal 14 number two, - Officer 15 MR. : So they would have been 16 the people that like for instance would go to 17 the SHU and pick up the count slips? 18 MS. : They would go to each 19 floor -- 20 MR. : Sure. 21 MS. : -- and pick up all 22 the count slips for the entire institution. 23 MR. : To include for the 24 special housing unit though? 25 MS. : Everywhere. EFTA00114209 27 1 MR. : Great. 2 MS. : Yes. Everywhere. 3 Whether that be medical - wherever we had 4 inmates at that time, they would have been 5 picking up those count slips. Or sometimes if 6 unit team or somebody like that is here. And 7 they're on the unit at the time, you know, 8 they'll say if they're on their way down 9 they'll say I'll take the count slip down. So 10 it just depends on what day it is and what we 11 have going on during that specific time. But 12 for the most part, when no one else has 13 delivered the count slips down, it would be 14 Well, on this day, Friday, August 15 9th. It would have been between and 16 or both. 17 MR. : Great. Do you mind just 18 - this is only so that we know what document 19 you're looking at - do you mind just initialing 20 and dating and then circling the people that 21 you just discussed? 22 MS. : Do you want me to 23 date each one? 24 MR. : No-no. I'm sorry. Just 25 on the top of the form, just an initial and a EFTA00114210 28 1 date. And then you can just circle the name of 2 the people that you just said. Just for the 3 purposes of the documents that we discussed 4 will be attached to the transcript of this. 5 And it's just to make sure that we have the 6 right document. Thank you. We'll come back. 7 MR. : So I'm going to also present 8 you with the roster for August 10, 2019. Can 9 you do the same for us again? Identify the 10 internal and the control officers? 11 MS. : Okay. 12 MR. : Do you want her to be 13 specific though between the hours of 6:00 and 14 8:00 a.m.? 15 MR. : Yes. So specifically, 10 16 p.m. 17 MR. : So between 10 p.m. and 18 6:00 a.m. 19 MR. : I think the roster -. What's 20 the time that starts on the roster for August 21 10th? Midnight? 22 MS. : Midnight. Yeah. 23 MR. : So let's identify from 24 midnight to let's say 25 MR. : 8:00 a.m. The same shift EFTA00114211 29 1 that you were on. 2 MR. : Yeah. 3 MS. : Okay. So I'm looking 4 at the assignment roster for Saturday, August 5 10, 2019. The control number one officer was 6 Ms. who is non-custody. She works in 7 the R&D - Receiving and Discharge department 8 for - she was on overtime. For day watch, 9 control number one is Officer . Control 10 number two is Officer (Phonetic Sp. 11 *00:27:07) who was on overtime. For evening 12 watch, in the control one position there was 13 Officer and control two was Officer 14 who was also non-custody. 15 MR. : Now when they - when the 16 SHU officers would call control for the counts 17 during that shift, who is it that they would 18 have called? And which counts would have been 19 called? For that shift? I think you said that 20 typically, actually it -- 21 MS. : Typically 22 MR. : -- works from 10:00 p.m. 23 to 6:00 a.m. but it shows on their schedule 24 it's 12:00 to 8:00. 25 MS. : Well the officers EFTA00114212 30 1 were working those hours. 2 MR. : Okay. 3 MS. : The officers were 4 working -- 5 MR. : So just the lieutenants 6 were different? 7 MS. : -- 12:00 to 8:00. 8 Yes. It was just the lieutenants. 9 MR. : Okay. So if they 10 actually worked 12:00 to 8:00. 11 MS. : To 8:00, 8:00 to 12 4:00, and 4:00 to midnight. That's correct. 13 MR. : Okay. So who on the 14 schedule then when the special housing unit 15 officers would call in, who was it that they 16 would call into? 17 MS. : They would normally 18 call control two. Now this is not all- 19 inclusive because if control two is busy, 20 sometimes they would call control one. Because 21 control two would be you know sometimes 22 handling back-to-back calls. And plus, they're 23 responsible for answering outside calls and 24 stuff to that nature as well. I mean when 25 people are calling in from eh outside, they EFTA00114213 31 1 don't care if they miss count time or not. But 2 the control number two officers work from 6:00 3 to 2:00 to 2:00 to 10:00. Those were their 4 hours. 5 MR. : Okay. 6 MS. : Okay? And um. 7 MR. : So 6:00 a.m. or 6:00 8 p.m.? 9 MS. : The day watch would 10 work - or the a.m. shift as we call it. They 11 would work from 6:00 a.m. to 2:00 p.m. 12 MR. : Okay. 13 MS. : And the p.m. shift 14 would work 2:00 p.m. to 10:00 p.m. 15 MR. : Okay. So specifically in 16 the hours that you were working there, who 17 would have been called by the special housing 18 unit? 19 MS. : Well like I said, 20 they would have been calling because I worked 21 morning watch. They would have been calling 22 There wouldn't have been a control two -. 23 MR. : So that's -. 24 MS. : Wait a minute. 25 MR. : So that's so yeah. Let's EFTA00114214 32 1 say for instance the 12:00 p.m. count, the 3:00 2 a.m. count, and the 5:00 a.m. count. Who would 3 have been called then on August 10th? 4 MS. : They would have been 5 calling control number one because I don't 6 think they had, um They would have been 7 calling -. I want to say they was calling 8 control number one. Because at this time, it 9 look like we had a control number two. Because 10 there was a time when internal number two would 11 fill in for the control number two. But it 12 doesn't look like this was during that time. 13 MR. : To your best guess, who 14 of the officers in the special housing unit, 15 who would have been called? For the 12:00, the 16 3:00, and the 5:00 a.m. counts, who would have 17 been called on those? 18 MS. : They would have been 19 calling the control center number one. 20 MR. : And who was that? 21 MS. : During the 12:00 to 22 8:00 shift that would have been Officer 23 who, like I said, was on overtime. She's non- 24 custody. She works in the R&D department. 25 MR. : Okay. EFTA00114215 33 1 MS. : That's where she's 2 assigned. 3 MR. : Okay. And then for those 4 same counts, 12:00 a.m., 3:00 a.m., and 5:00 5 a.m., who from internal would have collected 6 those slips? 7 MS. : It could have been 8 either one of them. 9 MR. : Okay. 10 MS. : Because on morning 11 watch, it look like there was two. But I'm 12 trying to remember at that time if um -. 13 Because sometimes the internal two would assist 14 control because there were other things that 15 needed to be done. But you have for internal 16 there on morning watch there was Officer 17 and Officer (Phonetic Sp. *00:31:14) who 18 was on overtime. Officer was on overtime 19 for midnight to 8:00. So between those two, 20 they would have been picking up the count 21 slips. 22 MR. : Just can you repeat those 23 two again? 24 MS. : That's internal would 25 have been Officer . And internal number EFTA00114216 34 1 two was Officer . And he was on overtime. 2 MR. : Great. Thank you very 3 much. 4 MR. : Can you do the same with 5 that? Just circle. 6 MR. : Just circle the names 7 that you just mentioned and then just initial 8 and date on the top. 9 MS. : Oh, you know what I'm 10 doing? 11 MR. : It's -. 12 MS. : I'm putting the date 13 of the roster on here. 14 MR. : Yeah, I know. You want 15 to date it today. I'm sorry. So today is 16 6/14/21. Sorry. And I'm handing you back the 17 other roster so you can fix that. 18 MR. : So the August 10th roster I'm 19 going to mark as Exhibit 2. And August 9th 20 will be Exhibit 1. 21 MR. : I wouldn't. this is -. 22 If you're doing exhibits, this is Exhibit 1. 23 MR. : Alright. 24 MR. : If you want to do that. 25 MR. : Okay. EFTA00114217 35 1 MR. : Because we're probably 2 going to have to go back to this, I wouldn't 3 mark them as exhibits. 4 MR. : Okay. No problem. 5 MR. : Because this is always 6 going to be Exhibit 1. 7 MR. : I understand. Just to 8 clarify before we move forward. How many 9 counts take place at the MCC? Daily? 10 MS. : It depends. During 11 the week we have the Let's start with day 12 watch. Day watch we have the 4:00 p.m. count. 13 Evening watch we have the 10:00 p.m. count. 14 Morning watch we have the 12:00 a.m., the 3:00 15 a.m., and the 5:00 a.m. So five. On weekends 16 and holidays, we have an additional count of 17 10:00 a.m. which is added for weekends and 18 holidays. 19 MR. : Okay. Thank you. So I'm 20 going to go back and I'm going to continue 21 reading from that spot. So I'm going to reread 22 that line and we'll move forward. 23 MS. : Okay. 24 MR. : In addition to the numbers 25 being recorded and compared to the master list EFTA00114218 36 1 or E-1 sheet, the guards will call in or 2 receive a call from internal and give a verbal 3 record of the account and internal will compare 4 that number to the number that they have on 5 file and advise the count matches and is good 6 or does not match and a count needs to be 7 conducted again. You clarified that. You 8 explained how the control and the internal 9 works. The count slips prepared by the guards 10 are then placed in the area for pickup by 11 another guard assigned in the MCC and brought 12 to control for review. In addition to the 13 official counts that are to be conducted at 14 specific times during each shift, 15 informed that the guards are also 16 responsible for conducing rounds every 30 to 40 17 minutes. During the rounds, the guards simply 18 walk the range and view that the prisoners are 19 alive and in their cells with no issues. The 20 number of prisoners is not recorded, but simply 21 the fact that a round was conducted. And the 22 officers who conducted it is. When asked, 23 stated that she has no knowledge 24 of rounds or counts not being conducted and 25 that no one would tell her if that were the EFTA00114219 37 1 case. 2 MS. : As far as the rounds 3 go, the rounds are irregular. So they're not 4 supposed to be done at the same time and 5 there's a reason for that. You know. So the 6 rounds are supposed to be conducted - are 7 usually conducted every hour and they're done 8 on an irregular basis. So that's how the 9 rounds are supposed to be done. 10 MR. : So you say every hour, 11 it's not every 30 minutes? 12 MS. : That would be in SHU. 13 MR. : Okay. 14 MS. : Special housing has 15 its own set of rules as far as the count goes 16 but on the other units, and even in SHU the 17 rounds are supposed to be irregular. 18 MR. : Sure. 19 MS. : They're not supposed 20 to be like every half hour or something like 21 that. 22 MR. : Is it correct that it's 23 every 30 minutes but it's supposed to be 24 between 30 and 40 minutes? 25 MS. : There's a little EFTA00114220 38 1 hangover just for that -- 2 MR. : Sure. 3 MS. : -- so that the rounds 4 can be irregular if you get tied up. Because 5 when you're making rounds, inmates will stop 6 you. They will hold conversations with you and 7 ask questions. You know and so it's hard to 8 keep those rounds within those guidelines 9 because there's always something to trip you 10 up. When you're making rounds you may notice 11 something out of place, so that would stop you. 12 But as far as those rounds getting conducted, 13 those rounds are supposed to be conducted on an 14 irregular basis. But do understand that there 15 are things that will trip you up. So sometimes 16 you may be on time. Sometimes you -. It's 17 hard to fall within those guidelines because 18 you're - it's live time. Everything is alive. 19 So you can't predict what's going to happen 20 while you're making your rounds. 21 MR. : Understood. And that was a 22 summary of your interview. So as you can see, 23 we have a few questions we want to follow 24 MS. : Right. 25 MR. : And we've got -. EFTA00114221 39 1 MS. : You have medical 2 emergencies. You have inmates that are 3 complaining, wait until you start making your 4 rounds to complain about being in pain or 5 something that's hurting them. Or a lot of 6 general stuff. They'll ask you questions just 7 about anything when you're making rounds. 8 MR. : Understood. 9 MS. : Mm-hmm. 10 MR. : I'm going to go back to my 11 interview now and I have a few questions for 12 you. If there were instructions of guidance 13 from upper management, how would you receive 14 them? 15 MS. : It depends. During 16 that time, they made -. Whoever was in the 17 office may come and say something to the person 18 in the office. And it was left up to everybody 19 else to get that information from that 20 individual. 21 MR. : Who was in the office at that 22 point? I mean is a certain person assigned to 23 the office or it could be anybody in the 24 office? 25 MS. : Like the lieutenant. EFTA00114222 40 1 Like a - when I say the office, I'm talking 2 about like the lieutenants' office. So 3 sometimes they would just - and more often than 4 not - they would just say something to whoever 5 is in the office. And that's how everybody is 6 supposed to get that information. 7 MR. : If there were instructions 8 from the lieutenants, who would give it? 9 MS. : We would expect the 10 captain to give it. 11 MR. : Did the instructions that 12 would come from above the captain? Or was it 13 always from the captain? 14 MS. : Um.... I don't -. I 15 mean, from time to time, some of the AWs would 16 put things out. But the normal chain would be 17 through the captain because that was our 18 immediate supervisor. 19 MR. : Okay. If you had important 20 details to discuss with your subordinates or 21 COs who report to you, how would you 22 communicate that to them? 23 MS. : One more time. 24 MR. : If you had important details 25 or instructions you wanted to discuss with your EFTA00114223 41 1 subordinates or COs, correctional officers, who 2 report to you, how would you communicate those 3 instructions to them? 4 MS. : I usually did it when 5 I made my rounds. And I would tell them. But 6 you could also do a thing such as 3-3-3s. And 7 that way, that's when everybody come on the 8 line and you could do it that way. But you 9 really didn't have time. It was easier to just 10 tell everybody individually because that way 11 you're with them in person. and it's just 12 easier for you to do it at that time because if 13 they had questions, then they could ask you 14 questions. And when you're doing over the 15 phone at the hole, you're sitting in the 16 office. So you're really not getting anything 17 done, you know. At least if I'm making my 18 rounds, I'm getting my rounds done and I'm 19 doing my - passing down information to my staff 20 at the same time. And also it lets me know 21 that you got it. I'm telling you. it's just 22 you and me. There's no distractions in the 23 background. There's nothing else going on. 24 But it just depends on the person. 25 MR. : Okay. EFTA00114224 42 1 MS. : How they got that 2 information to each individual staff. 3 MR. : Would you communicate that 4 directly with your COs or would you tell 5 another CO to pass on the message? 6 MS. : It depends on what 7 the information was. I mean things that you 8 want them to know and definitely. If it was 9 something that was a new policy or procedure or 10 something like that, you would definitely want 11 to tell them yourselves because at that time, 12 like I said, there wasn't anything coming out 13 in writing. That's generally how new policy 14 and procedure is put in place. You know you 15 either receive a memorandum saying starting 16 with this memorandum or starting with - 17 effective today or some other date, this is 18 what we're going to be doing. That's generally 19 how that information is put out. Or some type 20 of manual or something like that is updated. 21 Those are the ways that it's generally put out. 22 That way you have the information there and you 23 can refer back to it as needed. 24 MR. : What if it involved an 25 inmate? Like certain instructions for certain EFTA00114225 43 1 inmates. How would that come out? Would that 2 come out verbally or would that be written? 3 MS. : It depends on, like I 4 say, the person that's delivering the 5 information. It depended on that. 6 MR. : On August 9th when you came 7 on shift during that day, you said you were 8 working overnight. 9 MS. : Yes. 10 MR. : So technically, weren't you 11 on shift August 9th nighttime? Morning watch? 12 Do you remember? 13 MS. : August 9th going into 14 August 10th. 15 MR. : Okay. 16 MS. : So -. 17 MR. : Did you work the day before 18 too? You don't recall. 19 MS. : I don't know if I did 20 or not. I may have. 21 MR. : Let's try to focus -. 22 MS. : Yeah. I don't know. 23 MR. : No problem. So let's talk 24 about August -. 25 MR. : Um, so if you're asking - EFTA00114226 44 1 2 3 - MS. I work -- : What do you mean did 4 MR. : -- specifically August 5 9th -- 6 MS. : -- day watch or -? 7 MR. : It looks like she was on 8 from midnight to 8:00 the day before. 9 MR. : Day before too. 10 MR. : So that means you would 11 have left at 6:00 a.m. on August 9th. 12 MS. : Right. And came back 13 -. 14 MR. : And come back at 10:00 15 p.m. 16 MS. : That's correct. 17 MR. : So let's focus on 10:00 18 p.m. to 6:00 a.m. August 9th night going into 19 August 10th day. 20 MS. : Right. Because I 21 don't think I worked evening watch. 22 MR. : No there's a reason. Can I 23 ? 24 MR. : Sure. I'm just saying 25 she's done at 6:00 a.m. not at 8:00. EFTA00114227 45 1 MR. : Yeah, that's what I wanted to 2 ask. 3 MS. : Okay. 4 MR. : So I just want to clarify. 5 That day, I know you don't recall back on the 6 schedule, what is that showing? What time did 7 you leave on August 9th morning? 8 MS. : Oh. I would have 9 left probably - it depends on who was relieving 10 me. I probably would have left probably before 11 6:00. 12 MR. : Before 6:00. 13 MS. : Mm-hmm. 14 MR. : Would you -? 15 MS. : 6:00 a.m. 16 MR. : 6:00 a.m. By 6:00 a.m., 17 would you happen to have heard if there was an 18 inmate being removed from eh MCC? Or did that 19 come afterwards? Let's say they -. 20 MS. : What on August 9th? 21 MR. : August 9th. 22 MS. : I don't recall. What 23 day did Epstein die? Because I don't even 24 remember what day he passed. 25 MR. : August 10th. EFTA00114228 46 1 MS. : Okay. 2 MR. : Well that's when he was 3 found. 4 MS. : Okay. 5 MR. : He was found August 10th 6 morning. 7 MS. : So you said -. 8 MR. : August 9th. That would be 9 Friday morning. Right? You left the shift it 10 looks like 6:00 a.m. Right? 11 MS. : Which would have been 12 Saturday morning. 13 MR. : No-no. Sorry. I should 14 clarify. August 9th -- 15 MS. : Oh. 16 MR. : -- morning is Friday morning. 17 MS. : Okay. Friday 18 morning. 19 MR. : Friday morning, you did the 20 overnight shift. Then you left. And then you 21 came back August 9th, 10:00 p.m. and you worked 22 until 6:00 a.m. 23 MS. : Right. 24 MR. : Now I'm talking about August 25 9th -. Let's say August 8th 10:00 p.m. to EFTA00114229 47 1 August 9th -. 2 MS. : Oh my God. 3 MR. : The reason I'm asking is I'm 4 just trying to clarify. Would you have known 5 if any instructions came about inmates having 6 to be brought out for court or anything like 7 that. Would you have heard about it before you 8 left? 9 MS. : We're talking about 10 August -. 11 MR. : 9th. 12 MS. : I mean I may have. I 13 can't recall. 14 MR. : Okay. But does it happen 15 before 6:00 a.m. or it happens after 6:00 a.m. 16 normally? 17 MS. : You mean like inmates 18 that are going to court? 19 MR. : Going to court or being 20 removed from the prison for whatever reason. 21 MS. : I mean if it involved 22 me. Say if we had an inmate up on 10 South. 23 Because those inmates up there are generally 3- 24 man holes. So if there was an inmate that I 25 had to physically be involved in escorting, EFTA00114230 48 1 yes. They would notify me or the activities 2 lieutenant. It just depends. 3 MR. : No problem. Now I'm going to 4 keep going. Are you familiar with Inmate 5 Jeffrey Epstein? 6 MS. : Yes. 7 MR. : Okay. Did you work in the 8 SHU while Epstein was assigned to the SHU? 9 MS. : No. 10 MR. : Okay. Do you recall if 11 Epstein had a cellmate? 12 MS. : At some point he had 13 a cellmate. 14 MR. : Okay. Were you aware that 15 Epstein had attempted to commit suicide before? 16 MS. : Yes. 17 MR. : Okay. Do you recall around 18 what time - what date it was? 19 MS. : I know it was in 20 July. I can't remember the exact date. But I 21 know it was in July. 22 MR. : Were you there for that 23 incident? 24 MS. : Yes. 25 MR. : Okay. Quickly, do you EFTA00114231 49 1 remember? Like a short summary what 2 transpired? 3 MS. : Um, we were called to 4 the special housing unit. I think then we got 5 there and Officer Thomas was working that day. 6 When we got there, the officer informed us that 7 an inmate had tried to hurt himself. So we go 8 up to the cell and it's Epstein. 9 MR. : Okay. 10 MS. : And he's lying on the 11 floor seemingly out of it I guess you could 12 say. But when we tap him and we move him, we 13 could see him kind of looking up at us. But 14 then he would close his eyes like he didn't 15 want us to know that he was actually conscious. 16 MR. : Okay. 17 MS. : So we couldn't get 18 anything from him. He wouldn't respond to us. 19 But we knew that he was okay. He was 20 breathing. And like I said, he would look up 21 at us from time to time. When he didn't think 22 that we were looking at him. 23 MR. : Okay. 24 MS. : And -. 25 MR. : What happened after that? EFTA00114232 50 1 Was Epstein placed on suicide watch or psych 2 observation? 3 MS. : Yes. He was placed 4 on suicide watch. 5 MR. : Okay. 6 MS. : Officer Thomas was 7 assigned to watch him. And he literally stood 8 there at his cell all night watching him and 9 talking to him. 10 MR. : Who was? 11 MS. : Officer Thomas. 12 MR. : Okay. Same Thomas? 13 MS. : Yes. 14 MR. : Michael Thomas? 15 MS. : Yes. 16 MR. : Okay. 17 MS. : Yes. 18 MR. : How long - do you recall how 19 long he was on suicide watch? 20 MS. : I don't recall. 21 MR. : Okay. No problem. Now was 22 he eventually removed from suicide watch? 23 MS. : Yes. 24 MR. : What happened after suicide 25 watch? Was he placed on any of the EFTA00114233 51 1 observation? Or -? 2 MS. : I don't remember. I 3 don't remember if he went from suicide watch to 4 psych ops or if he went from suicide watch 5 straight back to the special housing unit. 6 MR. : So suicide watch - where does 7 that take place? 8 MS. : That's on the second 9 floor. 10 MR. : Second floor. What unit? 11 MS. : Medical. 12 MR. : Medical? 13 MS. : It's right out -. 14 It's like an extension to the medical unit 15 slash -. At that time, we had - there was a 16 female housing unit there. So it's adjacent to 17 the female housing unit. But the second floor 18 is our medical floor aside from the housing 19 unit. 20 MR. : Okay. 21 MS. : And the psych unit. 22 MR. : When Epstein was returned 23 back to the SHU. Do you recall any 24 instructions being given by upper management, 25 executive staff, regarding Epstein being EFTA00114234 52 1 assigned with a ceilmate? 2 MS. : No. 3 MR. : Okay. Did you -? I'm going 4 to go through each. Did you receive any 5 instruction from Captain in regard to 6 this? 7 MS. : No. 8 MR. : Okay. Do you recall? I'm 9 going to ask. Do you recall receiving an email 10 from psych instructing that Epstein needed a 11 celimate? 12 MS. : No. 13 MR. : I'm going to show you a 14 document. Right? Read that document. Who is 15 that email from? 16 MS. : This is fro 17 (Phonetic Sp. *00:49:19). 18 MR. : And who is that? 19 MS. : She was a 20 psychologist here at the time. 21 MR. : Okay. And what is the 22 summary of that email? 23 MS. : It's says inmate 24 Epstein register number 76318-054 is being 25 taken off of psych observation and needs to be EFTA00114235 53 1 housed with an appropriate cellmate. 2 MR. : What's the date of that 3 email? 4 MS. : This is July 30, 2019 5 at 12:30 p.m. 6 MR. : Do you recall getting that 7 email? 8 MS. : I don't recall. This 9 is the first I've seen of this email. This is 10 the first time I've seen this email. 11 MR. : So if you flip through the 12 pages, it actually shows you the recipients. 13 Is your name on that? 14 MS. : If she sent it to the 15 lieutenants group, I'm sure - more than likely 16 -. 17 MR. : There's a -. 18 MS. : Yeah. 19 MR. It's in alphabetical order. 20 MS. : Yeah. Yes, I'm here. 21 MR. Is there a reason why that -? 22 I mean, you don't recall reading that email 23 yourself then. 24 MS. : I don't even remember 25 seeing this email. EFTA00114236 54 1 MR. : Okay. Did you ever 2 participate in executive committee meetings? 3 MS. : No. 4 MR. : Okay. That was just the 5 higher ups? You don't even know who -? 6 MS. : I don't even know 7 what that -. 8 MR. : Okay. No problem. 9 MS. : Yeah, I don't -. 10 MR. : Okay. So I'll move on. 11 MR. : Initial and date. 12 MR. : Yeah. Sorry. Can you 13 initial and date that document for me? I'm 14 going to mention some names. Can you just let 15 me know what, if any, conversations you had 16 with any of these people regarding Epstein and 17 Epstein needing a cellmate at all times? 18 Captain Lieutenant 19 (Phonetic Sp. *00:51:28). 20 MS. : Okay. What do you 21 want me to do? I'm sorry. 22 MR. : No. I'm going to through the 23 names. 24 MS. : Okay. 25 MR. : If you recall if you had a EFTA00114237 55 1 conversation with any of these people in regard 2 to Epstein and Epstein needing a cellmate. 3 MS. : Okay. 4 MR. : Okay? This is prior to the 5 incident. 6 MS. : Okay. 7 MR. : Captain 8 Lieutenant . Lieutenant - 9 10 MR. : You need to let her say 11 yes or no after each one. 12 MR. : Okay. Sorry. Apologize. 13 Have you ever had a conversation with 14 Captain 15 cellmate? 16 MS. - in regard to Epstein needing a : No. 17 MR. : What about Lieutenant 18 ? 19 MS. : No. 20 MR. : Lieutenant 21 MS. : No. 22 MR. : Lieutenant 23 MS. : No. 24 MR. : Lieutenant 25 MS. : No. EFTA00114238 56 1 2 3 4 MR. : MS. MR. : MS. Lieutenant : No. Lieutenant : No. 5 MR. : Now following that I have a 6 few more names. The rest are correctional 7 officers. Same thing. Have you had any 8 conversations with them about Epstein requiring 9 a cellmate? CO 10 MS. : No. 11 MR. : CO 12 MS. : No. 13 MR. : If I mispronounce the name, 14 please correct me. CO 15 MS. : No. 16 MR. : CO Michael Thomas. 17 MS. : No. 18 MR. : CO Tova Noel. 19 MS. : No. 20 MR. CO : 21 MS. : No. 22 MR. 23 MS. : No. 24 MR. : CO 25 MS. EFTA00114239 57 1 MR. : Yeah. 2 MS. : No. 3 MR. : How about SOS 4 5 MS. : No. 6 MR. : Okay. When did you become 7 aware of Inmate Efren Reyes being removed from 8 the MCC? Efren Reyes. Do you know who Efren 9 Reyes is? 10 MS. 11 that is. 12 MR. : Okay. Do you recall who was 13 Epstein's cellmate? 14 MS. : When? : I don't even know who 15 MR. : During that period? After he 16 came back from suicide watch? 17 MS. : No. 18 MR. : Okay. 19 MR. : Do you remember if he had 20 one after that? We're talking about July 30th 21 when he came back. Are you -? 22 MS. : I didn't know if he 23 had one or not. 24 MR. : Okay. 25 MS. : Um. No. I didn't EFTA00114240 58 1 know if he had a cellmate or not to be honest 2 with you. No. 3 MR. : And you're not aware of any 4 requirements of him having a cellmate either? 5 MS. : I wasn't even aware 6 that they had sent out some information 7 regarding the fact that he needed to have a 8 cellmate. I would think that they would be 9 that that would be something that they would 10 verbalize. 