EFTA00117643.pdf

1 2 DIGITALLY RECORDED SWORN STATEMENT OF OIG CASE #: 2019-010614 DEPARTMENT OF JUSTICE OFFICE OF THE INSPECTOR GENERAL JUNE 21, 2021 RESOLUTE DOCUMENTATION SERVICES 28632 Roadside Drive, Suite 285 Agoura Hills, CA 91301 Phone: (818) 431-5800 APPEARANCES: OFFICE OF THE INSPECTOR GENERAL BY: BY: WITNESS: OTHER APPEARANCES: JASON FOY, ESQ. ERIC SARRAGA, ESQ. SERINE GREG 3 1 MR. The recorder is on. My 2 name is . I am a Senior 3 Special Agent with the U.S. Department of 4 Justice Office of the Inspector General New S York Field Office and these are my credentials. 6 This interview with Federal Bureau of Prisons 7 correctional officer is being 8 conducted as part of an official U.S. 9 Department of Justice Office of the Inspector 10 General investigation. Today's date is June 11 22, 2021 and the time is 10:09 a.m. This 12 interview is being conducted at - what is the 13 location - 15 -? 14 MR. FOY: 15 Bergen Street, Hackensack, 15 New Jerseii 16 MR. IIIIIIII : Thank you, sir. 17 MR. FOY: Bergen County Bar Association, 18 second floor conference room. 19 MR. : Okay. 20 MR. FOY: By the way, that was Jason Foy 21 speaking. 22 MR. Yes. Also present are 23 DO) OIG Special Agent 24 Correctional officer ; 25 attorneys, Jason Foy, and Eric Sarraga of Foy & 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 4 Seplowitz, LLC; as well as union representative Serine Greg of the Local 3149 with the BOP. This interview will be recorded by me, Senior Special Agent . Could everyone please identify themselves for the record and spell your last name. To starti_ again, I am DO) OIG Senior Special Agent DOJ OIG Special Agent MS. : I'm MR. FOY: Jason Foy, F-O-Y, attorney for MR. SARRAGA: Eric Sarraga, S-A-R-R-A-G-A, attorney for MS. GREGG: Serine Gregg, G-R-E-G-G, Local 3148. MR. : Thank you everyone. Ms. IIII, you are here today as a subject in this DOJ OIG investigation. This DO) OIG investigation concerns your alleged misconduct to include allegations of false statements, job performance failure, security failure, and reporting false information. This is an official DOJ OIG investigation and you are EFTA00117643 S 1 being asked to voluntarily provide answers to 2 our questions. Will you agree to a voluntary 3 interview with the DO] OIG? 4 MS. : Yes. 5 MR. : Alright. Great. And 6 then everyone that does voluntary interviews 7 with the DO] we provide them with these 8 voluntary interview forms. I don't know if you 9 guys were sent that at the time, but it says, 10 "United States Department of Justice Office of 11 the Inspector General, Warnings and Assurances 12 to Employee Requested to Provide Information on 13 a Voluntary Basis. You are being asked to 14 provide information as part of an investigation 15 being conducted by the Office of the Inspector 16 General. This investigation is being conducted 17 pursuant to the Inspector General Act of 1978 18 as amended. This investigation pertains to 19 your alleged misconduct to include allegations 20 of false statements, job performance failure, 21 security failure, and reporting false 22 information. This is a voluntary interview. 23 Accordingly, you do not have to answer 24 questions. No disciplinary action will be 25 taken against you if you choose not to answer 6 1 questions. Any statement you furnish may be 2 used as evidence in any future criminal 3 proceeding or agency disciplinary proceedings 4 or both. And of course, there's the DPA 5 waiver. I understand the warnings and 6 assurances stated above and I am willing to 7 make a statement or answer questions. No 8 promises or threats have been made to me and no 9 pressure or coercion of any kind has been used 10 against me. You can take a look at this and 11 review it. If you agree, there's a section 12 there for your name and signature. 13 MR. FOY: So the only thing that this is 14 actually subject to is the deferred prosecution 15 agreement. 16 MR. : Well so there's the 17 agreement that you had, so that's the part 18 where I'm talking about the specific part where 19 it says criminal. 20 MR. FOY: Mm-hmm. 21 MR. : That's something I think 22 that was worked out with the U.S. Attorney's 23 Office -- 24 MR. Exactly. 25 MR. : So -. 7 1 MR. FOY: I know there's no sort of 2 protection with regard to the disciplinary 3 internalliiiiiiiiiinistrative thing that -- 4 MR. : Correct. 5 MR. FOY: -- will happen at some point. 6 But I just wanted to make that clear. But go 7 ahead, yoiliiiiiiii IIII. 8 MR. : Now obviously, that is 9 pursuant to you answering questions truthfully. 10 MR. FOY: Right. Of course. That's the 11 exception to our agreement. 12 MR. : There's a line that says 13 employee si nature. 14 MS. . Mm-hmm. 15 MR. Alright. And the rest 16 will be filled out by the two of us. 17 MR. lila 18 MR. : Thank you, sir. 19 MR. Si 20 MR. : And thank you for signing 21 Ms. IIII. Alright. So I'm going to sign where 22 it says signature of the Office of the 23 Ins ector General S ecial Agent. Again, this 24 is 25 And Special Agent . I'm printing my name. , can you fill out the 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 8 rest for signature of witness, name of witness, date, time and place. MR. : This is Agent signing on the siinat eof witness. MR. : And then do you understand the form as ou read and you review? MS. : Yes, I do. MR. : Great. Thank you. Before starting the interview, I'd like to place you under oath. Can you please raise your right hand? Do you swear to tell the truth and nothing but the truth during this interview? MS. : Yes, sir. MR. Thank you, Ma'am. Alright. Please let me know if you do not understand any of my questions. I'll try to rephrase or ask it a different way. MS. : Okay. MR. : Alright. So this is something we ask everybody. Do you - what's your current home address? MS. MR. Thank you. What's your EFTA00117644 9 10 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 date of birth? MS. MR. your Social Securit MS. MR. Thank you. What's your highest level of education? MS. ,bachelor's degree. MR. : And what was your bachelor's degree in? MS. IIII: Criminal justice (Indiscernible *00:06:14) in law. MR. : And where did you receive that degree from? MS. John Jay. MR. : John Jay in New York City? MS. Yes, sir. MR. : And when did you graduate? MS. 1.7. MR. : Thank you. What did you do - just briefly - prior to working with the BOP? MS. IIII: Prior to working with the BOP I And your last four of number. 1 worked at the Post Office. 2 MR. : Okay. What did you do 3 there? 4 MS. : I was a mail handler. 5 MR. And for how long? 6 MS. six months. 7 MR. Six months? 8 MS. : Mm-hmm. 9 MR. And that was in 2016, 10 2016? When did you do that? 11 MS. : Yes. 12 MR. 2015 and 2016? 13 MS. No. At the post office, I was 14 there 2017. 15 MR. . Oh 2017. 16 MS. : '16, '17. Mm-hmm. 17 MR. Oh, okay. And do you 18 have any military service? 19 MS. : Yes. 20 MR. And what is that? 21 MS. : Military service? 22 MR. Yeah. Can you tell me 23 what the service? 24 MS. The Army. 25 MR. Army. And how long were 11 1 you in the Army? 2 MS. : Six years. 3 MR. : From when until when? 4 MS. 2008 to 2014. 5 MR. And what did you do with 6 the militar 7 MS. IIII: I was a patient administrative 8 specialist. 9 MR. 10 MS. 11 MR. 12 hospital? 13 MS. : Yes. 14 MR. : Okay. So you worked in a 15 hospital. And what was your rank when you left 16 the militar ? 17 MS. : E4 Specialist. 18 MR. : And did you leave - were 19 you honorabl , discharged? 20 MS. : Yes. 21 MR. : Okay. 22 MR. FOY: Can I - one second real quick? 23 For the post office, you said 16 - 17 but you 24 started MCC in 18. 25 MS. IIII: Yeah. And what is that? Patient admin. Patient as in like a 12 1 MR. FOY: So would it be 17 into 18? 2 MS. : 18 yeah. 3 MR. Oh you did start with the 4 BOP in '18? 5 MS. 6 MR. Not 7 MS. : No. That 8 (Indiscernible *00:07:49). 9 MR. FOY: Right. So it's '18, then she 10 left the Post Office in '17, going to - so I 11 think it's 16 -. No 17 - 18. 12 MS. IIII: '18 - Mm-hmm. 13 MR. FOY: Post Office. Then MCC. 14 MR. : Okay. And did you work 15 for anybody prior or in between your military 16 service and the post office? 17 MS. 18 MR. 19 MS. 20 MR. 21 that time? 22 MS. 23 MR. 24 to John Ja 25 MS. IIII: : No. No? Okay. Hm-mm. So you were unemployed at in '16? was an error in the No I was going to school. Oh that's when you went That's when I was going to John EFTA00117645 13 14 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 Jay. Yeah. MR. when was MS. MR. Okay. Thank you. And our Enter on Duty Date with BOP? : June 24, 2018. Okay. And when did you graduate from BOP training down at the Federal Law Enforcement Training Center? MS. IIII: Um, I want to say September of 2018. MR. : Okay. But you did graduate from there? MS. Yes, I did. MR. That was a correctional officer training? MS. : Yes. MR. : Alright. And when and where was your first office assignment with the BOP? MS. Sa that again? MR. When and where was your first office assignment with the BOP? So where did you start - did you start working in MCC and work there the entire time? MS. : Yes, sir. MR. Okay. And what positions 1 have you held with the BOP? 2 MS. : Correctional officer. 3 MR. • Okay. The entire time? 4 MS. Yes, sir. 5 MR. : Alright. And when you 6 were there last, who did you report to? Who 7 was your direct supervisor? Or did you have 8 one? 9 MS. : Lieutenant 10 MR. : And do you know how to 11 spell that last name? 12 MS. 13 MR. Thank you. What is your 14 current -? Again, this is something we ask 15 everybody. We won't be contacting your client. 16 But what is our current cell phone number? 17 18 MS. MR. : Okay. And how long have 19 you had that number? 20 MS. : Years. 21 MR. • Years. 22 MS. Mm-hmm. 23 MR. • So for a long time. 24 MS. Yes. 25 MR. And to include in 2019? 15 1 MS. 2 MR. : Okay. Any other cell 3 phone numbers? 4 MS. 5 MR. • Okay. And your current 6 email address? 7 MS. 8 MR. . Okay. Great. And have 9 you had that one also for years? 10 MS. Yes. 11 MR. Okay. Any others? 12 MS. Yes. 13 MR. What are the others? 14 MS. 15 MR. . Same? 16 MS. Mm-hmm. 17 MR. You've had that for 18 years? 19 MS. Yes. 20 MR. Okay. Both in 2019? 21 MS. Yes. 22 MR. Okay. Thank you. Um, do 23 you have any current -? I should have asked 24 this. Ar2a2u currently employed right now? 25 MS. IIII: No. 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 MR. MS. MR. last work at MS. 16 By no other means? Okay. And when did you the MCC? August 10, 2019. MR. And was that the same supervisor that you mentioned? MS. : Yes. MR. : Okay. Briefly, what training have you attended or conducted during your employment with the BOP? You mentioned the correctional officer training at FLETC. What other trainings have they provided for you? MS. IIII: Um, their two-week training when you first start at BOP. I forget what it's called. IF training. Yes. MR. IF training? MS. Mm-hmm. MR. And any other training? MS. MR. Annual refresher training? MS. : I have one. MR. : Okay. So you've gone to EFTA00117646 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 17 annual. And what about like a SHU training course? MS. MR. Okay. But you did - and this is just - you guys can take a look at this if you would like. This is the training that we have for you. That we asked for your list of training. I'm not asking you to necessarily verify that you've conducted all of it, but it shows the last time you did your annual training was on 3/8/2019 was when you actually completed that week of training. MS. MR. MS. MR. • Yes. • Does that sound correct? Correct. Again, this just goes along with it. It shows -. It shows what the syllabus was as well as the sign-in sheet where Ms. signed in. Again, it's - we're not asking to ou MS. : Mm-hmm. MR. : For - if you want to take a look at it you can. It just shows that you did that training in March of 2019. And anything that I'm going to provide to you, can 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 18 you just initial and date? And that's just a way for us to verify that that's what we showed you. MS. IIII: Okay. MR. FOY: Each page or just to top? MR. Nope, just the top of each page. MR. FOY: Okay. Is (Indiscernible *00:12:34)? MR. No, you do have that. So just briefly, you don't have to like list off the course syllabus. But what did they cover during that annual training? MS. IIII: Um they spoke about different areas like dealing with inmates. They spoke about the issues on the job like dealing with shortages. They spoke about um, basically like mask fitted I remember. MR. MS. MR. • Mask fitting? Mm-hmm. • Was that back in 2019? People were wearing masks as well? MS. : No like um. MR. : It's for OC's sprays? MR. Oh, for OC spray. 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 19 MS. : Yes. MR. : Okay. Did they include things like ethics, standards of conduct? MS. • Yes. MR. Okay. What about like counts and rounds? MS. IIII: I don't recall them talking about counts and rounds. MR. : Okay. So did they go over like MCC policies and guidance? MS. : Yes. MR. : Okay. And did they ever provide you with the policies and guidelines or did they ust speak to you about it? MS. : For in this training? MR. MS. MR. Yes. : They just spoke about it. At another time did they provide you with the polices and guidelines? MS. IIII: Yeah. It's on like the computer. MR. Okay. MS. The -. MR. Do you have to certify that you've like received it and you reviewed 20 1 it? Polices and guidelines? 2 MS. IIII: I think I signed that like you 3 receive it. 4 MR. : Right. Okay. If you 5 don't mind, just -. 6 MR. FOY: You want it in the lower right? 7 MR. : Doesn't matter. Top or 8 bottom. You know wherever there's room. I 9 typically do top, but bottom is totally fine. 10 MR. FOY: This one, that one. 11 MR. : Today's date is lune 22nd. 12 MR. FOY: That's part of the same 13 document. 14 MS. IIII: Hm. 15 MR. FOY: And just the top page. 16 MR. : And now you mentioned 17 that you didn't quite remember them going over 18 training when conducting counts and rounds in 19 this training. Did you - were you - did you 20 ever receive training on conducting counts and 21 rounds? 22 MS. : Yes. 23 MR. : Okay. When would that 24 have been? 25 MS. IIII: In an IF training. EFTA00117647 21 22 1 MR. And what does IF stand 2 for? 3 MS. IIII: Rm. 4 MS. GREGG: You want some clarity? I can 5 tell you -- 6 MR. : Sure. 7 MS. GREGG: -- just what it stands for. 8 Institution Familiarization training. 9 MR. : Okay. Great. And that's 10 something that the MCC provided directly? 11 MS. : Yes. 12 MR. : Okay. Great. And then 13 you had mentioned - did you ever receive 14 policies on counts and rounds? 15 MS. : No. 16 MR. I know you said you 17 certified. Do you remember that specific 18 policy - like receiving that? 19 MS. IIII: Like specifically on counts and 20 rounds? 21 MR. : I'm not asking you to 22 like verbatim tell me what it was. I'm just 23 saying like were you provided and you reviewed 24 it. DO you remember? 25 MS. IIII: Not specifically on counts and 1 rounds. Just like a general - 2 MR. Right. 3 MS. Like -. 4 MR. Like you know the housing 5 orders or unit policies and things like that. 6 When you're supposed to conduct counts, when 7 you're supposed to do rounds, that type of 8 thing. 9 MS. : The post orders. 10 MR. : Post orders. Right. 11 Okay. Great. You mentioned you didn't 12 remember ever going to quarterly SHU training. 13 This is a sign-in sheet for quarterly SHU 14 training. I just want to -. Is this your 15 signature on there for June 26, 2019? 16 MS. IIII: You see how I'm the last one on 17 the bottom of all of them? 18 MR. : Correct. 19 MS. : Because I wasn't at the 20 training when I came -. 21 MR. : Did they provide it to 22 you one-on-one though? 23 MS. : No. 24 MR. So how come -? 25 MS. : Because when I came back from 23 1 an injury, the lieutenant asked me to sign 2 because when they had program review, they need 3 to show that I received the training. But I 4 never did. She just asked me to sign. That's 5 why I wonder wh 6 MR. Who asked to do that? 7 MS. : Lieutenant 8 MR. : So that supervisor you 9 mentioned was your first line supervisor asked 10 you sign without providing you the training? 11 MS. : Yes. 12 MR. : And she didn't' like 13 provide you anything to review? 14 MS. : No. 15 MR. She didn't go over 16 anything with you? 17 MS. : No. 18 MR. Did you discuss this with 19 her - that how can you sign something without 20 being provided the training? 21 MS. IIII: Well I just told her I wasn't 22 here. I was out on an injury. She said she 23 knows but she needed me to sign it because they 24 need it for ro ram review. 25 MR. : What's her first name? 24 1 MS. 2 MR. And is she a lieutenant? 3 MS. : She's a - I don't know what she 4 is now. But she's not at MCC anymore. She's 5 at somewhere in Jersey. 6 MS. GREGG: I'm sorry. Before you go, are 7 you done with that question? 8 MR. : Actually, let me um, I 9 didn't do this. 10 MS. GREGG: Because I want to 11 (Indiscernible *00:17:14) 12 MR. : And I did forget to do 13 this. There's an advisory to the union 14 representative. 15 MS. GREGG: Mm-hmm. 16 MR. : Can you review this? And 17 I do apologize. But since you're speaking up a 18 little bit, let me hand this to you. and then 19 you can review that. And then if you want to 20 just take a look. After you're done reviewing, 21 you may sign it if you agree. 22 MS. GREGG: Will you be able to give me a 23 copy of it? 24 MR. : Yes. I think it says on 25 there that we will forward you a copy of that. EFTA00117648 25 1 MS. GREGG: I didn't even see that part. 2 MR. : Should I continue asking 3 questions while she's reviewing that or do you 4 want to wait? 5 MR. FOY: Yeah, you can ask questions. 6 Absolutel 7 MR. . : Sure. So there's another 8 training that you - it says that you conducted 9 on also June 26, 2019 for SHU suicide 10 prevention training. Did you also not receive 11 that trainin ? 12 MS. Yeah. I didn't. 13 MR. You did not receive that 14 training? 15 MS. 16 MR. Did you receive - so 17 there's slides in the back that shows the 18 training and how they conducted it. Did they 19 provide you with those slides? 20 MS. No because I wasn't there. 21 MR. You weren't there? 22 MS. I was out on an injury. 23 MR. Okay. Can you -? When 24 were you out on the injury? What are the 25 dates? 26 1 MS. IIII: From March 2019 to - I came 2 back in June. So when I came back in June, 3 that's when I was told to sign this. 4 MR. Okay. 5 MS. Mm-hmm. 6 MR. Alright. Thank you for 7 signing the Advisory to Union Representative. 8 MS. GREGG: I signed it (Indiscernible 9 *00:19:02). 10 MR. : I am just going to sign 11 that form as name of OIG special agent. Again, 12 I do apologize for not providing that up front. 13 MS. GREGG: So I just -. 14 MR. : I'm sorry, what was your 15 question? 16 MS. IIII: I want to call because 17 (Indiscernible *00:19:15) I'm just saying that 18 well I know that the dynamics are that I should 19 interrupt you in the middle of a question. But 20 interrupt her answering a question. So I was 21 asking were you done because I wanted to just 22 step out for Oust one second. 23 MR. You want to step out? 24 MS. Mm-hmm. 25 MR. Okay. We don't want to 27 1 interrupt the interview because we have a lot 2 of questions to get through. 3 MS. GREGG: Mm-hmm. 4 MR. : If the attorneys ask 5 that, that's not really -. But if you would 6 like to -. 7 MS. GREGG: So based on the agreement we 8 just signiiiiiiiii 9 MR. : Sure. 10 MS. GREGG: It acknowledges the right to 11 have me representing her. And part of those 12 rights are the ability to assist in 13 representing her. Right? And so I don't want 14 to dispute and I don't want to hold up the 15 process at all. I just want to say something 16 to her. 17 MR. : Sure. We'll let that - 18 we'll do that this time, but if this continues 19 to happen, I'm going to have to give you a 20 different form that says you can stay here 21 voluntarily if you want, but we're going to ask 22 you not to interrupt the interview. And if you 23 do, then we're going to ask her if she wants to 24 continue with the interview without you. 25 MS. GREGG: So but that form says 28 1 somethingliiiiiiiiito what you're saying. 