EFTA00117565.pdf

34 1 Alright. 2 What was 3 4 (Indiscernible 5 DO you know where we left off the last question that we asked? : It was what we asked for *00:24:53) about the injuries. : Okay. So you were 6 telling us you said March through June you were 7 injured? 8 MS. NOEL: Yes. 9 10 working during 11 MS. NOEL: 12 : And you were not actually that time? No. : Do you remember around 13 when in March and when did it end? Was it the 14 beginning of March, end of March, middle? 15 MS. NOEL: Um I'm not sure. I just know 16 it was March. 17 : Sometime in March? 18 MS. NOEL: Yes. 19 : But when you came back, 20 was it around the 26th when they asked you to 21 sign those? 22 MS. NOEL: I came back in June. I don't 23 recall the date exactly. 24 : Okay. 25 MS. NOEL: But I remember the day I came EFTA00117565 35 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 into work and the lieutenant asked me to go see Lieutenant And she asked me to sign and I said but I wasn't here. I was out on an injury. And she said she's aware but they need me to sign it for program review. Okay. MS. NOEL: So I signed. So both trainings when you signed, they didn't actually even provide you anything? MS. NOEL: No. Verbally? Electronically? Nothing? MS. NOEL: No. : Okay. And that was on the date that was signed that that happened? MS. NOEL: Actually she told me not to date it. I remember when I was signing, she said don't date it. But you dated it anyway? Did you have a conversation about that? MS. NOEL: No. : After you dated it, she didn't say why did you date it or anything like 25 that? EFTA00117566 36 1 2 3 4 5 6 7 8 9 10 11 12 13 14 SHU. 15 16 17 18 19 20 21 22 23 24 25 MS. NOEL: No. : Okay. Did you receive that training though in the annual training courses as well? Like the suicide prevention or the - you know how to operate in the SHU during MCC annual? Or the - I think you call it the IF training? Or during the correctional officer training at FLETC? MS. NOEL: Those trainings are like general overall training. It's not specifically speaking about SHU. Like SHU may come up in the conversations, but it's not specific to SHU or how to operate or run the Okay. MS. NOEL: Mm-hmm. Do you know if they were doing this with other employees as well? Having them sign training that they weren't actually conducting? MS. NOEL: I don't know. : Okay. But did you do this per the direction of your supervisor? MS. NOEL: Supervisor. Yes. : So she - did she EFTA00117567 37 1 specifically you must sign this? 2 MS. NOEL: Yes. 3 4 was 5 6 MS. NOEL: : Okay. And again, that And you said 7 and I apologize. I don't know if we were 8 interrupted when Where did you say she is 9 currently? 10 MS. NOEL: She is in Jersey I know. I'm 11 trying to -. 12 : At the FCI Fort Dix? 13 MS. NOEL: Yes. 14 : Okay. 15 MR. FOY: Question real quick. 16 : Absolutely. Do you want 17 a more precise answer to when she was out and 18 when she came back? 19 : Uh, so far -. 20 MR. FOY: Because I happen to know -- 21 : Oh sure. If you'd like. 22 MR. FOY: -- the approximate dates. 23 : Sure. You can provide 24 that. 25 MR. FOY: And this is based on my review EFTA00117568 38 1 of discovery and conversations with Ms. Noel. 2 We're looking at about March 15 to June 24-ish. 3 4 5 6 7 8 9 10 11 12 13 14 15 Foy. 16 17 18 19 20 21 22 23 24 : Okay. MR. FOY: And I note that the execution was on the 26th. But I think there was some time, you know, it's not like the first minute she was there they had her sign the document. Okay. MS. NOEL: Right. MR. FOY: So those are the estimated times. I could be off by a day or two, but Perfect. MR. FOY: The 15th of March to June 24th. And thank you attorney MR. FOY: No problem. : During your time at the MCC, how often were you assigned to the special housing unit also known as the SHU? MS. NOEL: Mm. : And this is an approximate. I'm not asking you for like exact amount. MS. NOEL: When I came back from the 25 injury, my assignment was the SHU. So from EFTA00117569 39 1 June 20-whatever to August 10th, I worked the 2 SHU. 3 : Okay. And that was your 4 quarterly assignment was in the SHU from - for 5 that whole summer 6 MS. NOEL: Yes. 7 : -- in 2019? 8 MS. NOEL: Yes. 9 : Okay. Thank you. So I 10 know that you said that you didn't - they 11 didn't provide you with the SHU training. Did 12 they provide you with the policies of the SHU? 13 MS. NOEL: No. 14 : So you never received 15 those policies? Would it have been when you 16 received and you said you had to initial and 17 date something electronically? I think you 18 said when you provided -? 19 MS. NOEL: That's the employee code of 20 conduct. 21 : Okay. 22 MS. NOEL: That's the - like the handbook 23 that's online. 24 : Should have they provided 25 you with the polices and post orders in the EFTA00117570 40 1 2 3 SHU? MS. orders. NOEL: In the SHU there is post 4 : Oh, okay. So in the SHU 5 there's the post orders. 6 MS. NOEL: Yes. 7 : And were you provided a 8 copy of that to review? 9 MS. NOEL: Yes. 10 11 : And had you reviewed that? 12 MS. NOEL: Yes. 13 : Okay. And when did you 14 review that? 15 MS. NOEL: When I came back. 16 : So sometime in that June 17 -- 18 MS. NOEL: So in June. 19 : -- or July timeframe? 20 MS. NOEL: Yes. 21 : Okay. So aside from hose 22 23 post orders, did you receive any other SHU training? 24 MS. NOEL: No. 25 : No. And who was EFTA00117571