11 MR. : Okay. 12 MS. : That they would make 13 sure that we individually -. That they would 14 check to make sure that we all read that 15 message. 16 MR. : Okay. 17 MS. : I mean if it was 18 something that was critical -. Because he was 19 on suicide watch. And because of the 20 circumstances that surrounded him. I would 21 expect for them to follow-up and make sure that 22 we all read that email and we were all aware 23 that he was to have a cellie. 24 MR. : Who would you expect to do 25 that? EFTA00114241 59 1 MS. : I would expect for 2 psychology to follow-up with us. I would 3 expect for definitely the captain to get with 4 us individually and tell us. 5 MR. : Okay. 6 MS. : Hold a lieutenant's 7 meeting or something to let us know that we 8 were to make sure that he had a cellmate. 9 MR. : Okay. If - let's say. Have 10 you ever dealt with an inmate that required a 11 cellmate before? 12 MS. : Not directly, no. 13 No. 14 MR. : But do you -? Okay. You 15 never have. But if let's say an inmate was 16 required to have a cellmate. And that cellmate 17 was removed for whatever reason. Do you know 18 what the procedure would be? 19 MS. : If an inmate was 20 required to have a cellmate. And everybody 21 knew. Because when you're talking about an 22 inmate that needs a cellmate, it's not just the 23 lieutenants who work with that inmate. The 24 officers are the ones who are assigned to that 25 inmate housing unit. Around the clock, 24/7. EFTA00114242 60 1 So you would definitely want that information. 2 That should be an all staff email to be honest 3 with you. Because that way everybody in the 4 institution knows that there's an important 5 reason why that inmate needs a cellmate. And 6 that way if at some point in time it's not 7 happening or there's a lapse in that, everybody 8 knows. So you've got - because you have staff 9 making rounds around the institution on the 10 housing units and all of that stuff all the 11 time. You know, different members of the 12 institution staff. So that would be an all 13 staff email just to alert everybody in the 14 institution that, you know, if you're ever in 15 that area and you come across this inmate and 16 he doesn't have a cellie, then you need to 17 follow-up, ask why, make sure somebody knows 18 that that inmate don't have a cellie. 19 MR. : I'm going to clarify. Based 20 on the fact that based on what we - our 21 investigation. Inmate Efren Reyes was assigned 22 as a cellmate for Jeffrey Epstein. 23 MS. : Okay. 24 MR. : And he was required - 25 according to psychology - he was required to EFTA00114243 61 1 have a cellmate. Now Inmate Efren Reyes was 2 removed from the MCC on August 9th morning 3 during the day watch. Now based on - I'm going 4 to read you the names again. Right. And you 5 just tell me. You might not know it directly, 6 but who would be responsible to take what 7 action when they found out that Efren Reyes was 8 removed. If there was a requirement, that 9 Epstein had to have a cellmate at all times, 10 and his cellmate was removed, who would be 11 responsible to take action? And I'm going to 12 mention the names. Let me know what their role 13 would have been and what action they should 14 have taken. 15 MS. : You're telling -. 16 You want me to tell you that. That's if in 17 fact they knew -. 18 MR. : Yeah. If in fact they knew. 19 MS. : Yeah. If in fact 20 they knew that he was supposed to have a 21 cellie. 22 MR. : Yes. 23 MS. : You know. Not 24 assuming that he had a cellie. 25 MR. : And so we don't have to EFTA00114244 62 1 go back and circle back to this. Not only - so 2 if he's naming a name, say what action should 3 have they taken and who should have told them 4 the information with regard to the need to have 5 a cellmate. 6 MS. : Well I would have to 7 know what position those officers had -- 8 MR. : Sure. 9 MS. : -- at the time that 10 this occurred also. Because -. 11 MR. : We can hand you the roster 12 again. 13 MR. : So this is the August 14 9th. I'll give you that one first. 15 MR. : But just start with 16 (Indiscernible *00:58:18). 17 MR. : Again, so he was removed 18 from his cell let's say around 8:30 a.m. and I 19 think he was removed from the institution 20 somewhere around 1:30 p.m. So 8:30 is when he 21 went to a court. And then by 1:30 he was gone. 22 MR. : They were pretty much 23 notified he's not coming back. 24 MS. : Mm. 25 MR. : So I'll start with Captain EFTA00114245 63 1 2 MS. : Yes. Captain 3 should have known. 4 MR. : How would he have known? Who 5 should have made him aware of it? 6 MR. : Let's just - instead of 7 going through it, let's just first start with 8 going from the bottom up. Who should have 9 known that he was removed? And how should the 10 chain of command have gone up? Looking at that 11 duty schedule roster. 12 MR. : Yeah. Based on that. Who 13 should have initially known that he was 14 removed? 15 MS. : Well R&D should have 16 known initially that the inmate was removed. 17 Now whether or not they would have known that 18 he was Epstein's cellie is something different. 19 MR. : Okay. 20 MS. : Like I said, if this 21 information had put out because Epstein was a 22 high-profile inmate. He had just attempted 23 suicide. That should have been an all-staff 24 email. That should have alerted everybody. 25 And not only that, but when that happens. EFTA00114246 64 1 First of all, when Epstein originally arrived 2 to the MCC, Epstein should have been placed on 3 10 South. That's our - what they consider the 4 maximum-security unit here. He never should 5 have been placed on 10 South anyway because 6 you're not guaranteed that anybody in this 7 building is going to maintain a cellie because 8 it's an administrative institution. Inmates 9 come and go all the time. So there's - they 10 don't have a sentence date. And with that 11 said, that means that at any point and time 12 while we're sitting here, the courts can 13 release somebody and that inmate is gone right 14 now. So to put out an email to certain 15 individuals and not make that an all-staff 16 email so that it would -. And I guess we have 17 to back and say what was the intentions of 18 that? If it's something that you feel is 19 concerning and that absolutely needs to happen 20 because you still feel that this inmate is at 21 risk, then you say to yourself, well why is he 22 being released from suicide watch? Or psych 23 ops. Why, you know? If you feel that this 24 inmate still needs this type of supervision. 25 And if the answer to that is yes, he still EFTA00114247 65 1 needs that type of supervision, then you would 2 recommend that, you know, why don't you keep 3 him?? Why aren't you maintaining him? You 4 know. On watch? If he requires that type of 5 supervision? Or why - since you didn't do it 6 to begin with - which they should have done. 7 Considering he was high-profile, he was an at- 8 risk inmate, just the fact that he was a high- 9 profile inmate, he should have been placed on 10 10 South. After he attempted suicide and they 11 determined that they was going to remove him 12 from that and required him to have a cellie. 13 Then they should have either made it an all- 14 staff email, made sure everybody was aware - 15 everybody. Not just -. And it's difficult 16 because people are on days off, people are on 17 vacation, people are on sick leave, you see 18 what I'm saying? 19 MR. : Okay. 20 MS. : So for somebody like 21 Epstein. Epstein should have automatically 22 gone to 10 South where he would have had 24- 23 hour monitoring on him at all times. 24 MR. : Okay. Assuming that the CO - 25 . Let's start with the COs. Assuming the COs EFTA00114248 66 1 in the SHU knew that this was a requirement. 2 In day watch. If he was removed at 8:30, who 3 is responsibility would it have been to notify 4 upwards? 5 MS. : It would have been 6 any of their responsibility if they were there 7 at the time and they were aware that he was 8 being moved or if they knew that he was even 9 supposed to have a cellie. 10 MR. : So who was the COs on for the 11 SHU? 12 MS. : On -? 13 MR. : Day watch for August 9th. 14 MS. : Day watch on August 15 9th would have been Officer , Officer 16 , and 17 MR. : Okay. And what would - if 18 they knew that Epstein was required to have a 19 cellmate, what should they have done? 20 MS. : If they knew that 21 Epstein required a cellie, and his cellie was 22 released, if they knew he wasn't coming back. 23 I mean I don't know if they knew that when the 24 cellie left that he was never coming back. I 25 don't know what any of these people were told. EFTA00114249 67 1 So I'm just assuming here. If his cellie was 2 released, and they knew for a fact that he 3 wasn't coming back, and if they knew that he 4 was supposed to have a cellie, which I doubt. 5 Because I didn't even know it. So -. 6 MR. : Let's just assume they knew. 7 Let's just go from there. If they knew. 8 MS. : Then one of them 9 should have called. 10 MR. : Called who? 11 MS. : The captain, 12 psychology, the lieutenant's office. One of 13 them. 14 MR. : Okay. And let's just say 15 they called the lieutenant's office. What 16 would the lieutenant's office have done? 17 MS. : They would have 18 followed up. They would have been like okay, 19 if they didn't know already, they would have 20 determined what's the status of this cellmate. 21 What is -? Is he coming back? They probably 22 would have moved Epstein out of that cell or 23 immediately put another inmate in the cell with 24 him. 25 MR. : Okay. EFTA00114250 68 1 MS. : But when you're 2 talking about somebody like Epstein, you can't 3 just put any inmate in that cell with Epstein. 4 So you know, you kind of have to seek guidance 5 on that and tell - let somebody know what you 6 have going on so they can determine who they 7 want in the cell with Epstein. Which is why it 8 goes back to 10 South. That's why he should 9 have been on 10 South because you can't. He's 10 not one of those inmates that you can just put 11 anybody in his cell with him. 12 MR. : Who would you have - seek 13 guidance from? 14 MS. : Me? 15 MR. : Yeah. 16 MS. : As a lieutenant? 17 MR. : To assign - get a new inmate 18 for Epstein. Who do you think? Because you 19 said he's high profile. Who would you have -? 20 MS. 21 the captain -- 22 MR. : Okay. 23 MS. I would have informed -- that you know the 24 cellie that he had had been released and asked 25 him you know how do you want us to move EFTA00114251 69 1 forward? 2 MR. : Okay. 3 MS. : Who do you want the 4 SHU officers to place in that cell with him? 5 MR. : So as per whoever the CO is 6 they should report it to the lieutenant or the 7 captain and they would have brought it up and 8 someone higher up should have assigned a 9 cellmate. 10 11 12 13 14 that he was supposed to have had a cellmate and 15 based upon that email that I just saw for the 16 first time, I'm sure they didn't - in this 17 group here. Or they would have contacted 18 somebody. 19 MR. : Okay. 20 MS. : These guys definitely 21 were not you know 22 , these cats - they wouldn't have ignored 23 that. They would have told somebody. If they 24 knew they would have definitely reported it to 25 somebody. And um -. MS. knew. MR. : Yeah. : The officers if they MS. : If they were aware EFTA00114252 70 1 MR. : How soon should have an 2 inmate been assigned to that cell? Normally, 3 what's the procedure? How soon after would 4 they -? 5 MS. : I say that Epstein 6 should have been on 10 South. 7 MR. : Okay. 8 MS. : So I mean, as quick 9 as possible. 10 MR. : Okay. That's it. 11 MS. : Yeah. As quick as 12 possible. 13 MR. : I'm not going to go through 14 names. You just explained this from the bottom 15 up. We just wanted to clarify. 16 MS. : Okay. 17 MR. : I'm going to move on. Did 18 you conduct on August 9th evening from 10:00 19 p.m. to August 10th the next day? Did you 20 conduct any rounds in the SHU during your 21 shift? 22 MS. : Yes. 23 MR. : What round did you do. Do 24 you recall? What count or rounds did you do in 25 the SHU? EFTA00114253 71 1 MS. : I don't remember what 2 rounds. 3 MR. : Okay. 4 MS. : I think it was 5 probably mid-morning I think. What do you mean 6 by rounds? Do you mean did I conduct my 7 lieutenant rounds? 8 MR. : Yeah. Lieutenant rounds. 9 MS. : Yeah. Yeah. 10 MR. : Mid-morning? 11 MS. : I think it was mid- 12 morning because there was a lot going on that 13 night. 14 MR. : No problem. 15 MS. : So I was running 16 behind. 17 MR. : Let's clarify this 18 because you weren't there mid-morning. 19 MR. : Mid-morning you mean 20 overnight. 21 MS. : Yes. Overnight. 22 MR. : Okay. So when you say 23 mid you mean like 4:00 a.m. on August 10th is 24 what you're saying? 25 MS. : Yeah. Probably. EFTA00114254 72 1 That sounds about right. 2 MR. : Okay. 3 MR. : Now I just have two 4 questions. Why do COs have to conduct rounds? 5 MS. : To make sure that the 6 inmates are safe. That they're still 7 breathing. That there is nothing illegal or 8 unauthorized going on inside the institution. 9 Just to make sure that everything is okay. 10 MR. : Okay. Is it -? Why do COs 11 have to conduct counts? 12 MS. : To account for all 13 the inmates. 14 MR. : Okay. Is it mandatory to 15 conduct counts and rounds? 16 MS. : It's part of your 17 duties. 18 MR. : Okay. Is it policy? 19 MS. : Yes, it's policy. 20 MR. : Okay. And you explained in 21 your previous interview about who is 22 responsible for conducting the rounds. As a 23 supervisor, you mentioned in your previous 24 interview that the supervisor should also 25 conduct one round per -. One count or one EFTA00114255 73 1 round? I mean what are they -? 2 MS. : Each lieutenant is 3 required to make rounds during their shift. 4 Whether that be the operations lieutenant or 5 whether that be the activities lieutenant. 6 Just a lieutenant. It doesn't have to be both. 7 If I'm operations lieutenant and I have an 8 activities lieutenant assigned, both of us 9 don't have to make rounds. The lieutenant - a 10 lieutenant just have to make rounds during each 11 respective shift. 12 MR. : Is there specific units that 13 they have to go to or can it be anything? 14 MS. : I mean if you're 15 making rounds, the idea is to go to each 16 housing unit. 17 MR. : Okay. 18 MS. : Now depending on what 19 you have going on during the night, sometimes 20 you may get that done. Sometimes you don't. I 21 mean there may be a lot going on at the 22 institution that you may not get around to 23 making the rounds done during your shift. 24 MR. : Okay. I want to take a quick 25 detour. I'm going to show you two documents. EFTA00114256 74 1 Can you show me what that is a map of? 2 MS. : I have no idea. 3 MR. : If you don't understand it -- 4 MS. : Yeah, I don't -- 5 MR. then just say it. 6 MS. : -- know what this is. 7 MR. : Okay. No problem. How many 8 tiers are there for the SHU? 9 MS. : I haven't been up 10 there in a while. I'm going to say there is 11 two. There's four tiers. I mean if you're 12 talking about upstairs and downstairs, there's 13 two tiers. 14 MR. : Two tiers. 15 MS. : Mm-hmm. And then you 16 have 10 South. And then you have Lower 10 17 South. So. If you count each individual tier, 18 I guess you would say five tiers. Because you 19 got Lower 10 South up there as well. 20 MR. : Okay. Five tiers. 21 MS. : Mm-hmm. 22 MS. : Thank you. I'm going 23 to move on. I'm going to show you a document. 24 Can you tell me what that is? 25 MS. : This is the E-1. EFTA00114257 75 1 MR. : What's an E-1? 2 MS. : The E-1 is a 3 computation of all the housing units. Well it 4 includes all the housing units and how many 5 inmates they have on their unit at the time in 6 which this is actually printed. 7 MR. : What time is that for? 8 MS. : It says August 10, 9 2019 at 12:35 -- 10 MR. : 12:35. And can you -? 11 MS. : -- a.m. 12 MR. : Can you find the count for 13 the SHU in there? You can flip through it. 14 You can -. 15 MS. : Yeah. It's -. 16 MR. : What units are they reflected 17 by? What do they call the units on the 18 document? Are they referred to as the SHU? Or 19 are they referred to by a different name? 20 MS. : They're referred to 21 by alphabets. 22 MR. : What alphabets? 23 MS. : For special housing 24 unit, it would be ZA. And their count is - at 25 this time - on August 10, 2019 at 0035, it was EFTA00114258 76 1 72. 2 MR. : If you flip through it, it 3 will tell you there might be more documents. 4 Keep going. It'll tell you who did the counts. 5 Do you recall who -? Based on the document, 6 can you tell me who did the count for the SHU? 7 Which SHU unit - ZA or ZB - was Epstein housed 8 in? 9 MS. : Epstein was in ZA. 10 MR. : ZA. And who did the count at 11 midnight? 12 MS. : There was an issue 13 with the count at midnight. 14 MR. : What was the issue? 15 MS. : There was an inmate 16 that they had removed from the unit and he was 17 on - he was being housed in the receiving and 18 discharge in one of the holding cells in R&D on 19 the third floor. And -. 20 MR. : Do you recall if that was 21 Inmate Fernandez? 22 MS. : I don't know what. 23 MR. : Okay. 24 MS. : I don't remember what 25 his name was. EFTA00114259 77 1 MR. : Okay. 2 MS. : But they were for 3 some reason I want to say. I don't know if 4 he was on dry cell or what his status was. 5 MR. : Was -? 6 MS. : I don't think he was 7 on suicide watch. I can't remember. 8 MR. : You said dry cell. Now dry 9 cell. Is that in R&D? 10 MS. : No. That's not in 11 R&D. Usually dry cell is done in the special 12 housing unit. So I can't remember what his 13 status was but he was I can't remember if 14 he was on dry cell or if he was on - if that 15 was an extension of the suicide watch. I can't 16 remember, but there was an inmate down there. 17 And he was being housed down there with the 18 watch on that particular night. And they were 19 counting him on the unit because they hadn't 20 received any guidance as to how he was going to 21 be counted. Because R&D, mind you, is the 22 intake unit. It's not a housing unit. 23 MR. : Okay. 24 MS. : So inmates are 25 theoretically are not supposed to be staying - EFTA00114260 78 1 spending the night down there. 2 MR. : So R&D. So they do mainly 3 intake you said. Right? 4 MS. : That's what they do. 5 Yeah. 6 MR. : If they move an inmate to R&D 7 what would it be for? Are they leaving the 8 (Indiscernible *01:14:14)? 9 MS. : Yeah because they're 10 leaving or they're going to court or something 11 like that. 12 MR. : On that sheet, what would you 13 identify the area - the unit - as for R&D on 14 there? 15 MS. : RA. 16 MR. : RA? 17 MS. : Yes. 18 MR. : Okay. Now based on that, you 19 said there was an issue with it. 20 MS. : Right. Because if 21 you have an inmate in RA, then it's going to 22 interfere with the special housing unit count. 23 If this inmate that's here on RA is from 24 special housing. Okay. 25 MR. : Yeah. EFTA00114261 79 1 MS. : When this - um. 2 Their count was originally 73. But then you 3 have an inmate in RA from special housing. 4 MR. : Okay. 5 MS. : So that would bring 6 it down to 72 because this inmate -. This is 7 an outcount. You do an outcount when an inmate 8 is in a different area than where he is housed. 9 Okay. 10 MR. : Okay. 11 MS. : And you can't have 73 12 inmates. If 73 is your base, if you've got an 13 inmate from that area on outcount, then that's 14 not a good count. 15 MR. : Right. So the count. So 16 let's get it right. According to the records, 17 how many inmates should have been at the 12:00 18 p.m. count. How many inmates should have been 19 in the SHU? 20 MR. : 12:00 a.m. 21 MR. : 12:00 a.m. Sorry. 22 MS. : Well that depends 23 because when they initially did this, that's 24 how they was counting the inmates. It wasn't 25 until I started doing that count that I EFTA00114262 80 1 realized that something wasn't right. So 2 that's how we got around to there's an inmate 3 in R&D. You know that's being housed down 4 there on watch. You know. That's how we got to 5 that. So it's like oh, so there's an inmate in 6 R&D. You know. And then you start asking 7 questions. Why is he there? What's the deal 8 with him? Because none of this information was 9 passed down. 10 MR. : Okay. 11 MS. : So I've got to ask 12 the staff what's going on. 13 MR. : I'm going to clarify. I'm 14 going to go back. My question is at midnight, 15 who did the count for the SHU? 16 MS. : According to this, it 17 says Thomas and Noel. 18 MR. : Alright. If they did the 19 count and how many people are supposed to do 20 the count? 21 MS. : Two. At least two. 22 MR. : Two. If they went through 23 the SHU and they did a head count, right. How 24 many people should they have down? 25 MS. : They should have EFTA00114263 81 1 gotten 72. But what I'm telling you is when 2 this count was done, they were counting this 3 inmate that was in R&D on that count because no 4 one had told them that the inmate was actually 5 somewhere else. And he was being counted in 6 that area. So they were logging -. So what I 7 understand - and that's how they understood it. 8 That that inmate was being carried on to their 9 count. 10 MR. : Even though they didn't get 11 eyes on the inmate? Even though they don't 12 know physically. If they physically cannot see 13 the inmate, they're allowed to put it in their 14 count? 15 MS. : Because the inmate is 16 being ghosted. They could call R&D and ask and 17 say he is the inmate there. Because there was 18 a staff member on the inmate. The problem was 19 not how many inmates they had or what's 20 counted. The problem was the status of this 21 inmate that was in R&D. 22 MR. : Okay. 23 MS. : They didn't' know the 24 status of the inmate in R&D whether he was 25 going to be -. Whether he was staying there EFTA00114264 82 1 altogether or how they were supposed to 2 indicate him on their count slip. They didn't 3 know any of that. That wasn't until they 4 brought this to my attention. And this was the 5 original count slip. There was another count 6 slip that they supposed to have been 7 completing. And place that in the Sally port, 8 but apparently nobody picked it up. So this 9 was the original count slip that was submitted. 10 MR. : Okay. 11 MS. : But they were 12 supposed to -. Once we corrected this issue, 13 with the dude in - with the guy in R&D and put 14 him on an outcount. And place him in R&D, then 15 they were supposed to go back, recount. They 16 were supposed to recount and then they was to 17 submit another count slip. 18 MR. : Okay. That's what I'm 19 getting to. 20 MS. : Yes. 21 MR. : So who found out that there 22 was an error with the count? Did they notify 23 you or did you found -? 24 MS. : Right. Right. When 25 they called. I think we kind of hashed it out EFTA00114265 83 1 together. 2 MR. : Okay. 3 MS. : You know because they 4 were saying that they had an inmate that was 5 not on the unit. And they was like well what 6 do we do? 7 MR. : Okay. 8 MS. : Because I guess -. I 9 don't know what had happened, but they knew 10 that the guy wasn't on the unit. So they was 11 trying to get it corrected. 12 MR. : Okay. 13 MS. : And of course we 14 started asking questions. Where is this inmate 15 at? What is he doing there? How long he's 16 been there. Dah-dah-dah-dah. But again, this 17 is count time. So you've just got to do the 18 best you can because we've got a count to 19 clear. You know. 20 MR. : Do you recall. Sorry. You 21 had a question. 22 MR. : I just want to make sure 23 that we're clear. So did they call in 73 24 without saying this is 73 with a guy that's not 25 actually here. Or did they just call in 73 and EFTA00114266 84 1 2 3 4 someone said how is this 73 if you guys only have 72? MS. : They called saying that their count was you know that they had the 5 count issue was 73. But they had an inmate 6 that had been removed that had been taken off 7 the unit and was taken to R&D. 8 MR. : Okay. So they knew that 9 when they called in the count? It wasn't like 10 -- 11 MS. : I mean -- 12 MR. : -- they said -- 13 14 MS. calling -. : -- they weren't 15 MR. : -- hey we've got 73 and - 16 - 17 MS. : No-no-no-no-no. 18 19 MR. : you have 73 for -- -- someone said how do 20 MS. : No. 21 22 MR. : there? -- someone that's not 23 MS. : No-no-no-no-no. When 24 they called in the count, they was like I have 25 73 but one of the inmates up here is in R&D. EFTA00114267 85 1 MR. : So they knew that there 2 was only 72 in SHU at the time. They made note 3 of the fact 4 MS. : Right because -. 5 MR. : I'm calling in 73 6 because that's what our numbers are supposed to 7 be, but one guy is not here. 8 MS. : And they didn't know 9 the status of that inmate. 10 MR. : Sure. 11 MS. : They didn't know -. 12 MR. : So it wasn't like after- 13 the-fact. Like somebody like you're saying -. 14 MS. : Like I caught them? 15 MR. : Yeah. Like wait, how are 16 you calling 73 -- 17 MS. : No. 18 MR. if one guy's not here. 19 MS. : No. No-no-no-no-no. 20 They -. 21 MR. : So they brought it to 22 your guys' attention rather than the other way 23 around? 24 MS. : And I said so how 25 many bodies do you have on the unit? And he EFTA00114268 86 1 said I have 72. 2 MR. : So that's a good answer. 3 So he - so Thomas is the one who called that 4 count? Rather than Noel? 5 MS. : I think it was 6 Thomas. I don't think I spoke to Noel about 7 the count. 8 MR. : So you don't remember 9 specifically though. But you -- 10 MS. : I think it was 11 Thomas. 12 MR. : -- believe it was Thomas. 13 MS. : It was a guy. 14 MR. : Okay. 15 MS. : And I said well how 16 many inmates do you have on your unit right 17 now? How many bodies? And he said 72. And I 18 said well let me call because I need to call 19 and make sure that this other body is where 20 it's supposed to be. I need to see this body. 21 I need to make sure somebody -. I need to know 22 what's going on with this body. Is a person 23 sitting on it? Is this guy somewhere in a room 24 by himself? 25 MR. : Okay. And you EFTA00114269 87 1 specifically recall that? 2 MS. : I told - and I said 3 go back. Go back around. Do another count. 4 And then send me a new count slip. 5 MR. : That says 72 versus 73? 6 MS. : That says 72. Yes. 7 MR. : So you instructed them to do 8 a recount. 9 MS. : Right. 10 MR. : Do you know if they did the 11 recount? 12 MS. : I don't know if they 13 did a recount because like I said -- 14 MR. : Okay. 15 MS. : I was in the 16 process. I had to continue with the count. I 17 had to verify and get some information 18 regarding this inmate in R&D. But I have no 19 reason to disbelieve that they didn't do the 20 count. 21 MR. : Now what if they -? If 22 they already knew there was 72 and one guy, 23 would they be required to actually do a new 24 count? Or just fill out a new count slip? 25 MS. : I told them to do a EFTA00114270 88 1 new count. Just to make sure. 2 MR. : So you told them to 3 actually do a new count? 4 MS. : Yeah. I told them to 5 do a new count. 6 MR. : And they were 7 instructions you provided to Thomas - or a 8 male. You don't know specifically if it was a 9 males voice? 10 MS. : Right. 11 MR. : Okay. 12 MS. : Right. But yeah, I 13 said, you know, what did you all count. He 14 said we counted 72. And I was like well you 15 know, count again. And then send me - redo 16 your count slip and just send me another count 17 slip. Because I'm going to - while I verify 18 this other information. 