2 MR. : I'm going to give you a 3 different form that says that I'm going to let 4 you interrupt the interview now to talk to her 5 out there. And if you do it again, I'm going 6 to ask that you not be here any longer so that 7 we can continue with the interview. Obviously, 8 her attorneys would stay here. So I just want 9 to make sure that we don't just continue. 10 MS. GREGG: I just need clarity then. I 11 need clariiiiiiiiii 12 MR. : Sure. 13 MS. GREGG: So the representing of and 14 talking to the employee who I have the right to 15 represent is considered by you an interruption 16 of the interview? 17 MR. : We haven't even gotten 18 into the questions yet. So -. 19 MS. GREGG: Well -. 20 MR. : -- yes, we need to 21 continue with the interview. But we're now -. 22 I can allow you to do that now. I'm just not 23 going to be able to allow you to continue to 24 stop the interview and leave the room. 25 MS. GREGG: I'm just asking for clarity EFTA00117649 29 1 right. So it was kind of -. 2 MR. : Sure. Absolutely. 3 MS. GREGG: And I don't mean to be 4 difficult. It kind of was a yes or no. So 5 you're saying to me based on the document that 6 I signed -. 7 MR. I'm saying that you can 8 assist her. 9 MS. GREGG: I didn't get to -. 10 MR. : Sure. Go ahead. 11 MS. GREGG: Okay. So you're saying based 12 on the document that I signed, in my right to 13 represent the employee, which is asking to 14 caucus and say something to Ms. is 15 interrupting the interview even though I have 16 the right to do so based on the document I 17 signed? 18 MR. : It's more for her to be 19 able to ask you for a question. 20 MS. GREGG: So it's just a yes or no. 21 MR. : Oh, no-no. I'm the one 22 that's leading the interview here. So if she 23 stops and asks you for clarity, absolutely. 24 You stopping to inform her? No. 25 MS. GREGG: I never identified to you that 30 1 I would be informing her of anything. 2 MR. : Okay. But so yes. To 3 answer your question, you can be here to 4 represent here if she's asking you for the 5 information. I don't want you stopping our 6 interview. 7 MS. GREGG: Mm-hmm. 8 MR. : And then asking to leave 9 the room. I'm going to allow that this time. 10 After that, I will consider that an 11 interruption of the interview. 12 MS. GREGG: Mm-hmm. 13 MR. : And then we'll have to 14 proceed from there. And then there's a 15 different form to provide you. So does that 16 make sense? 17 MS. GREGG: No it doesn't. 18 MR. : Okay. So I'm asking you 19 not to interrupt -. 20 MS. GREGG: Wait. It doesn't make sense 21 but I'm not - that was -. 22 MR. : So I'm asking you not to 23 interrupt the interview. She may defer to you 24 and ask you for questions. 25 MS. GREGG: Mm-hmm. 31 1 MR. I'm asking you not to 2 interrupt my questions. 3 MS. GREGG: Okay. It doesn't make sense 4 to me. What I'm interpreting is my ability to 5 represent is only if the employee asks a 6 question that's what you're saying to me. 7 MR. : Correct. So her 8 attorneys are here. 9 MS. GREGG: I got it. I got it. 10 MR. : Her attorneys are here. 11 I'm asking if she has a question for her union 12 representative -- 13 MS. GREGG: Mm-hmm. 14 MR. -- she may at any time 15 ask you. 16 MS. GREGG: I got it. 17 MR. I'm asking you not to 18 interrupt. 19 MS. GREGG: I got it. 20 MR. These questions are not 21 for you. 22 MS. GREGG: Mm-hmm. 23 MR. They're not directed at 24 you. 25 MS. GREGG: Mm-hmm. 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 32 MR. They're directed at Mrs. MS. GREGG: I'm not answering questions. I was just trying to -. I'm representing her. But I understand that there has been a determination of how I'm able to represent. And so I'll deal with that in a different venue. You can move forward. MR. : Alright. Let me read this real quick in this paperwork so that we're not going to have any disputes. MS. GREGG: We don't have to. You don't have to continue. Right. Because I don't want to interrupt. So you can go on ahead and move forward. MR. Okay. So it just says that you may not attempt to answer the questions. MS. GREGG: Mm-hmm. MR. Or dictate the employee's actions to question or otherwise take charge of proceedings. MS. GREGG: Mm-hmm. MR. : But affin, please feel free to go confer with Ms. EFTA00117650 33 1 MS. GREGG: I appreciate it. Thank you. 2 MR. : I am going to pause the 3 recording. It is currently 10:32 a.m. 4 [Whereupon, the above-entitled matter went off 5 the record and went back on the record.] Okay. 6 The recorder is back on. It is 10:38 a.m. 7 Tuesda lune 22 2021. This is Senior Special 8 Agent . We're resuming the 9 interview. Ms. I just remind you that you 10 are under oath and this is a voluntary 11 interview. I'm sorry. What was your question? 12 MS. GREGG: You need me to initial 13 (Indiscernible *00:24:24)? 14 MR. If you don't mind. And 15 again, it's just to show that you know, what we 16 are looking at. 17 MS. GREGG: Okay. 18 MR. Now since we took that 19 break, is there anything else we want to 20 discuss or -? 21 MS. FOY: No, we can move forward. 22 MS. : No thank you. 23 MR. : Thank you again very much 24 for your cooperation with this matter. Is 25 there anything else you wanted to -? No? 34 1 Alright. DO you know where we left off I=? 2 What was the last question that we asked? 3 MR. : It was what we asked for 4 (Indiscernible *00:24:53) about the injuries. 5 MR. : Okay. So you were 6 telling us you said March through June you were 7 injured? 8 MS. : Yes. 9 MR. : And you were not actually 10 working during that time? 11 MS. : No. 12 MR. : 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. IIII: Um I'm not sure. I just know 16 it was March. 17 MR. Sometime in March? 18 MS. 19 MR. But when you came back, 20 was it around the 26th when they asked you to 21 sign those? 22 MS. IIII: I came back in June. I don't 23 recall the date exactly. 24 MR. Okay. 25 MS. : But I remember the day I came 35 1 into work and the lieutenant asked me to go see 2 Lieutenant . And she asked me to sign 3 and I said but I wasn't here. I was out on an 4 injury. And she said she's aware but they need 5 me to sign it for rogram review. 6 MR. Okay. 7 MS. I signed. 8 MR. : So both trainings when 9 you signed, they didn't actually even provide 10 you anythin 11 MS. : N 12 MR. : Verbally? 13 Electronically? Nothing? 14 MS. : No. 15 MR. : Okay. And that was on 16 the date that was signed that that happened? 17 MS. IIII: Actually she told me not to 18 date it. I remember when I was signing, she 19 said don't date it. 20 MR. : But you dated it anyway? 21 Did you have a conversation about that? 22 MS. : No. 23 MR. : After you dated it, she 24 didn't say why did you date it or anything like 25 that? 36 1 MS. : No. 2 MR. : Okay. Did you receive 3 that training though in the annual training 4 courses as well? Like the suicide prevention 5 or the - you know how to operate in the SHU 6 during MCC annual? Or the - I think you call 7 it the IF training? Or during the correctional 8 officer training at FLETC? 9 MS. IIII: Those trainings are like 10 general overall training. It's not 11 specifically speaking about SHU. Like SHU may 12 come up in the conversations, but it's not 13 specific to SHU or how to operate or run the 14 SHU. 15 MR. Okay. 16 MS. Mm-hmm. 17 MR. Do you know if they were 18 doing this with other employees as well? 19 Having them sign training that they weren't 20 actually conducting? 21 MS. : I don't know. 22 MR. : Okay. But did you do 23 this per the direction of your supervisor? 24 MS. : Su ervisor. Yes. 25 MR. So she - did she EFTA00117651 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 37 specificall you must sign this? MS. : Yes. MR. : Okay. And again, that was MS. MR. • . And you said - and I apologize. I don't know if we were interrupted when -. Where did you say she is currently? MS. IIII: She is in Jersey I know. I'm trying to_ MR. MS. MR. • At the FCI Fort Dix? Yes. Okay. MR. 10.iestion real quick. MR. : Absolutely. Do you want a more precise answer to when she was out and when she came back? MR. Uh, so far -. MR. FOY: Because I happen to know -- MR. Oh sure. If you'd like. MR. FOY: -- the approximate dates. MR. Sure. You can provide that. MR. FOY: And this is based on my review 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 38 of discovery and conversations with Ms. IIII. We're looEilg_2l_gout March 15 to June 24-ish. MR. IIIIIIIIII: 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 the had her sign the document. MR. : Okay. MS. : Right. MR. FOY: So those are the estimated times. I could be off by a day or two, but -. MR. : Perfect. MR. FOY: The 15th of March to June 24th. MR. And thank you attorney Foy. MR. iiiiiiiiiiroblem. MR. : During your time at the MCC, how often were you assigned to the special housing unit also known as the SHU? MS. : Mm. MR. And this is an approximate. I'm not asking you for like exact amount. MS. IIII: When I came back from the injury, my assignment was the SHU. So from 39 1 June 20-whatever to August 10th, I worked the 2 SHU. 3 MR. : Okay. And that was your 4 quarterly assignment was in the SHU from - for 5 that whole summer -- 6 MS. : Yes. 7 MR. -- in 2019? 8 MS. Yes. 9 MR. 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. : No. 14 MR. : 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_ysT provided -? 19 MS. IIII: That's the employee code of 20 conduct. 21 MR. : Okay. 22 MS. : That's the - like the handbook 23 that's online. 24 MR. Should have they provided 25 you with the polices and post orders in the 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 40 SHU? MS. IIII: In the SHU there is post orders. MR. Oh, okay. So in the SHU there's the ost orders. MS. : Yes. MR. And were you provided a copy of that to review? MS. : Yes. MR. And had you reviewed that? MS. MR. : Okay. And when did you review that? MS. : When I came back. MR. So sometime in that June MS. So in June. MR. MS. MR. -- or July timeframe? Okay. So aside from hose post orders, did you receive any other SHU training? MS. MR. : No. And who was EFTA00117652 41 1 responsible for making sure that you actually 2 did receive SHU training? 3 MS. : I don't know. 4 MR. : You don't know was that a 5 lieutenant issue -- 6 MS. : I assumed -. 7 MR. • -- or your first line 8 supervisor? 9 MS. IIII: I would assume the lieutenant. 10 My supervisor. I don't know. 11 MR. And when you say the 12 lieutenant, who was the lieutenant in the SHU 13 at the time? 14 MS. : Lieutenant IIII. 15 MR. : IIII. Do you know his 16 first name? 17 MS. 18 MR. . Okay. And would he be 19 responsible for making sure that you were 20 training when you were in the SHU? 21 MS. IIII: I mean, I'm going to direct 22 that question to her. I don't know. 23 MR. : I don't want you to 24 direct a 222tion to her. 25 MS. fl: Okay. 42 1 MR. But if you need to like, 2 yeah, that's fine. 3 MS. : Mm-hmm. Yeah. 4 MR. : And if you don't know, 5 that's totally acceptable. 6 MS. : Yeah because I don't know. 7 MR. • Okay. No-no, that's a 8 totally acce table answer. 9 MS. : Mm-hmm. 10 MR. • So yeah, if you know - if 11 you don't know something or you do know 12 something, that's great. You don't really want 13 to ask other people for the answers. 14 MS. : Ri ht. 15 MR. : You know, obviously if 16 you need to confer, and you know with your 17 attorneys or your union representative, 18 absolutely fine. But we just want to try to 19 get away from them answering for you. 20 MS. : Okay. 21 MR. : Alright. And then from 22 your recollection though, you don't remember 23 receiving SHU training during the annual 24 refresher training? 25 MS. IIII: No. 43 1 MR. No. Okay. Did you 2 receive training on how to conduct rounds? 3 MS. : Yes. 4 MR. . And when was that? 5 MS. In IF. 6 MR. In IF? 7 MS. Mm-hmm. 8 MR. Okay. And what did it 9 teach you about conducting rounds? 10 MS. IIII: That you need two people to 11 count and conduct rounds. And one person goes 12 and counts. The other person goes and counts. 13 And then ou confirm the numbers of counting. 14 MR. : Okay. 15 MS. : And make sure when you're 16 counting that you're counting everybody's 17 standing at their bed when you're counting. 18 MR. : Okay. And did you 19 receive suicide prevention training during the 20 MCC annual refresher training? 21 MS. : I don't recall. 22 MR. You don't recall. 23 MS. : Mm-hmm. 24 MR. Okay. What was your 25 understanding if an inmate was placed, you 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 44 know, is suicidal or placed on suicide watch? What was your understanding of how you should treat those inmates? MS. IIII: If an inmate is placed on suicide watch, I don't deal with them. They go downstairs to suicide watch and they're being watched b other inmates. MR. : Mm-hmm. MS. : But and then when they're cleared, the come back to the unit. MR. : And are you trained - are you supposed to handle them differently when they come back to the unit? MS. • Uh no. MR. You're not? MS. You're not. MR. You're not supposed to handle them differently? MS. MR. MS. : No. Not at all? Because they're cleared to come back. MR. IIIIIIIIII: Okay. MS. : So once you're cleared, you're back to normal. EFTA00117653 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 45 MR. Okay. And were you assigned to the SHU on August 9th and 10th of 2019? MS. MR. • Yes. • Do you recall what time you began working on the SHU on August 9th? MS. : 4:00 to midnight. MR. : Four to midnight. And then on Amlt 10th? It was? MS. IIII: Midnight to eight in the morning. MR. Okay. You said, again, that was our quarterly bidded post. MS. • Yes. MR. Quarterly assignment. And what were your overall duties and responsibilities when you were assigned to the SHU? MS. IIII: It varies because I'm new and because I don't know how to run the SHU. I just always rely on the senior person that I'm working with. So even if the roster reflects that I'm the senior officer, because sometimes I'm assigned SHU 1, I don't do what SHU 1 is supposed to do because I don't know how to do 46 1 it. I rely on the senior officer that I'm 2 working with. 3 MR. : Okay. So you didn't 4 really know what your duties and 5 responsibilities were? Is that what you're 6 saying? 7 MS. IIII: In the SHU like um, to give out 8 food, to collect the trays, to give out linen, 9 collect linen. Whenever we would go down range 10 to give out those, we count that as a round to 11 make sure the inmates are good. You shower I 12 think ever other Count, that's it. 13 MR. : So rounds and counts are 14 a part of that though? 15 MS. IIII: Rounds and counts are a part of 16 it. But I've never worked in the SHU and 17 actually done rounds every 30 minutes. We go 18 down range to do stuff and we count it as a 19 round. 20 MR. Perfect. And that's 21 going to be something that we're going to 22 discuss. 23 MS. : Mm-hmm. 24 MR. : And ask you things like 25 who told you that and houses that, you know who 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 47 should have provided you with the proper training and information on how it was technicall supposed to be done. MS. : Mm-hmm. MR. : And were there any requirements - special requirements - for inmates who are assigned to the SHU? MS. : I don't know. MR. : That's fine. Do inmates in the SHU have cellmates? MS. : Yes. MR. : Okay. And are they required to have cellmates? MS. MR. MS. : I don't know. You're not sure? Hm-mm. MR. Are there any inmates that don't have cellmates? MS. : Yes. MR. : And do you know why they wouldn't have cellmates? MS. : I don't know. MR. : Did you ever - were you ever told it's because another inmate could harm that inmate? Or there were certain 48 1 classifications of an inmate? They never 2 discussed that with you? 3 MS. : No. 4 MR. : No? Okay. Did you ever 5 see training on medical emergencies? With 6 inmates? 7 MS. Mm. No. I just know like if 8 you are making a round and something happens to 9 an inmate, you call and you wait for somebody 10 to come before you enter the cell. That's all 11 I know. 12 MR. : Okay. But did you - were 13 you provided like CPR training or any kind of 14 like you know, if something were to happen in 15 front of y2lhow you would respond? 16 MS. IIII: Yes. We had CPR training 17 (Phoneticiiiiiiiiii5:08) 18 MR. : Okay. And when would you 19 conduct training like that CPR training or you 20 know if someone is trying to kill themselves or 21 something like that. When did you receive that 22 training? How you would respond to a medical 23 emergency? 24 MS. : That was in IF. 25 MR. IF as well? EFTA00117654 49 50 1 MS. : Mm-hmm. 2 MR. : Okay. So who is or was 3 Inmate Jeffrey Epstein? Reg number 76318-054? 4 MS. : Who was he? 5 MR. : Who was he? Was he an 6 inmate asst ned to the MCC? 7 MS. : Yes. 8 MR. : Was he assigned to the 9 SHU? 10 MS. : Yes. 11 MR. . Okay. Do you know what 12 he was at the MCC for and why he was 13 incarcerated by the BOP? 14 MS. IIII: Actually I didn't even know who 15 he was when I worked with him. It was the 16 other coworker that told me who he was. I 17 didn't know who he was. 18 MR. : And who -? 19 MS. : As in I knew his name but 20 didn't know like what he was there for and who 21 he actualireav 22 MR. : So and when you say the 23 other coworker told ou, who told you? 24 MS. 25 MR. 1 MS. : Uh-huh. 2 MR. : And what is first 3 name? 4 MS. EIM I 5 MR. 6 MS. : Mm-hmm. 7 MR. : And what did he inform 8 you? 9 MS. IIII: He basically said that this is 10 Jeffrey Epstein. You don't know who he is? 11 And I said no. And he was like he's in the 12 news every day. And I was like okay. I didn't 13 know. 14 MR. : Do you remember when you 15 had that conversation? Like at least if you 16 think about August 9th, August 10th? 17 MS. : Mm. No. 18 MR. : Was it obviously it was 19 then prior to August 9th? 20 MS. : Yes. 21 MR. : Okay. But you were 22 working in the SHU together? 23 MS. : Yes. 24 MR. : Okay. Was Epstein in the 25 SHU when you had that conversation? 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 51 MS. : Never. MR. : No. Was he with his attorneys? MS. : Mm-hmm. MR. : Okay. Do you remember anything else about that conversation when he told you about him? MS. : No. That was it. MR. Did he tell you why he was in? MS. : MR. : No? Just that he was famous and in the SHU? MS. MR. know why MS. MR. Did anyone ever tell you it was because he was a risk for suicide or safety concerns? MS. : No. MR. : No? We're going to get into this a little later, but do you know what the hotlist is? MS. IIII: Um.... Are those -? I think : Mm-hmm. Okay. Why was - do you stein was assigned to the SHU? : No. 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 52 the hotlist is like um, how should I say, like inmates that are like -. Inmates that are like - mm. MR. I'm just going to show you this and ask you if you ever received this training either. MS. : Mm-hmm. MR. : Or if you've ever seen it. This will spell out exactly what the hotlist is. MS. : Mm-hmm. MR. : So this is the MCC New York special housing unit. Slides. (Indiscernible *00:38:01) MR. Ed sorry. MR. : This one is special housing unit management suicide prevention. MS. : Mm-hmm. MR. : So can you just have - there's two different tabs here which -- MS. : Mm-hmm. MR. : -- the first one is going to say -. I'll just read it for the record. SHU hotlist identifies inmates with mental health conditions who may become dangerous, EFTA00117655 53 1 self-destructive, or suicidal when placed into 2 the SHU. 3 MS. 4 MR. And that - did you know 5 that? 6 MS. 7 MR. • So do you know what I'm 8 talking about when I say hotlist? There was a 9 list in the SHU of -. 10 MS. IIII: No. I actually thought that 11 the hotlist was something else. Like that was 12 on the coiiiiiiiiiio. I don't know that. 13 MR. : Okay. And then it talks 14 about when someone is on the hotlist, it's 15 supposed to be a special notation on the 16 hotlist, a special notation on the cell door, 17 and there's also a special notation on the SHU 18 board. 19 MS. IIII: Mm. There was never none of 20 that. 21 MR. : So did you ever -? Can 22 you just take a look quickly? You don't have 23 to look throw h that. Just basically the -- 24 MR. : The two tabs. 25 MR. : -- two tabs as well as 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 the front. MS. MR. you? Did MS. MR. 54 : Mm-hmm. Was that ever provided to ou ever see this? : Hm-mm. No. No. Okay. MR. FO1 Dclou want her to initial? MR. : If you could. Yeah. Just so that we can -. You can do it on the top page. No-no. Sorry. The front page. MR. : ON the front page. MR. FOY: Just the first page. MS. : Oh. MR. And do you know who would have been re uired to provide you that -- MS. : No. MR. -- information? No? And no one discussed that with you? MS. : No. MR. : Did anyone ever discuss the hotlist with you? MS. : Na. MR. Had you ever heard of the term hotlist? MS. IIII: No. 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 55 MR. You never even heard the term? MS. IIII: I thought that hotlist was like inmates that were like, um.... Like the inmates that were up on 10 South. Like those high inmates. Like El Chapo and those type of inmates. MR. : Sure. MS. : That's what I though hotlist was. MR. : Okay. And because you brought u 10 South, what's 10 South? MS. : The level above the SHU. MR. And is that a specialized unit that are even more secure than the SHU? MS. . Yes. MR. : And can you just explain to me a little bit about who goes there? What the cell makeup is? Are there cameras in each individual cell? MS. MR. MS. : I don't know. Oh, you don't know? Hm-mm. MR. Okay. Are inmates that are in those cells only one inmate per cell? 56 1 MS. : I think so. 2 MR. : And are they monitored 3 24/7? 4 MS. : Yes. 5 MR. : Okay. But you don't know 6 how they're monitored? 7 MS. : No. 8 MR. : Okay. But they're for 9 like a terrorist, high-profile, drugs -. 10 MS. : Yes. 11 MR. You know? 12 MS. : Mm-hmm. 13 MR. Okay. And that's one 14 floor above where the SHU is? 15 MS. : Yes. 16 MR. : Is it kind of in the 17 general location of the SHU though? 18 MS. : It's upstairs. 19 MR. Can you get to it through 20 the SHU? 21 MS. 22 MR. And would it be 23 considered as - I know it's 10 South and it's 24 unique. But is it also part of the general 25 SHU? EFTA00117656 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 57 MS. IIII: I mean when you come into the SHU, you iiiiiiiiiistairs and it's right there. MR. : Okay. Can you get to it by other means? MS. • No. MR. So you have to go thought the SHU -- MS. MR. MS. MR. Co through the SHU. -- to get -- Mm-hmm. -- into it? Okay. And how many correctional officers are placed in the 10 South? MS. MR. MS. MR. : Um, one. One? : Mm-hmm. And there's no way in or out other than through the SHU? MS. : Mm-hmm, through the SHU. MR. : Okay. So when they come in and out, do the officers that are working in the SHU - you know where you are working - are you the ones that have to allow them to get in and out of the SHU? MS. IIII: Yes. 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 58 MR. Okay. Do you recall who was workin on 10 South on August 9th or 10th? MS. MR. ' In? MS. Mm-hmm. MR. Okay. Was that August 9th or 10th or both? MS. IIII: I don't know about the 9th but the 10th. MR. : That's fine. And some of this stuff I'll probably at some point give you a list of the people so you can refer to like the roster so you don't have to -. MS. : Okay. MR. : You know you can recall that way if you remember that those people were in (Indiscernible 00:41:35). MS. : Okay. MR. : But you did say Epstein was assigned to the SHU on August 9th and August 10th, 2019? MS. : Yes. MR. Okay. And he was assigned to the SHU on the days leading up to August 9, 2019? 59 1 MS. : Yes. 2 MR. : Okay. Do you know 3 approximately how long Epstein was assigned to 4 the SHU? 5 MS. : No. 6 MR. : Was he assigned to the 7 SHU for the most part of when you were doing 8 you assignments in the SHU? 9 MS. IIII: When I came back and I was 10 working there? 11 MR. : Correct. 12 MS. 13 MR. Okay. 14 MS. Mm-hmm. 15 MR. : Yes? Okay. So does July 16 and August sound about right? That he was in 17 the SHU? 18 MS. : Mm-hmm. 19 MR. : Yes? What was Epstein's 20 routine while he was assigned to the SHU? We 21 talked about it briefly. He was with attorneys 22 and stuff. So was that like a daily routine? 23 Can you just tell me when he would come and go? 24 And when he would be in the SHU and not be in 25 the SHU? 60 1 MS. IIII: Oh I come in at 2:00. And I 2 come in at 4:00. And when I come in he's not 3 there. He would come back like around after 4 8:00. 5 MR. 8:00 p.m.? 6 MS. 7 MR. Okay. And did you 8 typically work after 8:00? So you come in at 9 2:00 or 4:00. When would you typically work 10 until? 11 MS. IIII: 2:00 to 10:00 or 4:00 to 12 midnight. Mm-hmm. 13 MR. : And then would you 14 typically do overtime shifts after that? 15 MS. IIII: No because I usually do it on 16 the front end. 17 MR. Okay. 18 MS. : So I usually come in the 8:00 19 to 4:00 and do 4:00 to 12:00. 20 MR. : And when you would come 21 in 8:00 to 4:00, would he be gone already? 22 MS. 23 MR. : Okay. But he would come 24 back around -? So he would be gone before 8:00 25 a.m. and come back around 8:00 p.m.? EFTA00117657 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 61 MS. : Mm-hmm. MR. : Would he eat when he was in the SHU? MS. IIII: He gets common fare. That's all I know. I don't know if he eats it. But he gets common fare. MR. : Would that be something you supplied after 8:00 p.m.? MS. : When he comes back. Yes. MR. : Okay. What time is typically feeding time? In the evening? MS. : Um...after 4:00? MR. : And so because he was away, does he get -? Would he get an individual tray that was saved for him or provided when he returned? MS. : Yes. MR. : Okay. And would you provide that try to him? MS. IIII: Not necessarily me just whomever. MR. MS. MR. : Did you ever? Yes. : Okay. Did you provide that to him on August 9th? 62 1 MS. Yes. 2 MR. : You were the one who did? 3 MS. : Mm-hmm. 4 MR. : Okay. Did you ever have 5 any communications with Epstein during his stay 6 at the MCC? 7 MS. 8 MR. 9 at all? 10 MS. 11 MR. : Okay. Did you even 12 verbal say hello - hello back? Anything like 13 that? 14 MS. Mm. He was in the shower to 15 make a phone call. And he was calling because 16 he wanted to come out of the shower. And I 17 told him that he had to wait because there were 18 other inmates out. And you can't move him and 19 them out at the same time. That's the only 20 conversation I ever had with him. 21 MR. : And we'll get into that 22 but was that phone call on August 9, 2019? 23 MS. • Yes. 24 MR. : Okay. But when you would 25 provide food or anytime he would come back : Never any conversations 63 1 after 8:00 p.m. - even when he was coming in or 2 out, you wouldn't even say hello? 3 MS. : No. 4 MR. : No? Okay. For the one 5 interaction you can think of with the phone 6 call, do you remember if that was a positive or 7 a negative interaction? Do you remember it at 8 all? Was it -? 9 MS. : It was regular. 10 MR. : Regular? 11 MS. Mm-hmm. 12 MR. : Did he seem upset? 13 MS. Uh, no. 14 MR. : No? Abnormal? Anything 15 out of the ordinary? 16 MS. : No. 17 MR. : No. What were your 18 instructions with regard to Epstein being 19 assigned to the SHU? 20 MS. : There was no instructions. 21 MR. : So no one said Epstein 22 was a high priority here? Pay closer attention 23 to him? 24 MS. : No. 25 MR. : Alright. So even when 64 1 you had that interaction with the one 2 individual who told you that he was a high- 3 profile person, that he was in the news all the 4 time, there was never a discussed that we need 5 to pay close attention to him? 6 MS. : No. 7 MR. And Lieutenant IIII, you 8 said was the lieutenant in the SHU, he never 9 told you to ay special attention to Epstein? 10 MS. : No. 11 MR. Okay. Was Epstein 12 assigned any cellmates when he was assigned to 13 the SHU? 14 MS. : Yes. 15 MR. And do you know when he 16 was assigned to the SHU was he always assigned 17 a cellmate? 18 MS. IIII: Um, I just know he had two 19 cellmates. 20 MR. Okay. Two different 21 ones? 22 MS. Yes. 23 MR. Alright. Did anyone ever 24 speak with you about Epstein needing a cellmate 25 when he was in the SHU? EFTA00117658 65 66 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 MS. : No. MR. : No? Who was the officer in charge or the OIC in the SHU? MS. : Me. MR. Um, are you talking about at 12:00 a.m.? MS. IIII: Yes. On (Indiscernible *00:46:06) -. MR. In general, was there like one officer in charge that has like is considered the OIC in the SHU? MS. IIII: That's what I'm telling you. On paper, it says me. But I don't know how to run the SHU. So I rely on the senior officer. Well on the roster, it says that I was the OIC. And -. MR. MS. MR. I think I'm just not asking the question correctly. I'm not talking about like from 12:00 a.m. to 8:00 a.m. on August 10th. I mean in general. Like in July and August when you were in the SHU, was there one person that was considered the officer in charge? Like hot, there's one lieutenant of the SHU which was El? Was there also an officer 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 in charge of the SHU? MS. 1.1o. MR. : Do you know who - wasn't it Grill? MR. Mr MR. : Do you know who is? MS. : Yes. MR. : Would he be considered the officer in charge? MS. IIII: See I don't know. Because on the roster, it can be a differentiiiiiiii MR. : Okay. Did have like a desk or a computer area that he always sat in when he was there? MS. : No. MR. Specifically? MS. It's the one that we all sit at. MR. But he didn't have one specific location that he would sit at? Like - ? MS. : No. MR. : No, he would sit wherever? 67 1 MS. : Yes. 2 MR. : Can you give me just like 3 a layout? How many desks and computers were 4 there in the SHU where the officers sat? 5 MS. IIII: It was two desks. One this way 6 and one this wa . 7 MR. : So kind of like an L type 8 of formation? 9 MS. IIII: Yes. And computers, about 10 three. 11 MR. . About three computers? 12 MS. Mm-hmm. 13 MR. And had you sat at all 14 three of those computers at least one time 15 during your shifts? 16 MS. : Um, yes. 17 MR. Okay. So it's just - it 18 rotates. You can sit at each one? 19 MS. I mean you can sit at any one. 20 MR. And do you remember ever 21 there being a sign posted on any of the 22 computers saying that Epstein was required to 23 have a cellmate? 24 MS. : No. 25 MR. Alright. And then 68 1 2 MR. Am I pronounciiiiiiiiiright? : Yeah. 3 MR. How do you spell that 4 last name? Do you remember? 5 MR. 6 MR. Thank you Agent 7 So he didn't have a specialized computer where 8 he would have posted a sign on a computer? 9 MS. : No. 10 MR. : No? What about - do you 11 recall ever seeing a sign posted on Epstein's 12 door? 13 MS. : No. 14 MR. : Saying that he was 15 required to have a cellmate? 16 MS. : No. 17 MR. No? Oka . Who was 18 Inmate 19 IMI? 20 MS. Uh, his first um cellmate that 21 he had. 22 MR. 23 MS. 24 MR. 25 July of 2019? Epstein's first cellmate? Mm-hmm. Was that his cellmate in EFTA00117659 69 1 MS. IIII: I'm not sure about the month, 2 but that was his first cellmate. 3 MR. : Okay. Do you recall if 4 was already in the SHU or was he 5 brought in specifically to be Epstein's 6 cellmate? 7 MS. • I don't know that. 8 MR. : You don't know that? 9 MS. 10 MR. : Okay. Are you aware of 11 an issues that took place between Epstein and 12 when they were cellmates? 13 MS. No. 14 MR. : No. Were you aware that 15 on or around July 23 of 2019 um that Epstein 16 allegedly attempted to commit suicide? 17 MS. IIII: I wasn't at work that day but I 18 was told. 19 MR. : Okay. And were you told 20 anything else about the incident? 21 MS. No. 22 MR. : Are you aware if 23 was his inmate at the time? 24 MS. Yes. 25 MR. : And you said you didn't 70 1 have any involvement in that matter though? 2 MS. I wasn't at work. Hm-mm. 3 MR. : Do you know if 4 was removed as Epstein's cellmate? 5 At that point? 6 MS. After that he had another 7 cellmate: 8 MR. : And do you know why they 9 changed? 10 MS. • But I don't know why. 11 MR. : Okay. Do you know who 12 would have made that decision to change 13 cellmates? 14 MS. 15 MR. 16 that 17 MS. 18 MR. 19 rumor? 20 MS. 21 MR. : Okay. Do you know what 22 was used in the incident when Epstein attempted 23 to - alle edly attempted to take his life? 24 MS. : No. 25 MR. : No? : No. Had you ever heard attempted to harm Epstein? No. : You didn't even hear that 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 71 MS. : Hm-mm. MR. : Do you know if it was like linens or a shirt or any kind of -? MS. : I don't know. MR. • No? MS. MR. with you? MS. MR. • And you didn't ask anybody about it? MS. : N MR. Do you know if Epstein was placed on suicide watch or psychological observation? MS. IIII: I think he was placed after that. But I don't know which one. MR. : Okay. Is it usually that someone will go on suicide watch for about 24 hours? Then after that they would go on what's called ps chological observation. MS. MR. MS. MR. • No one discussed that : I'm not sure. • You're not sure? Hm-mm. Is that done in the SHU 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 or elsewhere? MS. : It's done MR. : And downstairs, what - do you MS. IIII: Where the Unit 2. MR. MS. MR. 72 downstairs. when you say know where? suicide watch is or • Okay. So second floor? Mm-hmm. And do you know who makes the determination to be able to place someone on suicide watch or psychological observation? MS. : No. MR. : No? Okay. Does it sound right that he was placed on suicide watch on or around July 23, 2019? And returned to the SHU on or around July 30, 2019? MS. : Yes. MR. That sounds about right? MS. Mm-hmm. MR. And at that time, was Epstein as si ned another cellmate? MS. MR. Who - which cellmate? MS. MR. EFTA00117660 73 1 MS. Mm-hmm. 2 MR. : On or around Sul 30th. 3 And who was Inmate ? 4 MS. His cellmate. 5 MR. : Do you know anything 6 about him? 7 MS. 8 MR. : Okay. But you do know he 9 was his cellmate 10 August 9, 2019? 11 MS. Yes. 12 MR. : Okay. And do you know if 13 Inmate was already in the SHU? Or was he 14 brought in specifically to be Epstein's 15 cellmate? 16 MS. I don't know. 17 MR. : You don't know if he was 18 already in 19 MS. 20 MR. : Now do you ever -? Do 21 you have any involvement with the inmates when 22 you're in there? Would you like converse with 23 24 25 1 2 3 4 was removed on August 9, 2019? 5 MS. : No. 6 MR. : So even on August 9th you 7 didn't know that he was removed? 8 MS. : No. 9 MR. : You knew that Epstein had 10 a cellmate. You just didn't know that he 11 didn't have a cellmate on that day? 12 MS. IIII: He had a cellmate. I didn't 13 know that the cellmate was removed and wasn't 14 coming back. 15 MR. : Okay. So you never 16 learned on August 9th or August 10th for that 17 matter, prior to 6:30 that there was no other 18 inmate within Epstein's cell? 19 MS. : No. 20 MR. : Oka And do you know if 21 anybody was aware that MI was departing the 22 MCC or SHU rior to August 9, 2019? 23 MS. : I don't know. 24 MR. : You don't even know that 25 - you know at this point- if anyone was aware? from that point until about them or do ou just kind of -? MS. : No. MR. : No? so you don't -. Did was removed? MS. : Yes. 75 MR. : And did you know that he 74 1 you ever know why people were specifically in 2 the SHU? 3 MS. 4 MR. : No. Do you know why 5 Inmate was removed from the MCC on August 6 9, 2019? 7 MS. 8 MR. So even at this point do 9 you know _ylEhe was removed? 10 MS. IIII: No. I didn't even know he was 11 removed. 12 MR. : No, I'm saying even today 13 do you know that? 14 MS. • Oh no. 15 MR. : You don't even know that 16 he was removed? 17 MS. No. I'm saying at that point 18 in time, I didn't know that he was removed. 19 MR. : Yeah. So I'm even saying 20 as of tod.iy_:. 21 MS. IIII: But for now, I don't know the 22 reason wh he was removed. 23 MR. : Okay. 24 MS. 25 MR. • But you do know that he 76 1 MS. : No. 2 MR. : No. Do you know if it 3 was antici ated or not an anticipated move? 4 MS. : I don't know. 5 MR. : No? So on August 9th 6 during your time from 4:00 p.m. even to just 7 12:00 a.m. That was not discussed with you at 8 all or within the SHU? That Epstein's roommate 9 was removed? 10 MS. Never. 11 MR. Never? 12 MS. Never. 13 MR. Okay. And are you pretty 14 confident about that? 15 MS. : Yes. 16 MR. : Okay. Are you aware if 17 Epstein should have been reassigned a cellmate 18 after Inmate was removed on August 9, 19 2019? 20 MS. 21 MR. So you're not aware? 22 MS. 23 MR. If he should have been? 24 MS. 25 MR. So your understanding was EFTA00117661 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 77 he had cellmates. You just didn't know if one of them was removed that he should be reassigned one? MS. : Exactly. Mm-hmm. MR. : Okay. Do you know who was responsible for assigning Epstein a new cellmate? MS. : I don't know. MR. No. Could SHU staff have assigned Epstein a new cellmate? Would you have the authority being - working in the SHU - if you knew someone was supposed to have a cellmate? Do you have the authority to place another inmate with that person? MS. IIII: See I don't know. Because I'm that new. MR. MS. Okay. : So like I said, I rely on the senior person a lot. So I don't know. like that would be a question I would ask them. So I don't know. MR. : When you were - during your time in the SHU, which you said I guess was from you know late June through August 9th or 10th. Did you ever see that happen before? 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 78 SHU staff assign inmates with other inmates? MS. IIII: When an inmate comes, they place them with another inmate. MR. : And would they do that based upon their own responsibilities and duties or would someone tell them to do that? MS. MR. MS. : See I don't know. You don't even know? Hm-mm. MR. Okay. So you saw people be assigned with other ones, but you don't know how -- MS. MR. -- that was determined? MS. Yeah. MR. Okay. So you don't even know if you could have assigned Epstein a new cellmate? MR. MR. No. : I don't know. : Do you know if SHU staff should have assigned? You know like -. Or I guess you just answered that. So you said you know. And again, on August 9th, no one notified ou that was gone from the SHU? MS. IIII: No. 79 1 MR. And you were working in 2 the SHU. 3 MS. : No e. 4 MR. Do they typically tell 5 you when an inmate in the SHU is - has left and 6 is not comm back? 7 MS. IIII: Nobody said anything to me. I 8 don't know. 9 MR. : Because don't you have to 10 be able to keep your counts correct? And be 11 able to know how many people are in the SHU? 12 So if someone is removed, don't they have to 13 tell you? This person's not coming back so 14 your count is going to be lower. 15 MS. IIII: Mm-hmm. But it wasn't told to 16 me. So I don't know. 17 MR. : Um okay. Do you know who 18 the MCC staff psychologists were in August of 19 2019? 20 MS. : N 21 MR. : Do you have any dealings 22 with them at all? 23 MS. : No. 24 MR. Does the name Chief 25 ring a bell? 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 MS. MR. psychologist MS. MR. MS. MR. dealings MS. MR. MS. the unit. MR. : Okay. Prior to August 10th did ou have any dealings with her? MS. : No not really. MR. No. What about a Samantha MS. MR. MS. MR. with her? MS. MR. : So only with 2 80 No? How about staff Mm-hmm. I know her. Okay. Who is she? She's one of the psychologists. Okay. And did you heave with her? : I had dealings with her after. You after August 10th? : Like on August 10th she came to Demisa? Yes I know her. And who is she? sychologist. Did you have any dealings EFTA00117662 81 82 1 MS. IIII: Yes but she came after the 2 incident. 3 MR. : But what was your dealing 4 with her after the incident? 5 MS. : She just asked was I alright. 6 MR. : Okay. Did she ask you 7 anything about Epstein or his cellmate or 8 anything like that? 9 MS. No. 10 MR. : No? So it was specific 11 to you? 12 MS. Yes. 13 MR. : Okay. Are you aware was 14 Epstein meeting with staff psychologists during 15 his stay at the MCC? 16 MS. No. 17 MR. : No. Would have he met 18 with them I guess during suicide watch and 19 psychological obviously? 20 MS. : Yes. 21 MR. : Okay. So that. Did you 22 know that he did meet with them then? 23 MS. IIII: I don't know if he did, but I'm 24 going to assume he did. 25 MR. : Okay. But you do know 1 that he was laced on suicide watch? 2 MS. Yes. 3 MR. : And they never - no one 4 from psychology ever provided you instructions 5 with regard to when he returned - how he was to 6 be treated? 