19 MR. : Okay. And the fact that 20 there's only the two people in the SHU - Thomas 21 and Noel - you believe it to have been Thomas. 22 MS. : Right. 23 MR. : Okay. 24 MS. : And to be honest with 25 you, I'm giving myself some time so that I can EFTA00114271 89 1 figure out whether or not -. I want to know 2 whether or not this guy is actually in SHU. 3 MR. : Sure. 4 MS. : Or um, in R&D. So 5 I'm like you know just count again and make 6 sure just in case. I'm saying to myself. I'm 7 not saying this to him. I'm thinking to 8 myself, just in case, I called. And there's 9 nobody down there. I wanted to make sure that 10 this is actually the count. 11 MR. : Sure. 12 MS. : There. 13 MR. : And I want to make sure 14 so that something else is clear. When you as a 15 lieutenant are conducting rounds, that you're 16 required once per shift, that's rounds for 17 employees. Not conducting rounds with the COs 18 for inmates. So is your round to go around to 19 your employees to make sure? That's your 20 round? As opposed to participating in a count 21 or a round with the COs conducting of inmates? 22 Do you follow 23 MS. : We're not -. 24 MR. : -- what I'm asking? 25 MS. : We are not required EFTA00114272 90 1 to go to each individual cell and look at the 2 inmates. When we make rounds, we get with the 3 officers. We make sure that -. I mean if we 4 choose to do that we can. But -. 5 MR. : But there's no 6 requirement. For your requirement, that one 7 per shift of round. That's to do rounds with 8 your officer - or with your staff - as opposed 9 to conducting a round with them. 10 MS. : No. There was 11 nothing here said to us or in policy telling us 12 that we needed to go around -- 13 MR. : Sure. 14 MS. : -- on each housing 15 unit to each individual cell and check on the 16 inmates. If we chose to do that based upon 17 something that we knew wasn't right or 18 something that we had heard or something like 19 that during the course of our shift. Then that 20 - and we felt as though we needed to double 21 check on it. Because our officers are our eyes 22 and ears. And during that time, we didn't' 23 have a whole lot of time. We would spend half 24 of our shift just trying to fill overtime. At 25 that time. EFTA00114273 91 1 MR. : So are you supposed to 2 though? So if they do a count, are you 3 supposed to do a count with them during your 4 shift? 5 MS. : I can't remember at 6 that time if we were required to do at least 7 one count because one count per shift is what 8 we're required to do as a lieutenant. 9 MR. : One count with inmates? 10 MS. : No. One count in the 11 control center. 12 MR. : Okay. So you -. You're 13 not putting You're never putting your eyes 14 on the inmates doing a count with -. For 15 instance, in this case, if Noel and Thomas are 16 in the SHU, they're doing a 12:00 a.m. count, a 17 3:00 a.m. count, and a 5:00 a.m. count. Are 18 you doing any counts with them? 19 MS. : No I'm not doing any. 20 MR. : Okay. 21 MS. : I'm not - and it 22 wouldn't be for just SHU. It would be for any 23 housing unit. 24 MR. : Sure. 25 MS. : Period. But -. EFTA00114274 92 1 MR. : But for this instance, 2 specifically, I'm talking about the 12:00 a.m. 3 count, a 3:00 a.m. count, and a 5:00 a.m. 4 count. Is there any requirement for any 5 lieutenants that are in that you have oversight 6 over the SHU to do a count with them? 7 MS. : No. 8 MR. : No. 9 MS. : No. 10 MR. : And there wasn't at that 11 time? 12 MS. : No. 13 MR. : And you hadn't done one 14 at that time with them? 15 MS. : No. 16 MR. : So your requirements are 17 geared toward staff members not toward inmates? 18 MS. : Our -. 19 MR. : Because you're an officer 20 -. You're responsible for the staff. The 21 staff are responsible for the inmates. 22 Correct? 23 MS. : As a lieutenant, we 24 are required to do one count per shift in the 25 control center. We're required to take one EFTA00114275 93 1 count. 2 MR. : Sure. And this is the 3 one you did. You did the 12:00 a.m.? 4 MS. : This is the one count 5 6 MR. : And this is why you 7 reviewed it and said, I've got the get this 8 thing right. 9 MS. : Well during the 10 course of taking this count, that came up. 11 MR. : Okay. 12 MS. : And of course we had 13 to address it because we can't house the count 14 saying one thing in some area and it's not 15 adding up. I can't have an 16 MR. : So are they -- 17 MS. : -- inmate -. 18 MR. : -- calling you that day 19 then. So Thomas is calling you and providing 20 your count and that's the count that you did? 21 MS. : That's the I was 22 taking this count 23 MR. : So he didn't call control 24 - or he called control, but you were the person 25 he spoke with. EFTA00114276 94 1 MS. : Right. 2 MR. Gotcha. 3 MS. : Right. Right. 4 MR. : Do you recall that night, did 5 you participate in the 10:00 p.m. count? 6 MS. : Did I do what? 7 MR. : Did you participate - were 8 you there when the 10:00 p.m. count happened? 9 MS. : No. Hm-mm. 10 MR. : So you came on shift after? 11 MS. : I don't know if I 12 probably was here doing -- 13 MR. : But not participating. 14 MS. : -- the 10:00 p.m. 15 count. Yeah. But I didn't take the 10:00 p.m. 16 count. 17 MR. : Question. Do you know when 18 that inmate was removed to R&D? What time? 19 MS. : I have no idea. I 20 have no idea. That was done prior to me 21 getting there. 22 MR. : Now let's say the inmate was 23 removed prior to the 10:00 p.m. count. Would 24 the 10:00 p.m. count have been wrong? If they 25 reported? EFTA00114277 95 1 MS. : I have no - I can't 2 answer that. I don't know. 3 MR. : No-no. But you fixed it. 4 They called you, they asked for the -. Let me 5 show you the 10 - two more documents. Let's do 6 -. Take a look at this document. What is 7 that? 8 MS. : This is the E-1 for 9 August 9, 2019 at 9:33. 10 MS. : Okay. And what's the 11 count for the SHU at that point? 12 MS. : It's 73. 13 MR. : 73? 14 MS. : Mm-hmm. 15 MR. : And what's the count for RA? 16 RA being the R&D? 17 MS. : It's saying zero. 18 MR. : Okay. If the inmate was 19 moved prior to this count, to R&D, would 20 technically the count for the SHU have been 21 wrong? 22 MS. : That depends on what 23 the officers were told because like I said, RA 24 is not a housing unit. So no officer would 25 have been moving an inmate to RA on their own. EFTA00114278 96 1 Something -. 2 MR. : Okay. 3 MS. : There had to have 4 been some guidance that - whereby they was told 5 because this inmate was there all night with a 6 watch on him. 7 MR. : Which inmate? The one in 8 R&D? 9 MS. : The inmate that was 10 taken to -- 11 MR. : R&D? 12 MS. : R&D. Yes. The 13 inmate had a watch. There was a staff member 14 on the inmate. You can't -- 15 MR. : What was the watch for? 16 MS. : -- just put an inmate 17 in R&D and just leave him there. There's 18 nobody to watch him. R&D staff leaves at 19 10:00. So you can't just leave an inmate there 20 with nobody watching him. 21 MR. : So Maybe I'm saying this 22 wrong. I'm just trying to get clarification. 23 When you do - when a CO does a count - can they 24 account - but in the count - can they account 25 for an inmate that they do not get their eyes EFTA00114279 97 1 on? 2 MS. : Depending on who gave 3 them the instruction as to how that inmate was 4 going to be accounted for. 5 MR. : What about? 6 MS. : If that - say - if 7 that. If that inmate was in R&D at the 10:00 8 count, depending on how they were guided 9 because I mean they know that an inmate can't 10 be in R&D by himself either. So depending on 11 how that inmate was being counted, they may 12 have been given instructions by somebody to 13 ghost him. And count him in SHU. I don't 14 know. I can't explain that. 15 MR. : So COs have the ability it's 16 not per policy, COs have the ability to do 17 that? 18 MR. : To do what? 19 MR. : If they don't have eyes on, 20 if they can get instructions from another 21 person saying no, report it as your count? 22 MS. : That would have to be 23 someone in their chain of command that would 24 advise them to do that. 25 MR. : Who? Do you know? EFTA00114280 98 1 MS. : It would be someone 2 over the lieutenant's head because no 3 lieutenant is going to - that I knew at the 4 time - that I worked with at the time - would 5 have an inmate in a different area knowing that 6 inmate was not going to be coming back to that 7 housing unit. 8 MR. : So the key right now is we 9 don't know when the inmate was moved. Right? 10 MS. : I don't know when. I 11 can't tell you when the inmate was moved. This 12 happened before I got there. What specific 13 time he was moved, I don't know. 14 MR. : Let's say the inmate was 15 moved and they didn't' get the authorization 16 from the captain. Would the account have been 17 wrong? 18 MS. : I don't -. You know 19 as far as I know, it could have been someone 20 above the captain. I don't know. I can't 21 provide you with an adequate answer because -- 22 MR. : No problem. 23 MS. : I don't 24 MR. : We're going to go past that. 25 MS. : Okay. EFTA00114281 99 1 MR. : So I'm going to show you. 2 This is just for clarification purposes, just 3 for our records. I'm going to show you one 4 more document. What is F? 5 MS. : This is an E-1 for 6 August 9, 2019. The time is1541. 7 MR. : Okay. And that should be the 8 4:00 p.m. count? 9 MS. : Yes. This would have 10 been for the 4:00 count. 11 MR. : What is the lineup on top? 12 It says A-T-T-Y. What is that? 13 MS. : What? 14 MR. : Up here. Up here it says A- 15 T-T-Y. 16 MS. : Oh, that's attorney 17 conference. 18 MR. : Okay. And what is outcount? 19 On - towards the right. Over here. 20 MS. : Well.... 21 MR. : This one right here. 22 MS. : The outcount is the 23 This is for that section that you're 24 pointing to. That would be the number of 25 inmates that axe not in their respective EFTA00114282 100 1 housing units from these areas - the different 2 areas that are designated here. 3 MR. : Is it possibly because 4 they're leaving? 5 MS. : From the different 6 housing -. I have -. It could be a number of 7 things. 8 MR. : Okay. At 4:00 p.m. what was 9 the count in the SHU? 10 MS. : Um, 75. 11 MR. : 75? 12 MS. : Yes. 13 MR. : Okay. And what is the count 14 for RA? 15 MS. : Zero. 16 MR. : Okay. So that's R&D. 17 There's nobody there. Where is - according to 18 that if you flip through it. Where is Epstein 19 at that point? 20 MS. : It looks like he's in 21 attorney conference. 22 MR. : Okay. No problem. We're 23 going to keep going. 24 MS. : Okay. 25 MR. : Um.... On August 10th. EFTA00114283 101 1 2 3 4 Right. When did you go to the SHU? MS. : Like I said earlier, I think it was MR. : Can you do me a favor? Can 5 you sign it and date it just like before? 6 MR. : Initial and date on the 7 top. 8 MR. : Initial. 9 MS. : Which one? 10 MR. : All of them. 11 MR. : Oh. Since I showed you. 12 MS. : Okay. 13 MR. : I'll take that. When did you 14 -? Did you make a round into the SHU on August 15 10th? 16 MS. : Yes. 17 MR. : What time? 18 MS. : I don't remember what 19 time. It was like halfway between my shift 20 later on in the morning. 21 MR. : Did you speak to -? 22 MS. : Probably about 4:-- 23 something. Between 4:00 and 5:00 I guess. 24 MR. : Do you recall who the COs 25 were on duty? EFTA00114284 102 1 MS. : Yes. Thomas and 2 Noel. 3 MR. : Okay. Did you speak to them? 4 MS. : Yes. 5 MR. : Okay. And everything was 6 good? Did they say have any complaints or 7 anything like that? 8 MS. : No. They were fine. 9 MR. : Do you recall your 10 conversation at all? 11 MS. : I don't recall my 12 conversation with them, but I spoke to them for 13 a minute because I stopped there. I went up to 14 10 South and I made my rounds up there. And I 15 came back and I spoke with them again before I 16 left. 17 MR. : So you spoke with them 18 twice? 19 MS. : Yeah. I spoke with 20 them initially. And I told them you know when 21 I get back out -. I'm going to run up to 10 22 South and make my rounds and sign my books and 23 stuff up there. And then I'll get back with 24 you guys. I'll come back on my way down. 25 Because I needed to sign their round sheets. EFTA00114285 103 1 MR. : Okay. 2 MR. : Now you mentioned that you 3 don't know - you never heard of the requirement 4 for Epstein needing a cellmate. Right? 5 MS. : Right. 6 MR. : So you didn't know. 7 According to what you said before, you didn't 8 even know the COs knew that requirement. 9 MS. : If I didn't know, I 10 know they didn't know. And according to that 11 because I don't even see Where is that 12 email? Because I want to see who did they 13 actually send that to. If it says on the email 14 who they sent that to. 15 MR. : It looks like they sent 16 it up to all the officers, lieutenants and. 17 MS. : This says suicide 18 watch/psych observation update. 19 MR. : So on or around July 20 30th, Epstein came off of the suicide 21 observation and was placed back into the SHU. 22 And this was supposed to be the email saying 23 that he was required to have a cellmate while 24 he was in the SHU. 25 MS. : Yeah, but this isn't EFTA00114286 104 1 MYM all. 2 MR. : Right. So you said you 3 think it should have gone to all staff. 4 MS. : Yeah-yeah. 5 MR. : So I guess what I'm 6 MS. : This is only 7 addressed to suicide - whoever is in that 8 group. It looks like a group that they made 9 up. Because I never heard of that group 10 before. Suicide watch/psych -. 11 MR. 12 them? 13 MR. 14 MS. You never got the email from : Sure. So -. : Slash psych 15 observation update. I guess that's a group. 16 MR. : So these are the -. So 17 the one - pages one through three. These are 18 the people that they I guess placed in that -- 19 MS. : That they placed in 20 that group. 21 MR. -: group. And it looks 22 like it's all the lieutenants and the officers 23 in the institution as opposed to the COs 24 themselves. 25 MS. : You mean specific EFTA00114287 105 1 officers? Specific staff? Because I can 2 assure you that's not all of them. 3 MR. : That's not all of them. 4 Yeah. So I don't know how they actually chose 5 it. But you said you know you were on it but 6 you don't recall receiving it. 7 MS. 8 receiving that. 9 MR. : I do not recall : Now do you know -? I 10 don't know how it works here. I mean are you 11 in front of your computer? Do you read your 12 emails? How is that? 13 MS. : During that time, I 14 will be honest with you. I didn't have time to 15 read any emails because in addition to not 16 having a lot of staff, we had a bunch of 17 incidents that were going on during that time 18 as well. 19 MR. : Okay. 20 MS. : A bunch of body 21 alarms and stuff like that that was going on. 22 And because of the fact that we were so short- 23 handed, you didn't have time to read emails and 24 stuff at the time. You just had too much to do 25 with the time in your shift. It was just way EFTA00114288 106 1 too much. 2 MR. : Sure. 3 MS. : It was way too much. 4 MR. : So although this was sent 5 to you, you don't think you probably even 6 clicked on it? 7 MS. : I got a lot of emails 8 during that time that I can assure you I didn't 9 read. 10 MR. : Sure. Alright. So you 11 were unaware. How does it work -? Just can 12 you walk me through specifically on you know if 13 Reyes the cellie. Did you know that Epstein 14 had a ceilmate? 15 MS. : I didn't know Epstein 16 had a ceilmate. 17 MR. : So you didn't even know 18 he had a cellmate at all? 19 MS. : I didn't know if he 20 had a cellmate or not. 21 MR. : Okay. 22 MS. : When all of this 23 happened, it of course later came out that he 24 had a cellmate and the inmate was removed. But 25 as far as me having personal knowledge of EFTA00114289 107 1 whether or not he had a cellmate, I didn't know 2 if he had a cellmate or not. I assumed he had 3 a cellmate. 4 MR. : Now being that you know 5 they sent this email. You said who should have 6 advised you at least at some point, hey he 7 needs a cellmate. Where was the communication 8 breakdown there? 9 MS. : It wasn't just me. 10 It should have been everybody. 11 MR. : Sure. So what my question 12 is though, who is responsible for that? 13 MS. : The - you would think 14 that psychology would have called us or 15 somebody should have been making sure. 16 MR. : Okay. So let's go 17 through that. From psychology, who should 18 who dropped the ball here? 19 MS. : Well I'm not going to 20 say anybody dropped the ball because it's all 21 about responsibilities to -. 22 MR. : But somebody - psychology 23 I guess made the note. So is it the person 24 that's on the email, this 25 (Phonetic Sp. *01:39:47) Should have she gone EFTA00114290 108 1 around and aside from sending this email should 2 have she spoken to people or had a meeting? 3 What should have happened? 4 MS. : I mean if that's what 5 she -. I just feel as though they that - to 6 communicate Like I said originally. My 7 whole thing was Epstein should have been placed 8 on 10 South to begin with because he was that 9 type of inmate that checked all the boxes for - 10 - 11 MR. : Sure. 12 MS. : -- someone that 13 should have been placed on 10 South. 14 MR. : And that's going to be 15 one of my follow-up questions is what the 16 difference between the SHU and 10 South. But 17 specifically to this, like what should have 18 psychology done differently? 19 MS. : I would have made 20 sure - I just would have -. I just would have 21 made sure that everybody -. I never even would 22 have sent Epstein back to -. I would have 23 never even put him back in that position again. 24 MR. : So if he had -. 25 MS. : If he had a cellmate EFTA00114291 109 1 because even saying that he had a cellmate. 2 Even telling somebody that he should have had a 3 cellmate. Still wouldn't have prevented him 4 from trying to harm himself. We had just went 5 through that. 6 MR. : Sure. 7 MS. : We - that was a 8 scenario when they got him. That got to the 9 memo being done. 10 MR. : Okay. So -. 11 MS. : You know? He had a 12 cellmate then. 13 MR. : The other lieutenants 14 though in this case, they knew that he was 15 required to have a cellmate. Correct? 16 According to -- 17 MR. : Yes. 18 MR. : -- there? So it sounds - 19 From reviewing the other interviews, it 20 looks like you were the one that didn't know. 21 everyone else knew. Do you know why that would 22 have been? Who should have made sure you knew 23 that he needed a cellmate? 24 MS. : I would think whoever 25 knew that he needed an inmate. EFTA00114292 110 1 MR. : So that's what I'm 2 saying. Everyone else know. So like all the 3 other lieutenants and the captain. They all 4 said that they were aware that he was required 5 to have a cellmate. So the question So I 6 don't know if they got the information from the 7 email, if there was an all-hands. Who should 8 have made sure that you knew that he had a 9 cellmate? 10 MS. : Okay. So if they 11 knew that. If everybody is saying that they 12 knew he should have had a cellmate, then why 13 didn't he have one? 14 MR. : That's the -. 15 MS. : How did we get to 16 that? 17 MR. : That's the reason why 18 we're talking with you. That is the big issue 19 of why didn't he have one? Who? Where was the 20 communication breakdown? 21 MS. : I don't know. 22 MR. : So should have the 23 captain told you that? Should have the person 24 who relieved you that day? Should have that 25 person told you? Hey just so you know, Epstein EFTA00114293 111 1 doesn't have a cellmate. 2 MS. : It would have been 3 nice to have when I got relieved for someone to 4 have said yeah, by the way, we got this email 5 saying that we were notified the Epstein now 6 requires to have a cellmate. Yeah. That would 7 have been real helpful. 8 MR. : So looking at the Friday, 9 August 9th. Was it -? It looks like 10 Was that the person who relieved you? As the 11 ops lieutenant? It looks like he was the ops 12 lieutenant. 13 MS. : You relieved him. 14 MS. : Yeah. I would have 15 16 MR. : No. She relieved him. 17 It was August 9th. 18 MS. : Yeah. That would 19 have been who I would have relieved. 20 MR. : Or he would have relieved 21 you. Correct? Because that's August 9th. You 22 started August 10th at 12:00 a.m. So let's see 23 how it shows here. 24 MS. : I would have relieved 25 because was evening watch. EFTA00114294 112 1 MR. : But this was August 9th. 2 And you started August 10th, 12:00 a.m. 3 MS. : Right. So that would 4 have bene evening watch of -. 5 MR. : You would have relieved 6 him. Correct. 7 MS. : Right. I would have 8 relieved him. 9 MR. : And so should have he 10 told you? 11 MS. : I would - I mean -. 12 MR. : How would then -? Or 13 should have -? would have been gone. 14 So I'm assuming he would have been the one? 15 MS. : Let me tell you 16 something. In the real world in a real 17 institution that was running in the manner in 18 which it should. 19 MR. : Sure. 20 MS. : Sure. That would 21 have 22 MR. : And you're not saying -- 23 MS. occurred. 24 MR. that he did anything 25 wrong. EFTA00114295 113 1 MS. : And I'm not -. 2 MR. : Let's get this place up 3 to running as best as possible. 4 MS. : No. Let me -. 5 MR. : Where should have this 6 communication occurred? 7 MS. : Let's make something 8 clear right now. 9 MR. : Yeah. 10 MS. : I'm not here to cover 11 for anybody. 12 MR. : Yeah-yeah-yeah. 13 MS. : I'm not here to make 14 excuses for anybody or any of that. 15 MR. : Right. 16 MS. : What I'm trying to 17 get over to you is that at that particular time 18 when - even before 19 MR. : Mm-hmm. 20 MS. : Um....this incident 21 happened with Epstein. Even before the 22 suicide. We were so busy with a number of 23 different things. 24 MR. : Sure. 25 MS. : We were here when we EFTA00114296 114 1 were finding shanks every - an unusual amount 2 of shanks, cell phones, drugs. Inmates were 3 going out of their mind on drugs and all this 4 other stuff. We had inmates fighting, inmates 5 getting stabbed, inmates getting slashed. 6 There were -. In addition to everything else 7 that we had to take care of. We were doing 8 uses of forces. We didn't' have adequate staff 9 to even do a use of force or even to respond to 10 a body alarm a lot of times. There were 11 incidents where we as lieutenants were the only 12 people here and had to do things. So -. 13 MR. : So there's just 14 overwhelming You guys were just completely 15 overwhelmed. In the weeds. 16 MS. : We -. At that time, 17 there was just so much going on. 18 MR. : Right. 19 MS. : You would be hell- 20 bent to stay abreast of every little thing that 21 was going on. You just -. When your relief 22 came, you know, you was like let me get some 23 fresh air. 24 MR. : Just let me -. In this 25 circumstance. We're going to try to reign it EFTA00114297 115 1 in specifically to -. 2 MS. : If everything was 3 going fine -- 4 MR. : So how -. 5 MS. : -- and on a good day. 6 Yes. 7 MR. : Say he was - Reyes - 8 Epstein's inmate was released you know sometime 9 between 8:00 and 2:00. So I'm assuming the way 10 it should have worked is the CO should have 11 notified a lieutenant. The lieutenant maybe 12 should have notified the ops lieutenant. The 13 ops lieutenant should have notified the 14 captain. Is that the way it should have worked 15 in a perfect world? 16 MS. : It depends on who is 17 here. 18 MR. : But should -. So -- 19 MS. : I'm saying that's -- 20 MR. that's why we're 21 looking at the 9th. 22 MS. : -- what I would have 23 done. 24 MR. : Right. 25 MS. : I can't tell you what EFTA00114298 116 1 somebody -- 2 MR. : Because - but would that 3 -- 4 MS. : -- else would have 5 done. 6 MR. : -- be standard operating 7 procedure? That's the way it works? 8 MS. : That's not standing. 9 That's just what I would have done. 10 MR. : Okay. 11 MS. : Just to make sure 12 that -. 13 MR. : So let's say -. 14 MS. : Just to answer the 15 questions that I would have had regarding that. 16 MR. : So -. 17 MS. : I can't explain -. I 18 can't tell you what somebody else would have 19 done. 20 MR. : So let's say -- 21 MS. : Or should have done. 22 MR. for instance. 23 He was on the looks like 8:00 to 2:00 p.m. 24 Let's say he knew that Reyes was gone and 25 Epstein was required to have a cellmate. What EFTA00114299 117 1 should have he done? Should have he notified 2 and should have he notified 3 MS. used to -. If 4 he wasn't at that time, used to be the 5 SHU lieutenant. So probably would have 6 told them put somebody else in the cell with 7 him. 8 MR. : Okay. 9 MS. : You know? 10 MR. : So you think he would 11 have just taken immediate action? 12 MS. : I think he probably 13 would have said just put somebody in the cell 14 with him and call and say hey this dude 15 don't have a cellie. I took care of it or 16 whatever. 17 MR. : Now what about if -- 18 MS. : Or maybe he -. 19 MR. the executive staff 20 wants to have a hand in picking and choosing 21 who it is that Epstein is assigned to because 22 of his high-profile status? Should have 23 still done that temporarily? Or should have 24 just notified 25 MS. : That is - that wasn't EFTA00114300 118 1 written in stone. 2 MR. : Okay. 3 MS. : That is something 4 that I would have done. 5 MR. : You would have done what? 6 MS. : I would - that's 7 something that I would have done. 8 MR. : Was that temporarily? 9 MS. : I'm not saying that 10 that's across the board that every operations 11 lieutenant that was here that day and was that 12 found themselves in that position. I'm not 13 going to say that's what -. There's no 14 standard procedure for that situation because 15 that's out of the ordinary. First of all, if 16 we're going to go by what should have been 17 done, Epstein should have been on 10 South. 18 That's what should have been done. 19 MR. : Okay. 20 MS. : Period. 21 MR. : And what -? 22 MS. : Now everything when - 23 . 24 MR. : So you keep on going back 25 to 10 South. EFTA00114301 119 1 MS. : Right because -- 2 MR. : What the difference 3 between -- 4 MS. : -- that's how -- 5 MR. 10 South -? 6 MS. : -- important it is. 7 MR. : So what's the difference 8 between 10 South and the SHU? 9 MS. : The difference 10 between SHU is that SHU is for general 11 population inmates. 12 MR. : Okay. 13 MS. : You know. You're not 14 guaranteed to have a cellie there. You know. 15 So you may have a cellie and you may not. 16 Epstein was a high-profile inmate. All high- 17 profile inmates they usually assign to 10 18 South. Epstein had just -. Even before he 19 committed suicide. Everybody knew and that's 20 not just here. That's people in the region. 21 You know all the way up to Donald Trump knew 22 Epstein was here. You know. And when you look 23 at Donald Trump all the way down the line, you 24 know, to the regional director, the 25 correctional services administrator. All those EFTA00114302 120 1 people should have been involved in where 2 Epstein was placed when he got here. Now that 3 you know because they failed to do their job, 4 you know, and place him on 9 South where he 5 never should have been to begin with. 6 MR. : Nine South or 10? Oh 7 they put him in 9 South. 8 MS. : 9 South. 9 MR. : Okay. 10 MS. : They placed him in 11 regular old SHU. 12 MR. : Okay. 13 MS. : For inmates that 14 faced disciplinary action. Inmates that are 15 being separated from other inmates in 16 protective custody. Those to - things of that 17 nature. 18 MR. : So -. 19 MS. : If he -. 20 MR. : In 10 South, do inmates 21 all have cellmates in 10 South? 22 MS. : Inmates on 10 South 23 don't have cellmates. But. 24 MR. : Okay. 25 MS. : What they do have up EFTA00114303 121 1 there -. And I'm telling you he should have 2 been put up there from day one. Most 3 especially after he attempted suicide. So if 4 you didn't place him up there from day one. 5 When he attempted suicide with a cellmate. 6 Okay? Let's not forget that because when he 7 attempted suicide, he had a cellmate. 8 MR. : Yeah but isn't the reason 9 why he didn't - wasn't successful partly 10 because of the cellmate? My understanding was 11 because once you're - once you commit suicide, 12 you want another person to try to prevent it 13 from actually a suicide being successful. So 14 if they want someone in there to basically 15 watch him, wouldn't they want him in the SHU 16 versus 10 South? 17 MS. : You're not guaranteed 18 that -. 19 MR. : You're not guaranteed but 20 I think that the purpose of him being required 21 a cellmate was that they want someone in there. 22 And that's why they wanted him vetted. Because 23 the purpose was so that someone could be 24 watching him partly. If he's trying to hang 25 himself, there's obviously going to be another EFTA00114304 122 1 celimate in there saying what are you going? 2 MS. : First of all, an 3 inmate don't owe you nothing. 4 MR. : Sure. 5 MS. : Another inmate don't 6 owe you anything. And another inmate by policy 7 is not to be supervising another inmate. So by 8 you saying - because I don't even agree with 9 inmate companions. 10 MR. : Okay. 11 MS. : I've known a lot of 12 inmate companions who would antagonize the 13 person on watch just so they hang their damn 14 selves. Okay? 15 MR. : Okay. 16 MS. : So for you to sit 17 here and put somebody who you know is as high- 18 profile and as important as everybody made 19 Epstein out to be at that time, you relied on a 20 random inmate to keep him safe. I mean, that's 21 You're fooling yourself. 22 MR. : Okay. 23 MS. : You're fooling 24 yourself. 25 MR. : Okay. So just for your EFTA00114305 123 1 own personal opinion was that he should have 2 been on 10 South and he shouldn't have had an 3 inmate at all. He should have just had closer 4 eyes on by staff members? 5 MS. : That's not my 6 personal opinion. That's my professional 7 opinion. 8 MR. : Right. 9 MS. : Because I've worked 10 in this environment -- 11 MR. : Sure. 12 MS. : -- long enough to 13 know -- 14 MR. : Okay. 15 MS. : -- that if somebody 16 said important to you 17 MR. : Where psychology -. 18 MS. : -- and you wanted to 19 keep them safe, and for the type of inmate that 20 he was, that was the best environment for him. 21 They have cameras up there in every cell. And 22 they have a staff member 23 MR. : There's cameras in the 24 cell themselves? 25 MS. : There's cameras in EFTA00114306 124 1 each individual cell. And there is - the 2 officers have monitors right by their desk. 3 MR. : Okay. 4 MS. : So. 5 MR. : So if they would have had 6 eyes on at all times. 7 MS. : They would have had 8 eyes on him at all times. 9 MR. : Awesome. Okay. So 10 alright. I just wanted to get 11 MS. : And I mean -. 12 MR. : I really wanted to find 13 out though, in this specific circumstance, who 14 should have told you? That's the main 15 question. 16 MS. : I mean a lot of 17 people. 18 MR. : Who should have informed 19 you. 20 MS. : A lot of people could 21 have told me. 22 MR. : Right. 23 MS. : A lot of people could 24 have told me. 25 MR. : And you didn't have any EFTA00114307 125 1 conversations with anyone about that 2 requirement? Because again, it seems like 3 everybody else knew. You didn't. So I'm just 4 trying to figure out where that communication 5 breakdown 6 MS. : I don't know where it 7 8 MR. : - occurred. 9 MS. : -- occurred. 10 MR. : Okay. 11 MS. : To be honest with 12 you. 13 MR. : Okay. Would have it been 14 the captain is responsible for that? Or is it 15 in this instance, since you said you didn't 16 know at all, should have called 17 told you? 18 MS. : I don't -. Look. 19 Look. I'm not going to sit here and tell you 20 what somebody could have, should have, would 21 have done. Because like I said, there was a 22 lot of things going on at this institution. If 23 we're going to say "shoulda-woulda-coulda," 24 then we should have had adequate staffing. 25 MR. : Yep. EFTA00114308 126 1 MS. : We shouldn't have had 2 staff here that were dead on their feet. 3 MR. : Sure. 4 MS. : You know. Trying to 5 watch an inmate. And when all those 6 circumstances that was going on, there was a 7 lot of things that we should have been doing 8 that wasn't done. So it's not just about what 9 happened to Epstein. It's about everything 10 else surrounding his death that occurred that 11 didn't happen. 12 MR. : That's one point. 13 MS. : That should have been 14 occurring that didn't happen. 15 MR. : Okay. Now let's - I'm going 16 to take it out. Let's say you're on shift. 17 Inmate attempted to commit suicide. You know 18 there's an issue with the inmate. You're 19 leaving the shift. Do you have a conversation 20 with the person you're relieving - I mean 21 whoever's relieving you? Do you have a 22 conversation with that person and advise them 23 what happened during your shift? 24 MS. : Yes. I would -. 25 MR. : Why? Why would you do it? EFTA00114309 127 1 Just to reason -. 2 MS. : Because look. Let me 3 explain something to you. 4 MR. : No-no-no. I just need an 5 explanation. 6 MS. : No-no-no. I'm going 7 to give you an explanation. But I'm going to 8 give you the explanation that best suits the 9 question that you're 10 MR. : Okay. 11 MS. : -- asking me. When 12 we do these pass downs, everybody is different. 13 Some people tell you verbatim everything that 14 happened. Some people don't. That's just the 15 nature of the beast. You know. I could sit 16 here all day and say somebody should have told 17 me something. Or you know if they had the 18 information. But when you've got so many 19 things on your mind and you've dealt with so 20 many things during the course of the day, you 21 know, people don't want to continue to stand 22 there and do it. People forget. I mean they 23 could have been standing there talking to me 24 for five minutes with all the things that go on 25 during the course of the day. You know. EFTA00114310 128 1 That's not just here. That's every place I've 2 been when it comes to pass down. Some people 3 will tell you a bunch of stuff depending on 4 when it happened during the course of the day 5 and whatever else came behind it or came before 6 it. People they 7 MR. : No, I understand that. No- 8 no. I just 9 MS. : -- don't always 10 remember. 11 MR. : I get that. But let's just 12 say as Agent already mentioned. If 13 there was instructions form the captain down 14 and the lieutenant. Let's say Lieutenant 15 was aware of the instructions and was clear 16 instructions that Epstein had to have a 17 cellmate. And he knew that the cellmate was 18 removed. What was -. Let's just say in a 19 perfect world. What was his role? When he 20 left the shift. What should he have done? 21 MS. would have -. 22 MR. : No-no-no. It's not "would 23 have." What should he have done? 24 MS. : They would have 25 already had -. If you're telling me that this EFTA00114311 129 1 inmate left at what time? 2 MR. : Well he left the cell at 3 8:30 and by 1:30 he was gone from the 4 institution. 5 MS. : Okay. So by the time 6 I got here at 10:00 at night, he should have 7 already had. That should have already been 8 taken care of. 9 MR. : Okay. And that's what 10 we're asking. Who should have taken care of 11 it? 12 MS. : The first person to 13 have known that he didn't have a cellie. 14 MR. : So if was that 15 person, should have he what should have he 16 done? doesn't work for the BOP anymore. 17 So we're just asking what should have happened? 18 MS. : It doesn't matter 19 even if he was still 20 MR. : I know. I just -. 21 MS. : -- working for the 22 Bureau. I mean. If someone knew for a fact 23 that he was supposed to have had a cellie. And 24 they received some type of information or they 25 came aware of the fact that he didn't. And EFTA00114312 130 1 that inmate was never coming back. Depending 2 on that, they should have questioned to see 3 what was the circumstances surrounding that. 4 When they determine what the circumstances were 5 based upon the fact that if he was coming back 6 or whether or not he wasn't coming back, then 7 they should have made arrangements for him to 8 get another cellie. 9 MR. : Okay. I'm done. Can I see 10 the roster one more time? 11 MR. : Yeah. And then let's 12 stay specific to your instance so we don't have 13 to ask you like what should have they done? So 14 as far as yours. If you - and again you 15 weren't. But if you were aware that he was 16 required to have a cellmate. Was there any 17 action that you should have or could have taken 18 between the hours that you were working? 19 MS. : If I -. 20 MR. : Could cell mates have 21 been reassigned at that time of night? 22 MS. : Morning watch is not 23 the time to be moving inmates around because it 24 presents too much of a safety issue. 25 MR. : Sure. EFTA00114313 131 1 MS. : And being that if we 2 don't have adequate staffing, then -. Morning 3 watch, period. You're not even supposed to be 4 opening doors on morning watch. 5 MR. : So that's my question. 6 If had told you, which obviously he 7 didn't. Correct? 8 MS. : Correct. 9 MR. : If he had, could have you 10 even taken action? 11 MS. : I would have 12 contacted -. Like I said. I would have called 13 or psychology or somebody. 14 MR. : So even at that time of 15 night? 16 MS. : Even at that - yes. 17 Even at that time of the night. 18 MR. : Okay. 19 MS. : To figure out what's 20 going on with I mean I can't justify just 21 leaving him up there without a cellie if he's 22 supposed to have one. How am I going to 23 justify that? And that's not even something 24 that I would even risk. 25 MR. : What about the COs? If EFTA00114314 132 1 the COs knew - so Noel and Thomas - that he was 2 required to have a cellmate. Should have they 3 notified you? 4 MS. : They should have 5 notified me. If they knew that he was supposed 6 to have a cellie and he didn't, yes. And they 7 would have. 8 MR. : And in this -? 9 MS. : If they had known 10 that they would have. 11 MR. : In this instance they 12 never notified you though. Correct? 13 MS. : No. 14 MR. : So they didn't tell you 15 and during this 4:00 a.m. it sounds like you 16 talked to them twice. They never told you that 17 Epstein didn't' have a cellmate? 18 MS. : No. 19 MR. : Did they discuss Epstein 20 with you at all? 21 MS. : No. 22 MR. : Okay. And did they - 23 when they called control or any communications 24 you had over the telephone - did they ever 25 discuss Epstein? EFTA00114315 133 1 MS. : No. 2 MR. : Or the cellmate? 3 MS. : No. 4 MR. : Okay. 5 MS. : No. 6 MR. : So these are the 7 questions. We just want more like yes-no like 8 this. And I don't mean to rush you, but we 9 have a bunch of other interviews we have to 10 conduct. So if we can keep to those like yes- 11 no type of things would be so appreciated on 12 our end. 13 MS. : Well I can assure you 14 that everything is not going to be a flat yes 15 or no answer. 16 MR. : Absolutely. I 100% get 17 that. 18 MS. : Because nothing in 19 this business is 20 MR. : Right. 21 MS. : -- flat yes or no. 22 It's all off the cuff. So. 23 MR. : Absolutely. And that's 24 what we're just saying. Like if knew 25 what should have he done. It sounds like what EFTA00114316 134 1 you're saying is he should have notified the 2 captain and he should have made sure a cellmate 3 was put in there. If knew, same thing. 4 He should have notified the captain, he should 5 have put someone there. If you knew, you 6 should have notified the caption, you should 7 have put someone there. That's just the kind 8 of what the ops lieutenant does. Would it be 9 basically the ops lieutenant if it came up to 10 that person? They notify the captain. They 11 make sure it's done. Is that a fair 12 assessment? 13 MS. : Yeah. That's a fair 14 assessment. And you're just notifying - and 15 the only reason why we're letting the captain 16 know is to let him know. Hey, you know you 17 guys we keep telling you this guy should be on 18 10 South, but you keep him on SHU. And we keep 19 running into these close - really, really, 20 close calls. 21 MR. : So the staff -. 22 MS. : So that's one reason 23 why -- 24 MR. : Is the staff ever -? 25 MS. : -- you notify them. EFTA00114317 135 1 MR. : Did you ever have any 2 discussions about him needing to be 10 South 3 with anyone prior to -? 4 MS. : Everybody was telling 5 them that he needed to be on 10 South. 6 Everybody knew that. 7 MR. : Alright. So prior to him 8 even dying, you know, prior to August 10th. It 9 was the captain and above were notified, hey we 10 need to get him on 10 South? 11 MS. : Let me tell you 12 something. If we as lieutenants are 13 responsible for knowing everything that we're 14 supposed to know. and we're running this 15 institution off the cuff, we don't know what's 16 going to happen here at any given time of the 17 day or night. If we're required to know that, 18 you think that these cats in the region and in 19 the central office and at the executive staff 20 level don't know the same thing that or more 21 than we know? 22 MR. : So I guess the question 23 is have you ever had any conversation - did you 24 ever have any conversations with the caption 25 yourself at that time? EFTA00114318 136 1 MS. : We've mentioned to 2 them several times that Epstein should be on 10 3 South. 4 MR. : So who did you have 5 conversations with regarding that? 6 MS. : We've - I've never 7 had a conversation with anybody. But during 8 these times, when this stuff was happening, I 9 used to always say you guys need to put Epstein 10 on 10 South. Epstein needs to be on 10 South. 11 MR. : So my question is when 12 you say, "you guys," who were you saying that 13 to? 14 MS. . I would tell 15 16 MR. : So you specifically told 17 18 MS. : I would tell 19 that -. 20 MR. : Do you remember what his 21 responses were? 22 MS. : No. I don't remember 23 what his -. Apparently, it was nothing. He 24 never got moved. 25 MR. : Right. And that's what I EFTA00114319 137 1 just meant. Did you say like did he 2 acknowledge at least that information that was 3 provided to him? Hey, he should be on 10 4 South? 5 MS. : I don't know if he 6 did or not. 7 MR. : Bu you do recall actually 8 telling him that? 9 MS. : We all used to say 10 that Epstein needs to be 10 South. 11 MR. : Did you do it with a 12 group of other lieutenants when you say, "we 13 all used to?" 14 MS. : No. 15 MR. : But you yourself. Do you 16 recall at least on one occasion or more that 17 you told that? 18 MS. : Yeah. I mentioned to 19 that Epstein should be on 10 South. 20 Yes. 21 MR. : Prior to August 10th? 22 MS. : I don't know what the 23 date was. 24 MR. : I just mean prior to him 25 dying you told him this? EFTA00114320 138 1 MS. : Yes. Prior to him 2 dying. And after he died. I mean. 3 MR. : Okay. Sorry, I'll hand 4 it back over to you. I apologize for 5 hijacking. 6 MR. : Do you have anything else on 7 that topic? Because I'm going to jump through 8 that. 9 MR. : No. The main things, 10 again, are these about the email. Why it 11 wasn't received. The cellmate requirements 12 which she said that she didn't. who was 13 responsible for telling her that? What action 14 should have been taken. What did she know -? 15 MR. : That's (Indiscernible 16 *02:01:29) 17 MR. : Sure. 18 MR. : So I'm just going to jump to 19 a different topic. 20 MR. : And you mentioned how 21 cameras are so important in 10 South. So now 22 we're going to talk about the cameras that were 23 actually in the SHU. 24 MS. : Mm-hmm. 25 MR. : So basic question. Who had EFTA00114321 139 1 access to see what was happening on the 2 cameras? 3 MS. : What cameras? 4 MR. : The cameras inside the MCC. 5 As a lieutenant did you ever utilize the 6 cameras for your job? 7 MS. : I mean what cameras 8 are you talking about? Because we don't - 9 those of us who have access to cameras don't 10 have access to the same cameras or -. 11 MR. : You want to know about 12 the SHU cameras. 13 MR. : Yeah. It's about the SHU 14 cameras. 15 MR. : Who has access to the SHU 16 cameras? 17 MS. : Control. The control 18 center has access to the SHU cameras. We have 19 access to the SHU cameras. And as far as I 20 know, that's it. 21 MR. : When you say "we," is 22 that the lieutenant's office? 23 MS. : The lieutenant's 24 office. 25 MR. : Do you normally utilize the EFTA00114322 140 1 cameras for your job at all? For you daily 2 routine. Do you ever use it? 3 MS. : If we're looking for 4 - say we're looking for somebody say internal. 5 MR. : Okay. 6 MS. : We may glance at the 7 camera to see if we see them or something like 8 that. But we're not sitting there. We don't 9 even have time to do that. And even if we did, 10 we wouldn't be doing it. We're not sitting up 11 there the whole time during our shift and just 12 looking at the cameras to see what's going on. 13 MR. : No. That's not what I mean. 14 I just want to know. At that time - around 15 that time period, did you know that there were 16 cameras inside the MCC that were not working> 17 MS. : I don't believe I 18 did. 19 MR. : So it -. 20 MR. : Specific to the SHU. 21 MS. : Oh. No. 22 MR. : Did you know the cameras 23 -- 24 MS. : No. 25 MR. : -- in the SHU were -- EFTA00114323 141 1 MS. : No-no-no. 2 MR. not working? 3 MS. : No-no-no. I wasn't 4 aware. 5 MR. : So even though you were 6 the lieutenant at that night did you not know 7 ? 8 MS. : The only cameras that 9 I would know that I would be aware of if 10 they're working or not would be the cameras 11 that I have access to which I can look on the 12 TV monitor and see that they're actively not 13 working at the time. Or one of the other staff 14 members who have access to cameras would call 15 and tell me or say something to me about that 16 camera not working. 17 MR. : And did you know on 18 August 10th during your shift or I guess late 19 August 9th, early August 10th, that any cameras 20 in the SHU were not working? 21 MS. : No. I wasn't aware of 22 that. 23 MR. : As far as you remember, 24 were the live portion of the cameras working in 25 there? The ones that you were able to monitor EFTA00114324 142 1 in real-time. 2 MS. : The camera that we 3 had access to from the lieutenant's office at 4 the time was working. 5 MR. : Would that show you both 6 the staff members as well as the range? 7 MS. : That camera only - 8 that camera was really -. The visibility on it 9 was bad. It has always been bad. 10 MR. : So was it only one camera 11 that you could access from your office of the 12 SHU? 13 MS. : There was only one 14 camera that's up there on that monitor. 15 MR. : Okay. And what does that 16 camera show? 17 MS. : I think it shows like 18 the common area. 19 MR. : Okay. So it doesn't even 20 -- 21 MS. : The SHU. 22 MR. show the range? 23 MS. : The ranges and stuff 24 like that? No. 25 MR. : But are there cameras on EFTA00114325 143 1 the range? 2 MS. : Yes. There's cameras 3 on the range. 4 MR. : So who has access to 5 monitor that? 6 MS. : I mean whoever has it 7 up on their computer 8 MR. : Okay. So you could 9 toggle through what you want to look at. 10 MS. : We can't toggle 11 through -- 12 MR. : Okay. 13 MS. : -- on our cameras in 14 the lieutenant's office. No. 15 MR. : Okay. 16 MS. : And I don't 17 MR. : So in the lieutenant's 18 office, it's just -. Would control center? 19 Would they be the ones that would be having 20 eyes on the range? 21 MS. : Nobody is sitting 22 around watching the range. 23 MR. : Sure. 24 MS. : The only people who 25 would be watching the cameras is the officers EFTA00114326 144 1 that's assigned to 10 South. 2 MR. : Okay. 3 MS. : Because they have the 4 monitors right there at their desks. 5 MR. : 10 South or 9 South? 6 MS. : 10 South. 7 MR. : So 10 South watches the 8 SHU as well? 9 MS. : No. Ten South 10 watches the inmates assigned to 10 South. 11 MR. : Oh. Sorry. But specific 12 -. We're talking specifically to the SHU. So 13 if, for instance, the range -. 14 MS. : No. You asked me who 15 would be watching SHU. Who would have access 16 to those cameras? And I'm telling you the only 17 person who would be watching any cameras and 18 who is required to watch them would be the 19 officers that are assigned to 10 South. 20 Outside of that -- 21 MR. : But my question is -- 22 MS. : -- nobody is watching 23 any camera. 24 MR. : -- so no one is watching 25 it. But who -- EFTA00114327 145 1 MS. : As far as I know. 2 MR. -- would have had access 3 to it I guess is what we're saying. Who - if 4 someone wanted to look at the range within the 5 special housing unit, who would have access to 6 that camera? 7 MS. : I don't know if 8 control has access to that. 9 MR. : Okay. But your point is 10 no one's watching that. So if it's down, who 11 would know and how? 12 MS. : I would think the 13 people who are responsible for the cameras 14 would know. 15 MR. : And who is responsible 16 for the cameras? 17 MS. : The um, the 18 communication guys. 19 MR. : Do you know who -? 20 MS. : And that would be if 21 they -. I don't even know if they look at 22 every camera every day to make sure that -- 23 MR. : Sure. 24 MS. : -- they operative 25 because usually, staff reports that camera EFTA00114328 146 1 stuff when they notice it. 2 MR. : Well how - so would 3 people in the SHU know that their cameras were 4 down? 5 MS. : I don't know if they 6 would know that. I have no way of knowing 7 that. 8 MR. : You just said if staff 9 reported it. So that's the question would be 10 like if the range camera in the SHU was down, 11 who would know? Who would they notify? Who 12 was responsible? Do you follow? So how would 13 they know that the range camera was down? 14 MS. : I have no idea how 15 they would know. 16 MR. : You don't know? 17 MS. : Unless they have 18 access to it and they know - they can see it on 19 a monitor or something like that and see that 20 it's not working. I don't know outside of that 21 how they would know. 22 MR. 23 MS. 24 I don't know. 25 MR. : DO you know -? : Unless they was told. : Does the SHU have access EFTA00114329 147 1 to that? 2 MS. : Not that I'm aware 3 of. 4 MR. : Okay. So but you think 5 the communications would be the ones that would 6 know. Who in communications would be 7 responsible for getting it taken care of 8 fixing the cameras? 9 MS. 10 it? 11 MR. 12 MS. 13 communications. 14 MR. : If they knew about Right. : The guys that work in : All of them collectively? 15 Or is there one person? 16 MS. 17 don't work in communications. 18 19 MR. MS. I - look. Look. I : Sure. So I don't know if 20 one would know, another one would know, or if 21 they both would know at the same time. I don't 22 know. I can't tell you how another department 23 operates 24 MR. 25 named Mr. or how they conduct their business. : Okay. Was there someone (Phonetic Sp. *02:07:26) EFTA00114330 148 1 MS. : Mr. worked 2 down there. Yes. 3 MR. : Would he be potentially 4 the one responsible for fixing it? 5 MS. : I'm not going to say 6 he would be responsible for fixing it. But if 7 he was notified of it, he would have done it. 8 MR. : What was his -? 9 MR. : Okay. 10 MS. : I mean if that was 11 his job. If that's what people in this 12 institution wanted. 13 MR. : Okay. And what -? 14 MS. : Look. Let me make 15 this clear to you. I don't know what the 16 communications instructions were regarding 17 MR. : And we're not asking you 18 those questions. I'm sorry. We're not asking 19 you -. We're not looking at you to solve all 20 the problems. We just need to know like as far 21 as like if a camera goes down, who fixes it? 22 MS. : If a staff member had 23 access to a camera and that camera went out, we 24 would call the communications department to 25 have them take a look at that camera and to EFTA00114331 149 1 repair it or replace it, to fix it or whatever 2 needed to be done. 3 MR. : And roughly - 4 MS. : And that depends on 5 who answered the phone. That would be whoever 6 was working down there at the time, depending 7 on which one answered the phone. That's who we 8 would relay that information to. We weren't 9 picky about talking to a specific person. It 10 would be like if they work in that area, then 11 they should be capable of doing whatever it is 12 that we need to do to restore the cameras. Or 13 whatever manner they need to go about getting 14 it done. 15 MR. : How quickly usually does 16 that get resolved? If a camera goes down, do 17 they really get it back up and running pretty 18 quickly? Or does it take days? 19 MS. : If they're here and 20 they can replace it, they replace it on the 21 spot. 22 MR. : ON the spot? 23 MS. : Right. 24 MR. : Would it be abnormal for 25 it to take So if someone reported it on a EFTA00114332 150 1 Thursday, would it be abnormal for them to wait 2 until Monday to fix it? 3 MS. : I don't -. I can't 4 say that because I don't know what the 5 circumstances would be concerning why they're 6 waiting until Monday to do it. 7 MR. : Okay. 8 MR. : During your time as a 9 lieutenant during that time period, did you 10 ever see any cameras down for any extended 11 period of time? 12 MS. : Not that I can recall 13 right at this very moment. 14 MR. : And Mr. . What was 15 his position? Do you remember? 16 MS. : He's the 17 communications officer. I think that's his 18 title. 19 MR. : Do you know his first 20 name? 21 MS. : No. 22 MR. : I'm going to jump. 23 MR. : Yeah. Please. 24 MR. : Do you recall when you came 25 that evening August 9th. That evening when you EFTA00114333 151 1 came on the shift. Do you recall hearing about 2 Epstein making a phone call? 3 MR. : Jesus. This 4 (Indiscernible *02:09:51). 5 MR. : Do you recall that? 6 MS. : No. 7 MR. : Okay. Is it normal practice 8 -? I'm just going to -. Is it normal practice 9 -? Let's say an inmate had to make a phone 10 call. And the inmate doesn't have that line, 11 you know the PIN set up for them, is it normal 12 for an officer to use the legal line to allow 13 the inmate to make a phone call? 14 MS. : Not that I'm aware 15 of. 16 MR. : Okay. Have you ever heard of 17 anyone using the legal line other for anything 18 unauthorized? 19 MS. : No. 20 MR. : Okay. Did you interact or 21 see Epstein on August 9th? Interact with or 22 see Epstein on August 9th? 23 MS. : No. 24 MR. : Okay. 25 MR. : So neither August 9th nor EFTA00114334 152 1 August 10th? 2 MS. : No. 3 MR. : Did you ever have any 4 interactions with Epstein? 5 MS. : Yes, I've had 6 interaction. When he committed the suicide 7 when he attempted suicide. I interacted with 8 him then. 9 MR. : What about after that 10 date? 11 MS. : After that day, no. 12 MR. : Did you even see him 13 after that day? 14 MS. : No. 15 MR. : No? What about the cells 16 in the SHU? Can you see through them or are 17 they like open up a slide in order to see in? 18 MS. : No. You can see 19 through it. 20 MR. : You can see through them? 21 MS. : Mm-hmm. 22 MR. : From the SHU desk, can 23 you see? 24 MS. : No. No. No. No. 25 MR. : So if Epstein's desk I EFTA00114335 153 1 think that's what we're showing you before was 2 the SHU layout. I think it was 15 feet - the 3 closest cell to where the people are sitting in 4 the SHU. They cannot see -. 