7 MS. • No. 8 MR. : Or that he was - needed 9 to have a cellmate at all times. 10 MS. • No. 11 MR. : Or that you needed to 12 watch him? 13 MS. 14 MR. : Do you know who placed 15 him on suicide watch? 16 MS. No. 17 MR. : No? So what is your 18 understanding of suicide watch? When someone 19 is on suicide watch and comes back. What is 20 your understanding of how you're supposed to 21 treat those people? Now my understanding is 22 that you would have received this training you 23 know. Now I know you said you didn't do the 24 SHU training. But the other trainings that you 25 attended - the IF, the MCC annual, and the 83 1 correctional officer training at FLETC. Did 2 they discuss suicide? 3 MS. IIII: I mean if someone is like 4 explains to you that they're feeling a certain 5 kind of way or they want to harm themselves, 6 then you report it to them. They will place 7 them on suicide watch. But as far as when they 8 return, there's no - nothing special that we're 9 told to do when someone returns from suicide 10 watch. 11 MR. So they don't tell you 12 like this person's on suicide watch, he's 13 returning, he needs, you know a high likelihood 14 of attemptin to harm himself. 15 MS. : No. 16 MR. We should place him with 17 another cellmate. 18 MS. : No. 19 MR. That we should watch him. 20 MS. 21 MR. Or make sure that he 22 hasn't harmed himself. 23 MS. : No. 24 MR. : Or pay special close 25 attention to that individual. 84 1 MS. : No. 2 MR. : You said suicide watch 3 though, that is on the second floor? 4 MS. : Yes. 5 MR. : Okay. So you're not 6 aware that the requirement that if someone is 7 returned to the SHU that they're required to 8 have a cellmate if they were on suicide watch? 9 MS. : No. 10 MR. : Do you know the 11 difference between suicide watch and 12 psychological observation? 13 MS. : No. 14 MR. • No? Are they both done 15 in - on the second floor? 16 MS. : Yes. 17 MR. Okay. But you don't even 18 know what that is? 19 MS. : No. 20 MR. . Did you know that Epstein 21 was also on sychological observation? 22 MS. : No. 23 MR. • No? Just suicide watch? 24 MS. : Mm-hmm. 25 MR. And to you it's one and EFTA00117663 85 86 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 the same thing? MS. MR. MS. MR. : Yes. : Okay. Mm-hmm. • And I did ask about suicide watch, but do you know who placed Epstein on sychological observation? MS. : No. MR. : No? And you don't know - . Are inmates that come from psychological observation required to have a cellmate? MS. No. MR. : You don't know? MS. I don't know. MR. : So were you aware of any inmates that are in the SHU that were on suicide watch - came from suicide watch and psychological observation? MS. : No. MR. : And again, that hotlist. Did you say that you do remember there being one? MS. : No. MR. : In the SHU? MS. : No. 1 MR. So you don't even 2 remember there being a hotlist in the SHU? 3 MS. : No. 4 MR. : Would you like look 5 around at the boards and look at the walls and 6 see different things? 7 MS. : There is no board. 8 MR. No? There's no like -- 9 MS. 10 MR. -- where the post orders 11 are - where are they kept as -. 12 MS. : It's on the desk. 13 MR. : Was there also on the 14 desk something called the hotlist? 15 MS. : No. 16 MR. : Was there a list on the 17 desk that had like inmate's names and anything 18 next to them? Like a description? 19 MS. : There's a roster. 20 MR. : A roster like of all the 21 inmates in the SHU? Total? 22 MS. : Yes. 23 MR. : Well what about like - 24 and I only say this because I know that there 25 was one. So you don't recall saying like - 87 1 seeing like one list where there's special 2 people assigned to that list called the 3 hotlist? 4 MS. 5 MR. • No? And you did work 6 there all June, July, and August? Or not all - 7 end of June July, and then it's August. 8 MS. : Yes. 9 MR. : Did any staff 10 psychologist visit the SHU? 11 MS. : Yes. 12 MR. Did they ever visit 13 Epstein in the SHU? 14 MS. No. 15 MR. No? What time typically 16 would they come to the SHU when they would 17 visit? 18 MS. IIII: Um like after -. When I worked 19 the 8:00 to 4:00. I don't know. Sometime in 20 the day like ma be around 12:00. 21 MR. : And would they not have 22 come to the SHU to see Epstein because he 23 wasn't there at 12:00? 24 MS. : Because he wasn't there. 25 MR. Do you know if they ever 88 1 visited him when he was with his attorneys? 2 MS. : I don't know. 3 MR. : You don't know. So did 4 anyone - so psychologist, peers, supervisors, 5 or anyone else - ever tell you that Epstein was 6 required to have a cellmate? 7 MS. : Nobody. 8 MR. : Nobody. Did you ever 9 receive any emails? So any type or form of 10 communication? So not just verbal. Emails and 11 writing, text messages - anything? 12 MS. : No. 13 MR. : No? Do you have that 14 email? This isn't an email that was sent to 15 you. I just want to see if you - if someone 16 ever forwarded this to you. Did anyone ever 17 forward you -? This is -. First of all, this 18 is an email from . It says 19 suicide watch / psychological observation 20 update. It's what was sent on July 30, 2019. 21 It says inmate Epstein is being taken off 22 psychological observation and needs to be 23 housed with an appropriate cellmate. Did 24 anyone ever forward this information to you? 25 Being that you worked in the SHU where he was EFTA00117664 89 1 assigned? 2 MS. 3 MR. : No? So no one ever 4 discussed that with you in the SHU? Like none 5 of the other employees in the SHU that would 6 have received this? 7 MS. . No. 8 MR. Do you know why other 9 employees would have received this and you 10 wouldn't have? 11 MS. IIII: I'm not going to say that they 12 received it and I didn't. 13 MR. : Well if you look at the 14 back it's all the people that it was sent to. 15 So if you go to the last page, do you recognize 16 any of the people on there that worked in the 17 SHU with you? The names. Look at the last - 18 sorry, that middle page and toward the bottom. 19 The following page I think. Middle, toward the 20 bottom. 21 MS. . That's the lieutenant. 22 MR. . Do you recognize 23 Lieutenant on there? 24 MS. . Yes. But this is not sent 25 This is not the workers. 1 2 3 4 S 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 90 MR. : None of those people were assigned to the SHU? Towards the bottom of that? MS. : No. MR. : No? Okay. So just the only person that you see on that is Lieutenant IIII? MS. : Lieutenant IIII. MR. : And he never discussed that matter with you? MS. : No. MR. : If you don't mind, could you initial and date it? MS. : I initialed. MR. And date. MS. Ten.... MR. : The 22nd. 6/22/21. MR. Agent just has a couple questions on that. MR. Here. MR. : During your time in the SHU MS. Mm-hmm. MR. : Did any new inmates come in during your shift? 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 91 MS. III': On that specific day or in general? MR. : Yeah. From June to August. When you worked in the SHU. Did the SHU receive an new inmates? MS. : Yeah. MR. : When they came in, how did you assign the inmates? MS. IIII: I didn't. The senior officer did. MR. : Senior officer. Did you see them assigp_inmates? Assign a cell to them. MS. IIII: Like they put them in a cell? Yes. MR. : Were they ever put by themselves? MS. : I don't remember. MR. : Do you recall any inmates being placed by themselves in the SHU? MS. IIII: I think there was one inmate by himself. MR. by himself? MS. : I don't know. MR. So of all the inmates, : Any reason why he was placed 92 1 there was only one that was by themselves? 2 MS. IIII: I think it was an inmate by 3 himself on C tier. 4 MR. : Now you mentioned that day 5 were you on August 9th you were notified that 6 was removed. But during your time 7 in the SHU, were you ever notified if an inmate 8 was ever removed from the SHU for whatever 9 reason? Were you notified about it? 10 MS. No. 11 MR. : How would you find out if the 12 inmate was supposed to be in the SHU or not? 13 MS. IIII: How would I find out if an 14 inmate isiiiiiised -? 15 MR. : Let's say the morning 16 started. 17 MS. Mm-hmm. 18 MR. : You came on shift at 2:00 19 p.m. or possibly 4:00. After that, there's 20 counts and rounds. When you do the counts, 21 right. I just want to know in terms of how 22 would you know if an inmate was removed or not? 23 MS. IIII: When I count and he's not 24 there. 25 MR. : You wouldn't be notified any EFTA00117665 93 94 1 other way? 2 MS. No. 3 MR. : That's all I have. 4 MR. : And I know we discussed 5 the cellmates, but were you ever told you 6 needed to keep a close watch on Epstein -- 7 MS. : No. 8 MR. : -- when he was there? 9 No? Who was the MCC warden in July and August 10 of 2019? 11 MS. 12 MR. : Is that ? 13 MS. Yes. 14 MR. : Okay. What 15 communications did you have with the warden 16 with regard to Epstein being housed within the 17 MCC or the MCC SHU? 18 MS. : None. 19 MR. : None. And he never 20 provided you special instructions with regard 21 to Epstein? 22 MS. 23 MR. : Did the warden ever tell 24 you that Epstein was required to have a 25 cellmate? 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 MS. : No. MR. : Did the warden ever visit the SHU during Epstein's stay at the MCC? I don't know. Not on my shift. : Not during your shift? MS. MR. MS. MR. : No? Okay. Do you know if the warden ever met with Epstein during his stay? MS. • I don't know. MR. : Who were the MCC associate wardens in August of 2019? MS. Um, associate warden was MR. MS. Yes. MR. aware of? MS. : Anyone else? That you're MR. : Okay. And what communications did you have with or the other AW with regard to Epstein being housed within the MCC or the MCC SHU? MS. IIII: None. 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 95 MR. None? Would you have communications with any of the AWs? MS. . No MR. : No? So did you not even ever speak with them? MS. : Not in the SHU. MR. • Not in the SHU. When would you_laak with them? MS. IIII: On the regular housing unit when they made rounds. MR. So in July and August did you ever s eak with them that you recall? MS. : No. MR. • No. So not since you were assi ned to the SHU at the end of June. MS. : Mm-hmm. MR. Okay. What about the warden? Is that the same thing? MS. . Mm-hmm. MR. No communications? MR. FOY: Don't know. MS. : No. MR. : No? MR. FOY: Don't answer if you don't know. MS. IIII: Okay. 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 96 MR. FOY: Oka MR. : Do you know if any of the AWs ever visited the SHU during Epstein's stay? MS. .lon't know. MR. : You don't know. Not during your watch though? MS. MR. : Okay. Do you know if any of the AWs ever met with Epstein during his stay at the MCC? MS. : I don't know. MR. : You don't know. But not when you were in the SHU? MS. : Not on my shift. MR. Who was the MCC captain in July and August of 2019? : Captain . Is that Yes. MS. MR. MS. MR. Okay. And what communications did you have with Captain with regard to Epstein being housed within the MCC or the MCC SHU? MS. : None. MR. None? And did he ever EFTA00117666 97 1 provide you with special instructions with 2 regards to E stein? 3 MS. : No. 4 MR. Captain 5 MS. 6 MR. 7 you that Epstein was required to have a 8 cellmate? 9 MS. 10 MR. 11 captain ever visit the SHU during Epstein stay 12 at the MCC? 13 MS. : Not on my shift. 14 MR. : Not during your time? 15 Okay. And do you know if the captain ever met 16 with Epstein during his stay at the MCC? 17 MS. : I don't know. 18 MR. : You don't know. So who - 19 ? I'm going to give you now just because -. 20 Uh okay, where are the rosters? I'm going to 21 ask her about some of the supervisors that were 22 on duty. So are you familiar with these 23 rosters? Like just by looking at it are you 24 able to decipher who was on duty and who 25 wasn't? Or who was on duty on August 9th and 7 Did the captain ever tell In the SHU? No? Did the 98 1 10th? I'm giving you the MCC New York daily 2 assignment roster. So there's August 9th and 3 August 10th. So who were the MCC supervisors 4 on duty with responsibility for overseeing the 5 SHU on August 9th and 10th? Do you recall if 6 Lieutenant was there on August 9th or 7 10th? 8 MS. : I don't recall. 9 MR. You don't recall. 10 MS. 11 MR. Okay. So he wasn't 12 there. So if he's not there, who has oversight 13 over the SHU? 14 MS. : I don't know. 15 MR. : Do you - would it be the 16 operations lieutenant or the activities 17 lieutenant? 18 MS. : I don't know. 19 MR. : You don't even know who 20 is - that would have responsibility if the 21 lieutenant of the SHU wasn't there? 22 MS. : No. 23 MR. : Would anybody if 24 Lieutenant wasn't there check in with you? 25 MS. : I mean the other lieutenant 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 99 would make a round. MR. What other lieutenant would that be? MS. IIII: Whoever was on. You mean that day? MR. Yes. On August 9th and August 10th. I'm wondering who had responsibility of the SHU? If Lieutenant IIII wasn't there. He was the SHU lieutenant. MS. IIII: In the daytime, it was a regular officer acting. MR. • Okay. MS. : From the when I was on at 4:00 to 12:00. MR. : Okay. MS. : And then from midnight it was Lieutenant MR. Okay. So would that other person that you're referring to. Do you know who that was? MS. : The acting? That was acting? MR. Acting. MS. MR. SOS =? MS. : Say that again. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 100 and MS. MR. • Okay. What about by looking at that. Would the - do you see where it says 7 MS. MR. . Would that person have oversight over the SHU from - does it say that that person was the operations lieutenant? MS. IIII: That's what it says here but I didn't see Lieutenant MR. : And do you know as being the operations lieutenant would they be responsible for overseeing the SHU? If -? MR. Was it SOS Senior Officer Specialist MS. Yes. MR. Is that MS. (Indiscernible *01:11:25) MR. I might be saying that name wrong,__ MS. IIII: I'm not sure of her first name, but -. those are the tw That's fine. Oki. o that you remember: MR. 2 Was Acting in the day. Yes. Yes EFTA00117667 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 101 MS. : I don't know. MR. : You don't even know that? Okay. So you don't know if after -. Is it true that after replaced him as the operations lieutenant? MS. : According to this, yes. MR. : Okay. And you're not aware that that person would have oversight over the SHU? MS. • I don't know. MR. : You don't know. No one ever talked to you about isn't there. Who should you go to if there are any problems or who would check in with you? MS. IIII: No. I would call downstairs to the lieutenant's office. MR. : And would you just talk to whoever answered? MS. Yes. MR. : And who would sit in the lieutenant's office? MS. The lieutenants. MR. : All of them? MS. MR. : So it wouldn't be like 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 102 the operations lieutenant and the activities lieutenant? MS. • No. All the lieutenants. MR. : Okay. They all just sit in there to ether? MS. Mm-hmm. MR. : Not one of them specificall answers the phone though? Just -? MS. No. Anybody. MR. : Okay. Do you remember -? Again, Lieutenant was reportedly off on August 9th and August 10th. MS. Mm-hmm. MR. : Do you recall ever seeing him on Au ust 9th or August 10th? MS. Hm-mm. MR. : Where would Lieutenant sit? When he was at the MCC? MS. : U stairs. MR. : When you say upstairs, upstairs where? MS. IIII: There's an office right next to 10 South u stairs there. MR. : Within the SHU? MS. : Yes. 103 1 MR. Okay. So he was 2 physicall in the SHU? 3 MS. Yes. 4 MR. . Alright. So when he 5 wasn't there, would any other lieutenant come 6 visit the SHU? 7 MS. : When they make rounds. 8 MR. : Okay. When they make 9 rounds. And do you remember if that person was 10 the acting or the operations lieutenant or the 11 activities lieutenant? The person that would 12 do those rounds? 13 MS. : I don't know. 14 MR. : You don't know. you just 15 knew that they were a lieutenant. 16 MS. : Yes. 17 MR. : Okay. So would you even 18 be provided that information where there's a 19 duty agent roster? Is that something that 20 would be like, hey. It's up. If I need to get 21 in contact with somebody, I can look at that 22 roster and see who is where? 23 MS. IIII: No. Just call the lieutenant's 24 office. 25 MR. Just call the 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 104 lieutenant's office. MS. : Yes. MR. : Okay. And I believe you answered this, but did you have an communications with Lieutenant IIII regarding Epstein at all? MS. : No. MR. So he never provided you any special instructions with Epstein? MS. : No. MR. And you never - Lieutenant never told you Epstein was required to have a cellmate in the SHU? MS. MR. No. Operations Lieutenant I" know who was from August 9th? Do you know that individual? MS. : Yes. MR. • But as the operations lieutenant, you don't know that he was responsible for overseeing the SHU on August 9, 2019? MS. : I don't know. MR. : Did you have any communications with Lieutenant regarding EFTA00117668 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 105 Epstein bein housed at the MCC or in the SHU? MS. : No. MR. : He never did - did Lieutenant ever provide you with special instructions with regard to Epstein? MS. : No. MR. : Did Lieutenant ever tell you that Epstein was required to have a cellmate while he was assigned to the SHU? MS. IIII: No. I'm going to ask you these questions with a couple people. So I just want you to like really think about those people and they're goin to be repetitive. MS. : Okay. MR. : Because I know you can just simply say I didn't have any communications. But I want you to really think about that individual and any communications you had with that person with regard to Epstein and the SHU and your assignments. Okay? MS. : Okay. MR. Who is Lieutenant 7 MS. : A lieutenant. MR. : A lieutenant. By looking 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 106 at that roster, was he on it on August 9th? MS. : No. MR. : No. Do you know if he was physically present at -? Do you recall if he was ph sically present on August 9th? MS. MR. leave. I there. MS. • Okay. MR. : So you don't recall having an communications with him? MS. : No. MR. Alright. And did Lieutenant ever provide you with special instructions with regard to Epstein? MS. : No. MR. : No. Did Lieutenant ever tell you that Epstein was required to have a cellmate while he was assigned to the SHU? MS. MR. And then this is who you were just referring to. Who was senior officer specialist just want : I don't recall. He was reportedly on sick to make sure that he wasn't No. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 107 MS. : An officer. MR. : And on August 9th, was she the acting lieutenant responsible for overseein2_1be SHU? MS. IIII: I don't know if she was responsible for overseeing the SHU, but I know she was the acting lieutenant. I don't know for the whole building. MR. But you said she -- MS. But she -. MR. -- conducted a round? MS. She did. MR. Okay. So if she conducted a round, would that lead you to believe that she was probably -? Hey, Lieutenant isn't there, she's conducting the round here, she's probably got oversight over the SHU? MS. IIII: I don't know. It could be another lieutenant also. I don't know. MR. SHU on Au MS. MR. Okay. Did she visit the ust 9, 2019? : Yeah, she did. And what time was she on duty on August 9th? By looking at that roster. 108 1 Can you tell? 2 MS. : It says 8:00 to 4:00. 3 MR. I think it would just be 4 on that first age. 5 MR. : Is that August 10th or 9th? 6 MS. This is 9th. 7 MR. It just says 8:00 to 8 4:00? 9 MS. Yes. 10 MR. : Can you check on the 11 lieutenants column up top? 12 MS. • (Indiscernible *01:17:34) 13 MR. : Is there a name? 14 MR. It should be under 15 activities lieutenant. 16 MS. : Oh yeah. 4:00 to midnight. 17 MR. : 4:00 to midnight? Okay. 18 So you knew that - you do recall having an 19 interaction with her. Did she have any 20 communications with - we're talking 21 about now - with regard to Epstein being housed 22 within MCC or the SHU? 23 MS. : No. 24 MR. No? And did she provide 25 you with any special instructions with regard EFTA00117669 109 110 1 to Epstein? 