5 MS. : I don't care where 6 you are inside a housing unit. You cannot see 7 from any - unless you're standing there in that 8 window, you can't see inside somebody's 9 MR. : And is the window open 10 the whole time? 11 MS. : I mean you may be 12 able to see if their light is on or something 13 like that. Whatever that window - whatever you 14 can see from that vantage point, you may be 15 able to see like the corner of something or 16 whatever. But no. 17 MR. : Is the window open the 18 whole time? Or do you have to open it and 19 close it? 20 MS. : The window is open 21 all the time. 22 MR. : And about how big is that 23 window? 24 MS. : I don't know how big 25 it is. EFTA00114336 154 1 MR. : Is it like 12 inches by 2 12 inches? 3 MS. : I don't know how big 4 it is. 5 MR. : Okay. But you've been in 6 the SHU though? 7 MS. : Yes I've been in the 8 SHU. But I don't have to measure the window to 9 tell you how big it is. 10 MR. : But I mean the difference 11 between like you know a three-foot by two-feet 12 or is it like -? 13 MS. : I'm not going to 14 I'm not even going to speculate on the 15 measurements. I mean. 16 MR. : Is it -? 17 MS. : I don't know how big. 18 I don't know the measurements of the window. 19 MR. : So we've never been in 20 there. So we're just asking because we've 21 never put eyes on - in the SHU. So is it a 22 large thing that you can - where you have to 23 kind of like get up close to it or -? 24 MS. : No. It's a little 25 narrow. It's a small window. It's not a big, EFTA00114337 155 1 huge window where -. 2 MR. : So would it be like as 3 big as this? 4 MS. : No. It wouldn't be 5 that big. 6 MR. : So smaller than basically 7 12X12? Roughly 16X12? 8 MS. : Sir, go up there and 9 look at the window. Because I don't 10 MR. : Okay. 11 MS. : -- know the 12 measurements of the window. 13 MR. : Okay. So for the record, 14 I'm holding up a piece of paper that's roughly 15 16 inches by 12 inches. And it is being said 16 that it is smaller than that. 17 MR. : SHU inmates. What are they 18 allowed to have in their cell? What kind of 19 items are they allowed to have inside3 their 20 cell? If you're placed in the SHU. 21 MR. : It depends on what your 22 status is in the SHU. I mean you have inmates 23 that are in there on AD status. You have 24 inmates that -- 25 MR. : What's AD? EFTA00114338 156 1 MS. : -- are on DS. 2 Administrative Detention. You have inmates 3 that they're on disciplinary segregation. You 4 have inmates up there that are up there for 5 protective custody. You have inmates up there 6 for various reasons. So there is different 7 items that each depending on their status they 8 are allowed to have. 9 MR. : So there's no set SHU policy 10 on what inmate is allowed to have and not have 11 in the cell? 12 MS. : I don't know what 13 their polices - what their policy is. If they 14 have a set policy here, in general, I've never 15 seen a set policy for this institution in 16 particular about what the inmates can have or 17 what they couldn't have if they're in SHU. 18 MR. : Okay so no -. 19 MS. : But I'm sure there 20 has to be something. 21 MR. : So what kind of holding was 22 Epstein under? What would he fall under? 23 MS. : I don't know what. 24 To be honest with you, I don't know what 25 because he wasn't up there for disciplinary EFTA00114339 157 1 action. He wasn't up there pending 2 disciplinary action. So I'm going to - and I 3 don't want to say he was up there for 4 protective custody. Because like I said 5 previously, and I'll continue to say that, for 6 someone in his position, he never should have 7 been up on SHU. 8 MR. : Now someone in the SHU. Are 9 they allowed to have the same types of items as 10 a normal person in a regular cell? Or they 11 have only a limited amount of items? 12 MS. : Um, Epstein, to be 13 honest with you, there's no telling what they 14 didn't allow Epstein to have in his cell. 15 MR. : Why do you say it like that? 16 MS. : I say it like that 17 because I know that he was always trying to get 18 things that he wasn't supposed to have. And to 19 be honest with you, I don't know if they 20 approved them or not. 21 MR. : What was he trying to get? 22 MS. : He was - when he was 23 in attorney conference he was trying to get his 24 meals delivered - his hot trays and stuff like 25 that. Regular inmate trays delivered to EFTA00114340 158 1 attorney conference. Things of that nature. 2 So -. 3 MR. : Did he get special 4 privileges? 5 MS. : I don't know if he 6 did or not because I worked nights. So I 7 didn't' have a lot of interactions with Epstein 8 or any other inmates during the daytime because 9 I wasn't here. 10 MR. : Was Epstein allowed to have 11 pill bottles in his cell? 12 MS. : I don't know if he 13 was or not. 14 MR. : Are inmates allowed to have 15 pill bottles in the cell? 16 MS. : If medical says that 17 they can have them, yes. 18 MR. : Okay. How many changes or 19 clothing or linens are inmates allowed to have 20 in the SHU? 21 MS. : I don't know what 22 their policy is up there on SHU. My previous 23 institution, they in SHU they don't have any 24 exchange of clothing up in SHU. When they get 25 their shower, their rec and shower, they're EFTA00114341 159 1 given a new set of clothing at that time. But 2 they don't maintain any additional clothing in 3 the special housing unit outside of that. I 4 don't know what they do here. But that's how 5 it was always done at my previous institution. 6 MR. : So inmates shouldn't have two 7 or three different pairs of -? 8 MS. : Like I said, I don't 9 know what their policy is or was in SHU at that 10 time because things change here. Because 11 things around here change on a moment-to-moment 12 basis. 13 MR. : How was Epstein with 14 direction with other inmates? Did he have any 15 issues with any inmates? 16 MS. : I don't know what his 17 interaction was with other inmates. 18 MR. : When was the last time you 19 interacted with Epstein? 20 MS. : I just told you. 21 When he attempted suicide. 22 MR. : Okay. Do you know why 23 Epstein was in prison? 24 MS. : Uh, because of some 25 allegation that he was having - engaging in EFTA00114342 160 1 sexual acts with underage females. 2 MR. : So the next set of questions 3 is just general questions we have to ask. Did 4 you have any specific feelings regarding why he 5 was in prison? 6 MS. : No. 7 MR. : Okay. Did you speak about 8 Epstein with other inmates? 9 MS. : No. 10 MR. : What time did you leave shift 11 hat day? I know 12 MS. : It was right after 13 5:00. 14 MR. : After 5:00? 15 MS. : Yes. 16 MR. : And when did you hear about 17 the incident? 18 MS. : I think it was - I 19 was working late that day because I had some - 20 I was still finishing up my work. And I don't 21 know probably 7:00 sometime after 7:00 I guess. 22 MR. : You left after 7:00? Or you 23 heard after 7:00? 24 MS. : I think it was after 25 7:00. I wasn't really looking at the clock. I EFTA00114343 161 1 was here working. I had went downstairs to 2 finish some work that I had that I didn't get 3 to finish during my shift. And at some point 4 in time, that's when I heard that um that they 5 had had a medical emergency up in SHU. 6 MR. : But were you here on the 7 premises? 8 MS. : Yes. I was still 9 here. 10 MR. : Did you respond up there at 11 all? 12 MS. : I called up there to 13 make sure everybody was okay. And they - when 14 I asked who was up there they was telling me 15 that they didn't have but one or two staff 16 members up there. So yes. I went up there to 17 see if they needed some help because I knew 18 feeding and all that stuff still needed to be 19 done. 20 MR. : So when you went up to the 21 SHU after the incident, was Epstein still in 22 the SHU or was he removed already? 23 MS. : No. He wasn't there. 24 MR. : He wasn't there. Did you get 25 to see the inside of the cell? EFTA00114344 162 1 MS. : No. No. Nope. 2 MR. : Did you have any 3 communications with Michael Thomas or Toby Noel 4 after this incident? 5 MS. : Noel was still there. 6 I asked her if she was okay. And she said, you 7 know not really. And I went to help them feed 8 and shortly after that, when I came back up out 9 the range after feeding the tier, she was gone. 10 They had pulled her off her post. 11 MR. : Okay. After that day, did 12 you have any communications with them? 13 MS. : No. 14 MR. : Okay. 15 MR. : When inmates come off of 16 suicide watch and are in or assigned to the 17 SHU, so suicide watch to the SHU. Are they 18 assigned a cellmate? 19 MS. : One more time. 20 MR. : So when inmates come off 21 of suicide watch or psych observation and 22 they're on psych observation due to suicide 23 watch, are they assigned If they are then 24 assigned to the SHU, are they assigned a 25 cellmate? EFTA00114345 163 1 MS. : No. 2 MR. : No? When you said that 3 you were working nights, were you working 4 nights all in August 2019? 5 MS. : I don't. If that was 6 my quarterly post, more than likely I was. But 7 offhand I can't remember. 8 MR. : Do you remember if you 9 would have been working days as well? I'm just 10 trying to rectify -. 11 MS. : I mean I would have 12 to look at my schedule. 13 MR. : Sure. 14 MS. : I don't know if I was 15 working both or if I was strictly assigned to 16 that one. I'm not sure. 17 MR. : Okay. 18 MR. : I just had a follow-up on 19 that. 20 MR. : So you said. Sorry, go 21 ahead. 22 MR. : Did you work overtime during 23 that time? 24 MS. : What do you mean? 25 MR. : You mentioned everyone's EFTA00114346 164 1 working overtime during that time. Right? 2 Everyone's mandated and everything. 3 MS. : I'm sure at some 4 point in time. I don't' know if it was around 5 that time, but yeah. If a lieutenant then 6 called in sick, yeah. We was required to stay 7 and work that shift. 8 MR. : Would that be -? So that 9 would be the day watch? 10 MS. : It could have been 11 either or. Well depending on what shift you're 12 working. 13 MR. : So you said you were 14 involved with responding to the July 23rd 15 incident where Epstein originally tried to 16 commit suicide? 17 MS. : Yes. 18 MR. : Now is it your 19 understanding that he tried to commit suicide? 20 MS. : As far as I know. 21 MR. : Did you hear anything 22 about his cellmate attempting to kill him? 23 MS. : There was some 24 reference that I guess he had mentioned at that 25 time that his cellmate had done that to him. EFTA00114347 165 1 But when I went back and spoke to him he never 2 mentioned that to me. He never said. 3 MR. 4 questioned Epstein? 5 MS. When you say you actually : Yes. 6 MR. : And what did he say to 7 you? 8 MS. : He didn't say 9 anything. He really didn't say anything about 10 the incident. He said that he had gotten up to 11 get some water and the next thing he knew -. I 12 think that was what he said. He had gotten up. 13 I would have to look at my memo. I think he 14 said he had gotten up to get some water or 15 something like that. And the next thing he 16 knew we were there. 17 MR. : Okay. And what number 18 were you in responding? 19 MS. : I don't know what - 20 if I was first if we went because usually when 21 we respond to an emergency, we -. Even if I 22 get on the elevator first, the elevator may 23 stop and pick up somebody else along the way. 24 But I think it was me and I don't know. I 25 don't' remember. EFTA00114348 166 1 MR. : When you did respond, 2 what did you see? 3 MS. : Um. 4 MR. : When you got to the cell? 5 MS. : He was lying on the 6 floor. He appeared to eb unresponsive. But 7 when we walked up to him, we would see his 8 chest rising. And he was kind of clammy. 9 MR. : Did he have anything 10 around his neck? 11 MS. : No. He didn't have 12 anything around his neck. 13 MR. : Okay. 14 MS. : And there were 15 different times when he would open one eye and 16 kind of you know like he was trying to see what 17 we were doing. And then he would close his 18 eyes. But he would never respond to us. He 19 just wanted to maintain that mode like he was 20 unconscious or something like that. I guess. 21 I don't' know what was going through his mind. 22 MR. : Do you know if someone 23 removed something that was around his neck? 24 MS. : I don't know if 25 someone. I don't' know. EFTA00114349 167 1 MR. : Okay. Point being, like 2 if he's claiming someone tried to kill him, but 3 also at the same time is saying that he's 4 trying to commit suicide. He didn't' have 5 anything around his neck. Is there any reason 6 for you to believe that his cellmate was 7 actually trying to kill him? 8 MS. : No. I mean I had no 9 proof that his cellmate tried to do anything to 10 him. And I'm trying to remember what the 11 officer said. I don't' even remember offhand 12 what the officers were telling me. I don't 13 know if they saw him with something around his 14 neck or what they observed. But I can't 15 remember. I would have to refer back to my 16 notes. Because that was a long time ago. 17 MR. : Sure. So if counts are 18 not conducted. And I'm assuming -. Are counts 19 more important than rounds? Or are they both 20 just as equally as important? 21 MS. I mean they're both 22 important. They are both independently 23 important. 24 MR. : Okay. So let's go first 25 with counts. If counts are not conducted, who EFTA00114350 168 1 is -. So if counts are signed off on. You're 2 given a count slip. If those counts actually 3 weren't conducted. So if let's say for 4 instance that during your shift, the 12:00 5 a.m., the 3:00 a.m., and the 5:00 a.m. If they 6 were not conducted - those counts- who is 7 responsible for that? For them being signed 8 and certified? Who - so I'm assuming the 9 people? Noel and Thomas are the ones assigned 10 to that shift. And they are the ones who 11 certify that those counts were conducted and 12 then provided to you. Are they the only ones 13 that are responsible for providing false 14 information? 15 MS. : Providing false 16 information? 17 MR. : Correct. So if they're 18 saying they conducted counts but they didn't. 19 So they were providing you with something 20 saying either 72 or 73, but those counts were 21 not conducted. 22 MS. : How would I know if 23 they weren't conducted? 24 MR. : Right. That's what I'm 25 asking. So are they the only ones that are EFTA00114351 169 1 responsible for falsifying that? 2 MS. : Who else would know 3 whether or not they did them or not? I mean -- 4 MR. : That's what I'm asking. 5 MS. no one else would 6 have any way of knowing. 7 MR. : So it doesn't' go above 8 them. If they are the ones that are saying it, 9 there's no other people that can like verify 10 that it actually was conducted. 11 MS. : How would they verify 12 it? 13 MR. : That's my question to 14 you. 15 MS. : And that's what I'm 16 saying to you. If they're the ones that are 17 There is no reason whatsoever for us to ever 18 believe that someone is not conducting their 19 counts or doing what they're supposed to be 20 doing. You know. We're not out there with 21 them. I mean we have no way of knowing what 22 As far as I know, no one has any way of knowing 23 what I'm doing when I'm here. 24 MR. : Sure. 25 MS. : You know so you have EFTA00114352 170 1 to have confident in and you have to know your 2 staff. That's what it comes down to. You have 3 to walking and talking. It's not just about 4 the inmates. It's not just about you know what 5 we did with Epstein. IT's about every inmate 6 that was being housed at MCC at the time. 7 Every inmate had the potential to hang 8 themselves or kill themselves or do whatever. 9 It wasn't just about Epstein. We're 10 responsible for every inmate in this 11 institution. 12 MR. : Sure. 13 MS. : And I have - if I 14 have absolutely no reason to believe that a 15 staff member in this building or doubt unless 16 they reveal something to me that would make me 17 doubt what they said is true. 18 MR. : So -. 19 MS. : Other than that I 20 have no reason to believe that a staff member 21 isn't doing what they're supposed to be doing. 22 MR. : So if you were told that 23 the 12:00 a.m., 3:00 a.m. and 5:00 a.m. counts 24 were not conducted on August 10th, does that 25 surprise you? EFTA00114353 171 1 MS. : Yes, that would 2 surprise me. 3 MR. : It does surprise you? 4 MS. : Yes. 5 MR. : Okay. Do you have any 6 reasons to believe that either r Thomas or Noel 7 did not conduct counts in the past? 8 MS. : No. 9 MR. : No? 10 MS. : I have no reason to 11 believe. I don't even believe that they didn't 12 do it that night to be honest with you. But 13 no, I have no reason to believe that they 14 didn't -=. 15 MR. : Have you heard that they 16 made any statements to any other staff members 17 about not conducting rounds or counts? 18 MS. : No. No. 19 MR. : So you never heard those 20 either? 21 MS. : No. 22 MR. : Okay. And you don't know 23 of them ever not conducting rounds or counts 24 other than -? 25 MS. : I don't know of them EFTA00114354 172 1 or any other staff members not conducting 2 counts or rounds or anything like that. 3 MR. : Okay. And you didn't -? 4 On August 10th, did you speak to them at all 5 about hey did you guys really do these counts? 6 MS. : No. 7 MR. : Okay. 8 MS. : No. 9 MR. : What about with the 10 rounds? So would you be surprised to find out 11 that they didn't' do rounds on August 10th 12 during your shift? 13 MS. : Yes. I would be 14 surprised to find out 15 MR. : Okay. 16 MS. : -- that they didn't' 17 do rounds. Yes. 18 MR. : So if it were found out 19 that they didn't do any rounds. That to you is 20 shocking? You would be like wait what? 21 MS. : Yes. I would be 22 surprised that they didn't do 23 MR. : Okay. Do you have any 24 follow-ups on those specific questions? 25 Specifically with falsification of rounds and EFTA00114355 173 1 counts? Who has to sign off on the counts and 2 rounds? 3 MR. : What do you mean? 4 MR. : So is it solely the COs 5 that are in the SHU? Or does someone else have 6 to verify on the counts that they were 7 conducted? 8 MS. : I mean you can't 9 verify that they're conducted. You can verify 10 that the -. 11 MR. : That they provided you 12 that information. 13 MS. : Right. That they 14 turned in the count slip. 15 MR. : Right. 16 MS. : But you can't verify 17 anything else. 18 MR. : So there's no procedure 19 in place for a lieutenant to make sure that COs 20 are actually performing the duties that they 21 say they're doing? 22 MS. : Do you know how many 23 people who have -? Supervisors would have to 24 be in -? That would mean that a supervisor 25 would have to be on every unit during every EFTA00114356 174 1 count. 2 MR. : Well I'm talking 3 specifically about the SHU. 4 MS. : And watching the 5 count. 6 MR. : I'm speaking specifically 7 to the SHU. So in the special housing unit, 8 there's no verification process. If the COs 9 are saying they did it, you just take their 10 word. There's no way to verify it. 11 MS. : SHU is no different, 12 sir. Before this incident with Epstein, SHU 13 was no different than any other unit in this 14 building. It's not about whether or not solely 15 whether or not SHU is doing it. It's about 16 whether -- 17 MR. : So you're saying -- 18 MS. : -- everybody on every 19 unit -- 20 MR. : -- prior to this incident 21 -- 22 MS. : -- is doing it. 23 MR. -- is there something 24 that has been implemented since then? To 25 ensure that counts and rounds are being EFTA00114357 175 1 conducted? 2 MS. : No. 3 MR. : So it's still the same. 4 It's all up to the COs. If they're certifying 5 that they did it, the lieutenants are taking 6 their word for it. 7 MS. : That's correct. 8 MR. : Okay. 9 MS. : That's correct. As 10 far as I know. Yes. 11 MR. : On August 10th during 12 your shift from August 9th 10:00 p.m. to 6:00 13 a.m. the following day. What was the chain of 14 command? Was it Noel or Thomas or was there a 15 hierarchy? Was one in charge of the other? 16 Was one subordinate or were they both equal? 17 MS. : What do you mean? 18 You mean inside the SHU? 19 MR. : Correct. So does one 20 give the other orders or do they work tougher? 21 Is there a hierarchy in there? 22 MS. : Well they should be 23 working together. 24 MR. : Okay. But there's no 25 like person that's in charge of the other? EFTA00114358 176 1 MS. : No. 2 MR. : So if -? 3 MS. : No. 4 MR. : And how was it determined 5 with counts and rounds? Is there someone that 6 takes lead on it? Or is it? 7 MS. : No. 8 MR. : No? 9 MS. : I mean we all have 10 the same responsibilities. 11 MR. : Okay. Back over to you. 12 MR. : Just for in terms of policy- 13 wise. If a count is wrong. Right, there's an 14 issue with the count. What does the policy 15 state? What should happen? 16 MS. : What type of issue? 17 MR. : Let's say the COs in the SHU 18 did a count. And the count comes to the 19 control center and it's wrong. They identify 20 if the fact that it's wrong. What's the next 21 step? 22 MR. : What do you mean? It's wrong 23 how? 24 MR. : The count is off. The number 25 is wrong. Let's say it said 72 -. EFTA00114359 177 1 MS. : You mean the count 2 slip? The count slip comes to control -? 3 MR. : Yes. 4 MS. : And the count slip is 5 wrong? 6 MR. : Yes. 7 MS. : Then if control is 8 aware of that, and especially if control is 9 taking the count. Then control will call them 10 back and tell them I need a new count slip 11 because this one is not right. And usually the 12 only time that that would happen would be like 13 in the incidents where we may have moved a 14 staff member during that time. And we need to 15 go back and update that count slip that we were 16 originally getting. Or like in this case with 17 the inmate being in R&D. We needed to go back 18 and get another count slip that reflected the 19 new count which was 72. Once we put the inmate 20 in R&D. 21 MR. : Okay. On that same topic, if 22 the count was wrong, and you told them that 23 they needed to go back and do another count. 24 MS. : Not that the count 25 was wrong. That the count slip was wrong. The EFTA00114360 178 1 number that was reflected on the count slip was 2 wrong. 3 MR. : Did you see them do the 4 count? 5 MS. : No. 6 MR. : So the number they reported 7 was wrong. The count should have been -. 8 MS. : They said that they 9 had -. They said that they had their count was 10 73 but that they had there was an inmate that 11 was in R&D. So that was the problem. They 12 never did a count slip saying - they never said 13 my count is 73 and left it at that. They were 14 clear to say that the count is - SHU has 73 but 15 there is an inmate that is down on the third 16 floor in R&D. Or something to that effect. 17 They notified me that there was an inmate that 18 was off their housing unit. 19 MR. : So you're saying the count 20 wasn't wrong. 21 MS. : What was on the count 22 slip was wrong. 23 MR. : The count slip was wrong 24 but she said that they explained it when they 25 delivered it. EFTA00114361 179 1 MR. : But you just stated a little 2 bit before that the count wasn't wrong, the 3 count slip was wrong. 4 MS. : The count slip was 5 wrong. 6 MR. : Why did you ask them to go 7 back and do the count? 8 MS. : Because I needed to 9 find out what was going on with this dude in 10 R&D so that, you know, if they in fact -. If 11 we made changes to whatever the status was to 12 this guy in R&D. If he was in fact going to be 13 there overnight or whatever the case may be, 14 then we needed to get him off of their count. 15 So while I was verifying that, I said, you know 16 what just go back and do it again just to make 17 sure. While I'm looking into this thing with 18 this dude. I didn't say that to them. I'm 19 thinking to myself. I'll have them go back and 20 do another count while I check on this inmate 21 that was -. 22 MR. : There's a possibility the 23 count was wrong then. 24 MS. : What do you mean? 25 MR. : You said go back and verify EFTA00114362 180 1 if the guy was still there or not there. 2 MS. : I didn't say go back 3 and verify if the guy was still there. I said 4 while I verify what's going on with this guy in 5 R&D to see if he's still in R&D. That's what 6 I'm talking about. I wanted to verify if he 7 was still in R&D. And if he was if he was 8 going to be staying there. Because I wasn't 9 aware that there was an inmate in R&D. So from 10 my own, and I wasn't verbalizing this. I was 11 saying this to myself. 12 MR. : But the point being is you 13 got a count that was a 73 and you said do it 14 again. Correct? 15 MS. : The count slip that 16 was 73 was broke down because they had put the 17 count slip out. 18 MR. : Right. And you -- 19 MS. : So - 20 MR. : -- asked them to do the 21 count again though. Because you got a count - 22 and this is where I just want to make sure that 23 we're all on the same page here. So you did 24 though take action. You got a count slip that 25 seemed to be inaccurate and questioned it. You EFTA00114363 181 1 said can you do the count again. 2 MS. : I hadn't even gotten 3 the count slip then. 4 MR. : Oh, okay. 5 MS. : Like I said, when 6 they called in the count, they said the count 7 like the count in the book or wherever they was 8 reading it from say 73 but there is an inmate 9 in R&D. 10 MR. : So that's how they called 11 the count in? There's 73, but there's one 12 inmate in R&D. And you said, can you do the 13 count again? 14 MS. : They wasn't even 15 really calling in the count. They was 16 questioning. You know they were basically 17 informing me that we've got 73 -. Because they 18 weren't even sure what they should do or how 19 they should go about it. 20 MR. : Okay. 21 MS. : You know. They just 22 wanted it to be known that there was an inmate 23 off their housing unit that was somewhere else. 24 He wasn't physically on the housing unit. And 25 that was the whole question as to how do they EFTA00114364 182 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 want us to do - how are we supposed to count this guy? What's the deal with that? So I'm saying, you know, let me - I need to figure this out. know that So I need Because I wasn't - I didn't even there was a guy in R&D at the time. to verify that there is a guy in R&D and what's the status of this dude in R&D, why he's there. All these questions I have to ask before I can even tell them anything about it. MR. : So at what point would have they filled out the count slip? After you did the verification? Would have they then created the count slip? MS. : They would have created a new count slip. MR. : Okay. So -. MS. : And that count slip apparently was never picked up because -- MR. : Never picked up and not recorded. MR. THIELHORN: -- because the one that you all was able to get a copy of was the 73 and not the one that reflected the in count which would have been 72. MR. : And do you know that EFTA00114365 183 1 there was a count slip that was created? 2 MS. : I have no reason to 3 believe that there wasn't. 4 MR. : But do you have a reason 5 to believe that there was? Did you ever see 6 one? 7 MS. : If I had saw it, it 8 would have been during the time that I would 9 have taken the count and I would have attached 10 it to the rest of the count slips and went on 11 about my business. 12 MR. : So at the same time we're 13 saying to you there's no reason to believe that 14 there wasn't. there's also then no reason to 15 believe that there was. 16 MS. : I - let me tell you - 17 . 18 MR. : The point being is that 19 you don't know. You don't know if there was a 20 count slip. 21 MS. : If -. Let me tell 22 you something. Based upon the fact that I've 23 worked with these guys for a certain period of 24 time and I know what they're capable of doing. 25 I can for the most part tell you what somebody EFTA00114366 184 1 would do and what they wouldn't do. I have 2 never had a problem with a staff member not 3 correcting their count slip or not sending me 4 another - a corrected count slip. 5 MR. : Now we're only asking you 6 because I have personally not seen it. So I'm 7 asking you if there's another one, do we need 8 to go try to find this. Or do you not know. 9 MS. : You're not going to 10 find it. I mean it's two years after. 11 MR. : Right. 12 MS. : Where are you going 13 to find it at? If it wasn't picked up - I mean 14 the fact that they could have put it out there 15 and no one picked it up. 16 MR. : Here's a question. If they 17 did do one, right, it's expected that they 18 should have for that one. Right. A new one. 19 Yes or no? Because of the error, it was 20 expected that they would have filled out a new 21 one with the correct number. 22 MS. : I'm sure that they 23 feel that they filled out another one and 24 probably put it out in and it was an oversight 25 on somebody's part and they didn't pick it up. EFTA00114367 185 1 MR. : Yeah but here's the thing. 2 You don't know if - yes or no. Did you see it 3 for that? Yes or no. 4 MS. : No. I didn't' see 5 it. 6 MR. : No-no. We're going that 7 would it possibly have been picked up at the 8 3:00 a.m. count? 9 MS. : I don't know when it 10 could have been picked up, sir. 11 MR. : Is it in the same place? Or 12 is it a different place it's kept? 13 MS. : Depending. I mean 14 they could have put it in the same place. They 15 could have put it in a different place. I 16 don't know. 17 MR. : Okay. That's it. We just 18 want to know. 19 MR. : I can't tell you something 20 that I didn't see. If I didn't see it, I can't 21 22 MR. : And that's what -- 23 MS. : -- tell you where 24 they put it or who picked it up or what 25 happened to it. EFTA00114368 186 1 MR. : And that's what we're 2 getting at. The point being is that you're not 3 sure. So we just don't want to - because you 4 said you have no reason to believe that they 5 didn't. That indicates that they did. And we 6 just want to make sure that you're correct. 7 You've never seen it. You're actually not sure 8 if they did or not. 9 MS. : Okay. 10 MR. : Is that correct though? 11 MS. : No. I never saw the 12 count slip. 13 MR. : Okay. Perfect. I mean 14 it's not like a "gotcha," we just want to make 15 sure 16 MR. : Yeah. 17 MR. : -- that you dint - there 18 isn't a count slip out there that we need to 19 try to go find. 20 MS. : Let me tell you 21 something. It's -. If-if-if. I can't - if I 22 can make something right that's wrong or need 23 correcting, then that's what I'm here for. I'm 24 not here to like I said, and I'll say this a 25 thousand times. I'm not here to cover for EFTA00114369 187 1 nobody. I'm not here to provide false answers 2 for something that somebody had done, but at 3 the same time, you all are throwing these 4 questions at me about what somebody would have 5 done. I don't know what's in somebody's mind 6 - 7 MR. : Ma'am, we're absolutely 8 not asking 9 MS. : -- with the stuff -- 10 MR. : -- those questions. 11 We're asking you 12 MS. : -- that's taken 13 place. 14 MR. : We're saying did you see 15 it. So that's what we're trying to get you to 16 answer more like yes, no, I don't know on that 17 front. So we're trying to keep it consolidated 18 and ask you direct questions. What did you 19 know? Did you know if they did another count 20 slip? 21 MS. : Well what I also know 22 is there's no reason for them to not have done 23 it. I've never had a reason or a circumstance 24 where somebody didn't do a corrected count 25 slip. I mean it's - there's really nothing to EFTA00114370 188 1 it. 2 MR. : And this is only because 3 of the way you're answering this. Should have 4 you ensured that they did a new count slip? 5 MS. : I had no reason to. 6 MR. : But was it your 7 responsibility to ensure that they created a 8 new count slip? 9 MS. : It was my 10 responsibility to tell them. Well they knew to 11 create it. If the count was different, they 12 knew to create a new count slip. I'm not 13 required to wait around for that count slip to 14 manifest itself in SHU when I have a thousand 15 other duties to do. 16 MR. : Okay. 17 MS. : I leave that you 18 know. 19 MR. : So it's your requirement 20 to do a new count but it's not your requirement 21 to follow up to obtain a new count slip. 22 MS. : Because what 23 generally happens is that the internal officers 24 would go pick that count slip up and bring it 25 down to the control center. And they would EFTA00114371 189 1 attach it to that count. 2 MR. : And would have it then 3 been Noel or Thomas' responsibility to contact 4 internal to tell them to come get it? Or would 5 it have been your responsibility to tell 6 internal to? 7 MS. : Sometimes I would 8 tell them. Sometimes SHU would tell them. It 9 just depends -- 10 MR. : Okay. 11 MS. : -- on the 12 circumstance. 13 MR. : In this circumstance do 14 you know who would have been responsible for 15 that? 16 MS. : I mean we all could 17 have done it. 18 MR. : Okay. 19 MS. : We all could have 20 done it. 21 MR. : So when you say depending 22 on circumstance in this -. 23 MS. : Well that was just 24 something I said. But any of us could have 25 done it. If control - if I see that control EFTA00114372 190 1 MR. : So let's get at it this 2 way. Did you contact internal? 3 MS. : Let me tell you 4 something. If internal comes to the control 5 center, and I walk over there to drop off count 6 slips that they've already collected. And I 7 walk over there and I see them there. And I'll 8 say hey, can you go grab the new one from 9 9 South. That would be an example of a 10 circumstance. 11 MR. : Okay. So in this 12 circumstance, did you contact internal and tell 13 them to get the new slip? 14 MS. : I didn't contact -- 15 MR. : Okay. 16 MS. : -- to tell them. 17 MR. : And are you aware if 18 Thomas and Noel contacted internal to come 19 collect a new slip? 20 MS. : They may have. And I 21 may have 22 MR. : But you're not aware? 23 MS. : And control may have 24 announced it over the intercom. I can't 25 remember from -- EFTA00114373 191 1 MR. : Sure. 2 MS. : -- this year to that 3 one. 4 MR. : You're not aware. Great. 5 MS. : You know if that 6 actually occurred. 7 MR. : Now you mentioned that an 8 all-staff email should have been put out that 9 Epstein had a requirement. Who should have put 10 that out? 11 MS. : The person - the -. 12 MR. : Is that psychology? The 13 warden? The captain? The AW? 14 MS. : I mean they all 15 should have been doing it. 16 MR. : Okay. 17 MS. : To be honest with 18 you, they all should have known that he should 19 have been up on 10 South. 20 MR. : Okay. 21 MS. : But. 22 MR. : Has an all-staff email 23 ever gone out before saying that this person is 24 on suicide watch. He's required to have an 25 email. I mean a ceilmate. EFTA00114374 192 1 MS. : Here? 2 MR. : Yes. 3 MS. : I've never seen that. 4 I've never seen that done here. But we didn't 5 have -. I'm trying to remember a time when 6 prior to Epstein that I had even seen an email 7 period about an inmate needing an inmate in the 8 cell to be housed with another inmate. To be 9 honest with you. 10 MR. : Okay. Now speaking to 11 that though, you know, we showed you the email 12 that was sent to you that you said you don't 13 recall ever receiving it. Do you have a lot of 14 emails that have gone unread? 15 MS. : I'm sure I do. 16 MR. : Okay. So yeah. You 17 didn't receive this but there's also a lot of 18 emails that you didn't receive 19 MS. : There's a lot of 20 emails that I receive 21 MR. : -- and you probably 22 haven't -- 23 MS. : -- and have time to 24 read at that time because of everything that 25 was going on during our shift and in this EFTA00114375 193 1 building. 2 MR. : And is that just a 3 constant issue of just trying to keep up with 4 emails as well as do your job? 5 MS. : That was a constant 6 issue. Yes. Because there was so much going 7 on in this building at the time. So much 8 chaos. That you didn't have time to read. 9 MR. : Okay. 10 MS. : You didn't have time 11 to read a lot of the emails that you'd gotten. 12 But most importantly, if when you're talking 13 about information that's that important, you 14 know. Whoever is sending out the information. 15 Whoever got the information should always be 16 trying to make sure that everybody knows that 17 this is important. We have to make sure that 18 he had a cellie because like I said, the 19 officers are the main ones who come in contact. 20 MR. : And that goes back to our 21 original question. 22 MS. : With the inmates. 23 MR. : If the chain of command 24 went up toe during that time and that he 25 knew that he was required to have a cellmate EFTA00114376 194 1 and didn't. what should have he done? 2 MS. 3 MR. 4 lieutenant at the time, so put yourself into 5 the place of : If what? : If you were the ops If you knew 6 was required to have a cellmate, 7 current cellmate was removed, he that Epstein and his should have - 8 and what you said was, I believe, he should 9 have notified the captain and ensure that a 10 cellmate was put in place. 11 MS. 12 have done. 13 14 MR. MS. : That's what I would : Correct. : I said was the 15 SHU lieutenant at one point. So he probably 16 would have assigned another inmate to the cell. 17 It just depends on you as a supervisor. 18 MR. : Sure. 19 MS. : There is nothing 20 written in stone concerning how you're going to 21 - indicating how you're going to handle that 22 situation because -. 23 MR. : And if the inmate that 24 was removed - Reyes - was done at the end of 25 his shift, should have he then passed that EFTA00114377 195 1 information on to the next operations 2 lieutenant to be able to handle the situation? 3 MS. : That's if he knew 4 about it. But chances are, he probably would 5 have had it 6 MR. : No, let's -- 7 MS. : -- done before he 8 left. 9 MR. : Okay. 10 MS. : I can't -. 11 MR. : So you think that 12 MS. : Look. I can't answer 13 for him. 14 MR. : Sure. 15 MS. : I don't know what he 16 should have done or what he would have done or 17 what -- 18 MR. : If it was -. 19 MS. : -- he could have 20 done. 21 MR. : -- as an ops lieutenant. 22 Do you think even if it happened at the end of 23 a shift, he should have handled it? 24 MS. : I'm not saying what 25 he should have done. EFTA00114378 196 1 MR. : Okay. 2 MS. : I'm saying Look. 3 What he should have done and what he could have 4 done and what he would have done is on him. 5 MR. : Sure. 6 MS. : We don't have - there 7 is no instruction or no instructional manual 8 that tells us every little thing that we're 9 supposed to be doing 10 MR. : Right. 11 MS. : -- for every scenario 12 because it'll never happen. 13 MR. : Okay. 14 MS. : You'll never have an 15 exact scenario for everything that happens. 16 You just have to use your common sense and good 17 judgment regarding it. 18 MR. : So going back to what you 19 said about your hours aren't specific to what 20 the duty agent roster says. You said you would 21 work -. Although the roster says 12:00 a.m. to 22 8:00 a.m., you were actually 10:00 p.m. to 6:00 23 a.m. What would have have been on August 24 9th. Looking at the duty roster. What times 25 would he have actually - have worked according EFTA00114379 197 1 to that? 2 MS. : I'm thinking he would 3 have worked -. he would have came in around 4 6:00 and worked until 2:00. 5 MR. : Okay. So he would have 6 been 6:00 a.m. to 2:00 p.m.? 7 MS. : Yes. 8 MR. : And then would 9 have been 2:00 p.m. to 10:00 p.m.? 10 MS. : That's correct. 11 MR. : Okay. If he didn't 12 If didn't tell that, would have 13 it then been the ultimate responsibility for 14 the COs to again report it up the chain of 15 command? Or because they reported it 16 previously, would that have covered them with 17 hey we got it up to the ops lieutenant. That 18 person's supposed to take care of it. Do you 19 follow what I'm saying? So for people working 20 in the SHU. They had already reported it up. 21 It got to . At that point, is everybody 22 in the SHU covered? They reported it. Or 23 should each subsequent shift has also reported 24 hey he's supposed to have an inmate - he's 25 supposed to have a cellmate in here. He EFTA00114380 198 1 doesn't. 2 MS. : That's if they knew. 3 There is no reason for me to believe that those 4 guys that was there on SHU that if they knew 5 that, whether or not before they left, I'm sure 6 they would have questioned that again as to 7 what you want me to do about this particular 8 situation. 9 MR. : Okay. So should have 10 each So then let's say if Thomas and Noel 11 did know. And they knew he was without a 12 cellmate. Should have they then told you? 13 When you did your rounds? Like when they're 14 calling control. And you're stopping by at 15 4:00 a.m. Would have it been their 16 responsibility to say hey, just so you know, 17 he's required to have a cellmate and he 18 doesn't. 19 MS. : I'm not going to say 20 that that's what they should have done because 21 there's no rules and regulations regarding 22 that. But they - I would have - if it was me, 23 I would have mentioned it. 24 MR. : Okay. So even if they 25 know, somebody told them just make sure. He's EFTA00114381 199 1 required to have a SHU at that point, they're 2 not actually required to notify someone. 3 MS. : If what? If somebody 4 tells -? 5 MR. : So you're saying that 6 there's no rules and - 7 MS. : If who tells them 8 that? 9 MR. : So if they are told. And 10 I'm not saying you did. 11 MS. : You're saying -. Okay 12 so now you're saying if they knew that he was 13 supposed to have a cellie. 14 MR. : Correct. 15 MS. : Yeah. If they knew 16 the was supposed to have a cellie. 17 MR. : If they knew -. Yeah. 18 So if they then because it was during their 19 shift. They should have at some point informed 20 you hey he's supposed to have a cellmate and he 21 doesn't. And they didn't do that. Correct? 22 MS. : That's correct. 23 MR. : Okay. Fair enough. 24 That's it. You done? 25 MR. : (Indiscernible *02:48:29) EFTA00114382 200 1 MR. : What? 2 MR. : Do you know of any - 3 currently, do you know of any policy violations 4 that's happening at the MCC? 5 MS. : As far as what? 6 MR. : For August 9th and 10th 7 or are you talking about -- 8 MR. : No-no-no. Just in general. 9 MR. : -- just in general? 10 MR. : In general. In general, do 11 you know of any policy violations or any kind 12 of violations happened here at the MCC? 13 MS. : What I do know is 14 that there are people here who abuse their 15 power. They blame everybody for everything and 16 they expect everybody to members of 17 correctional services and to take on the 18 responsibilities of other departments when it's 19 clearly not their responsibility. You have a 20 lot of people that come here that really are 21 not versed on what it is they're supposed to be 22 doing - their responsibilities. So they pawn 23 that off on other people. But there's a -. 24 There's no clear and defined form of policy and 25 procedure here. There's no consistency that EFTA00114383 201 1 goes on here. Everything is hodge-podge. A 2 lot of times, people are required to make 3 decisions off the cuff or to do -. Because 4 when you come here, if you don't have or while 5 you're here - or working here. There is no 6 formal guidance that teaches and guides staff 7 to know what they're supposed to be doing. 8 There's nothing written in stone regarding what 9 you're supposed to be doing and what you're 10 supposed to be doing on a daily basis. There 11 are post orders and stuff like that. But 12 they're not in depth enough to let staff know 13 this is what you're supposed to be doing. 14 There are a lot of things that - decision that 15 people make off the cuff that's not ever put in 16 writing. And that they would tell whoever's 17 here at the time. And I guess expect that 18 information to get disseminated throughout the 19 institution. And it's not. That's not being 20 done. That's not being done. So you have a 21 lot of - we have a lot of new staff here. And 22 a lot of them are falling between the cracks 23 because they just aren't getting information to 24 them in a manner in which they should. 25 MR. : On what you just mentioned. EFTA00114384 202 1 So you're saying that there's orders or 2 decisions coming down from up above? And it's 3 not being properly communicated out. 4 MS. : This is how. This is 5 how this place has always been. You -. People 6 in-in-in-in um positions will require the 7 people up under them to carry their load rather 8 than them carrying their own load. When if - 9 if I'm a lieutenant, my duties and 10 responsibilities and authority end at a certain 11 level. At that point, the captain and above 12 takes over. A lot of times, you don't see 13 that. They expect you to do your job and their 14 job as well. We can't -. There are certain 15 decisions that we can't make. If it was up to 16 me, Epstein would have been up on 10 South. So 17 those are the type of decisions where you tell 18 people that these things are wrong. You give 19 them intel about certain things. And here we 20 are. We done found a loaded gun in the 21 institution. That - those type things should 22 never happen. Never happen. 23 MR. : That's all I have. 24 MR. : Anything else? 25 MR. : Nope. EFTA00114385 203 1 MS. : You have Thomas and 2 Noel that were left holding the bag for 3 something that a decision that should have been 4 made by the staff way above their level in 5 regard to Epstein and what was best for him 6 during his time here. It may not have saved 7 his life, but we certainly would have been in a 8 better position if he had decided to take it 9 somewhere. 10 MR. : But do you agree that 11 counts and rounds need to be conducted? If 12 people are falsifying counts and rounds -? 13 MS. : I'm not. I don't 14 know anything about -- 15 MR. : If -. 16 MS. : -- people falsifying 17 counts -- 18 MR. : But if -- 19 MS. : -- but yes -- 20 MR. : -- they were. 21 MS. : -- counts and rounds 22 need to be done. They're important. 23 MR. : Right. And if they were 24 aware that there was a cellmate requirement, 25 they should have reported the matter to someone EFTA00114386 204 1 like yourself. 2 MS. : Yeah, but you have 3 other people that are - were responsible for 4 disseminating that information to - 5 MR. : Okay. 6 MS. : -- everybody to make 7 sure that everybody had that information. And 8 everybody knew that. 9 MR. : Right. And that -- 10 MS. : And they also had -. 11 MR. I guess like yourself, 12 you received an email but you didn't read it. 13 So that's where there's one of those things 14 that yeah, there's definitely things to work 15 out. But I'm just saying when you say, like 16 there are things that sound like they were 17 probably done wrong here like counts and rounds 18 aren't being conducted. People aren't 19 reporting information up the chain if they're 20 being told to do so. But as well as everything 21 else, you're saying as an institution. 22 MS. : When I first came 23 into the Bureau, you didn't even have email. 24 So how was - and you still now is no different 25 than back then. You still have inmates who was EFTA00114387 205 1 with in potential danger. The same situations 2 that existed in the institutions then. It's 3 the same instances that exist now. So if back 4 then they were able to make sure everybody was 5 one the same page and that information was 6 disseminated and it got to everybody. Why 7 should it be any different here? You can't 8 rely on an inmate because first of all, in 9 order to know, you don't just send out. That's 10 the whole purpose of walking and talking. To 11 disseminate information that way. Because 12 you're never guaranteed that when you send out 13 an email that somebody is going to read it. I 14 have a ton of emails on my computer at home 15 that I don't read. So nothing is guaranteed. 16 You have to know. When you're in charge and 17 you're running something, you-you-you-you need 18 to know that whatever you put out there, that 19 if it's that important, if it's that important, 20 why are you sending it through an email anyway. 21 Why aren't you calling somebody on the phone? 22 Back it up. Call people on the phone. Make 23 sure everybody knows. 24 MR. : I think the purpose is to 25 put it in writing. But yeah, so email but also EFTA00114388 206 1 verify verbally. 2 MS. : You need to verify 3 that if you're sending those emails to 4 pertinent people who should have access to that 5 information that everybody knows about it. 6 MR. : Do you all have all staff 7 like we're lieutenants are all present where 8 they can verbalize something to you? Is that 9 done here? 10 MS. : Do we have what? 11 MR. : So you're saying that not 12 only an email but people should verbalize it. 13 But there's a ton of people that need to know 14 things. So is there a process in place where 15 someone like the captain, say? If the warden 16 tells the captain make sure he has a cellmate, 17 is there a process in place where the captain 18 can get in front of all the lieutenants and 19 tell them this? Or is that - is there -? 20 MS. : The captain has 21 access to every lieutenant here. The captain's 22 office is -. 23 MR. : But how would he know 24 about verbalizing? We have to tell each 25 individual lieutenant. EFTA00114389 207 1 MS. : He should. 2 MR. : So each -- 3 MS. : If it's that 4 important. 5 MR. : -- lieutenant he needs to 6 specifically tell? And were you - being the 7 ops lieutenant - were you one of the people he 8 should have specifically told? 9 MS. : He should have told 10 all of us. Not just time. He should have told 11 all of us. 12 MR. : SO if you were -. 13 MS. : Um, psychology should 14 have made sure that we all knew that. 15 MR. : And this goes to like 16 since you didn't know. You have an email but 17 no one verbalized it. Who should have told 18 you? Whose ultimate responsibility do you 19 believe it was that hey that's the position 20 that really should have informed me. I'm the 21 ops lieutenant. I should have known that he 22 needed an inmate. Who was the person that 23 should have told you that verbally? 24 MS. : Everybody who had 25 stake in making sure. EFTA00114390 208 1 MR. : But you relay believe 2 that every single one of this person should 3 have verbally told you this? 4 MS. : They should have made 5 sure that enough people knew whereby everybody 6 should have known. 7 MR. : So this is what we talked 8 about. Everybody did know but you. So who 9 should have told you? 10 MS. : No. 11 MR. : The lieutenants. The 12 lieutenants -- 13 MS. : Everybody didn't 14 know. 15 MR. : -- that were involved 16 here all knew that he was required to have an 17 inmate. You're the only one who said that you 18 didn't know. So my question to you is they all 19 knew. Who should have been the one to tell 20 you? 21 MS. : The same people that 22 told them. Just tbc they read the email 23 doesn't mean that before they read the email, 24 they wasn't aware. 25 MR. : Okay. EFTA00114391 209 1 MS. : I mean that doesn't 2 say that. 3 MR. : No. I do believe that 4 most of these people were told verbally. So 5 that's what I'm saying. Who should have 6 verbally told you? 7 MS. : Who verbally told 8 them? 9 MS. : So whoever verbally 10 told them should have verbally told you? 11 MS. : I mean -. 12 MR. : Okay. 13 MS. : A number of 14 You've got Psychology has a stake 15 MR. : Sure. 16 MS. : -- in whether or not 17 he has a cellie. Right? 18 MR. : Do you understand what 19 I'm saying? I'm saying like psychology, the 20 captain, the warden, the AW. They can't all 21 tell you the same thing. It should be on 22 person. I'm assuming that should have told 23 you. 24 MS. : There's never one 25 person that disseminates information. That's EFTA00114392 210 1 how we all know what happens here. When you 2 don't have one person -. 3 MR. : Okay. 4 MS. : One person that would 5 mean that that one person would have to work 6 every shift to let everybody know what's going 7 on. But if you see me here, and you know that 8 that's important. Then you should at least 9 make the effort to hey, did you know? 10 MR. : Right. 11 MS. : I mean we're not -. 12 MR. : And bin g that the 13 captain doesn't you work when you work at 14 nights especially. It sounds like from July 15 30thto the time that this happened. 16 MR. : At some point in time. 17 MR. : So would that have been 18 the other ops lieutenant? His requirement to 19 tell you. 20 MS. : At some point in 21 time. I'm sure. The captain seen me between 22 July 30th and every day at some point 23 thereafter. 24 MR. : Okay. So by saying the 25 captain, does that mean you believe the captain EFTA00114393 211 1 is the one who should have told you that? 2 MS. : If the captain knew, 3 the captain should have made sure that we knew. 4 MR. : Okay. 5 MS. : You know, they're the 6 - they're the - they're the - they're the 7 chain. 8 MR. : And that's my question is 9 who is that chain of command? Who was 10 responsible for letting you know? The captain? 11 MS. : If he knew. 12 MR. : Okay. So -. 13 MS. : He should have 14 ensured. He should have mad ensure that we all 15 knew. 16 MR. : Alright. 17 MS. : That we were aware of 18 that information. That we knew. 19 MR. : So the person that should 20 have told you is the captain? That's what I'm 21 getting at. 22 MS. : Whoever was 23 responsible for ensuring that inmate's safety 24 and wellbeing. Whoever had a stake in that 25 should have been making sure that everybody EFTA00114394 212 1 knew. Whether it was the warden making sure. 2 MR. : Sure. So if the warden 3 contacted the captain and told the captain hey 4 make sure all your lieutenants know -. 5 MS. : Whether it was the 6 warden telling the AWs, the AWs telling the 7 captains and telling them to tell us. 8 MR. : But the person above you. 9 So let's say. Take this as like what I'm 10 telling you. 11 MS. : It could have been -. 12 It could have been another officer, sir, that 13 knew and didn't. 14 MR. : Okay. And that's my 15 question. 16 MS. : And could have said 17 hey. 18 MR. : So in this instance, if 19 the warden told the captain, the captain you 20 know telling the lieutenants. Should have it 21 been both your relieving ops lieutenant as well 22 as the captain are the ones that should have 23 been telling you this? 24 MS. : Which one? Which 25 relieving? EFTA00114395 213 1 2 3 4 MR. : Well in this case it would have been MS. : I mean, but you said the email came out on July 30th. 5 MR. : Sure. But I'm saying -. 6 7 MS. anybody between : So it could have been 8 MR. : But then to back up 9 10 MS. : -- then forward. 