2 MS. 3 MR. : Did SOS ever tell 4 you that Epstein was required to have a 5 cellmate when he was assigned to the SHU? 6 MS. : No. 7 MR. : Okay. Now we're going to 8 go on to some staff members. Who was present 9 in the SHU when you worked in the SHU on August 10 9, 2019? So you said you were from 4:00 to 11 midnight on that August 9th. Do you recall who 12 that was? 13 MS. and 14 MR. IIIIIIIIII: Just and 15 When you arrived to the SHU was anybody else 16 there? 02_2u recall replacing? 17 MS. IIII: I don't remember who I 18 relieved. 19 MR. Do you know a 20 IIIIIII? 25 MS. 23 LPL . MR. MR. 24 MS. : Yes. . . 21 MR. 22 : Alright. And 1 2 MS. : Yes. 3 MR. Were either of them in 4 the SHU on August 9 2019? 5 MS. 6 MR. 7 MS. Mm-hmm. 8 MR. But while you were there, 9 not 10 MS. I don't remember. But I 11 remember because he spoke to me. 12 MR. Okay. So 13 are the people that you 14 remember that were in the SHU? 15 MS. : Yes. 16 MR. Okay. And you said that 17 you remember speaking with you? 18 MS. 19 MR. About what? 20 MS. : He told me he placed Epstein in 21 the shower to use the phone. And he called and 22 told me to take the phone from him. 23 MR. : Can you give me a little 24 more detail on that? What do you mean? 25 MS. IIII: So because he -. 2 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 111 MR. lust walk me through. This one is one of those ones I'll ask you to explain a little more. Can you just from eh start of the conversation to what you did with Epstein to the finish. MS. IIII: Okay. So Epstein stays in attorney conference all day. So I guess when it's time to use the phone, he's not present. So when he came upstairs, gave him the hone in the shower to use the phone. And then left. He called on the phone. I happened to answer and he said, "Hey can you take the phone from Epstein? Because the time is up." So -. MR. : So when he gave him the phone he left and no one else was present with Epstein when he was on the phone? MS. : No. Nobody was there. MR. : Do you know that to be a legitimaq_pfactice? MS. IIII: I mean it's in the SHU, so yeah. MR. So is no one supposed to be - because is the SHU a recorded line? MS. IIII: I don't know. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 112 MR. So do you know if someone is calling from a non-recorded line, are you supposed to take notes of that call? MS. : I don't know. MR. : Do you know if you're supposed to log the telephone call in any kind of a logbook? MS. : N MR. Okay. So your understanding is gave him - plugged in the line, ave him the phone, and then left? MS. : Yes. MR. No one was there to monitor? MR. Okay. So he -. MS. : We were in the SHU, but nobody was monitiiiiiiiiii MR. : How far away from you was he when he was making this call? MS. IIII: He was on C tier. And like that's far from the desk. MR. : Approximately - do you know how to like -? MS. : I don't know. MR. Is it like from here to EFTA00117670 113 1 like that fire extinguisher over there? Or is 2 it further? 3 MS. IIII: No. Maybe from the wall by the 4 AC to over there. 5 MR. : Okay. So approximately 6 25 feet? 7 MS. : Mm-hmm. 8 MR. : Could you hear his 9 conversation from there? 10 MS. No. 11 MR. : And were you asked to 12 listen to his conversation? 13 MS. No. 14 MR. : Prior to placing the 15 call, did speak to you at all? 16 MS. No. 17 MR. : So just after he placed 18 the call, he called you and what did he say? 19 MS. IIII: He said to take the phone from 20 him because the time is up. 21 MR. : Do you know how long he 22 was on that hone? 23 MS. No. 24 MR. : Were you watching him 25 while he was on that phone? 115 1 the call in the shower, cell closed behind him, 2 it was approximately 25 feet from you but you 3 didn't hear anything? 4 MS. : No. 5 MR. • And he didn't - and 6 didn't instruct you? 7 MS. : No. 8 MR. Did you ever experience 9 that prior to that instance? Where an inmate 10 would do that in the SHU? 11 MS. IIII: Yeah. If they have to use the 12 phone and where there cell is, it's not 13 working. They place them in there because they 14 have to plug it close to where they can have 15 access to the hone. 16 MR. : Okay. So in their cells 17 do they have cell lines that they can typically 18 call from? 19 MS. N 20 MR. Are the inmates provided 21 anything to be able to make calls? 22 MS. : No. 23 MR. : Some kind of a card pass 24 or number or like something to be able to -? 25 MS. IIII: Oh, like a pack and - yeah. 114 1 MS. 2 MR. : Was it abnormal for an 3 inmate to be out by himself on the phone in the 4 SHU? 5 MS. : No. 6 MR. : So they can just freely - 7 that's not an abnormal circumstance? 8 MS. IIII: No because he wasn't free. He 9 was in a cell. He was in a cell on the phone. 10 But he -. 11 MR. : Oh so he was in a cell? 12 MS. : Yeah but he was - he was in the 13 shower because the jack - where his cell is, 14 the jack didn't work. So he was placed in the 15 shower to use the phone there. But the shower 16 is like a cell. 17 MR. : Okay. So was the door 18 closed -- 19 MS. Yes. 20 MR. -- in the cell? So he 21 was in the shower area. Was he by himself? 22 MS. Yes. 23 MR. : Were showers running? 24 MS. 25 MR. : He was just - he placed 1 MR. 2 what that is? 116 : Okay. Can you explain 3 MS. IIII: I mean I don't know too much 4 about it. I just know that they have a PIN 5 that they use to use the phone. 6 MR. : Okay. Do you know if 7 Epstein had that PIN to use the phone? 8 MS. : I don't know. 9 MR. : But specifically with 10 regard to the shower, having an inmate call 11 from the shower, have you ever experienced that 12 before? 13 MS. : Yes. 14 MR. When was the last time 15 you had eaLienced that prior to August 9th? 16 MS. IIII: If the jack is not working. 17 The jack that's closest to their door. If it's 18 not working, then it's being plugged at the 19 bottom where the shower is. So you place them 20 in the shiiiiiiiiiiso they can reach the phone. 21 MR. : And do you know if that 22 was an authorized practice? 23 MS. : I don't know. 24 MR. : Okay. And did you ever 25 place anybody in the shower to do that? EFTA00117671 117 118 1 MS. 2 MR. No? 3 MS. 4 MR. . Who typically does that? 5 MS. The officers. 6 MR. Okay. But not you, 7 right? 8 MS. 9 MR. Would you ever allow 10 inmates to lace calls? 11 MS. : When -. 12 MR. • You personally. 13 MS. • When I come on, they have 14 already like of their phone calls. 15 MR. : Oh, okay. So it's not 16 typically one of your responsibilities? 17 MS. : No. 18 MR. : What was unique about 19 this situation with Epstein? 20 MS. IIII: Well I guess because he's 21 always downstairs, so they made an exception 22 for him to make a call. 23 MR. : Okay. Do we need to take 24 a break? 25 MR. FOY: DO you need to use the bathroom 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 or anythin MS. IIII: No. MR. FOY: We can continue. were MR. : Great. Alright. So what instructions. You said that he's - his time is up. So what's - how much time is he allotted? MS. : I don't know. MR. : Do you know how long he was in that shower? MS. : Mm.... I don't know. MR. : You don't know. Was it like 5 minutes, 10 minutes -? MS. IIII: It wasn't 5 minutes. He was in there for ma be 20 minutes. MR. 20 minutes? Okay. And where was 7 MS. He was gone. MR. Like left the SHU altogether? MS. Mm-hmm. MR. So he placed him in there MS' MR. : -- left the SHU, and then 119 1 where did he call you from in order to say get 2 the phone from him? 3 MS. IIII: A phone in the building. I 4 don't know where because it doesn't say where. 5 Like the phone rang and I answered. And he 6 just told me to take the phone from Epstein. 7 His time is .. 8 MR. : Is that weird to you at 9 all? That he again, he gave someone a phone, 10 put them in the shower and then left? 11 MS. 12 MR. That's not weird? 13 MS. 14 MR. • Okay. But without 15 filing anybody -. Did you know if he - 16 - provided anybody instructions prior 17 to him de arting the SHU? 18 MS. • I don't know. 19 MR. You don't know. 20 MS. 21 MR. else was in the SHU 22 with you 23 MS. 24 MR. And did you recall when 25 around that took place? 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 120 MS. Like the time? MR. : Yep. MS. : It had to have been about after 8:00 because that's the time he comes back from attorney conference. MR. Okay. So around 8:00 p.m. - ish? MS. MR. MS. MR. look? Was gave him his MS. MR. That's fine. : After. After 8:00 p.m. - ish? Mm-hmm. Okay. Are you able to assigned to the SHU when he phone call? : No. Where was he assi ned? Do you know what - why went to the SHU in the first place? Was the escorting Epstein back from his attorneys? MS. MR. reason wh MS. MR. : I'm not sure. So you don't know the he actually entered the SHU? : No. I don't know. And you -? Do you remember if he walked into the SHU with Epstein EFTA00117672 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 121 and immediately placed him into the shower area? Or do you think that he went and retrieved_Lpitein from his cell? MS. IIII: No. He didn't retrieve him from his cell. He came in and said that he was going to ive him a phone call. MR. : So he was with him at the time? MS. IIII: Yes. And he placed him in the shower. MR. So do you recall then if he walked in the SHU with Epstein? MS. IIII: I don't know if he walked in with him. But after because you could come in and he could have been -. There's a holding cell there. That's why I'm saying I don't know. And then he came in after with him. But from that door to the shower, he walked in with MR. Okay. So Epstein wasn't in his own cell? MS. : No. MR. He could have potentially been in a holding cell? MS. IIII: Yes. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 122 MR. Alright. But you don't know who brough Epstein -- MS. : No because -- MR. : -- back there? MS. -- somebody could have brought him up and then - so I don't know. MR. : Okay. Now in order to i et tto the SHU though, either you, or MS. : Had to open the -. MR. : -- open the door. Do you remember who opened the door on that day? : I don't know. It was not you? MS. MR. MS. MR. Okay. And I'm sorry, you may have said this and I do apologize. What time did M I a n g I I I I I I I I work there until? MS. IIII: .= was 4:00 to 12:00 and was 2:00 to 10:00. MR. : Okay. And what was the hierarchy with the three of you that were present at that time? Is there someone that was in charge as an officer in charge? Or how does that work when you're working together 123 1 with those two other individuals? 2 MS. IIII: I don't know who was in charge. 3 We just kind of worked together that day. But 4 I don't know as far as who is the -. 5 MR. : Is everyone considered 6 equals? When you're working together? 7 MS. IL Well I'm the newest person 8 there, so and - I don't know how 9 long they've been there, but -. 10 MR. : Does it - does then when 11 you work with someone else, is it based upon 12 how long the 've been with the Bureau? 13 MS. : No. 14 MR. : So is there -. I know 15 you're saying you're the newest. So you might 16 ask them questions. But is there like when 17 there's three of you in there, is there someone 18 that's supposed to be in charge? Or are you 19 all equaljy_:? 20 MS. IIII: On the roster it'll say who is 21 supposed to be in charge. 22 MR. : Okay. So (Indiscernible 23 *01:28:25) -. 24 MS. IIII: But that doesn't necessarily - 25 that's not necessarily the case. 124 1 MR. On that roster on August 2 9th of those three people, who does it say 3 should have been in charge? 4 MR. ..t's on the first page. 5 MR. : It's on the first page. 6 If you look all the way to the left, you'll see 7 SHU assignments. And then you can look - go 8 over to the right and see their names. I 9 believe. 10 MS. : I don't see I'm looking 11 for . I don't see that. 12 MS. GREGG: Really quick, can I just show 13 her how she reads -- 14 MR. : Absolutely. 15 MS. GREGG: -- a roster? 16 MS. IIII: Oh I see him here. 17 MS. GREGG: So - sorry. Most of what 18 they're asking you would be on page one and 19 page two, right? So these are your shifts. 20 These are the posts. And then these are the 21 people who worked that shift too. If morning 22 watch, 3:00, 6:00 to 2:00, 6:00 and 8:00 is day 23 watch. This is the p.m. 12:00 to 8:00, 2:00 to 24 10:00, and this is all your evening watch. 25 This is like a person with a day off, sick EFTA00117673 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 MR. FOY: Can you show her where the 25 answer is on the paper? 125 leave, so on and so forth. These things I don't believe apply to their questions because these are all the changes that took place on the roster. MR. : Most everything is going to be on the first page. MS. GREGG: Yeah, so this can be a little bit confuilg. MS. IIII: Okay. MS. GREGG: And it probably doesn't apply to the stuff that they're asking. MS. IIII: Okay. MS. GREGG: So you would just focus on -. MS. IIII: These two pages. MS. GREGG: Yeah. The shifts are up top. MR. FOY: So how does she determine who's the boss? Because that's the question. MS. IIII: Yeah. MS. GREGG: So this - these positions will tell you who is in that position for that shift. Right? I don't want to answer the question for you, but when you look at the SHU 126 1 MS. GREGG: Here. SHU I. That's your 2 OIC. 3 MS. IIII: Okay. 4 MS. GREGG: Straight across. SHU II. SHU 5 III is your 6:00 to 2:00, 2:00 to 10:00. And 6 SHU IV is straight across. Right? So for 7 example, SHU IV was vacant on Sevel i watch. 8 And then this is showing that was SHU 9 number one for the evening watch shift. 10 MS. IIII: And this one to what time? 11 MS. GREGG: Shift III is 6:00 to 2:00. 12 MS. IIII: Oh, okay. 13 MS. GREGG: And then shift ten is 2:00 14 10:00. 15 MS. 16 MR. 17 that assistance. 18 MS. GREGG: Mm-hmm. 19 MS. • So basically on this 20 have been 21 MR. 22 have been 23 MS. 24 MR. 25 I? : Okay. In charge. Mm-hmm. : Okay. Because he was SHU Okay. : Thank you very much for to it would would 127 1 MS. : Yes. 2 MR. : And do you know what SHU 3 I means he was the officer in charge? 4 MS. : Yes. 5 MR. : What does SHU II and SHU 6 III represent? Are there different duty 7 responsibilities - duties and responsibilities 8 based upon if you're SHU I, SHU II, or SHU III? 9 MS. IIII: I just know whoever the number 10 one is would be the person in charge. But as 11 far as two and three, I don't know the 12 differenciiiiiiiiiinsibility. 13 MR. : Now in the time that you 14 worked there, did that actually play into 15 anything? If someone was SHU I or SHU II or 16 SHU III? 17 MS. : N 18 MR. : No? So -. 19 MS. Because we're always short- 20 staffed. 21 MR. Okay. So would that mean 22 that like if the person SHU I even though on 23 paper they're the officer in charge, they're 24 actually not providing orders or anything? 25 Everyone's equally -. 128 1 MS. : Doing what we need to do. 2 MR. : Okay. So everybody 3 basically has the same job responsibility. 4 MS. : Yes. 5 MR. : Okay. So you don't look 6 to someone as the actual officer in charge. 7 MS. IIII: I do because I don't know. So 8 - but not necessarily the officer in charge, 9 just whoever that I'm working with. 10 MR. : Okay. And what was your 11 -? I don't know, this may have just answered 12 that, but what was your role in the SHU on 13 August 9, 2019? What SHU number were you? 14 MS. : Number two. 15 MR. : Number two. Like again, 16 you don't believe that actually provided you 17 with a different responsibility that SHU I or 18 SHU III? 19 MS. : No. 20 MR. No? Okay. And what 21 conversations did you have with the SHU staff 22 that you worked with on August 9th regarding 23 Epstein? 24 MS. : None. 25 MR. : So you said that the one EFTA00117674 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 was with MS. Yes. MR. the phone call. MS. : Yes. MR. back then. MS. Mm-hmm. MR. Any other conversations at that point with regard to Epstein? MS. : Um.... No. MR. : Any follow on to when he said get the phone from Epstein? MS. IIII: No. When he said to get the phone, I got the phone. And I spoke to Epstein. MR. : Okay. And what was it that you lake with Epstein about? MS. IIII: I was told that your time is up and I have to take the phone. And he said okay. MR. : Okay. And did say to then place him back in his cell? Or was that understood? MS. IIII: No. That was understood. 129 Correct? With regard to Now try to put yourself 130 1 MR. : And is that what you did? 2 MS. : I didn't place him back in the 3 cell. I went to the bathroom upstairs on 10. 4 MR. : Okay. 5 MS. : And when I came back, he was 6 placed back in his cell. 7 MR. : Okay. So what did you 8 do? You went to the shower and just instructed 9 him throu h the door? 10 MS. : Yeah. 11 MR. To hang up? 12 MS. : No. I told him that I was told 13 that his time was up and I have to take the 14 phone in. And he said okay. And then he 15 handed me the hone. It's like a slot. 16 MR. : Okay. And then you 17 walked awa ? 18 MS. : Yes. 19 MR. : And he just stayed there 20 and waited? 21 MS. Yes. 22 MR. And then who brought him 23 from the shower to his cell? 24 MS. IIII: I don't know. well it had to 25 be and because it takes two 131 1 people to move him. And I went to the 2 bathroom. 3 MR. : Okay. So you used the 4 restroom at the time that he was transported -? 5 MS. : Back to his cell. Yes. 6 MR. : Okay. And did you have 7 any conversation with the individuals after 8 they placed - before or after they placed him 9 into the cell? 10 MS. N 11 MR. . Did you instruct them, 12 hey I just took the phone from him, can you 13 place him back into the cell? 14 MS. : Yes. 15 MR. : Okay. So you did talk to 16 them about that. 17 MS. IIII: Yes. I said I was going to the 18 bathroom and he has to go back to the cell. 19 MR. Okay. That was the 20 extent of it? 21 MS. That was the extent of it. 22 MR. . Alright. And again we 23 briefly talked about him, but IIIIIIII. 24 MS. : Yes. 25 MR. Now do you know if he 1 2 3 4 5 6 7 8 9 worked that day? MS. : In the morning. MR. MS. MR. MS. and 132 And who replaced him? Because he worked 6:00 to 2:00 in 2:00 to 10:00. MR. Okay. So when someone gets replaced, do they typically give a 10 briefing? Like so would - and I apologize 11 about the name but - . Would they - 12 would he typically be responsible to provide 13 with information so that he - you know 14 with regard to what happened on his assignment 15 so that he can utilize that for when he's not 16 replacing him? 17 MS. : I don't know. 18 MR. Does that make any sense? 19 MS. : I mean I don't know if he's 20 typically required to, but I guess if there's 21 information to give, he would give it to him. 22 But I don't know if he has to. 23 MR. : Okay. And during your 24 time, was there an- iiiiirsation with any 25 information that gave to ? Or EFTA00117675 133 1 passed alon 2 MS. : I wasn't -. 3 MR. : For the replacements? 4 MS. : I wasn't there at 2:00. I came 5 in at 4:00. But nothing was told to me. 6 MR. So never informed 7 you or in your presence? 8 MS. No. 9 MR. Okay. So there was no 10 discussion for Epstein to be reassigned a 11 cellmate? 12 MS. 13 MR. And again, you didn't 14 even know that his cellmate wasn't there? 15 MS. : Wasn't there. 16 MR. : Okay. And should have 17 you known that his cellmate wasn't there? 18 MS. : I don't know. 19 MR. : So when you're doing 20 rounds and conducting counts, wouldn't that be 21 when you would know if someone was with or 22 without a cellmate? Because you said only one 23 other person there didn't have a cellmate. 24 Correct? 25 MS. IIII: But people move all the time. 134 1 When you're in SHU, like let's say if you did 2 something and you're in trouble. So you're in 3 the SHU. You could be sent back to your 4 regular unit. So it wouldn't be odd like if I 5 was counting and the person wasn't there. It 6 would just be lesser the count. But it 7 wouldn't be odd if the physical person wasn't 8 there to me. Because people move back all the 9 time. 10 MR. : But wouldn't they have to 11 advise you if you knew that there was only one 12 person without - you know, one person that 13 doesn't have a cellmate. Wouldn't they have to 14 advise you? Hey, this person left, so this 15 persons' in there by himself. 16 MS. IIII: I don't know. Because nobody 17 said anytiiiiiiiiii. 