11 MR. should have told 12 told you. Or should have the 13 captain told all three? 14 MS. : We should have had - 15 16 we should have known that way, way before that day. 17 MR. : Well they did know. 18 MS. : Okay. 19 20 MR. is for you. : And so that's my question 21 MS. : Okay. 22 MR. : So they knew, the captain 23 knew. The warden knew. You didn't know. Who 24 should have told you? Should have your 25 relieving ops lieutenants told you? Or should EFTA00114396 214 1 have your captain told you? 2 MS. : Whoever knew that day 3 that he was left without a cellie. And who 4 came in contact with me should have you know. 5 MR. : Okay. So the highest 6 level basically the highest officer. So if 7 knew it would have been - and he didn't 8 tell the captain, it would have been his 9 responsibility to either told the captain and 10 the ops lieutenant next to him. And that ops 11 lieutenant should have told the captain or you. 12 The point being the information never go to 13 you. 14 MS. : I never was told. 15 MR. : Sure. No. And that's 16 why. 17 MS. : I never was told that 18 he didn't' have a cellie on that day. 19 MR. : Okay. 20 MS. : But as far as what 21 somebody supposed to do is clearly left up to 22 that individual and what their knowledge is and 23 how much they know. How long they've been on 24 the job and how well they do their job and so 25 forth and so on. EFTA00114397 215 1 MR. : Okay. 2 MS. : All of us don't 3 necessarily handle things all the same way. 4 We're not all - we don't all think alike. We 5 don't share the same brain. So how one person 6 handle it is not necessarily how somebody else 7 would have handled it. But -. 8 MR. : Sure. But everybody has 9 their duties and responsibilities. And that's 10 it. 11 MS. : That's correct. 12 MR. : Alright. 13 MR. : Just one left. In regard to 14 August 9th and 10th. Is there anything that we 15 forgot that we didn't ask or that you think we 16 should have asked about? Any important details 17 that we might have missed? 18 MS. : Concerning Epstein? 19 MR. : Concerning Epstein. 20 MR. : No. 21 MR. : Okay. 22 MS. : Not that I can think 23 of. 24 MR. : That's it. 25 MR. : Alright. It is currently EFTA00114398 216 1 12:39 p.m. on June 14, 2021. This is Senior 2 Special Agent and I am 3 turning of the recorder. 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 EFTA00114399 217 CERTIFICATE I hereby certify that the foregoing pages represent an accurate transcript of the electronic sound recording of the proceedings before the Department of Justice, Office of the Inspector General in the matter of: Interview of Marci Bratton, Transcriber EFTA00114400 A Ability - 97:15, 97:16 Able - 23:11, 23:25, 141:25, 153:12, 153:15, 182:22, 195:2, 205:4 Abnormal - 149:24, 150:1 Above - 5:19, 40:12, 98:20, 135:9, 169:7, 202:2, 202:11, 203:4, 212:8 Abreast - 114:20 Absolutely - 22:3, 64:19, 133:16, 133:23, 170:14, 187:7 Abuse - 200:14 According - 25:20, 60:25, 79:16, 80:16, 100:17, 103:7, 103:10, 109:16, 196:25 Accordingly - 5:11 Account - 20:2, 36:3, 72:12, 96:24, 98:16 Accounted - 97:4 Acknowledge - 137 :2 Across - 60:15, 118:10 Act - 5:8 Action - 5:13, 61:7, 61:11, 61:13, 62:2, 117:11, 120:14, 130:17, 131:10, 138:13, 157:1, 157:2, 180:24 Actively - 141:12 Activities - 48:1, 73:5, 73:8 Acts - 160:1 AD - 155:23. 155:25 Added - 35:17 Adding - 93:15 Addition - 19:25, 20:20, 21:4, 35:24, 36:12, 105:15, 114:6 Additional - 22:9, 35:16, 159:2 Address - 7:7, 93:13 Addressed - 104:7 Adequate - 98:21, 114:8, 125:24, 131:2 Adjacent - 51:16 Administrative - 20 :1, 64:8, 156:2 Administrator - 119 :25 Advise - 36:5, 97:24, 126:22 Advised - 107:6 Afternoon - 24:24 Afterwards - 45:19 Against - 5:13, 5:23 Agency - 5:16 Agent - 3:5, 3:23, 4:5, 4:8, 4:10, 6:10, 128:12, 196:20, 216:2 Agents - 17:10 Ago - 167:16 Agree - 4:20, 122:8, 203:10 Ahead - 21:9, 163:21 Air - 114:23 Alarm - 114:10 Alarms - 15:13, 22:23, 105:21 Alert - 60:13 Alerted - 63:24 Alike - 215:4 Alive - 36:19, 38:18 Allegation - 159:25 Allow - 151:12, 157:14 Allowed - 81:13, 155:18, 155:19, 156:8, 156:10, 157:9, 158:10, 158:14, 158:19 Along - 165:23 Alphabetical - 53:1 9 Alphabets - 75:21, 75:22 Already - 11:11, 15:15, 19:2, 67:19, 87:22, 128:12, 128:25, 129:7, 161:22, 190:6, 197:20 Alright - 8:7, 10:18, 34:23, 80:18, 106:10, 124:10, 135:7, 211:16, 215:12, 215:25 Also - 3:22, 5:3, 6:11, 24:10, 28:7, 29:14, 36:15, 41:6, 41:20, 62:10, 72:24, 167:3, 183:14, 187:21, 192:17, 197:23, 204:10, 205:25 Alter - 9:24 Although - 106:4, 196:21 Altogether - 9:8, 82:1 Always - 35:5, 38:9, 40:13, 128:9, 136:9, 142:9, 157:17, 159:5, 193:15, 202:5 Am - 4:8, 5:20, 6:9, 6:14, 131:22, 216:2 Amended - 5:8 Amount - 114:1, 157:11 And/Or - 5:17 32:22 Announce - 16:9 Announced - 190:2 4 Answer - 5:12, 5:14, 5:20, 64:25, 86:2, 95:2, 98:21, 116:14, 133:15, 187:16, 195:12 Answered - 149:5, 149:7 Answering - 30:23, 188:3 Answers - 4:19, 7:2, 187:1 Antagonize - 122:1 2 Anybody - 15:11, 17:1, 17:2, 39:23, 64:6, 68:11, 107:20, 113:11, 113:14, 136:7, 213:7 Anymore - 129:16 Anyone - 125:1, 135:3, 151:17 Anyway - 64:5, 205:20 Apartment - 7:9 Apologize - 55:12, 138:4 Apparently - 82:8, 136:23, 182:18 Appeared - 166:6 Appears - 25:18 Appreciated - 133:1 1 Appropriate - 53:1 Approved - 157:20 Approximately - 3: 2, 3:19 Area - 20:6, 20:7, 36:10, 60:15, 78:13, 79:8, 79:13, 81:6, 93:14, 98:5, 142:18, 149:10 Areas - 100:1, 100:2 Aren't - 65:3, 196:19, 201:23, 204:18, 205:21 Arrangements - 13 0:7 Arrived - 64:1 Arrives - 19:22 Aside - 51:18, 108:1 Ask - 7:1, 16:17, 23:10, 38:7, 39:6, 41:13, 45:2, 52:9, 60:17, 80:11, 81:16, 130:13, 160:3, 179:6, 182:8, 187:18, 215:15 Asked - 4:18, 5:4, 36:22, 68:24, 95:4, 144:14, 161:14, 162:6, 180:20, 215:16 Asking - 23:22, 43:25, 47:3, 80:6, 83:14, 89:24, 127:11, 129:10, 129:17, 148:17, 148:18, 154:20, 168:25, 169:4, 184:5, 184:7, 187:8, 187:11 Assessment - 134: 12, 134:14 Assign - 16:11, 68:17, 119:17 Assignment - 8:25, 24:21, 29:4 Assist - 22:6, 22:10, 22:25, 33:13 Assume - 67:6 Assumed - 107:2 Assuming - 61:24, 65:24, 65:25, 67:1, 112:14, 115:9, 167:18, 168:8, 209:22 Assurances - 4:25, 5:19 Assure - 105:2, 106:8, 133:13 Attach - 189:1 Attached - 28:4, 183:9 Attempted - 48:15, 63:22, 65:10, 121:3, 121:5, 121:7, 126:17, 152:7, 159:21 Attempting - 164:2 2 Attention - 82:4, 85:22 Attorney - 99:16, 100:21, 157:23, 158:1 Authority - 202:10 Authorization - 98: 15 Automatically - 65: 21 Available - 16:6, 16:8, 23:5 Average - 16:19 AW - 191:13, 209:20 Awesome - 124:9 Aws - 40:15, 212:6 B Background - 7:6, 41:23 Bad - 21:22, 22:4, 23:2, 23:3, 23:4, 142:9 Bag - 203:2 Balances - 14:13 Ball - 107:18, 107:20 Barrel - 15:9 Base - 79:12 Based - 60:19, 60:20, 61:3, 63:12, 69:15, 76:5, 78:18, 90:16, 130:5, 183:22 Basic - 138:25 Basically - 22:10, 121:14, 134:9, 155:6, 181:16, 214:6 Basis - 5:2, 37:8, 38:14, 159:12, 201:10 Bear - 12:12 Beast - 127:15 Become - 57:6 Begin - 65:6, 108:8, 120:5 Behind - 71:16, 128:5 Belief - 6:23 Below - 15:9 Bene - 112:4 Bent - 114:20 Best - 6:22, 32:13, 83:18, 113:3, 123:20, 127:8, 203:5 Better - 203:8 Between - 13:15, 22:14, 27:15, 28:13, 28:17, 33:19, 37:24, 101:19, 101:23, EFTA00114401 108:16, 115:9, 119:3, 119:8, 119:10, 130:18, 154:11, 201:22, 210:21, 213:7 Big - 110:18, 153:22, 153:24, 154:3, 154:9, 154:17, 154:25, 155:3, 155:5 Bin - 210:12 Birth - 7:12 Bit - 7:6, 179:2 Blame - 200:15 Board - 118:10 Bodies - 85:25, 86:17 Body - 15:13, 22:23, 86:19, 86:20, 86:22, 105:20, 114:10 Book - 181:7 Books - 102:22 Bop - 7:24, 8:14, 8:25, 10:9, 129:16 Both - 5:17, 21:12, 24:18, 27:16, 73:6, 73:8, 142:5, 147:21, 163:15, 167:19, 167:21, 167:22, 175:16, 212:21 Bottles - 158:11, 158:15 Bottom - 15:9, 63:8, 70:14 Boxes - 108:9 Brain - 215:5 Branch - 8:3 Break - 9:15, 9:18 Breakdown - 107:8, 110:20, 125:5 Breathing - 49:20, 72:7 Bring - 79:5, 188:24 Broke - 180:16 Brooklyn - 7:9 Brought - 36:11, 47:6, 69:7, 82:4, 85:21 Bu - 137:7 Building - 64:7, 170:15, 174:14, 193:1, 193:7 Bunch - 17:2, 105:16, 105:20, 128:3, 133:9 Bureau - 3:11, 8:8, 15:23, 17:25, 129:22, 204:23 Business - 133:19, 147:23, 183:11 Busy - 30:19, 113:22 C C3D - 7:9 California - 18:20 Calling - 30:25, 31:20, 31:21, 32:5, 32:7, 32:19, 84:14, 85:5, 85:16, 93:18, 93:19, 181:15, 198:14, 205:21 Calls - 30:22, 30:23, 134:20 Camera - 140:7, 141:16, 142:2, 142:7, 142:8, 142:10, 142:14, 142:16, 144:23, 145:6, 145:22, 145:25, 146:10, 146:13, 148:21, 148:23, 148:25, 149:16 Cannot - 81:12, 153:4, 153:6 Capable - 149:11, 183:24 Captains - 13:22, 212:7 Captain's - 206:21 Caption - 134:6, 135:24 Care - 31:1, 114:7, 117:15, 129:8, 129:10, 147:7, 153:5, 197:18 Career - 18:3, 19:7 Carried - 81:8 Carry - 202:7 Carrying - 202:8 Case - 37:1, 89:6, 89:8, 91:15, 109:14, 177:16, 179:13, 213:1 Cats - 69:22, 135:18 Caught - 85:14 Cellmates - 120:21, 120:23 Cells - 20:7, 20:15, 36:19, 76:18, 152:15 Center - 3:22, 21:17, 21:21, 32:19, 91:11, 92:25, 139:18, 143:18, 176:19, 188:25, 190:5 Central - 135:19 Certain - 39:22, 42:25, 64:14, 183:23, 202:10, 202:14, 202:19 Certainly - 203:7 Certified - 168:8 Certify - 168:11 Certifying - 175:4 Chain -40:16, 63:10, 97:23, 175:13, 193:23, 197:14, 204:19, 211:7, 211:9 Chances - 195:4 Change - 159:10, 159:11 Changes - 158:18, 179:11 Chaos - 193:8 Charge - 175:15, 175:25, 205:16 Check - 58:14, 90:15, 90:21, 179:20 Checked - 108:9 Checks - 14:13, 22:19 Chest - 166:8 Choose - 5:13, 90:4 Choosing - 117:20 Chose - 90:16, 105:4 Circle - 28:1, 34:5, 34:6, 62:1 Circling - 27:20 Circumstance - 114 :25, 124:13, 187:23, 189:12, 189:13, 189:22, 190:10, 190:12 Circumstances - 58 :20, 126:6, 130:3, 130:4, 150:5 Claiming - 167:2 Clammy - 166:8 Clarification - 96:22 , 99:2 Clarified - 36:7 Clarify - 35:8, 45:4, 46:14, 47:4, 60:19, 70:15, 71:17, 80:13 Clear - 83:19, 83:23, 89:14, 113:8, 128:15, 148:15. 178:14, 200:24 Clearly - 200:19, 214:21 Clicked - 106:6 Clock - 59:25, 160:25 Close - 49:14, 134:19, 134:20, 153:19, 154:23, 166:17 Closer - 123:3 Closest - 153:3 Clothing - 158:19, 158:24, 159:1, 159:2 CO - 42:5, 56:9, 56:11, 56:14, 56:16, 56:18, 56:20, 56:22, 56:24, 65:24, 69:5, 96:23, 115:10 Coercion - 5:22 Collect - 190:19 Collected - 33:5, 190:6 Collectively - 147:1 4 College - 7:22 Comes - 128:2, 170:2, 176:18, 177:2, 190:4 Coming - 12:23, 18:16, 19:4, 42:12, 62:23, 66:22, 66:24, 67:3, 67:21, 98:6, 130:1, 130:5, 130:6, 202:2 Command - 63:10, 97:23, 175:14, 193:23, 197:15, 211:9 Commit - 48:15, 121:11, 126:17, 164:16, 164:19, 167:4 Committed - 119:19 , 152:6 Committee - 54:2 Common - 20:7, 142:18, 196:16 Communicate -15: 1, 15:6, 40:22, 41:2, 42:3, 108:6 Communicated -1 4:25, 15:8, 202:3 Communication -1 07:7, 110:20, 113:6, 125:4, 145:18 Communications - 132:23, 147:5, 147:6, 147:13, 147:17, 148:16, 148:24, 150:17, 162:3, 162:12 Companions - 122: 9, 122:12 Compare - 21:14, 36:3 Compared - 20:18, 20:21, 21:5, 35:25 Complain - 39:4 Complaining - 39:3 Complaints - 102:6 Complete - 20:11 Completed - 21:16 Completely - 114:1 4 Completing - 82:7 Completion - 20:15 Computation - 75:3 Computer - 105:11, 143:7, 205:14 Concerning - 64:19 , 150:5, 194:20, 215:18, 215:19 Conducing - 36:16 Conduct - 23:7, 70:18, 70:20, 71:6, 72:4, 72:11, 72:15, 72:25, 133:10, 147:23, 171:7 Conducting - 72:22 , 89:15, 89:17, 89:21, 90:9, 169:18, 171:17, 171:23, 172:1 Conference - 99:17, 100:21, 157:23, 158:1 Confident - 170:1 Conscious - 49:15 Consider - 64:3 Considering - 65:7 Consistency - 200: 25 Consolidated - 187: 17 Constant - 193:3, 193:5 Contact - 189:3, 190:2, 190:12, 190:14, 193:19, 214:4 Contacted - 69:17, 131:12, 190:18, 212:3 Continue - 22:12, 35:20, 87:16, 127:21, 157:5 Conversation - 55: EFTA00114402 1, 55:13, 102:10, 102:12, 126:19, 126:22, 135:23, 136:7 Conversations - 38 :6, 54:15, 56:8, 125:1, 135:24, 136:5 Copy - 182:22 Corner - 153:15 Corrected - 82:12, 83:11, 184:4, 187:24 Correcting - 184:3, 186:23 Correction - 3:21 Correctional - 3:11, 9:21, 9:25, 10:10, 18:3, 41:1, 56:6, 119:25, 200:17 Coulda - 125:23 Couldn't - 49:17, 156:17 Counselor - 10:11, 10:13, 10:19, 11:11, 18:25 Counted - 21:12, 21:24, 77:21, 81:5, 81:20, 88:14, 97:11 Counting - 77:19, 79:24, 81:2 Couple - 16:17 Course - 14:8, 14:18, 15:5, 83:13, 90:19, 93:10, 93:12, 106:23, 127:20, 127:25, 128:4 Court - 47:6, 47:18, 47:19, 62:21, 78:10 Courts - 64:12 Cover - 113:10, 186:25 Covered - 197:16, 197:22 Cracks - 201:22 Create - 188:11, 188:12 Created - 182:13, 182:15, 183:1, 188:7 Credentials - 3:8, 4:1 Criminal - 5:16 Critical - 58:18 Cuff - 133:22, 135:15, 201:3, 201:15 Current - 7:7, 7:17, 194:7 Currently - 3:2, 10:11, 12:10, 16:14, 24:20, 200:3, 215:25 Custody - 29:6, 29:14, 32:24, 120:16, 156:5, 157:4 D Dah - 83:16 Daily - 14:6, 35:9, 140:1, 201:10 Damn - 122:13 Danger- 205:1 147:25, 148:1, 150:14 Date - 7:11, 8:20, 27:23, 28:1, 34:8, 34:12, 34:15, 42:17, 48:18, 48:20, 53:2, 54:11, 54:13, 64:10, 101:5, 101:6, 137:23, 152:10 Dating - 6:13, 27:20 Days - 16:24, 16:25, 65:16, 149:18, 163:9 Daytime - 158:8 Dead - 126:2 Deal - 80:7, 182:2 Dealt - 59:10, 127:19 Death - 4:16, 126:10 December - 8:12, 10:24, 18:1 Decided - 203:8 Decision - 201:14, 203:3 Decisions - 201:3, 202:2, 202:15, 202:17 Defined - 200:24 Definitely - 42:8, 42:10, 59:3, 60:1, 69:20. 69:24. 204:14 Delivered - 27:13, 157:24, 157:25, 178:25 Delivering - 43:4 Department - 3:5, 3:16, 29:7, 32:24, 147:22, 148:24 Departments - 200: 18 Depended - 43:5 Depending - 73:18, 97:2, 97:8, 97:10, 128:3, 130:1, 149:6, 156:7, 164:11, 185:13, 189:21 Depends - 12:7, 13:7, 27:10, 35:10, 39:15, 41:24, 42:6, 43:3, 45:9, 48:2, 79:22, 95:22, 115:16, 149:4, 155:21, 189:9, 194:17 Depth - 201:12 Described - 18:5, 19:18, 20:4 Describing - 19:25 Designated - 100:2 Desk - 124:2, 152:22, 152:25 Desks - 144:4 Details - 40:20, 40:24, 215:16 Detention - 156:2 Determine - 24:1, 68:6, 130:4 Determined - 65:11, 67:20, 176:4 Detour - 73:25 Didn't' - 81:23, 90:22, 98:15, 114:8, 132:17, 158:7, 167:4, 172:11, 172:16, 185:4, 214:18 Die - 45:23 Died - 138:2 NM' Difference - 22:13, 108:16, 119:2, 119:7, 119:9, 154:10 Differently - 108:18 Difficult - 65:15 Dint - 186:17 Direct - 187:18 Direction - 159:14 Directly - 42:4, 59:12, 61:5 Director - 119:24 Disbelieve - 87:19 Discharge - 29:7, 76:18 Disciplinary - 5:12, 5:16, 120:14, 156:3, 156:25, 157:2 Discuss - 40:20, 40:25, 132:19, 132:25 Discussed - 27:21, 28:3 Discussions - 135: 2 Disseminate - 205: 11 Disseminated - 201 :18, 205:6 Disseminates - 209 :25 Disseminating - 20 4:4 Distractions - 41:22 Document - 27:18, 28:6, 52:14, 54:13, 74:23, 75:18, 76:5, 95:6, 99:4 Documents - 28:3, 73:25, 76:3, 95:5 Does - 12:20, 36:6, 47:14, 51:6, 96:23, 106:11, 134:8, 142:15, 146:25, 149:15, 149:18, 170:24, 171:3, 173:5, 175:19, 176:14, 210:25 Doesn't - 32:12, 60:16, 73:6, 111:1, 129:16, 129:18, 142:19, 151:10, 198:1, 198:18, 199:21, 208:23, 209:1, 210:13 Doesn't' - 169:7 DOJ - 3:22, 4:8, 4:15, 4:20, 4:24 Donald - 119:21, 119:23 Don't' - 8:19, 164:4, 165:25, 166:21, 166:25, 167:11 Doors - 131:4 Double - 16:15, 90:20 Doubt - 67:4, 170:15, 170:17 Downs - 127:12 Downstairs - 74:12, 161:1 Drop - 190:5 Dropped - 107:18, 107:20 Drugs - 114:2, 114:3 Dry - 77:4, 77:8, 77:11, 77:14 DS - 156:1 Dude - 82:13, 117:14, 179:9, 179:18, 182:7 Due - 162:22 33:25 Durant - 55:24 Duties - 14:6, 14:12, 18:5, 19:18, 20:1, 22:15, 22:24, 72:17, 173:20, 188:15, 202:9, 215:9 Duty - 16:15, 23:20, 63:11, 101:25, 196:20, 196:24 Dying - 135:8, 137:25, 138:2 E Earlier - 101:2 Early - 141:19 Ears - 90:22 Easier - 41:9, 41:12 Eb - 166:6 Education - 7:21 Effect - 178:16 Effective - 42:17 Effort - 210:9 Efren - 57:7, 57:8, 60:21, 61:1, 61:7 Eh - 30:25, 45:18 Eight - 8:6 Either - 33:8, 42:15, 58:4, 65:13, 97:10, 164:11, 168:20, 171:6, 171:20, 214:9 Elevator - 22:17, 165:22 Emails - 105:12, 105:15, 105:23, 106:7, 192:14, 192:18, 192:20, 193:4, 193:11, 205:14, 206:3 Emergencies - 39:2 Emergency - 161:5, 165:21 107:24 Employed - 17:25 Employee - 4:25 Employees - 89:17, 89:19 End - 133:12, 194:24, 195:22, 202:10 Engaging - 159:25 Enough - 15:12, 123:12, 199:23, 201:12, 208:5 Ensure - 174:25, 188:7, 194:9, 211:14 Ensured - 188:4, 211:14 Ensuring - 211:23 EFTA00114403 Entire - 18:2, 26:22 Environment - 123: 10, 123:20 Epstein's - 57:13, 63:18, 115:8, 152:25 Equal - 175:16 Equally - 167:20 Error - 82:22, 184:19 Escorting - 47:25 Especially - 15:6, 15:7, 15:14, 121:3, 177:8, 210:14 Evening - 24:24, 25:16, 26:5, 26:12, 29:11, 35:13, 44:21, 70:18, 111:25, 112:4, 150:25 Eventually - 50:22 Everyone - 4:6, 109:21, 110:2 Everyone's - 163:2 5, 164:2 Everything - 4:17, 38:18, 72:9, 102:5, 114:6, 115:2, 118:22, 126:9, 127:13, 133:14, 135:13, 164:2, 192:24, 196:15, 200:15, 201:1, 204:20 Everywhere - 26:25 , 27:2 Evidence - 5:15 Exact - 8:20, 48:20, 196:15 Exactly - 22:14 Example - 190:9 Exceed - 18:18 Exchange - 20:12, 158:24 Excuses - 113:14 Executive - 51:25, 54:2, 117:19, 135:19 Exhausted - 16:4 Exhibit - 24:11, 24:12, 34:19, 34:20, 34:22, 35:6 Exhibits - 34:22, 35:3 Exist - 205:3 Existed - 205:2 Expect - 23:21, 40:9, 58:21, 58:24, 59:1, 59:3, 200:16, 201:17, 202:13 Expected - 184:17, 184:20 Expired - 18:21 Explain - 97:14, 116:17, 127:3 Explained - 36:8, 70:14, 72:20, 178:24 Explanation - 127:5 , 127:7, 127:8 Extended - 150:10 Extension - 51:14, 77:15 Extra - 22:5 Eye - 166:15 Eyes - 22:10, 49:14, 81:11, 90:21, 91:13, 96:25, 97:19, 123:4, 124:6, 124:8, 143:20, 154:21 166:18 F Faced - 120:14 Facility - 18:4 Failed - 120:3 Failure - 5:10 Fair - 134:11, 134:13, 199:23 Fall - 38:17, 156:22 Falling - 201:22 False - 168:13, 168:15, 187:1 Falsification - 172: 25 Falsifying - 169:1, 203:12, 203:16 Familiar - 48:4 Far - 26:7, 37:2, 37:15, 38:12, 98:19, 106:25, 130:14, 139:19, 141:23, 145:1, 148:20, 164:20, 169:22, 175:10, 200:5, 214:20 Favor - 101:4 FCI - 9:1, 11:2 Federal - 3:10, 8:8 Feed - 162:7 Feeding - 161:18, 162:9 Feel - 64:18, 64:20, 64:23, 108:5, 184:23 Feelings - 160:4 Feet - 126:2, 153:2, 154:11 Felt - 90:20 Female - 51:16, 51:17 Females - 160:1 Fernandez - 76:21 Few - 38:23, 39:11, 56:6 Field - 3:7 Fifth - 19:8 Fighting - 114:4 Figure - 89:1, 125:4, 131:19, 182:3 File - 36:5 Fill - 17:2, 17:23, 32:11, 87:24, 90:24 Filled - 182:11, 184:20, 184:23 Find - 75:12, 124:12, 172:10, 172:14, 179:9, 184:8, 184:10, 184:13, 186:19 Finding - 114:1 Fine - 8:24, 102:8, 115:3 Finish - 161:2, 161:3 Finishing - 160:20 First - 5:2, 8:25, 25:6, 53:9, 53:10, 62:14, 63:7, 64:1, 69:16, 118:15, 122:2, 129:12, 150:19, 165:20, 165:22, 167:24, 204:22, 205:8 Five - 35:15, 74:18, 74:20, 127:24 Fix - 34:17, 149:1, 150:2 Fixed - 95:3 Fixes - 148:21 Fixing - 147:8, 148:4, 148:6 Flat - 133:14, 133:21 Flip - 53:11, 75:13, 76:2, 100:18 Floor - 3:20, 26:19, 49:11, 51:9, 51:10, 51:17, 51:18, 76:19, 166:6, 178:16 Focus - 43:21, 44:17 Follow - 17:21, 38:23, 58:21, 59:2, 60:17, 89:22, 108:15, 146:12, 163:18, 172:24, 188:21, 197:19 Followed -67:18 Following - 56:5, 175:13 Fooling - 122:21, 122:23 Foot - 154:11 Force - 114:9 Forces - 15:14, 114:8 Forget - 121:6, 127:22 Forgot - 215:15 Form - 4:24, 4:25, 6:9, 27:25, 128:13, 200:24 Formal - 201:6 Fort - 7:8 Forth - 214:25 Forward - 6:1, 35:8, 35:22, 69:1, 213:10 Found - 46:3, 46:5, 61:7, 82:21, 82:23, 118:12, 172:18, 202:20 Four - 18:23, 74:11 Fresh - 114:23 Friday - 24:21, 25:3. 27:14, 46:9, 46:16, 46:17, 46:19, 111:8 Front - 105:11, 187:17, 206:18 Furnish - 5:15 Future - 5:15 G Gate - 20:6, 20:13, 20:16 Gave - 23:19, 97:2 Geared - 92:17 General - 3:6, 3:17, 5:6, 5:8, 22:24, 39:6, 119:10, 156:14, 160:3, 200:8, 200:9, 200:10 Generally - 25:24, 42:13, 42:18, 42:21, 47:23, 188:23 Georgia - 11:6, 11:7 Getting - 38:12, 41:16, 41:18, 53:6, 82:19, 94:21, 114:5, 147:7, 149:13, 177:16, 186:2, 201:23, 211:21 Ghitto - 56:14 Ghost - 97:13 Ghosted - 81:16 Give - 20:24, 21:19, 36:2, 40:8, 40:10, 62:14, 127:7, 127:8, 175:20, 202:18 Given - 18:17, 51:24, 97:12, 135:16, 159:1, 168:2 Giving - 88:25 Glance - 140:6 Glencoe - 8:16 4:12. 6:16 God - 47:2 Goes - 37:15, 68:8, 148:21, 149:16, 193:20, 201:1, 207:15 Gone - 16:5, 21:11, 62:21, 63:10, 64:13, 65:22, 104:3, 107:25, 112:13, 116:24, 129:3, 162:9, 191:23, 192:14 Good - 21:22, 36:5, 79:14, 86:2, 102:6, 115:5, 196:16 Gotcha - 94:2, 186:14 Gotten - 81:1, 165:10, 165:12, 165:14, 181:2, 193:11 Grab - 190:8 Graduate - 8:13 Great - 27:1, 27:17, 34:2, 191:4 66:16, 69:21 Group - 53:15, 69:17, 104:8, 104:9, 104:15, 104:20, 104:21, 137:12 Grueling - 17:4 GS9 - 11:12 Guaranteed - 64:6, 119:14, 121:17, 121:19, 205:12, 205:15 Guard - 20:8, 20:11, 20:12, 20:13, 20:15, 36:11 Guards - 19:20, 20:5, 20:8, 20:22, 21:6, 36:1, 36:9, 36:15, 36:17 Guidance - 39:12, 68:4, 68:13, 77:20, 96:4, 201:6 Guided - 97:8 Guidelines - 38:8, 38:17 Guides - 201:6 Gun - 202:20 Guy - 82:13, 83:10, 83:24, 85:7, 86:13, 86:23, 87:22, 89:2, 134:17, 179:12, 180:1, 180:3, 180:4, 182:2, 182:5, 182:6 EFTA00114404 Guys - 69:20, 84:1, 102:24, 114:14, 134:17, 136:9, 136:12, 145:18, 147:12, 172:5, 183:23, 198:4 Guys' - 85:22 Guy's - 85:18 H Hadn't - 77:19, 92:13, 181:2 Half - 37:20, 90:23 Halfwa - 101:19 Hand - 6:19, 62:11, 117:20, 138:3 Handed - 105:23 Handing - 34:16 Handle - 194:21, 195:2, 215:3, 215:6 Handled - 195:23, 215:7 Handling - 30:22 Hands - 110:7 Hang - 121:24, 122:13, 170:7 Hangover - 38:1 Happen - 38:19, 45:17, 47:14, 64:19, 126:11, 126:14, 135:16, 176:15, 177:12, 196:12, 202:22 Happened - 49:25, 50:24, 83:9, 94:8, 98:12, 106:23, 108:3, 113:21, 126:9, 126:23, 127:14, 128:4, 129:17, 185:25, 195:22, 200:12, 210:15 Happening - 60:7, 136:8, 139:1, 200:4 Happens - 47:15, 63:25, 188:23, 196:15, 210:1 Hard - 13:23, 38:7, 38:17 Harm - 109:4 Hashed - 82:25 Hat - 160:11 Haven't - 19:6, 74:9, 192:22 Having - 47:5, 58:4, 105:16, 106:25, 143:19, 159:25 Head - 80:23, 98:2 Hear - 18:7, 18:13, 19:15, 160:16, 164:21 Heard - 45:17, 47:7, 90:18, 103:3, 104:9, 151:16, 160:23, 161:4, 171:15, 171:19 Hearing - 151:1 Held - 10:9, 12:9, 12:10 Hell - 114:19 Help - 161:17, 162:7 Helpful - 111:7 Her - 18:2, 18:6, 19:25, 23:11, 28:12, 36:25, 55:10, 138:13, 162:6, 162:10 Here's - 184:16, 185:1 Hey - 84:15, 107:6, 110:25, 117:14, 134:16, 135:9, 137:3, 172:5, 190:8, 197:17, 197:24, 198:16, 199:20, 207:19, 210:9, 212:3, 212:17 Hierarchy - 175:15, 175:21 High - 63:22, 65:7, 65:8, 68:19, 117:22, 119:16, 122:17 Higher - 54:5, 69:8 Highest - 7:20, 214:5, 214:6 Hijacking - 138:5 Himself - 49:7, 86:24, 97:10, 109:4, 121:25 Hire - 14:11 Hm - 94:9 Hmm - 10:17, 17:8, 39:9, 45:13, 74:15, 74:21, 95:14, 113:19, 138:24, 152:21 Hodge - 201:1 Hold - 38:6, 59:6 Holding - 76:18, 155:14, 156:21, 203:2 Hole - 41:15 Holes - 17:22, 47:24 Holidays - 35:16, 35:18 Home - 7:7, 205:14 Honest - 58:1, 60:2, 88:24, 105:14, 125:11, 156:24, 157:13, 157:19, 171:12, 191:17, 192:9 Hot - 157:24 Hour - 37:7, 37:10, 37:20, 65:23 Hours - 13:9, 13:13, 13:15, 16:16, 16:18, 28:13, 30:1, 31:4, 31:16, 130:18, 196:19 House - 93:13 Housed - 53:1, 76:7, 76:17, 77:17, 79:8, 80:3, 170:6, 192:8 Huge - 155:1 Hurt - 49:7 Hurting - 39:5 Hyphen - 4:13 I Idea - 73:15, 74:2, 94:19, 94:20, 146:14 Identify - 4:6, 23:11, 28:9, 28:23, 78:13, 176:19 Ignored - 69:22 I'll - 3:8, 5:3, 13:16, 18:14, 21:3, 27:9, 54:10, 62:14, 62:25, 101:13, 102:23, 102:24, 138:3, 157:5, 179:19, 186:24, 190:7 Illegal - 72:7 Immediate - 40:18, 117:11 Immediately - 67:23 Implemented -174: 24 Important - 40:19, 40:24, 60:4, 119:6, 122:18, 123:16, 138:21, 167:19, 167:20, 167:22, 167:23, 193:13, 193:17, 203:22, 205:19, 207:4, 210:8, 215:16 Importantly - 193:1 2 Inaccurate - 180:25 Inches - 154:1, 154:2, 155:15 Incident - 48:23, 55:5, 113:20, 160:17, 161:21, 162:4, 164:15, 165:10, 174:12, 174:20 Incidents - 105:17, 114:11, 177:13 Include - 26:23 Includes - 75:4 Inclusive - 30:19 Independently - 16 7:22 Indicate - 82:2 Indicates - 186:5 Indicating - 194:21 Indiscernible - 6:7, 62:16, 78:8, 138:15, 151:4, 199:25 Individual - 39:20, 42:2, 74:17, 90:1, 90:15, 124:1, 206:25, 214:22 Individually - 41:10, 58:13, 59:4 Individuals - 64:15 Informed - 17:24, 36:15, 49:6, 68:20, 124:18, 199:19, 207:20 Informing - 181:17 Initial - 27:25, 34:7, 54:11, 54:13, 101:6, 101:8 Initialing - 27:19 Initially - 63:13, 63:16, 79:23, 102:20 Inmate's - 211:23 Inside - 20:10, 72:8, 139:4, 140:16, 153:6, 153:8, 161:25, 175:18 inside3 - 155:19 Inspector - 3:6, 3:17, 5:6, 5:7 Instance - 26:16, 32:1, 91:15, 92:1, 116:22, 125:15, 130:12, 132:11, 144:13, 168:4, 212:18 Instances - 205:3 Instead - 63:6 Institutions - 205:2 Instructed - 87:7 Instructing - 52:10 Instruction - 52:5, 97:3, 196:7 Instructional - 196: 7 Instructions - 39:12 , 40:7, 40:11, 40:25, 41:3, 42:25, 47:5, 51:24, 88:7, 97:12, 97:20, 128:13, 128:15, 128:16, 148:16 Intake - 77:22, 78:3 Intel - 202:19 Intentions - 64:17 Interact - 151:20, 151:21 Interacted - 152:7, 159:19 Interaction - 152:6, 159:17 Interactions - 152:4 , 158:7 Intercom - 16:9, 190:24 Interfere - 78:22 Internals - 21:23 Interrupt - 18:14 Interview - 3:10, 3:19, 4:4, 4:20, 5:11, 6:2, 6:17, 6:21, 18:4, 19:17, 38:22, 39:11, 72:21, 72:24 Interviewed - 3:15 Interviews - 109:19, 133:9 Into -4:16, 20:9, 21:25, 30:16, 43:13, 44:18, 101:14, 103:21, 134:19, 179:17, 194:4, 204:23 Investigation - 3:18 , 4:16, 5:5, 5:6, 5:9, 17:10, 60:21 Involved - 42:24, 47:21, 47:25, 120:1, 164:14, 208:15 Irregular - 37:3, 37:8, 37:17, 38:4, 38:14 is1541 - 99:6 Island - 9:1, 9:3, 9:19 Isn't - 103:25, 121:8, 170:21, 186:18 Issue - 76:12, 76:14, 78:19, 82:12, 84:5, 110:18, 126:18, 130:24, 176:14, 176:16, 193:3, 193:6 Issues - 36:19, 159:15 Items - 155:19, 156:7, 157:9, 157:11 It'll - 76:4, 196:12 Its - 37:15 Itself - 188:14 EFTA00114405 I've - 11:22, 12:10, 13:23, 19:12, 53:9, 53:10, 80:11, 93:7, 122:11, 123:9, 128:1, 136:6, 152:5, 154:7, 156:14, 183:22, 187:23, 192:3, 192:4 J Jay - 55:24 Jean - 56:1 Jeffrey - 4:16, 48:5, 60:22 Jermaine - 55:7 Jessant -11:3 Jessup - 11:2, 11:4, 11:5, 11:6, 11:13, 11:16, 12:2, 19:2 Jesus - 151:3 Job - 5:9, 120:3, 139:6, 140:1, 148:11, 193:4, 202:13, 202:14, 214:24 Joiner - 66:16 Judgment - 196:17 July - 10:15, 10:16, 48:20, 48:21, 53:4, 57:20, 103:19, 164:14, 210:14, 210:22, 213:4 Jump - 138:7, 138:18, 150:22 June - 3:2, 3:18, 216:1 Justice - 3:6, 3:17 Justify - 131:20, 131:23 K I Keep - 13:23, 19:14, 38:8, 48:4, 65:2, 76:4, 100:23, 118:24, 122:20, 123:19, 133:10, 134:17, 134:18, 187:17, 193:3 Kept - 185:12 Key - 14:24, 20:11, 98:8 Kill - 164:22, 167:2, 167:7, 170:8 Kind - 5:23, 49:13, 68:4, 82:25, 134:7, 154:23, 155:18, 156:21, 166:8, 166:16, 200:11 Knowing - 98:5, 135:13, 146:6, 169:6, 169:21, 169:22 Knowledge - 6:23, 36:23, 106:25, 214:22 Known -47:4, 63:3, 63:4, 63:9, 63:13, 63:16, 63:17, 122:11, 129:13, 132:9, 181:22, 191:18, 207:21, 208:6, 213:15 Knows - 60:4, 60:8, 60:17, 193:16, 205:23, 206:5 L Lapse - 60:7 Large - 154:22 Last - 3:23, 4:7, 159:18 Late - 16:25, 141:18, 160:19 Later - 101:20, 106:23 Lateral - 11:12, 12:3 Layout - 153:2 Lead - 176:6 Least - 17:5, 41:17, 80:21, 91:6, 107:6, 137:2, 137:16, 210:8 Leave - 11:22, 12:24, 13:5, 21:13, 45:7, 65:17, 96:17, 96:19, 160:10, 188:17 Leaves - 96:18 Leaving - 78:7, 78:10, 100:4, 126:19, 131:21 Legal - 151:12, 151:17 Lets - 41:20 Letting - 134:15, 211:10 Level - 7:20, 135:20, 202:11, 203:4, 214:6 - IM Lieutenants' - 40:2 Lieutenant's - 18:2 2, 59:6, 67:12, 67:15, 67:16, 98:2, 139:22, 139:23, 142:3, 143:14, 143:17 Life - 203:7 Light - 153:12 Likely - 53:15, 163:6 Limited - 157:11 Line - 35:22, 41:8, 119:23, 151:10, 151:12, 151:17 Linens - 158:19 Lineup - 99:11 List - 16:7, 20:19, 20:22, 21:5, 35:25 Literally - 50:7 Lithe - 7:6, 10:4, 37:25, 114:20, 154:24, 179:1, 196:8 Live - 38:18, 141:24 Load - 202:7, 202:8 Loaded - 202:20 Logging - 81:6 Long - 8:7, 9:2, 10:2, 11:15, 