18 MR. : So I'm not -. I'm just 19 saying in general now. So like if you're 20 conducting your rounds and your counts, in 21 order for you to know who you're supposed to be 22 counting and what -. During both rounds and 23 counts, you know, who are you supposed to be 24 checking on. Wouldn't you need to know if a 25 cellmate was removed and now there's only one 135 1 inmate in the cell? 2 MS. IIII: No. like if I'm counting and 3 the person is not there. Like say the count 4 was 66. And I counted 6S, that's just what 5 I'll count. 6 MR. : And you wouldn't try to 7 like figure out where is the 66th? 8 MS. IIII: No because whoever moved the 9 person would have I guess documented where they 10 moved them to. 11 MR. : So you wouldn't - it is 12 after you count at 65, then would you have to 13 just go try to find paperwork. Hey, is there 14 another gu that someone else moved? 15 MS. : No. 16 MR. : Okay. So how do you 17 reconcile the numbers? Rather than me saying 18 so many words, you tell me how -- 19 MS. : Okay. So let's say -. 20 MR. : -- do you know who's in 21 the SHU? 22 MS. IIII: So let's say like if there was 23 66 people in there. And one person moved to 24 wherever. They would have already did that. 25 So it wouldn't be for me to do. When I count 136 1 now because the person is not there, I'm going 2 to just count 65. But the number is not going 3 to be off because whoever moved the body 4 already moved them to like let's say back to 5 the unit or wherever. So I wouldn't be trying 6 to find or figure out where the person went. 7 I'm just S i coui i . 8 MR. : Okay. So and you're 9 counting during the counts, right? Not during 10 the rounds? 11 MS. : Ri ht. During the counts. 12 MR. : Rounds are every 30 13 minutes a roximately? 14 MS. Yeah. 15 MR. So during those rounds, 16 are you supposed to be when you're conducting 17 the rounds, what is the intent of those rounds? 18 MS. IIII: Whoever is in there to make 19 sure that the 20 MR. : So if you don't know who 21 is in there, how do you make sure that they're 22 there and okay? 23 MS. IIII: Because they would have already 24 been -. If the person is not there, like they 25 would have already been moved in the system. EFTA00117676 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 137 So if I'm making a round, I'm not going be like well oh this person is not in here. Because people go to different places. They go back to the unit. They go to court. They go to different places. So again, it wouldn't be odd if somebody is not there. I mean I could ask the person that I'm working with. Like oh hey, whatever ha to so-and-so, but. MR. : Alright. So you're saying that even though you knew only one inmate didn't have a SHU and especially, it sounds like ou're working later. MS. : Mm-hmm. MR. • So everyone should pretty much be back from wherever they went to. Correct? MS. : Correct. MR. So at that point, you only know one person doesn't have a cellmate. You're walking through and you see that someone doesn't have a cellmate. You're not asking -- MS. MR. MS. : But see I don't know -. • -- where is that person? : But see I don't know that the I person has to have a cellmate. So again, even 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 138 though the one person doesn't have a cellmate, it's not odd to me because I don't know that they have to have a cellmate. What if the person went back to the unit? I didn't know where went to. MR. Okay. MR. : Can I ask her something? MR. Yes, please. MS. Mm-hmm. MR. : I just want to clarify. When you come in, right. Let's say you come on re- shift. Is there somewhere near the computer that tells you how many inmates are supposed to eb in the SHU? MS. MR. MS. : On the roster. : On the roster? Yes. MR. : And now let's say - do you review the roster when you come in? MS. No. MR. : So how do you know? Let's just say someone went missing. How do you know? MS. IL I don't know. MR. : But isn't that - when you 139 1 come on shift, right. You're responsible. I'm 2 not saying this is the case. But you're 3 responsible to know how many inmates are in the 4 SHU at that time. Right? 5 MS. IIII: When I come on shift, I just 6 come on and relive the person and just -. Like 7 when I come on at 4:00, it's time to feed. So 8 I'm doing trays and I'm feeding. I'm not 9 looking to see who's on the roster or -. You 10 would probably wait for count time to count and' 11 then count to see how much people is in there. 12 But I'm not looking to see okay the roster says 13 75 and I'm counting to make sure there's 75 14 people. Ilf•iunt time. 15 MR. : So when you're doing your 16 rounds, all you're doing is the people that you 17 see, are they okay. If someone escaped, you 18 wouldn't know that until count time? 19 MS. : I wouldn't. No. 20 MR. : Okay. And that's 21 basically - that answers it. So she's saying 22 that she's not even worried about if someone is 23 not there. She's only worried about the people 24 that are there. Is that correct? 25 MS. IIII: Yes. Yes. 140 1 MR. Alright. 2 MS. GREGG: What - I've got a question. 3 MR. : Absolutely. 4 MS. GREGG: Would procedural clarification S help with the 6 MR. : Sure. We have all the 7 polices here. Would you like me to show her 8 the policies? I'm happy to do that. 9 MS. GREGG: Yeah. Or I could explain it. 10 MR. : I'll give her the 11 policies and just ask if she's familiar with 12 them. That's fine. So she knows what she 13 should have done. 14 MS. GREGG: I'll just say this to you. 15 The policy is very general for the entire 16 agency, to MCC New York. 17 MR. : Okay. 18 MS. GREGG: So. 19 MR. : While he's looking, I just 20 want clarification. 21 MS. Mm-hmm. 22 MR. When you came in, if an 23 inmate was removed, would that roster have been 24 edited? 25 MS. IIII: It should be. EFTA00117677 141 1 MR. : Do you recall if that roster 2 - was there a roster on your desk? 3 MS. IIII: There's always a roster. But I 4 don't look at the roster. 5 MR. : But you don't recall if there 6 was anything - if there was a notification or 7 anything written down saying inmate 8 was removed from the SHU? 9 MS. No. 10 MR. : Is that something the 11 previous shift should have communicated to you? 12 MS. : They could have. 13 MR. : Alright. So I'm going to 14 read this out loud and then I'll provide it to 15 you. This is the Metropolitan Correctional 16 Center, New York, New York specific post 17 orders. This is specifically says SHU number 18 one. And I think that would be the officer in 19 charge as we just discussed. But I think that 20 they're, like you said, everyone's kind of 21 responsible for the same thing. But it 22 discusses right here, I'm going to go down to 23 the third paragraph on page 2 of 18. It says 24 report for duty by telephone with the 25 operations lieutenant and receive any 142 1 additional information. Begin making 30 -. So 2 according to this, it says when you're report 3 to duty, you're supposed to talk to the 4 operations lieutenant and receive whatever 5 information you're supposed to on your shift. 6 It says, "Begin making 30-minute rounds 7 ensuring you document the findings into True 8 Scope (Phonetic Sp. *01:42:49). Staff will 9 observe all inmates in continued lockdown 10 status once in the first 30-minute period of 11 the hour. Example, 12:00 to 12:30 a.m. 12 Followed by another round in the second 30- 13 minute period of the same hour 12:30 to 1:00 14 a.m. This will ensure an inmate is observed at 15 least twice per hour. These rounds are to be 16 conducted on an irregular schedule and no more 17 than 40 minutes apart. All observations must 18 be documented. It should be clearly understood 19 that none of these activities are to take place 20 until the evening watch officer is relieved. 21 It should be noted that it is understood that 22 not all of the above will be accomplished by or 23 before the count." Then it talks about 24 official count time. The SHU number two 25 officer you said you were working, is that for 143 1 both your shifts? Because this is specifically 2 talking about 12:00 a.m. What were you at 3 12:00 a.m. on August 10th? 4 MS. : I think I was number one. Yes. 5 MR. : Alright. So this 6 actually is pertaining to your shift during 7 12:00 a.m. to 8:00 a.m. So -. 8 MR. FOY: You mean according to what you 9 just read? 10 MR. What I just read. This 11 says for -- 12 MR. FO tiliA. 13 MR. : -- the specific 14 (Indiscernible *01:43:58) so we're SHU number 15 one. So I guess what you were supposed to do 16 per post orders was when you get on board, 17 you're supposed to call the operations 18 lieutenant. And then you're supposed to say 19 hey, is there any information I need to know. 20 And then you're supposed to start making your 21 counts. And that would be like where you would 22 find out Epstein doesn't have a cellmate. Make 23 sure that when you're doing your rounds, you 24 know there's nobody in there. You know I would 25 think. Is that - was that your understanding 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 144 at all? MS. : No. I've never -. MR. : Was that ever put into practice? MS. IIII: No. Nobody ever calls the lieutenant when they get on shift. MR. So no one ever talked to them? MS. MR. Okay. Is there - I don't know if I need to continue reading this because we're going to take a lot of time with it if we do. Just because I read it, if you want to take a look. And just initial and date there. And then we're just going to move on. MS. : Mm-hmm. MR. Because that's - this is taking up. MR. FOY: Initial the top. MR. : But the point on that matter was that you knew you were supposed to observe the people that were there. You weren't too concerned about people that weren't there. MS. IIII: Nothing. Correct. EFTA00117678 145 1 MR. Is that a correct 2 understandin ? 3 MS. : Yes. 4 MR. Alright. On August L_. 9th 5 do you recall having any discussions with IIIII 6 regarding E stein? 7 MS. No. 8 MR. And again, would 9 have been the one - did you say he was the one 10 who replaced -? 11 MS. : Relieved 12 MR. 13 provided with information, did not 14 provide you with that information. 15 MS. I don't know if 16 MR. Yeah-yeah-yeah, I know. 17 I'm askin that -. 18 MS. : Oh about didn't -. 19 MR. If he did that, 20 certainly didn't provide it to you. 21 MS. : No. 22 MR. : Okay. And didn't 23 provide you with any special instructions 24 regarding22tein? 25 MS. IIII: No. Okay. So if 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 146 MR. No? Did you discuss the need for Epstein to be reassigned a cellmate with anyone on August 9th? MS. : No. MR. : No. When did depart the SHU? On August 9th? MS. MR. MS. MR. Nathan : At 10:00. 10:00 p.m.? Correct? Correct. You said unit manager . He actually wasn't in the SHU? I mean he wasn't assigned to the SHU. I'm sorry. MS. MR. He was just in there in order to facilitate the start of this telephone conversation? MS. : Phone call. Yes. MR. And you don't know why he was in there in the first place? MS. No. MR. So you don't know if he brought E stein in? MS. : No. MR. : He just - and you're not 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 147 the one to allow them? MS. : No. MR. : Alright. So he didn't actually have any responsibilities in the SHU? MS. : No. MR. : And aside from the iiiii iine conversation that you had with , with specifically with regards to get the phone away from him, his time is up. Any other conversations? MS. : With , no. MR. No. About Epstein or otherwise. MS. MR. No. Any conversations with him ip_person? MS. IIII: Only when I took the phone from him. MR. No-no, not Epstein. MS. : Oh, no. MR. : And that's what I was asking about before. It's just to make sure that we're clear. Any other conversations aside from that one conversation on the phone 148 1 where he said get the phone from Epstein his 2 time is uph__ 3 MS. IIII: And when he came in, he said 4 I'm going to put him in the shower to use the 5 phone. 6 MR. And that was the extent 7 of it? 8 MS. That was the extent of it. 9 MR. Okay. Nothing to do with 10 Epstein bein housed with MCC or SHU? 11 MS. No. 12 MR. Or the need for a 13 cellmate? 14 MS. 15 MR. Do you know who 16 authorized to provide Epstein with that 17 telephone call? 18 MS. : I don't know. 19 MR. : No. Who plugged the 20 telephone line into the legal line in the 21 shower area? 22 MS. 23 MR. did. And do you 24 know if he did that per ' direction? 25 MS. IIII: No. EFTA00117679 149 1 MR. You're not sure. And to 2 you, that was an authorized practice? 3 MS. IIII: To use the phone in the shower? 4 Yeah. 5 MR. : What is that line in the 6 shower area for? 7 MS. I don't know. 8 MR. : Is it -? Okay. Is there 9 usually a phone that's plugged in there? Or is 10 it just a 11 MS. 12 MR. -- line that's available? 13 MS. The jack is there. 14 MR. Just the jack. And you 15 know that to be a legal line like for 16 attorneys? 17 MS. : I don't know. 18 MR. : You don't know that 19 that's what that is - a legal line? 20 MS. : I don't know. 21 MR. : But what is just your 22 overall understanding briefly about policy for 23 inmates assigned to the SHU when they need to 24 make a phone call? How often do they get to do 25 it? How do they do it? 'so 1 MS. IIII: Um. When they had them the 2 phone in the cell and they use that PIN - the 3 number - to make the phone call. How often, I 4 don't know. Because that's usually done before 5 I come in. But I know showers are every other 6 day. I don't know if phones is every other day 7 also. 8 MR. Okay. So you're not 9 sure? 10 MS. I'm not sure. 11 MR. You said you didn't hear 12 any part of that telephone conversation? 13 MS. : No. 14 MR. : Did you see any part of 15 that teleftwine conversation? 16 MS. IIII: Only when I went to go get it 17 from him. 18 MR. But while he was on it? 19 MS. 20 MR. Discussing? 21 MS. 22 MR. And no one observed him? 23 MS. 24 MR. So no one watched him or 25 listened? 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 151 MS. : No. MR. : And no one informed you to watch or listen? MS. : No. MR. And previous instances when people have used that line, were other - were people watching and listening to those people? MS. MR. Epstein brou MS. MR. And around what time was back to his cell did you say? : Ma be about after 9:00. : So he did the telephone call sometime before 9:00 and around after 9:00 is when he has put back into his cell? MS. IIII: Probably because I was in the bathroom. MR. : And you went to the bathroom ou think around 9:00? MS. I'm not sure. MR. : Sure. MS. But around. MR. : I'm not asking for specifics. MS. IIII: Yeah. Like around. 152 1 MR. Around 9:00 p.m. 2 MS. Mm-hmm. 3 MR. Okay. And you said 4 you're not the person who brought him. Someone 5 else did. After someone else brought him to 6 his cell, did you have any more conversations 7 with Epstein? 8 MS. : Yes. 9 MR. Okay. What - when was 10 that and where? 11 MS. IIII: Not a conversation when I 12 counted. 13 MR. When did you count? 14 MS. At 10:00. 15 MR. At 10:00 p.m. you 16 counted? 17 MS. 18 MR. So you actually went 19 through each tier and counted? 20 MS. : Yes. 21 MR. : And did you go into the 22 tier? Or did you just go up to the door? 23 MS. : I went into the tier. 24 MR. : Okay. So you didn't head 25 around at 10:00 p.m. you didn't stop at the EFTA00117680 153 154 1 door and just look in? You actually went 1 MR. Take the mattress off the 2 through? 2 bunk? 3 MS. : Yeah, I went through. 3 MS. And put it on the floor. 4 MR. : And looked through and 4 MR. Sleep there. Is that 5 counted each person? 5 typical? 6 MS. IIII: Yes because he was on the 6 MS. : For him. 7 floor. And I knocked. And he put his hand up. 7 MR. : For him? Which other 8 MR. : Okay. So that wasn't 8 inmates do that? 9 just from the outer door of the tier. 9 MS. IIII: Not in the SHU, but sometimes 10 MS. No. 10 they do that. 11 MR. . That was actually -. 11 MR. : And is there anything up 12 MS. , that was in there. 12 with policy that prohibits people from doing 13 MR. Okay. And you said you 13 that? 14 don't know who brought him back to the cell. 14 MS. : Not that I know of. 15 MS. : No I was in the bathroom. 15 MR. : No. So it wasn't 16 MR. : Okay. And when - around 16 anything of concern? 17 10:00 p.m. you looked in and you said he was on 17 MS. No. 18 the floor and he put his hand up? 18 MR. : Okay. But he - did you - 19 MS. IIII: Yeah. He sleeps on the floor. 19 did he verbalize anything or just put his hand 20 The mattress - he puts the mattress on the 20 up? 21 floor. 21 MS. : He put his hand up. 22 MR. : Okay. So you never 22 MR. : lust like, I'm accounted 23 actually see his bunk. He would sleep on the 23 for? 24 floor. 24 MS. : Ri ht. 25 MS. IIII: The floor yeah. 25 MR. : Okay. And is that after 155 156 1 you said ou knocked? 1 MR. : Okay. 2 MS. : Yes. 2 MS. : So the cord has to be ran from 3 MR. : And did you communicate 3 outside of his room all the way down to be 4 with him at all? 4 plugged in. 5 MS. Mm... 5 MR. : It's for sleep apnea? 6 MR. You okay? 6 MS. : I don't know what else it's 7 MS. 7 for. But that's what I know people use it for. 8 MR. No. So it was just a 8 MR. : And did you get it for 9 knock and hand up. 9 him? 10 MS. : Yes. 10 MS. IIII: It's in his room. It's just 11 MR. No communication. 11 for it toliiiiiiiiid in. 12 MS. None. 12 MR. : Oh. And did you plug it 13 MR. lust visualization. 13 in for him? 14 MS. Yeah. 14 MS. Yes. 15 MR. And notice anything 15 MR. Okay. So you did have 16 different about him at that time? 16 some communication with him then? 17 MS. No. 17 MS. IIII: Well he asked and I just 18 MR. No. You said that was 18 nodded. Anc aliged it in. 19 around 10:00 p.m.? 19 MR. : So okay. So when I ask 20 MS. IIII: I think he asked for the CPAP 20 you these things, I just really want you to be 21 machine to be plugged in because he had a CPAP 21 clear with like -- 22 machine. 22 MS. : Mm-hmm. 23 MR. : What's a CPAP machine? 23 MR. : -- if there's 24 MS. rthen people have sleep apnea, I 24 communications just really think about like 25 guess they use that machine. 25 what communications you actually had. EFTA00117681 157 158 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MS. : Mm-hmm. MR. : So just tell me about specifically what you can remember. Because again, if this is the last time you saw him. Just try to recall -- MS. : Remember it. MR. : -- what it is he said. MS. : I remember he put his hand up. And he asked about the CPAP machine to be plugged in. That's it. MR. Do you remember his words? Like -- MS. : NO. MR. • -- did he say, "CPAP machine." Or, "Can you plug this in for me?" MS. IIII: I don't remember how he said it, but basically he asked for it to be plugged in. But I don't remember exactly what he said or how he said it. MR. : Alright. So at that point you went and plugged it in? MS. : Yes. MR. : Alright. And that's like a cord that runs like under his cell door or something? 1 MS. : Yes. 2 MR. : Okay. And then any 3 conversations afterwards? 4 MS. : No. 5 MR. : No. Alright. Can you 6 just briefly explain the process of people 7 entering and exiting the SHU? 8 MS. : There's double doors. 9 MR. Okay. 10 MS. : And we open the doors to let 11 the person in. 12 MR. : So is there somebody that 13 they have to go through an outer door first to 14 get to your door? 15 MS. IIII: Yeah. There's two doors. And 16 so they come in the first door, then the second 17 door, and then in the SHU. 18 MR. : How do they get into the 19 first door? 20 MS. We open the door. 21 MR. Not the control center? 22 MS. 23 MR. • So you're able to - from 24 the first door before they get to your door, 25 you open both doors? 159 1 MS. : Yes. 2 MR. : Okay. So the control 3 center, they don't call for it first and the 4 control center pops the first door? And then 5 you have ke s for the second door? 6 MS. : No. 7 MR. : Alright. Okay. So I'm 8 going to stop talking. You tell me exactly how 9 they do it. Somebody knock or they call or 10 buzz or what? 11 MS. IIII: Somebody knocks. Or sometimes 12 they use the radio. And then we go to the door 13 and open the door. 14 MR. : So do you have a - from 15 your desk is there a buzz to -? 16 MS. IIII: No. You've got to open it with 17 a key. 18 MR. . The initial outer door? 19 MS. Both doors. 20 MR. So you go, you open the 21 inner door to you and then go to the -- 22 MS. Door. 23 MR. outer door -- 24 MS. 25 MR. - and do the second? 1 MS. : Yes. 2 MR. 3 both doors? 4 MS. Yes. 160 And you have control over 5 MR. Alright. Does the 6 operations center also have control over that 7 outer door? 8 MS. IIII: I don't know. I don't think 9 for SHU don't know. 10 MR. : Alright. Anytime people 11 enter and exit, you've always - 12 MS. • The person on the inside yes. 13 MR. • For both doors. 14 MS. Yes. 15 MR. Alright. And that's the 16 same as when they leave? 17 MS. : Yes. 18 MR. So after they leave that 19 second outer door -- 20 MS. : Mm-hmm. 21 MR. -- you go, you lock that 22 manually - 23 MS. : Mm-hmm. 24 MR. -- and then lock the 25 other one? EFTA00117682 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 161 MS. : Yeah. MR. : Manually? Both manually from the SHU? MS. IIII: If that one I think - the outer one like once you Dull it in it locks. MR. MS. : Okay. Which one is that? outer door. MR. : The outer door. And who entered and exited the SHU on August 9, 2019 between let's say for the first shift: 9:00 p.m. and 12:00 p.m. So if you have to open up two doors, I'm assuming that's kind of a process and there aren't many of you in there. MS. MR. MS. MR. Lieutenant : Lieutenant No you said on the first : First shift. From shift? 9:00 p.m. to 12:00 a.m. - 12:00 a.m. sorry. MS. : From - I don't know. MR. : So it would be the people that were in there. Correct? Would that be and MS. . And me. MR. : And you. Anyone else? MS. I'm trying to remember because 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 162 you said between 9:00 p.m. and 12:00 a.m. I don't remember exactly when made her rounds, but -. MR. : Okay. would have showed up at one time or another though? MS. : Yes. MR. : Do you remember that conversation when she showed up? MS. No. MR. : Did she talk to you about anything? MS. MR. : Did you specifically speak to her at all? MS. I mean I said hey. MR. : Just hey. MR. : What's up. MR. : Okay. And who allowed to enter and exit? MS. I don't remember that. MR. : Alright. Do you know who - when and left, who allowed them to leave? MS. Mm. I don't remember that. MR. You don't remember that. 163 1 MS. 2 MR. : Alright. And who was 3 present with you in the SHU after midnight? 4 From approximately 6:30, 6:33 a.m. on August 5 10, 2019? 6 MS. : Me and 7 MR. Anyone else? 8 MS. 9 MR. 10 MS. 11 MR. At around what time did 12 she visit? 13 MS. : I don't remember the time. 14 MR. 15 sound right? 16 MS. IIII: I don't remember the time. To 17 be honest. 18 MR. Okay. Was there another 19 officer that you remember around like 5:30 a.m. 20 visiting? 21 MS. IIII: No. The officer upstairs - he 22 left to go et food and come back. 23 MR. : So would that be 10 24 South? 25 MS. IIII: Yes. Visitors? Lieutenant Does around 4:00 a.m. 164 1 MR. Alright. And then when 2 he leaves 10 South to come to the SHU, do you 3 also have to allow him access into the SHU? Or 4 is he able to get into the SHU by himself? 5 MS. : Coming down from 10 South? 6 MR. Mm-hmm. 7 MS. relieved him. And then 8 he came down and went. 9 MR. relieved the 10 person on 10 South? 11 MS. : Yes. 12 MR. So wasn't assigned 13 to the SHU? He was assigned to 10 South. 14 MS. He was assigned to the SHU. 15 MR. : So can you just explain 16 what you mean by relieved? You mean he relived 17 him temporarily while he got food? 18 MS. IIII: He called and said that the 19 lieutenant said that he could go get his food. 20 So can one of us relieve him to go get his 21 food. So went, relieved him, and he 22 came down and he went out to get his food. 23 MR. : Okay. So you were the 24 only person in the SHU at that point? 25 MS. IIII: Downstairs I guess. EFTA00117683 165 1 MR. r: And MI'? 2 MS. : As far as the time, I don't 3 know. 4 MR. : Okay. So are they the 5 only two people that were in the SHU between -? 6 MR. FOY: Do yaLynt the context of when 7 that request from IIIII to get coverage to get 8 food? Because there's a context there. 9 MR. : Sure. I mean. 10 MR. FOY: Alright. So I want you to talk 11 about what you were doing before when he asked 12 you. Right. 13 MS. IIII: Okay. 14 MR. FOY: You remember what you were 15 doing, rigtti 16 MS. IIII: I remember what I was doing but 17 I -. 18 MR. FOY: This is a three event, there's a 19 five event and then -. 20 MS. •: Oh! Like I counted with 21 upstairs at that time. And when I came back 22 downstairs, he called and he said that the 23 lieutenant said to relive him to get food. I 24 didn't believe him, so I called the 25 lieutenant's office. And I said, did you say 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 166 for me to relive to get food? But another lieutenant came on, so he said well I don't know if the lieutenant before said that. So I said okay and I hung the phone up. And said I'll go relieve him so he could go get his food. MR. Okay. And I do apologize. You counted with him? MS. : Yes. MR. And you're talking about the individual in 10 South. MS. MR. the SHU and then MS. MR. MS. : Yes. And then you came back to relieved him? : Yes. Um. : But I don't remember if it was at the 3:00 or the 5:00. I don't remember which one. MR. : Alright. And I do apologize. I just want to make sure I have this clear. So when you went up at either 3:00 or 5:00, and I'm assuming it was 5:00, you helped him count. And at that point he's - when he said he wanted to go get food? 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 167 MS. IIII: When I came back downstairs he called. MR. Oh so not while you were doing the count. MS. : No. MR. : So you left. MS. Came back downstairs. MR. : He called and said I just spoke to the lieutenant? MS. IIII: He said the lieutenant said for when you had to relieve me to get food. MR. And then you said you verified that? MS. : I called. MR. : The lieutenant? MS. : Yes. MR. : Was this both both times? Was that who it was? MS. IIII: No. When I called, Lieutenant answered and he said he didn't know. MR. : SO it was Lieutenant IIII. So this would have been at like 5:30 then probabl ? MS. : Probably. MR. : Okay. If you look at the 168 1 schedule, can you tell me what time came 2 on? 3 MS. On here it says 8:00 to 4:00. 4 MR. Are you looking at 8/10 - 5 August 10th? 6 MS. IIII: Yes. But it was before that. 7 It was (Indiscernible *02:00:18). 8 MR. : Oh, sorry. So there's a 9 little caveat there. So the officers' times 10 are two hours before, do he would have started 11 at 6:00. But I believe he actually - his would 12 be 6:00 to 2:00 as opposed to 8:00 to 4:00 like 13 the roster. So it's confusing. Um, they 14 allowed the lieutenants to come in two hours 15 earlier and end their shift two earlier. 16 MS. : Hm. 17 MR. : But I do believe he 18 arrived at 5:30. So this would have been 19 probably you said - you said there were two 20 different lieutenants you spoke to. So I'm 21 assuming one - 22 MS. IIII: No I spoke to Lieutenant , 23 asking did he say for me to relive to 24 get the food. So he said he doesn't know. 25 Maybe Lieutenant told him. But I EFTA00117684 169 1 didn't speak to her. 2 MR. : Sure. And what I'm - I 3 think that he started around S:30. So he 4 probably called around like 5:28, spoke with 5 lieutenant - and then you probably called 6 shortly after 5:30. Does that sound like 7 potentiall could have happened? 8 MS. : Could have. Yes. 9 MR. : Okay. So does around 10 that 5:30 timeframe right before you know you 11 were going to feed the inmates. Does that 12 sound about right? 13 MS. : Ri ht. 14 MR. : Okay. So the 5:00 a.m. 15 count. That (Indiscernible *02:01:18)? 16 MS. : Ri ht. 17 MR. : Okay. So he is - and I'm 18 sorry, who was in the 10 South? 19 MS. 16r. 20 MR. It was and then who 21 else visited the SHU where Epstein was housed 22 between 12:00 a.m. and 6:30? 23 MS. : Lieutenant 24 MR. : Are they the only two 25 people that visited the SHU aside from you and 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 S. : Yes. MR. MS. MR. the SHU with then? MS. IIII: On the paper it says that I was the number one. MR. And would that be - I know you said a lot of time it's because you're new, you would ask other people for guidance. Is that because that was your quarterly post? MS. : Yes. The post. MR. And was in there as an overtime post? MS. : Yes. MR. assignment? MS. MR. 170 Okay. No one else? Okay. When you were in was there a hierarchy Not his regular : Correct. Okay. So on paper, you were in charge. But in practice, you're both the same. MS. IIII: In practice, I ask because I don't know. So even if I'm in charge, I don't 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 171 know everything because I'm new. So I ask the senior officer. MR. : Okay. Do .remember any conversations you had with that night? MS. : As far as -? MR. : Just were you conversing? While you were there? Just the two of you? MS. : I'm not -. MR. : I'm not asking for what conversations at this point. I'm just saying were you talking to one another? MS. : No not really. MR. : You guys didn't really communicate or talk? MS. : No. MR. Okay. Do you remember any conversations with regard to Epstein at all? MS. MR. • No. Alright. So it's just you two, you said , and IIII. The only four people from that - those periods when you started your shift at 12:00 a.m. to 6:30? No. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 172 MS. : Correct. MR. What was the purpose of visit? MS. To conduct a round. MR. Okay. And what is she required to do during a round? MS. : I don't know. MR. Are you aware if she was supposed to conduct a count with you during her round? Or -? MS. IIII: She's not supposed to conduct the count. But I don't know how she's supposed to conduct her rounds. MR. : So do you understand if her round is at a round of her staff members? Or is it also she's supposed to do anything with inmates when she does rounds? MS. : I don't know. MR. : You don't know. And do you remember when she entered and exited the SHU who let her in and out? MS. : I did. MR. Both times? Both in and out? MS. IIII: Yes. EFTA00117685 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 173 MR. : Okay. And then what about when departed the SHU? Who let him in and out? MS. : That I don't remember. MR. : Would it be -? MS. : But it probably would have been me. MR. relived him -- MS. MR. MS. MR. up there MS. MR. -- you since Ri ht. Went upstairs. -- Correct? Yes. I would think went then you probably would have -- : Let them out. Mm-hmm. Okay. And both with and r, you verified that that those doors were shut and sealed? MS. : Yes. MR. : And no one else got in and out between those times? MS. : No. MR. And were they - those two individuals authorized visitors - and authorized visits - within the SHU? 174 1 MS. : Who Lieutenant 2 MR. : Was their presence in the 3 SHU authorized? 4 MS. . Yes. 5 MR. Was it justified. And 6 did you see them the entire time that they were 7 actually in the SHU? 8 MS. : Yes. 9 MR. Was there anything out of 10 the ordinar 11 MS. 12 MR. No. Any - either of them 13 have any conversations about Epstein? 14 MS. : No. 15 MR. : And you say 16 was the o erations lieutenant on August 10th? 17 MS. : Yes. 18 MR. . Did you have any 19 conversations with her on the phone? 20 MS. : No. 21 MR. : That you recall? No. 22 What about like when you guys would call in 23 counts? 24 MS. IIII: I don't remember who took the 25 count, but when I got called control to give 175 1 the count, I don't remember if it was her that 2 took the count. But. 3 MR. : Okay. So you don't 4 recall any other conversations with 5 aside from when she visited at 4:00 to 6 check in? 7 MS. : Correct. 8 MR. And she never provided 9 any special instructions? 10 MS. No. 11 MR. About anything during 12 that shift? 13 MS. : 14 MR. 15 never told you that Epstein was 16 required to have a cellmate? 17 MS. No. 18 MR. Didn't ask about or 19 anything? 20 MS. 21 MR. : Or about a new cellmate 22 being place in? 23 MS. 24 MR. Alright. And we just 25 briefly mentioned that who was Lieutenant • She never told - 176 1 2 MS. IIII: The lieutenant that came on in 3 the morniii 4 i MR. : Okay. And he started - 5 we believe around 5:30 based upon what we just 6 talked about. 7 MS. : Correct. 8 MR. : Okay, 5:30 a.m. on August 9 10th. And during that conversation, you said 10 that you called Lieutenant IIII. What all was 11 spoken about during that call? 12 MS. IIII: If I should relive to get 13 food. If that's what he said. 14 MR. Any discussion about 15 inmates? 16 MS. 17 MR. Any discussion about 18 Epstein? 19 MS. 20 MR. No. He didn't' provide 21 any special instructions or ask about anything 22 about your shift? 23 MS. No 24 MR. About him coming on? 25 MS. : EFTA00117686 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 177 MR. No. Do you remember if the control center, R&D, or anyone else called the SHU on August 9th or 10th during your two shifts? About Epstein's cellmate leaving? MS. IIII: I don't know. If they did, they didn't s eak to me. MR. : You didn't speak with anybody? MS. MR. R&D or anyone else?› MS. MR. • If an inmate is removed from the SHU and is released from the MCC, how does the SHU find out? MS. : I don't know. MR. : You don't know? MS. MR. Has that ever happened to you before? MS. MR. : Where an inmate had gone? No. • When an inmate goes to court or something and then is released? MS. IIII: But I don't -. If that happens, like I'll give the phone to the senior officer because I don't know. But that never 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 178 happened where like an inmate was released when I'm there. MR. : So from 4:00 p.m. on August 9th, you don't recall that call coming in -- MS. . 0. MR. : -- or a discussion happening -- MS. MR. back? MS. MR. : Not to me. -- about not coming : Not to me. No. And you didn't have a conversation with anybody at all? MS. : No e. MR. : And you don't know if control or R&D or anybody spoke with anyone else? MS. . I don't know. MR. Even if they didn't discuss the details of it. You didn't overhear 22 that conversation? 23 MS. : No. 24 MR. So what is your 25 understanding? If is released on August 179 1 9th from the SHU. Epstein is required to have 2 a cellmate. What should have happened? 3 MS. IIII: I don't know what should have 4 happened because when I came in at 4:00, the 5 cell was empty. So I don't know what should 6 have happened. Epstein came back and went to 7 his cell. I don't know where is or if 8 he's coming back. So I don't know what should 9 have happened. 10 MR. : Okay. So if an inmate is 11 required to have a cellmate, such as Epstein, 12 when the cellmate -. Sorry, I don't know if I 13 just misspoke. If Epstein was required to have 14 a cellmate, as Epstein was, after his cellmate 15 departs, which was , do you know if 16 there's a - how long it should take for him to 17 get replaced? 18 MS. Oh. I don't know. 19 MR. You don't know that? 20 MS. 21 MR. Do you know who the 22 decision-makers would be on that? 23 MS. : I don't know. 24 MR. : Do you know if you were 25 authorized to assign Epstein a cellmate? 180 1 MS. : I don't know. 2 MR. : Again, no conversations 3 at all with -? 4 MS. : None. 5 MR. : He's gone. No? Um and 6 you don't remember him being removed from the 7 roster list so when you're doing your rounds 8 and your counts. 9 MS. : N 10 MR. You know how many are 11 supposed to be counting. 12 MS. : No. 13 MR. : Alright. We're just 14 going to talk a little bit about counts and 15 rounds. According to you, what is a cell count 16 and you have it in front of you if you need to 17 refer to the policy. But what is your 18 understanding of a cell count? Or sorry, an 19 inmate count. 20 MS. IIII: You count every inmate to make 21 sure thatiiiiiiiiiilive. 22 MR. : To make sure that they're 23 alive? And accounted for? 24 MS. : Yes. 25 MR. Alright. And can you EFTA00117687 181 182 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 just explain the process? MS. IIII: The first officer goes down and counts. And then the second officer goes down and counts. And we confirm the numbers. MR. : Okay. And prior to confirming the numbers, do you tell the other officer how many you counted? MS. : No. MR. : Alright. So you get your number, then another officer goes down, gets their number. MS. And when they come back. MR. And is that tier by tier or do you MS. MR. Yes. Tier by tier. Tier by tier. Just one person stands outside while the other person -- MS. : Yes. MR. -- goes down range and counts the inmates? MS. : Yes. MR. So do you have to like see the person moving, see - what do you need to do wheLLysiu're doing that count? MS. IIII: You need to see the prisoner 1 move. 2 MR. Do you have to like talk 3 to them? Make sure they're responsive or 4 anything? 5 MS. IIII: Or you could see them 6 breathing. 7 MR. : Just as long as you see 8 some life. Okay. So what are the requirements 9 in the SHU on how often is a count conducted 10 for counts? 11 MS. IIII: Counts is at 4:00. I mean it's 12 been a long time. I really don't remember. 13 But I think 4:00, 10:00, 12:00, 3:00, and 5:00. 14 MR. : Okay. So 4:00 p.m., 15 10:00 p.m., 12:00 a.m., 3:00 a.m., and 5:00 16 a.m.? 17 MS. : Yes. 18 MR. : And is that every day or 19 is it Monda through Friday? Do you know? 20 MS. : Every day. 21 MR. Every day. And you're 22 just making sure they're alive. You don't 23 actually have to speak with them? 24 MS. : No you don't. 25 MR. Okay. And what's the 183 1 difference? What's a round? 2 MS. IIII: I mean the round you're walking 3 down the tier basically checking to see if 4 they're okay. But you're not counting. You're 5 just checiiiiiiiiiike sure. 6 MR. : So you're doing the same 7 thing you're just not counting -- 8 MS. : Counting. 9 MR. : -- the inmates? Alright. 10 So you're making sure that they're okay and 11 they're alive. But you're not just -- 12 MS. Counting. 13 MR. -- actually making sure 14 they're -. 15 MS. IIII: Yeah like you don't need a 16 number. 17 MR. But one CO goes down, 18 checks, and then does the other one? Or does 19 there onl need to be one? 20 MS. : Well it's one. 21 MR. : So both don't need to 22 actually do that? 23 MS. : No. 24 MR. Alright. So just one CO 25 goes down. Does the other CO have to remain at 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 184 the door to make sure that CO is okay? MS. : Yes. MR. : Okay. So is that the difference then? MS. IIII: Between the counts and the rounds. Yes. MR. and that's er your understanding of policy. MS. : Yes. MR. round, do MS. MR. Only one CO is required Okay. And during a ou have to speak with the inmates? : You don't have to. No? But on both instances both COs have to be present. You're just saying with rounds, only one CO actually needs to o down. MS. : Co down range. Yeah. MR. : You said the purpose is to make sure they're okay and they're alive? MS. : Yes. MR. : And are they - are the counts and the rounds both documented? MS. : Yes. MR. : And do you have to sign documents when you conduct counts and rounds? EFTA00117688 185 1 MS. : Yes. 2 MR. : Okay. Now if you and 3 another officer like on the case of when you 4 work 12:00 a.m. to 8:00 a.m. If you and 5 another officer are the only ones assigned to 6 the SHU, are you both just as responsible for 7 documenting the round sheets and the count 8 slips? So if you're the one documenting all 9 the rounds for the 30-minute rounds, is your 10 documentation - does that also carry weight for 11 the other person that's with you? Are you 12 signing for both of you? 13 MS. IIII: I don't think so because it's 14 just my si nature. 15 MR. : So you would take 16 responsibility for the cell count rather than 17 saying that you're both responsible? Or the 18 round -? 19 MS. IIII: Well the rounds and the counts 20 have to be done with two people. 21 MR. : But -. 22 MS. : But on the -. 23 MR. : Let me just show you so 24 you know what I'm talking about. I'm just 25 going to show you for August 9th and 10th the 186 1 cell counts and the rounds so that there's no 2 misunderstanding. So this first one is going 3 to be the 8/9/2019 for the 30-minute check 4 sheet. And the other one is going to be 5 8/10/2019. Can you just let me know if you see 6 your handwriting and initials on these two 7 documents? 