50:18, 50:19, 83:15, 123:12, 167:16, 214:23 Looking - 24:21, 27:19, 29:3, 49:13, 49:22, 63:10, 111:8, 115:21, 140:3, 140:4, 140:12, 148:19, 160:25, 179:17, 196:24 Looks - 44:7, 46:10, 100:20, 103:15, 104:8, 104:21, 109:20, 111:9, 111:11, 116:23 Lower - 74:16, 74:19 rl Lying - 49:10, 166:5 M Ma'am - 187:7 Mad - 211:14 Main - 20:6, 124:14, 138:9, 193:19 Mainly - 22:21, 78:2 Maintain - 64:7, 159:2, 166:19 Maintainin - 65:3 Making - 15:7, 38:5, 38:10, 38:20, 39:3, 39:7, 41:17, 60:9, 73:15, 73:23, 107:15, 151:2, 207:25, 211:25, 212:1 Male - 88:8 Males - 88:9 Man - 47:24 Management - 39:1 3, 51:24 Mandated - 15:21, 15:25, 17:1, 164:2 Mandations - 15:20 , 16:2 Mandatory - 16:3, 16:12, 72:14 Manifest - 188:14 Manner - 112:17, 149:13, 201:24 Mans - 22:17 Manual - 42:20, 196:7 Many - 8:5, 13:22, 16:18, 35:8, 74:7, 75:4, 79:17, 79:18, 80:19, 80:24, 81:19, 85:25, 86:16, 86:17, 127:18, 127:20, 158:18, 173:22 Map - 74:1 Mark - 24:11, 34:19, 35:3 26:6, 26:14, 27:16 Master - 20:19, 20:22, 21:5, 35:25 Match - 36:6 Matches - 36:5 Mates - 130:20 Matter - 17:14, 18:17, 129:18, 203:25 Maximum - 64:4 Maybe - 22:7, 96:21, 115:11, 117:18 MCC - 12:14, 13:18, 18:20, 19:7, 19:20, 20:2, 35:9, 36:11, 45:18, 57:8, 61:2, 64:2, 139:4, 140:16, 170:6, 200:4, 200:12 Meals - 157:24 Means - 44:10, 64:11 Meant - 137:1 Measure - 154:8 Measurements - 15 4:15, 154:18, 155:12 Medical - 27:3, 39:1, 51:11, 51:12, 51:14, 51:18, 158:16, 161:5 Meet - 17:9 Meeting - 17:12, 17:16, 59:7, 108:2 Meetings - 54:2 Member - 81:18, 96:13, 123:22, 148:22, 170:15, 170:20, 177:14, 184:2 Members - 60:11, 92:17, 123:4, 141:14, 142:6, 161:16, 171:16, 172:1, 200:16 Memo - 109:9, 165:13 Memorandum - 42: 15, 42:16 Mention - 54:14, 61:12 Mentioned - 34:7, 72:23, 103:2, 128:12, 136:1, 137:18, 138:20, 163:25, 164:24, 165:2, 191:7, 198:23, 201:25 Message - 42:5, 58:15 Metropolitan - 3:21, 18:3 Michael - 50:14, 55:22, 56:16, 56:22, 162:3 Mid - 71:5, 71:10, 71:11, 71:18, 71:19, 71:23 Midnight - 13:14, 19:21, 28:21, 28:22, 28:24, 30:12, 33:19, 44:8, 76:11, 76:13, 80:14 Might - 61:5, 76:3, 215:17 Miguel - 56:24 Military - 8:1 Mind - 27:17, 27:19, 77:21, 114:3, 127:19, 166:21, 187:5 Minute - 21:1, 31:24, 102:13 Minutes - 36:17, 37:11, 37:23, 37:24, 127:24 Miscounted - 22:8 Mispronounce - 56: 13 Miss - 31:1 EFTA00114406 Missed - 215:17 Mm - 10:17, 17:8, 39:9, 45:13, 62:24, 74:15, 74:21, 94:9, 95:14, 113:19, 138:24, 152:21 Mode - 166:19 Moment - 150:13, 159:11 Monday - 15:22, 150:2, 150:6 Monitor - 3:21, 141:12, 141:25, 142:14, 143:5, 146:19 Monitoring -65:23 Monitors - 124:2, 144:4 Month - 8:23 Months - 8:16, 9:5, 9:23 More -15:8, 16:18, 17:6, 40:3, 40:23, 53:15, 56:6, 76:3, 95:5, 99:4, 130:10, 133:7, 135:20, 137:16, 162:19, 163:6, 167:19, 187:16 Most - 27:12, 121:2, 183:25, 193:12, 209:4 Move - 6:1, 35:8, 35:22, 49:12, 54:10, 68:25, 70:17, 74:23, 78:6 Moved - 66:8, 67:22, 95:19, 98:9, 98:11, 98:13, 98:15, 136:24, 177:13 Moving - 22:18, 22:21, 95:25, 130:23 Much - 15:17, 15:18, 34:3, 62:22, 105:24, 106:1, 106:3, 114:17, 130:24, 193:6, 193:7, 214:23 MYM -104:1 Myself - 6:9, 88:25, 89:6, 89:8, 179:19, 180:11 N Name - 3:4, 3:23, 4:7, 6:4, 6:5, 6:10, 6:15, 21:20, 25:11, 28:1, 53:13, 56:13, 62:2, 75:19, 76:25, 150:20 Named - 147:25 Names - 34:6, 54:14, 54:23, 56:6, 61:4, 61:12, 70:14 Naming - 62:2 Narrow - 154:25 Nature - 30:24, 120:17, 127:15, 158:1 Navy - 8:4 Necessarily - 215:3 , 215:6 Neck - 166:10, 166:12, 166:23, 167:5, 167:14 Needed - 33:15, 42:23, 52:10, 58:7, 90:12, 90:20, 102:25, 109:23, 109:25, 135:5, 149:2, 161:17, 161:18, 177:17, 177:23, 179:8, 179:14, 207:22 Needing - 54:17, 55:2, 55:14, 103:4, 135:2, 192:7 Needs - 36:6, 52:25, 59:22, 60:5, 64:19, 64:24, 65:1, 107:7, 136:10, 137:10, 207:5 Neither - 151:25 Next - 18:23, 70:19, 160:2, 165:11, 165:15, 176:20, 195:1, 214:10 Nice -111:3 Nights - 15:16, 23:21, 24:17, 24:18, 158:6, 163:3, 163:4, 210:14 Nighttime -43:11 Nine - 120:6 Nobody - 82:8, 89:9, 96:18, 96:20, 100:17, 143:21, 144:22, 187:1 Noel - 56:18, 80:17, 86:4, 86:6, 88:21, 91:15, 102:2, 132:1, 162:3, 162:5, 168:9, 171:6, 175:14, 189:3, 190:18, 198:10, 203:2 Non - 29:6, 29:14, 32:23 None - 80:8 Nope - 162:1, 202:25 Nor - 151:25 Normal - 40:16, 151:7, 151:8, 151:11, 157:10 Normally - 30:17, 47:16, 70:2, 139:25 Note - 85:2, 107:23 Notes - 167:16 Nothing - 6:20, 16:13, 22:3, 41:23, 72:7, 90:11, 122:3, 133:18, 136:23, 187:25, 194:19, 201:8, 205:15 Notice - 38:10, 146:1 Notified - 62:23, 111:5, 115:11, 115:12, 115:13, 117:1, 117:2, 117:24, 132:3, 132:5, 132:12, 134:1, 134:4, 134:6, 135:9, 148:7, 178:17, 194:9 Notify -48:1, 66:3, 82:22, 134:10, 134:25, 146:11, 199:2 Notifying - 134:14 November - 11:18, 11:19, 19:13 Numbers - 20:17, 20:18, 20:21, 21:4, 25:22, 35:24, 85:6 [ O Oath - 6:18 Observation - 50:2, 51:1, 52:25, 103:18, 103:21, 104:15, 162:21, 162:22 Observed - 167:14 Obtain - 188:21 Obviously - 121:25, 131:6 Occasion - 137:16 Occurred - 62:10, 112:23, 113:6, 125:8, 125:9, 126:10, 191:6 Occurring - 126:14 Offhand - 163:7, 167:11 Official - 3:16, 4:15, 23:20, 36:13 Officially - 13:11, 13:13, 15:24, 16:15, 16:16 Often - 40:3 Oh - 34:9, 45:8, 46:15, 47:2, 80:5, 99:16, 101:11, 120:6, 140:21, 144:11, 181:4 OIG - 3:22, 4:8, 4:15, 4:21, 4:24 Old - 120:11 Once - 17:20, 20:10, 21:11, 23:1, 82:12, 89:16, 121:11, 177:19 Ones - 59:24, 141:25, 143:19, 147:5, 168:9, 168:10, 168:12, 168:25, 169:8, 169:16, 193:19, 212:22 One's - 145:10 Ooh - 14:22 Open - 20:7, 152:17, 153:9, 153:17, 153:18, 153:20, 166:15 Opening - 131:4 Operates - 147:23 Operating - 116:6 Operations - 14:3, 14:5, 73:4, 73:7, 118:10, 195:1 Operative - 145:24 Opinion - 123:1, 123:6, 123:7 Opposed - 89:20, 90:8, 104:23 Ops - 51:4, 64:23, 111:11, 115:12, 115:13, 134:8, 134:9, 194:3, 195:21, 197:17, 207:7, 207:21, 210:18, 212:21, 213:25, 214:10 Order - 53:19, 152:17, 205:9 Orders - 175:20, 201:11, 202:1 Ordinary - 118:15 Original - 82:5, 82:9, 193:21 Originally - 64:1, 79:2, 108:6, 164:15, 177:16 Our - 4:19, 13:8, 13:13, 15:24, 40:17, 51:18, 60:20, 64:3, 85:6, 90:19, 90:21, 90:24, 92:18, 99:3, 133:12, 140:11, 143:13, 192:25, 193:20 Outcount - 79:7, 79:13, 82:14, 99:18, 99:22 Outside - 16:10, 20:16, 30:23, 30:25, 144:20, 146:20, 159:3 Over - 9:24, 10:4, 11:12, 11:24, 12:3, 16:9, 41:14, 92:6, 98:2, 99:19, 113:17, 132:24, 138:4, 176:11, 190:5, 190:7, 190:24, 202:12 Overnight - 24:9, 43:8, 46:20, 71:20, 71:21, 179:13 Oversight - 92:5, 184:24 Overtime - 14:11, 16:3, 16:4, 16:5, 16:8, 16:10, 16:11, 16:12, 26:11, 29:8, 29:11, 32:23, 33:18, 34:1, 90:24, 163:22, 164:1 Overwhelmed - 114 :15 Overwhelming - 11 4:14 Owe - 122:3, 122:6 Own - 37:15, 95:25, 123:1, 180:10, 202:8 P Page - 180:23, 205:5 Pages - 53:12, 104:17 Pain - 39:4 Pairs - 159:7 Paper - 155:14 Parkway - 7:9 Part - 3:16, 5:4, 5:18, 17:24, 27:12, 72:16, 183:25, 184:25 Participate - 54:2, 94:5, 94:7 Participating - 89:2 0, 94:13 Particular - 21:14, 21:19, 77:18, 113:17, 156:16, EFTA00114407 198:7 Placed - 36:10, Prevent - 121:12 Proof -167:9 143:20, 143:22, Partly - 121:9, 50:1, 50:3, 50:25, Prevented - 109:3 Properly - 202:3 144:13, 145:4, 121:24 64:2, 64:5, 65:9, Previous - 72:21, Protective - 120:16, 146:10, 146:13, Pass - 42:5, 127:12, 103:21, 104:18, 72:23, 158:22, 159:5 156:5, 157:4 162:9 128:2 104:19, 108:7, Previously - 17:9, Provide - 4:19, Ranges - 142:23 Passed - 45:24, 108:13, 120:2, 157:5, 197:16 4:23, 5:1, 5:4, 98:21, Rank - 19:4 80:9, 194:25 120:10, 155:20 Print - 6:5, 6:10 187:1 Rather - 85:22, Passing -41:19 Places - 20:12 Printed - 75:6 Provided - 88:7, 86:4, 202:7 Past - 98:24, 171:7 Please - 3:24, 4:6, Printing - 6:15 137:3, 168:12, Read - 5:2, 17:20, Pawn - 200:22 6:4, 6:19, 6:24, 18:9, Prior - 7:23, 18:16, 173:11 19:24, 52:14, 58:14, Pending - 157:1 18:13, 19:15, 24:19, 55:4, 94:20, 94:23, Providing - 93:19, 58:22, 61:4, 105:11, Per - 16:22, 16:23, 25:9, 56:14, 150:23 95:19, 135:3, 135:7, 168:13, 168:15, 105:15, 105:23, 20:4, 69:5, 72:25, Plus - 16:20, 30:22 135:8, 137:21, 168:19 106:9, 192:24, 89:16, 90:7, 91:7, Podge - 201:1 137:24, 138:1, Psych - 50:1, 51:4, 193:8, 193:11, 92:24, 97:16 Pointing - 99:24 174:20, 192:6 51:21, 52:10, 52:25, 204:12, 205:13, Perfect - 115:15, Polices - 156:13 Prison - 47:20, 64:22, 104:14, 205:15, 208:22, 128:19, 186:13 Policy - 42:9, 42:13, 159:23, 160:5 162:21, 162:22 208:23 Performance - 5:9 72:18, 72:19, 90:11, Prisoners - 20:10, Psychologist - 52:2 Reading - 35:21, Performing - 173:2 97:16, 122:6, 156:9, 20:14, 20:19, 36:18, 0 53:22, 181:8 0 156:13, 156:14, 36:20 Psychology - 59:2, Real - 111:7, 112:16, Period - 4:18, 156:15, 158:22, Prisons - 3:11, 8:8, 60:25, 67:12, 142:1 16:19, 57:15, 91:25, 159:9, 176:12, 17:25 107:14, 107:17, Realized - 80:1 118:20, 131:3, 176:14, 200:3, Privileges - 158:4 107:22, 108:18, Really - 15:10, 41:9, 140:15, 150:9, 200:11,200:24 Probably - 8:16, 123:17, 131:13, 41:16, 124:12, 150:11, 183:23, Population - 14:8, 9:4, 35:1, 45:9, 191:12, 207:13, 134:19, 142:8, 192:7 14:18, 119:11 45:10, 67:21, 71:5, 209:14, 209:19 149:17, 160:25, Personal - 106:25, Port - 22:1, 82:7 71:25, 94:12, Pulled - 162:10 162:7, 165:9, 172:5, 123:1, 123:6 Portion - 141:24 101:22, 106:5, Purpose - 121:20, 181:15, 187:25, Personally - 184:6 Position - 9:6, 9:7, 117:5, 117:12, 121:23, 205:10, 200:20, 207:20 Person's - 197:18 9:20, 12:6, 12:9, 160:21, 184:24, 205:24 Reasons - 156:6, Pertains - 5:9 12:10, 12:14, 18:18, 192:21, 194:15, Purposes - 28:3, 171:6 Pertinent - 206:4 19:1, 19:19, 21:23, 195:4, 204:17 99:2 Reassigned - 130:2 Phone - 7:18, 29:12, 62:7, 108:23, Problem - 35:4, Pursuant - 5:7 1 41:15, 149:5, 149:7, 118:12, 150:15, 43:23, 48:3, 50:21, Putting - 34:12, Rec - 158:25 151:2, 151:9, 157:6, 203:8, 207:19 54:8, 71:14, 74:7, 91:13 Receive - 20:23, 151:13, 205:21, Positions - 10:9, 81:18, 81:20, 98:22 21:6, 36:2, 39:13, 205:22 202:6 100:22, 178:11, Q 42:15, 52:4, 192:17, Phones - 114:2 Phonetic - 29:10, 33:17, 52:17, 54:19, 107:25, 147:25 Physically - 47:25, 81:12, 181:24 Pick - 21:23, 22:23, 26:17, 26:21, 165:23, 184:25, 188:24 Possibility - 179:22 Possible - 15:18, 70:9, 70:12, 113:3 Possibly - 100:3, 185:7 Post - 162:10, 163:6, 201:11 Posts - 17:3 Potential - 170:7, 205:1 184:2 Problems - 148:20 Procedure - 42:9, 42:14, 59:18, 70:3, 116:7, 118:14, 173:18, 200:25 Proceedings - 5:16, 5:17 Process - 87:16, 174:8, 206:14, Quarterly - 163:6 Questioned - 130:2, 165:4, 180:25, 198:6 Questioning -181: 16 Quick - 70:8, 70:11, 73:24 Quickly -48:25, 149:15, 149:18 192:18, 192:20 Received - 77:20, 129:24, 138:11, 204:12 Receiving - 29:7, 52:9, 76:17, 105:6, 105:8, 192:13 Recipients - 53:12 Recommend - 65:2 Record - 4:7, 20:17, Picked - 9:10, 19:1, Potentially - 148:3 206:17 20:19, 20:24, 25:10, R 22:1, 26:8, 82:8, Power - 200:15 Professional - 123. 36:3, 155:13 182:18, 182:19, Practice - 151:7, 6 RA - 78:15, 78:16, Recorded -4:5, 184:13, 184:15, 151:8 Profile - 63:22, 78:21, 78:23, 79:3, 20:21, 21:4, 35:25, 185:7, 185:10, Predict - 38:19 65:7, 65:9, 68:19, 95:15, 95:16, 95:23, 36:20, 182:20 185:24 Premises - 161:7 117:22, 119:16, 95:25, 100:14 Recorder - 3:1, Picking - 27:5, Prepared - 36:9 119:17, 122:18 Raise - 6:19 216:3 33:20, 117:20 Present - 3:22, Promises - 5:21 Random - 122:20 Records - 79:16, Pickup - 36:10 24:3, 28:7, 206:7 Promoted - 10:12, Range - 20:8, 99:3 Picky - 149:9 Presents - 130:24 10:19, 18:1, 18:17, 20:14, 21:12, 21:13, Recount - 82:15, Piece - 155:14 Pressure - 5:22 19:3 21:14, 21:16, 36:18, 82:16, 87:8, 87:11, Pill - 158:11, 158:15 Pretty - 62:22, Promotion - 11:8 142:6, 142:22, 87:13 PIN - 151:11 149:17 Pronounce - 3:23 143:1, 143:3, Rectify - 163:10 EFTA00114408 Redo - 88:15 149:25, 178:6, 196:21 36:1, 78:12 Refer - 42:23, 197:15, 197:20, Scenario - 109:8, Sheets - 102:25 167:15 197:22, 197:23, 196:11, 196:15 She's - 23:11, Reference - 164:24 203:25 Rising - 166:8 Schedule - 13:12, 32:23, 33:1, 44:25 Referred - 75:18, Reporting - 204:19 Risk - 64:21, 65:8, 29:23, 30:14, 45:6, Shocking - 172:20 75:19, 75:20 Reports - 145:25 131:24 63:11, 163:12 Short - 49:1, 105:22 Reflected - 75:16, Requested - 5:1 Second - 51:8, Shortly - 162:8 177:18, 178:1, Require - 202:6 Role - 61:12, 128:19 51:10, 51:17 Shoulda - 125:23 182:23 Requirement -61:8 Room - 3:21, 25:5, Section - 99:23 Shouldn't - 123:2, Regard - 17:13, , 66:1, 90:6, 92:4, 25:6, 25:7, 86:23 Secure - 20:13, 126:1, 159:6 52:5, 55:1, 55:14, 103:3, 103:8, 125:2, 20:16 Show - 3:8, 52:13, 62:4, 203:5, 215:13 188:19, 188:20, Roster - 16:4, Security - 5:10, 73:25, 74:1, 74:23, Regarding - 17:10, 191:9, 203:24, 23:20, 24:21, 25:20, 7:14, 14:9, 64:4 95:5, 99:1, 99:3, 51:25, 54:16, 58:7, 210:18 28:8, 28:19, 28:20, Seeing - 53:25 142:5, 142:16, 87:18, 116:15, Requirements - 58: 29:4, 34:13, 34:17, Seek - 68:4, 68:12 142:22 136:5, 148:16, 4, 92:16, 138:11 34:18, 62:11, 63:11, Seemed - 180:25 Showed - 101:11, 160:4, 196:17, Requires - 65:4, 130:10, 196:20, Seemingly - 49:11 192:11 198:21, 201:8 111:6 196:21, 196:24 Seems - 25:18, Shower - 158:25 Region - 119:20, Requiring - 56:8 Rosters - 24:4 125:2 Showing - 45:6, 135:18 Reread - 35:21 Roughly - 149:3, Seen - 53:9, 53:10, 153:1 Regional - 119:24 Resign - 9:10 155:7, 155:14 156:15, 184:6, Shows - 29:23, Register - 52:24 Resigned - 9:5, 9:7 Round - 36:21, 186:7, 192:3, 192:4, 53:12, 111:23, Regular - 120:11, Resolved - 149:16 70:23, 72:25, 73:1, 192:6, 210:21 142:17 157:10, 157:25 Respective - 22:1, 89:18, 89:20, 89:21, Segregation - 156:3 Sick - 65:17, 164:6 Regulations - 198:2 73:11, 99:25 90:7, 90:9, 101:14, Selves - 122:14 Sign - 6:4, 16:5, 1 Respond - 15:13, 102:25 Send - 87:4, 88:15, 101:5, 102:22, Reign - 114:25 22:22, 49:18, 114:9, Routine - 140:2 88:16, 103:13, 102:25, 173:1 Relay - 149:8, 208:1 161:10, 165:21, Routinely - 19:22 205:9, 205:12 Signed - 168:1, Release - 64:13 166:1, 166:18 Rules - 37:15, Sending - 108:1, 168:7 Released - 64:22, Responding - 164:1 198:21, 199:6 184:3, 193:14, Signing - 6:7, 6:8, 66:22, 67:2, 68:24, 4, 165:18 Run - 102:21 205:20, 206:3 6:9, 6:13, 6:14 115:8 Response - 4:17 Running - 71:15, Senior - 3:22, 4:10, Relied - 122:19 Responses - 136:2 112:17, 113:3, 216:1 Simply - 36:17, Relief - 13:8, 114:21 1 134:19, 135:14, Sense - 11:12, 36:20 Relieve -13:15 Responsibilities -1 149:17, 205:17 196:16 Since - 11:20, Relieved - 12:25, 9:19, 107:21, Runs - 14:11 Sent - 53:14, 58:6, 11:22, 12:6, 12:8, 110:24, 111:3, 176:10, 200:18, Rush - 133:8 103:14, 103:15, 13:23, 18:1, 19:11, 111:10, 111:13, 200:22, 202:10, 106:4, 107:5, 19:12, 65:5, 101:11, 111:16, 111:19, 215:9 S 108:22, 192:12 125:15, 174:24, 111:20, 111:24, 112:5, 112:8 Responsibility - 66: 3, 66:6, 188:7, SA - 6:12 Sentence - 64:10 Separated - 120:15 207:16 Relieving - 45:9, 126:20, 126:21, 212:21, 212:25, 213:25 Rely - 205:8 Remained - 18:22 Remove - 65:11 Repair - 149:1 Repeat - 7:1, 21:3, 33:22 Rephrase - 7:1 Replace - 149:1, 149:20 Report - 13:19, 17:19, 23:8, 40:21, 41:2, 69:6, 97:21, 197:14 Reported - 69:24. 94:25, 146:9, 188:10, 189:3, 189:5, 197:13, 198:16, 200:19, 207:18, 214:9 Rest - 56:6, 183:10 Restore - 149:12 Results - 23:9 Return - 20:11, 20:16 Returned - 51:22 Reveal - 170:16 Review - 5:3, 36:12 Reviewed - 93:7 Reviewing - 109:19 Reyes - 57:7, 57:8, 57:9, 60:21, 61:1, 61:7, 106:13, 115:7, 116:24, 194:24 Safe - 72:6, 122:20, 123:19 Safety - 14:9, 130:24, 211:23 Sally - San - 9:6, 9:11, 9:24, 10:8, 18:20 Sat - 22:13 Saturday - 15:23, 29:4, 46:12 Saved - 203:6 Saw - 69:15, 167:13, 183:7, 186:11 Says - 52:23, 75:8, 80:17, 87:5, 87:6, 99:12, 99:14, 103:13, 103:17, 158:16, 196:20, Separates - 20:6 Served - 8:8 Service - 8:2, 9:16, 9:18 Services - 119:25, 200:17 Set - 22:10, 37:15, 151:11, 156:9, 156:14, 156:15, 159:1, 160:2 Seven - 9:5 Several - 136:2 Sexual - 160:1 Shanks - 114:1, 114:2 Share - 215:5 Sheet - 20:22, 21:5, Single - 208:2 Sir - 155:8, 174:12, 185:10, 212:12 Sit - 122:16, 125:19, 127:15 Sitting -41:15, 64:12, 86:23, 140:8, 140:10, 143:21, 153:3 Situation - 118:14, 194:22, 195:2, 198:8 Situations - 205:1 Six - 8:9, 8:16, 9:5, 9:23 Sixteen - 16:20 Slash - 51:15, 104:14 Slashed - 114:5 Slide - 152:17 EFTA00114409 Slips - 21:24, 21:25, 22:23, 26:8, 26:17, 26:22, 27:5, 27:13, 33:6, 33:21, 36:9, 183:10, 190:6 Small - 154:25 Smaller - 155:6, 155:16 Social - 7:14 Solely - 173:4, 174:14 Solve - 148:19 Somebody's -153: 8, 184:25, 187:5 Sometime - 115:8, 160:21 Sometimes - 13:24, 22:4, 27:5, 30:20, 30:21, 33:13, 38:15, 38:16, 40:3, 73:19, 73:20, 189:7, 189:8 Somewhere - 62:20 , 81:5, 86:23, 181:23, 203:9 Soon - 8:14, 70:1, 70:3 Sorry - 19:24, 27:24, 34:15, 34:16, 46:13, 54:12, 54:21, 55:12, 79:21, 83:20, 138:3, 144:11, 148:18, 163:20 SOS - 57:3 Sound - 204:16 Sounds - 72:1, 109:18, 132:15, 133:25, 210:14 Sp - 29:10, 33:17, 52:17, 54:19, 107:25, 147:25 Speak - 101:21, 102:3, 160:7, 172:4 Speaking - 174:6, 192:10 Specific - 27:11, 28:13, 36:14, 73:12, 98:12, 104:25, 105:1, 124:13, 130:12, 140:20, 144:11, 149:9, 160:4, 172:24, 196:19 Specifically - 28:15, 31:15, 44:4, 86:9, 87:1, 88:8, 92:2, 106:12, 108:17, 115:1, 136:16, 144:12, 172:25, 174:3, 174:6, 207:6, 207:8 Speculate - 154:14 Spell - 4:7, 25:9, 25:10 Spend - 90:23 Spending - 78:1 Spent - 18:2, 19:6 Spoke - 86:6, 93:25, 102:12, 102:15, 102:17, 102:19, 165:1 Spoken - 108:2 Spot - 35:21, 149:21, 149:22 SSA - 6:14 Stabbed - 114:5 Staffing - 15:10, 125:24, 131:2 Stake - 207:25, 209:14,211:24 Stand - 127:21 Standard - 116:6, 118:14 Standing - 116:8, 127:23, 153:7 Start - 4:7, 12:21, 24:23, 35:11, 39:3, 62:15, 62:25, 63:7, 65:25, 80:6 Started -8:11, 8:17, 10:15, 79:25, 83:14, 111:22, 112:2 Starting - 6:17, 42:15, 42:16 Starts - 15:24, 28:20 State - 176:15 Stated - 5:19, 36:23, 179:1 Statement - 5:14, 5:20 Statements - 171:1 6 Status - 67:20, 77:4, 77:13, 81:20, 81:24, 85:9, 117:22, 155:22, 155:23, 156:7, 179:11, 182:7 Stay - 114:20, 130:12, 164:6 Staying - 77:25, 81:25, 180:8 Step - 176:21 Stone - 118:1, 194:20, 201:8 Stood - 50:7 Stop - 38:5, 38:11, 165:23 Stopped - 102:13 Stopping - 198:14 Straight - 51:5 Strictly - 163:15 Stuff - 17:4, 22:20, 30:24, 39:6, 60:10, 102:23, 105:21, 105:24, 114:4, 128:3, 136:8, 142:23, 146:1, 157:24, 161:18, 187:9, 201:11 Submit - 82:17 Submitted - 82:9 Subordinate - 175: 16 Subordinates - 40: 20, 41:1 Subsequent - 21:15 , 23:4, 197:23 Successful - 121:9, 121:13 Such - 41:6 Suits - 127:8 Summary - 17:18, 17:24, 38:22, 49:1, 52:22 Sunday - 15:22, 15:24 Supervise - 14:7, 14:16 Supervised - 14:17 Supervises - 19:20 Supervising - 20:3, 122:7 Supervision - 64:24 , 65:1, 65:5 Supervisor - 13:18, 14:15, 40:18, 72:23, 72:24, 173:24, 194:17 Supervisors - 173:2 3 Surprise - 170:25, 171:2, 171:3 Surprised - 172:10, 172:14, 172:22 Surrounded - 58:20 Surrounding - 126: 10, 130:3 Swear - 6:19 System - 16:9 T Table - 23:22 Taken - 5:13, 52:25, 61:14, 62:3, 84:6, 84:7, 96:10, 117:11, 129:8, 129:10, 130:17, 131:10, 138:14, 147:7, 183:9, 187:12 Takes - 176:6, 202:12 Taking - 93:10, 93:22, 175:5, 177:9 Talk - 15:19, 43:23, 138:22 Talked - 132:16, 208:7 Tap - 49:12 Tbc - 208:22 Teaches - 201:6 Team - 27:6 Technically - 43:10, 95:20 Telephone - 3:20, 132:24 Tells - 196:8, 199:4, 199:7, 206:16 Temporarily - 117:2 3, 118:8 Temporary - 18:18 Ten - 10:4, 10:6, 144:9 Terminal - 9:1, 9:3, 9:19 Terms - 176:12 Than -17:6, 40:3, 53:15, 79:8, 85:22, 86:4, 135:21, 155:6, 155:16, 163:6, 167:19, 170:19, 171:24, 174:13, 202:8, 204:25 Thank - 3:9, 4:2, 6:6, 6:8, 6:12, 6:16, 6:24, 7:5, 7:11, 8:2, 28:6, 34:2, 35:19, 74:22 Themselves - 4:6, 104:24, 118:12, 123:24, 170:8 Theoretically - 77:2 5 Thereafter - 210:23 They'll - 27:8, 27:9, 39:6 They've - 21:16, 190:6, 214:23 Thing - 41:6, 56:7, 93:8, 93:14, 108:7, 114:20, 134:3, 135:20, 154:22, 165:11, 165:15, 179:17, 185:1, 196:8, 209:21 Thinking - 89:7, 179:19, 197:2 Third - 3:20, 76:19, 178:15 Thomas' - 189:3 Though - 26:24, 28:13, 81:10, 81:11, 86:9, 90:20, 91:2, 107:12, 108:5, 109:14, 124:13, 132:12, 141:5, 154:6, 180:21, 180:24, 186:10, 192:11 Thousand - 186:25, 188:14 Threats - 5:21 Three - 18:23, 104:17, 154:11, 159:7, 213:13 Throughout - 14:11 , 14:14, 22:20, 22:22, 22:24, 23:1, 201:18 Throwing - 187:3 Thursday - 150:1 Tied - 38:4 Tier - 74:17, 162:9 Tiers - 74:8, 74:11, 74:13, 74:14, 74:18, 74:20 light - 15:15 lighter - 15:16 limes - 36:14, 54:17, 61:9, 65:23, 114:10, 124:6, 124:8, 136:2, 136:8, 166:15, 186:25, 196:24, 201:2, 202:12 Title - 4:24, 150:18 Toby - 162:3 Today - 3:18, 34:15, 42:17 Toe - 193:24 Together - 83:1, 175:23 Toggle - 143:9, 143:10 Ton - 205:14, 206:13 Too - 24:9, 43:18, 44:9, 105:24, 106:1, 106:3, 130:24 Took - 9:5, 117:15 Top - 27:25, 34:8, 99:11, 101:7 Topic - 138:7, 138:19, 177:21 Tougher - 175:20 Tova - 56:18 Toward - 92:17 Towards - 99:19 EFTA00114410 Track - 13:23 Training - 8:14 Transcript - 28:4 Transfer - 9:8, 11:1 Transferred - 10:25, 11:8, 11:24, 18:24 Transfers - 11:20 Transpired -49:2 Trays - 157:24, 157:25 Tried - 15:18, 49:7, 164:15, 164:19, 167:2, 167:9 Trip - 38:9, 38:15 True - 21:8, 170:17 Trump - 119:21, 119:23 Truth - 6:20 Try - 7:1, 7:2, 43:21, 114:25, 121:12, 184:8, 186:19 Turned - 173:14 Turning - 216:3 TV - 141:12 Twenty - 8:9 Twice - 102:18, 132:16 Type -42:19, 64:24, 65:1, 65:4, 108:9, 123:19, 129:24, 133:11, 176:16, 202:17, 202:21 Types - 157:9 Typically - 29:20, 29:21 U Uh - 159:24 Ultimate - 197:13, 207:18 Um - 31:6, 32:6, 33:12, 40:14, 43:25, 49:3, 57:25, 69:25, 79:1, 89:4, 100:10, 100:25, 113:20, 145:17, 157:12, 161:4, 166:3, 202:6, 207:13 Unauthorized - 72: 8, 151:18 Unaware - 106:11 Unconscious - 166: 20 Under - 6:18, 156:22, 202:7 Underage - 160:1 Understand - 5:18, 5:24, 5:25, 6:25, 35:7, 38:14, 74:3, 81:7, 128:7, 209:18 Understanding - 12 1:10, 164:19 Understood - 13:17 , 38:21, 39:8, 81:7 Units - 37:16, 60:10, 73:12, 75:3, 75:4, 75:16, 75:17, 100:1 Unless - 22:4, 146:17, 146:23, 153:7, 170:15 Unlock - 20:6 Unread • 192:14 Unresponsive • 166 :6 Until - 11:17, 18:23, 39:3, 46:22, 79:25, 82:3, 150:2, 150:6, 197:4 Unusual - 114:1 Update - 103:18, 104:15, 177:15 Updated - 42:20 Upon - 20:15, 69:15, 90:16, 130:5, 183:22 Upper - 39:13, 51:24 Ups - 54:5, 172:24 Upstairs - 74:12 Upwards - 66:4 Use - 114:9, 140:2, 151:12, 196:16 Used - 5:15, 5:23, 117:3, 117:4, 136:9, 137:9, 137:13 Uses - 15:14, 114:8 Using • 151:17 Usually - 37:7, 41:4, 77:11, 119:17, 145:25, 149:15, 165:20, 177:11 Utilize - 16:14, 139:5, 139:25 V Vacated -17:3 Vacation - 65:17 Vantage - 153:14 Various - 14:12, 156:6 Verbal - 20:24, 36:2 Verbalize - 58:10, 206:8, 206:12 Verbalized - 207:17 Verbalizing - 180:1 0, 206:24 Verbally • 43:2, 206:1, 207:23, 208:3, 209:4, 209:6, 209:7, 209:9, 209:10 Verbatim - 127:13 Verification - 174:8, 182:12 Verify - 87:17, 88:17, 169:9, 169:11, 173:6, 173:9, 173:16, 174:10, 179:25, 180:3, 180:4, 180:6, 182:6, 206:1, 206:2 Verifying • 179:15 Versed - 200:21 Versus - 87:5, 121:16 Very - 34:2, 150:13 Vetted - 121:22 View - 36:18 Violations - 200:3, 200:11, 200:12 Visibility - 142:8 Voice - 88:9 Voluntarily -4:18 Voluntary - 4:20, 5:1, 5:11, 16:10 W Wait - 21:1, 31:24, 39:3, 85:15, 150:1, 172:20, 188:13 Waiting -150:6 Waiver - 5:18 Walk - 20:8, 20:13, 36:18, 106:12, 190:5, 190:7 Walked - 166:7 Walking - 170:3, 205:10 Wanted - 25:4, 25:5, 40:25, 45:1, 70:15, 89:9, 121:22, 123:18, 124:10, 124:12, 145:4, 148:12, 166:19, 180:6, 181:22 Wants • 16:7, 16:10, 117:20 Warden • 191:13, 206:15, 209:20, 212:1, 212:2, 212:6, 212:19, 213:23 Warnings - 4:25, 5:19 Washington - 56:9 Watch/ Psych - 103:18, 104:10 Watches • 144:7, 144:10 Watching - 50:8, 96:20, 121:24, 143:22, 143:25, 144:15, 144:17, 144:22, 144:24, 145:10, 174:4 Water - 165:11, 165:14 Ways - 42:21 Weeds • 114:15 Week - 15:21, 15:24, 35:11 Weekends • 35:15, 35:17 We'll - 7:5, 28:6, 35:22 Wellbeing • 211:24 Went - 8:15, 9:24, 12:2, 18:25, 51:3, 51:4, 62:21, 80:22, 102:13, 109:4, 148:23, 161:1, 161:16, 161:20, 162:7, 165:1, 165:20, 183:10, 193:24 Weren't -43:10, 71:18, 84:13, 130:15, 149:8, 168:3, 168:23, 181:18 We've • 13:22, 38:25, 83:18, 84:15, 136:1, 136:6, 154:19, 154:20, 181:17 Whatever - 47:20, 59:17, 117:16, 128:5, 149:1, 149:11, 149:13, 153:13, 153:16, 170:8, 179:11, 179:13, 205:18 Whatsoever - 169:1 7 Whereby - 96:4, 208:5 Wherever • 27:3, 181:7 Whether - 21:22, 27:3, 63:17, 73:4, 73:5, 81:24, 81:25, 89:1, 89:2, 107:1, 130:6, 169:3, 174:14, 174:15, 174:16, 198:5, 209:16, 212:1, 212:5 Which - 29:18, 35:17, 46:11, 65:6, 67:4, 68:7, 75:6, 76:7, 96:7, 101:9, 112:18, 131:6, 138:12, 141:11, 149:7, 177:19, 182:24, 201:24, 212:24 While - 38:20, 48:8, 64:12, 74:10, 88:17, 103:23, 179:15, 179:17, 179:20, 180:4, 201:4 Whoever - 16:10, 23:5, 39:16, 40:4, 69:5, 104:7, 109:24, 143:6, 149:5, 193:14, 193:15, 209:9, 211:22, 211:24,214:2 Whoever's - 126:21 , 201:16 Whole - 19:7, 90:23, 108:7, 140:11, 153:10, 153:18, 181:25, 205:10 Whose - 207:18 Willing - 5:20 Window • 153:8, 153:9, 153:13, 153:17, 153:20, 153:23, 154:8, 154:18, 154:25, 155:1, 155:9, 155:12 Wise - 176:13 Within - 38:8, 38:17, 145:4 Without - 11:21, 83:24, 131:21, 198:11, 214:3 Witness - 6:15 Word - 174:10, 175:6 Worked - 13:18, 14:19, 24:9, 30:10, 31:20, 44:21, 46:21, 98:4, 115:10, 115:14, 123:9, 148:1, 158:6, 183:23, 196:25, 197:3, 197:4 Works - 20:2, 29:6, 29:22, 32:24, 36:9, 105:10, 116:7 World - 112:16, 115:15, 128:19 Woulda - 125:23 Wouldn't - 31:22, 34:21, 35:2, 49:18, 69:22, 91:22, 109:3, 121:15, 140:10, 155:4, 184:1 EFTA00114411 Writing - 42:13, 201:16, 205:25 Written - 43:2, 118:1, 194:20, 201:8 Y Year - 8:11, 8:17, 17:6, 18:18, 18:21, 191:2 Years - 8:5, 8:9, 10:5, 10:6, 18:23, 184:10 Yep - 125:25 York - 3:7, 7:9, 19:7 You'd - 193:11 You'll - 196:14 Yours - 130:14 Yourself - 53:23, 64:21, 122:21, 122:24, 135:25, 137:15, 194:4, 204:1, 204:11 Yourselves -42:11 You've - 16:3, 16:5, 19:10, 60:8, 79:12, 83:17, 127:18, 127:19, 154:5, 186:7, 209:14 Z ZA - 75:24, 76:7, 76:9, 76:10 ZB - 76:7 Zero - 95:17, 100:15 '95 - 8:20, 8:21 0 00:03:37 - 6:7 00:27:07 - 29:11 00:31:14 - 33:17 00:49:19 - 52:17 00:51:28 - 54:19 00:58:18 - 62:16 0035 - 75:25 01:14:14 - 78:8 01:39:47 - 107:25 02:01:29 - 138:16 02:07:26 - 147:25 02:09:51 -151:4 02:48:29 - 199:25 1 1:30 - 62:20, 62:21, 129:3 100% - 133:16 11 - 8:12, 12:3, 12:4, 18:1 11209 - 7:10 12 - 154:1, 154:2, 155:15 12:00 - 29:24, 30:7, 30:10, 32:1, 32:15, 32:21, 33:4, 35:14, 79:17, 79:20, 79:21, 91:16, 92:2, 93:3, 111:22, 112:2, 168:4, 170:23, 196:21 12:30 - 53:5 12:35 - 75:9, 75:10 12:39 - 216:1 12X12 - 155:7 14 - 3:2, 17:13, 216:1 14th - 3:18 15 -153:2 16 - 16:16, 155:15 16X12 - 155:7 1994 - 8:12, 18:1 1995 - 8:22 2 2:00 - 31:3, 31:11, 31:14, 115:9, 116:23, 197:4, 197:6, 197:9 2000 -18:19 2001 - 18:19 2005 - 10:15, 10:16 2010 - 10:23, 10:24, 11:7, 18:2 2014 - 11:18, 11:19, 11:22, 19:11, 19:13 2019 - 12:13, 17:13, 24:4, 24:22, 25:4, 28:8, 29:5, 53:4, 75:9, 75:25, 95:9, 99:6, 163:4 2021 - 3:2, 216:1 23rd - 164:14 24 - 65:22 24/7 - 59:25 3 I 3:00 - 32:1, 32:16, 33:4, 35:14, 91:17, 92:3, 168:5, 170:23, 185:8 30 - 36:16, 37:11, 37:23, 37:24, 53:4 30th - 57:20, 103:20, 210:22, 213:4 30thto - 210:15 3-3-3s -41:6 4 4:00 - 30:12, 35:12, 71:23, 99:8, 99:10, 100:8, 101:23, 132:15, 198:15 40 - 36:16, 37:24 5 5:00 - 32:2, 32:16, 33:4, 35:15, 91:17, 92:3, 101:23, 160:13, 160:14, 168:5, 170:23 6 6/14/2021 - 6:13 6/14/21 - 34:16 7 7:00 - 160:21, 160:22, 160:23, 160:25 72 - 76:1, 79:6, 81:1, 84:2, 85:2, 86:1, 86:17, 87:5, 87:6, 87:22, 88:14, 168:20, 176:25, 177:19, 182:24 75 - 100:10, 100:11 76318-054 - 52:24 8 8:00 - 13:14, 19:21, 28:14, 28:25, 29:24, 30:7, 30:10, 30:11, 32:22, 33:19, 44:8, 44:25, 115:9, 116:23, 196:22 8:30 - 62:18, 62:20, 66:2, 129:3 8th - 46:25 9 9:33 - 95:9 9:35 - 3:19 9:37 - 3:3 9:38 - 6:13 9315 - 7:8 EFTA00114412