8 MS. : Yes. 9 MR. Okay. Do you see it on 10 both? 11 MS. : Yes. 12 MR. Okay. And I guess we'll 13 first discuss August 9th. Where do you see it 14 and from what time to what time? 15 MS. : From 4:00 to 11:30. 16 MR. : And are you ever one of 17 them? 18 MS. : Yes. 19 MR. : Okay. So every 30 20 minutes, you have your initials. And you wrote 21 those. That's actually your initials on that 22 one? 23 MS. : Yes. 24 MR. : And what about on August 25 10, 2019? 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 187 MS. : Yes. MR. : Okay. So what I'm asking here is by you placing those initials is that now fall on you? Or if you're only two people in there like on August 10th -- MS. : Mm-hmm. MR. : -- are you basically signing for both people? Or do you think you're only signing for yourself there avowing that the round was conducted. MS. : I don't know. MR. : Okay. MS. : I guess because like you're trying to say if the rounds have to be conducted with two people, when I sign it would be -. I don't know. MR. : Okay. But you did sign and certif that they were conducted? MS. : Yes. MR. : Okay. And what do you do with the rounds - the sheets - how are they maintained? MS. IIII: Well I usually fill it out like prior in hopes to conduct the round. Like when I work in the SHU, I've never actually done the 188 1 round every 30 minutes. Like when you go down 2 to give out toilet paper, that's counted as a 3 round. To pick up trays, it's counted as a 4 round. To give out food, that's counted as a 5 round. But and then you fill it out either 6 after or before. You're not sitting like every 7 30 minutes like filling it out. 8 MR. : Okay. And you're - you 9 said you do it a lot of times prior to actually 10 conductin the round? 11 MS. : Yes. 12 MR. : Alright. And with 13 rounds, do you call anybody with that 14 information? 15 MS. • No. 16 MR. : What's done with the 17 sheet? Is it at the end of the shift something 18 done with it? Are they logged into the BOP 19 database at all? What happens with those 20 sheets? 21 MS. IIII: I don't know. Because it's 22 left on the table. I don't know what they do 23 with them. 24 MR. : So as far as you know, 25 you just fill it out and you leave it there? EFTA00117689 189 190 1 MS. : Yes. 2 MR. : Okay. You don't ever 3 provide it to anyone. 4 MS. No. 5 MR. : And you don't ever go 6 into any BOP database and enter those rounds. 7 MS. • No. 8 MR. : Do you know if someone 9 else does? 10 MS. I don't know. 11 MR. : You don't know. Okay. 12 What about with counts? Do you call people 13 after you do the counts? 14 MS. Yes. Control. 15 MR. : You call control? 16 MS. Yes. 17 MR. : And do you recall on 18 August 9th or August 10th you called - did you 19 call anyone with those numbers? 20 MS. : Yes. 21 MR. : Okay. And do you 22 remember which counts you called? 23 MS. : I don't remember which. 24 MR. : You know you did some of 25 them you just don't remember specifically which 1 ones? 2 MS. Which ones. 3 MR. : Okay. And do you 4 remember speaking with lieutenants when you're 5 there or with regular officers assigned to the 6 control center? 7 MS. IIII: I don't remember who I spoke 8 to. 9 MR. : You don't remember. Well 10 with the count slips, you said you just leave 11 those round slips on the table. When you're 12 done - when you do the count slips, what do you 13 do with those slips? 14 MS. IIII: We did the same thing. We 15 filled them out before. 16 MR. : Before you actually 17 conduct the count before you filled them out. 18 MS. : Yes. 19 MR. : So before actually even 20 getting the number, you fill out the number? 21 MS. : Because we know the number. 22 MR. : Okay. So do you then 23 call somebod with the number? 24 MS. : Yes. 25 MR. : Who do you call? 191 1 MS. : Control. 2 MR. : Control? Okay. And you 3 provide them the number that you wrote on that 4 document? 5 MS. : Yes. 6 MR. : Sorry, we did this. My 7 question was supposed to be what do you do with 8 the physical pieces of paper? 9 MS. IIII: Stick it in the door and then 10 internal takes it. 11 MR. So no one actually comes 12 in -- 13 MS. : No. 14 MR. : -- to the SHU? You stick 15 it in what door? 16 MS. : The outer door. 17 MR. : So you open up the 18 interior - the inner door and then you go to 19 the outer door and you -- 20 MS. : Stick it in there. 21 MR. • -- there's like a special 22 slot for it? 23 MS. IIII: Not a slot. It's just between 24 the door. 25 MR. Okay. Internal never 192 1 comes in though? 2 MS. IIII: They didn't that day. I don't 3 know if they ever come in, but they didn't 4 (Indiscernible *02:17:51). 5 MR. : Okay. On August 9, 2019, 6 you said you filled all that out. What rounds 7 did you conduct during your shift on August 9, 8 2019? 9 MS. IIII: That's hard for me to tell 10 because I didn't conduct it every 30 minutes. 11 It was give out food, pick up the trays, give 12 out toilet paper, go down. So those were the 13 rounds that I conducted. Bu it don't. 14 MR. : So you were counting a 15 round as j21/ doing something with an inmate? 16 MS. IIII: Yes because I actually 17 physicall walked. 18 MR. Every tier all six? 19 MS. 20 MR. Is there six tiers in the 21 SHU? 22 MS. : Yes. 23 MR. : Okay. 24 MR. : Two floors - two levels. 25 MS. : Yes. Yes. EFTA00117690 193 1 MR. So when you do these 2 rounds, when you would go down range and handle 3 an inmate or give something to an inmate, you 4 would then also do all six? 5 MS. : Yes. 6 MR. : Alright. So about how 7 often -. Let's ask it a different way. About 8 how many of those didn't you do on August 9th? 9 MS. IIII: I don't know. I can't give a 10 number of how much I didn't do. But. 11 MR. : Are some of those that 12 were documented, were they not done? 13 MS. : Yes. 14 MR. : Alright. So you didn't 15 do some of them. You just don't know which -- 16 MS. : Ones. 17 MR. -- ones? 18 MS. Ri ht. 19 MR. Alright. And -. Okay. 20 MR. FOY: Let me just say to help clarify. 21 MR. Absolutely. 22 MR. FOY: The times that you wrote down. 23 MS. IIII: Okay. 24 MR. FOY: Right? 25 MS. Mm-hmm. 194 1 MR. FOY: When did you write the times 2 down? 3 MS. IIII: Before. 4 MR. FOY: Alright. So when you did a 5 round to take toilet paper, did you change the 6 time to reflect that particular round? Did you 7 do anything_2ith the paperwork to change -- 8 MS. IIII: No. 9 MR. FOY: -- the actual time? 10 MS. : No. 11 MR. : And why did you do that? 12 Is it because of the requirement? 13 MS. : kph did I fill -? 14 MR. : Why did you fill these 15 ahead of time? Were you just trying to stay on 16 top of what the actual requirement was to 17 conduct a 30-minute round was? 18 MS. IIII: I mean I don't know why I did 19 it. I juiiiiiiiiiidid it that way. 20 MR. : Did someone train you to 21 do it that way? 22 MS. IIII: I mean I've seen it done that 23 way before - after. And three's people that 24 actually do it as they do it. It's been done 25 all three different ways. 195 1 MR. Some do it before, some 2 do it durin some do it after? 3 MS. Yes. 4 MR. . And just this instance 5 you did it all before? 6 MS. : Yes. 7 MR. : Alright. And some - at 8 least some of them. Would you say the majority 9 were not done or were done? 10 MS. : On the 9th? Majority was done. 11 MR. : You believe the majority. 12 Now I know we're doing estimates because you 13 don't know exactly. You think like 51% or do 14 you think -? 15 MS. : I don't know. 16 MR. You don't know. 17 MS. 18 MR. . Alright. But again, for 19 the ones that you did do, you're not just going 20 down one tier. 21 MS. No 22 MR. You're going down all six 23 tiers? 24 MS. : I'm doing all. 25 MR. : You are? 196 1 MS. : Yes. 2 MR. : And that's - this is the 3 under-oath thing. We've got to make sure 4 because the video is and all that kind of 5 stuff. 6 MS. : Yes. 7 MR. : That's your 8 understandin 9 MS. 10 MR. Alright. That you're 11 actually checking every door. 12 MS. : Yes. 13 MR. : And when you go give that 14 one-person toilet paper or whatever, you're 15 actually looking at all the different doors? 16 MR. FOY: Can we take a break real quick? 17 Because I need to take a break. 18 MR. : Absolutely. 19 MR. FOY: ldiscernible *02:20:53) 20 MR. : Yeah-yeah. Absolutely. 21 Alright. So it is currently 12:35 p.m. We are 22 going to take a quick break. [Whereupon, the 23 above-entitled matter went off the record and 24 went back on the record.] The recorder is back 25 on. This is Senior Special Agent EFTA00117691 197 1 . It is 12:49 p.m. Ms. IIII, I 2 remind you this is a voluntary interview and 3 you are under oath. 4 MS. : Mm-hmm. 5 MR. : Alright. Is there 6 anything that we wanted to revise before we 7 continue? 8 MR. FOY: Yeah. I want her to go back. 9 This was from earlier about the double door. 10 How they o erate. 11 MR. : Okay. 12 MR. FOY: I think there were some 13 unintentional inaccuracies on that. 14 MR. : Sure. 15 MR. FOY: That we clarified. So let's 16 start with that first. 17 MS. IIII: The outer door control pops the 18 outer door. I control the inner door. So the 19 outer dooiliiiiiiii be opened by control. 20 MR. : Okay. So we were talking 21 about like popping the -. It was just your 22 memory was foggy? 23 MS. IIII: I don't remember a lot of 24 stuff. But yeah. The outer door, you have to 25 call control to pop the 27 door. And we 198 1 control the inner door. 2 MR. : Okay. And then just 3 while we're going back. It's something I was 4 probably going to follow-up on later. But 5 there's been a ton of questions of like you 6 don't know. 7 MS. 8 MR. I just want to remind you 9 - you did go to the Federal Law Enforcement 10 Training Center -- 11 MS. : Yes. 12 MR. : -- where you were trained 13 as a correctional officer. And you also 14 received this IF training which I think you 15 said was like a two-week in-house training. 16 MS. : Yes. 17 MR. : Is that what that was? 18 As well as you received the annual training. 19 And all this stuff that we're talking about 20 isn't like the real detailed stuff. This is 21 like you know conducting counts and rounds. 22 And the essential duties as a correctional 23 officer. So I'm assuming you -. Is it safe to 24 assume that you received this training you know 25 during those trainings? I know you didn't go : Yes. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 199 to the SHU trainings. But not too far from when this happened, you were only on for a little over a year. And you conducted all three of those trainings. Correct? MS. IIII: I was only on for a little under a year. The training that I received in Georgia is specific to camps and not necessarily high rises. And the in-house training, the roster reflects all these trainings but we didn't' actually receive all the training because sometimes there was nobody to train us. MR. . Okay. MS. So when I say I don't know, I don't know. MR. Yeah, no. It's just almost every question. I feel like we've gone through 18 pages so far and so many of them are MS. ,cause I really -. MR. : -- like I don't know. So. MS. .eally don't know. MR. : Alright. It's just because you know people are going to say like 200 1 well you went to all these trainings. You 2 should know at least some of this stuff. So I 3 just wanted to try to get you to like think 4 back on your training. 5 MS. : Mm-hmm. 6 MR. : And your duties and your 7 responsibilities when I'm asking these 8 questions just so you can really like think. 9 Do I really now know or is that you know, did I 10 know that these things should be done. Does 11 that make sense? 12 MS. : Correct. 13 MR. And then um -. 14 MR. Can I say -? 15 MR. Yes, please. 16 MR. : lust to clarify. I know you 17 might not have received some of the official 18 trainings. Some of this stuff you might learn 19 along the wa 20 MS. : Mm-hmm. 21 MR. : From your daily duties. 22 MS. : Right. 23 MR. : Like it's repetitive. Some 24 of the stuff that you do. So you might have 25 known this based on the fact that you've done EFTA00117692 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 201 it on a daily basis. So if you say I don't know and you actually done it as part of your daily duties, it kind of contradicts each other. MS. I understand. MR. : And I just had a question. You mentioned the door. Was at any point in time - on the 9th, 10th or - was there a practice to ever leave the doors propped open in the SHU? MS. MR. • Alright. I think my last question, I just want to revisit it just to make sure that we're of the same understanding. So again when you're pre-populating all of these rounds. Correct? MS. : Correct. MR. : But you're saying you believe you did more than 50% of the rounds that were listed. MS. IIII: I can't give you a percentage - MR. Sure. MS. Sure. I don't know how to : put a percentage to a round. But I can only 202 1 tell you that I conducted rounds as I went to 2 go do something. But I can't give you a 3 number. 4 MR. : And I want to make sure 5 we understand too, if you're going down range 6 to give some inmate like toilet paper or 7 something, that you're also at that time where 8 you're saying you did a round, not just talking 9 about that tier, but all six tiers. 10 MS. : Yes. 11 MR. : Alright. So you're going 12 down to give somebody a toilet paper. At that 13 point -- 14 MS. IIII: Because I'm giving toilet paper 15 to everybod . 16 MR. : Alright. So you're not 17 just addressing one inmate. 18 MS. No. 19 MR. You're saying when you're 20 giving ever body toilet paper. 21 MS. : Yes. 22 MR. So on August 9th -. 23 MS. : When I'm giving food, I give 24 everybody food. When I'm collecting trays, I'm 25 collecting all the trays. I'm giving toilet 203 1 paper. 2 MR. So aside from eh times 3 you're now giving toilet paper and giving food 4 and collecting trays, which are a handful of 5 those times, granted. 6 MS. : Mm-hmm. 7 MR. • Are you doing any other 8 rounds? 9 MS. : Yes. And if somebody calls -. 10 MR. • On August 9th -- 11 MS. Yes. 12 MR. • -- we're talking about. 13 MS. : On the 9th. If somebody calls 14 and asks for something, yes, I conduct a round. 15 MR. And that's kind of what 16 I'm getting at. You're - if you're handling 17 one specific inmate, because they called and 18 asked for something. You're then also 19 addressin the other five tiers? 20 MS. : Yes. 21 MR. • Okay. 22 MS. Because usually when one calls, 23 everybody else hears and everybody wants 24 somethingiiiiiiiiiist do it. 25 MR. : Alright. So on August 204 1 9th, you didn't conduct all the documented 2 rounds. 3 MS. : No. 4 MR. : But you did do some of 5 them? 6 MS. Yes. 7 MR. And you don't have a -- 8 MS. A number. 9 MR. -- half or anything -- 10 MS. 11 MR. -- like that. Okay. 12 MR. FOY: But I think the clear point is 13 when she did it, it's not based on the times on 14 the paper. 15 MR. : Okay. 16 MR. S lit? So that doesn't match. 17 MR. : Alright. So -. 18 MR. FOY: The times she did it versus the 19 time on the paper. Because that paper is done 20 at the beginning of the shift. With the time 21 already selected. 22 MR. : Oh, are you filling out 23 the entire aper at the beginning of the shift? 24 MS. : Yes. 25 MR. : Oh! So you're not doing EFTA00117693 205 1 it every 30 minutes just prepopulating before 2 you do the round. 3 MR. FOY: Right. 4 MS. : No. 5 MR. : You're going at the very 6 beginning of the shift, filling everything out 7 the -. 8 MS. : Yes, sir. 9 MR. : So that -. When did you 10 fill out the August 9th round sheet? 11 MS. IIII: Like how the numbers are like 12 the round sheets before, like the times. So I 13 just fill it out because that's what I've seen 14 being done. Like it's filled out before or 15 sometimes at the end after. So I fill it out 16 all before. 17 MR. : Okay. So you 18 prepopulated that entire thing at the very 19 beginning of your shift? 20 MS. : Yes. 21 MR. : And then you just 22 conducted rounds as needed? 23 MS. • Yes. 24 MR. Alright. And you've seen 25 people do that? 206 1 MS. : Yes. 2 MR. : Who else have you seen do 3 that? 4 MS. IIII: I mean I don't have a specific 5 name, but I've seen it done. 6 MR. : Did anyone ever tell you 7 to do that? 8 MS. IIII: This is actually I think the 9 first time I've ever done the round sheets 10 because I've never actually done the round 11 sheets in the SHU. But those two days were the 12 days that I've done the round sheets in the 13 SHU. 14 MR. : So if this was your first 15 time doing a round sheet, did someone instruct 16 you on how to do it? 17 MS. IIII: No because I just followed what 18 I seen. But I've worked with people before 19 that was filling it out and that's how it's 20 been done. 21 MR. : And did you have 22 discussions with them when you were -? 23 MS. IIII: No. I never had a discussion 24 about it. 25 MR. So you just observed 207 1 people doin this? 2 MS. : Yes. 3 MR. : But no one ever told you 4 to do that? 5 MS. : No. 6 MR. : And did you know that it 7 was wrong to do that? 8 MS. : No. 9 MR. : You didn't know that it 10 was wrong to prepopulate the rounds you 11 conducted when you weren't conducting those 12 rounds? 13 MS. IIII: No. I mean if I'm putting the 14 time on there saying that I conducted the round 15 at this time, and I didn't conduct the round at 16 this time, that's wrong. But I didn't think it 17 was wrong to fill it out all before or after 18 because that's how they do it. 19 MR. : So that's a contradicting 20 statement. You know that it's not right to 21 conduct a round at the time that you conducted 22 it, but you didn't know that it was wrong to 23 (Indiscernible *02:28:16). 24 MR. FOY: She knows that now. But this is 25 the way it was done. 208 1 MR. Yeah. 2 MR. FOY: She followed. But like when you 3 look at the policy and now that we're here and 4 we've had discussions. Okay. That's not how 5 it's supposed to work. 6 MR. : But at the time that 7 you're filling this out on August 9th at the 8 beginning of your shift saying that you 9 conducted these rounds at a time that they 10 weren't conducted yet. You had to have known 11 that that wasn't -. Maybe you saw people doing 12 the wrong thing, but you couldn't have possibly 13 thought that that was correct. 14 MS. : Well I -. 15 MR. : Because you're falsely 16 certifying that rounds are completed when you 17 didn't. There's times even that they're events 18 in the future. 19 MS. IIII: I understand but I didn't know 20 that. I just followed whatever I saw that was 21 being done. 22 MR. : I absolutely understand 23 the defense that you said other people have 24 done this and you're following their guidance. 25 But you can't possibly think that it's okay to EFTA00117694 209 1 fill out certifications saying that you 2 conducted rounds in the future that haven't 3 taken place and that you actually didn't do at 4 the same time. Is that something being lost in 5 translation? Do you follow what I'm asking 6 you? Do you think it's okay to sign on the 7 round sheet that you conducted a time -? 8 Conducted a round -? 9 MS. IIII: But it's the same thing as the 10 end. Like if I do it all at the end at the 11 times that I'm putting, I'm not going to 12 remember all those times specifically. 13 MR. : Absolutely. I would also 14 argue that anytime you're falsifying a record, 15 you always know that that's wrong. 16 MS. : So. But. I mean. 17 MR. : So I do understand that 18 you're saying other people do it. And that's 19 why I want to get into who else is doing this? 20 Who trained you on that? How do you know that 21 was the way that things were done? So that's 22 where my question of who talked to you about 23 it. You said no one actually spoke to you 24 about it. But you -- 25 MS. IIII: No. I just seen people do 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 that. MR. who did you -- MS. MR. 210 : -- observed people. So Because I never had -. -- observe do that? MS. I never had a conversation with about filliac,tround sheets. MR. : Right. So if that's going to be the argument that you're doing it based upon your training and experience, I need to know more about this training and experience. Who is it that you experienced do this in the ast? MS. : People that I've worked with. MR. : So I'd like you to think about alright, I know this because I saw that person do it. Who? MS. Um. MR. : So you've witnessed prepopulate or at the end of the shift? MS. IIII: I don't remember exactly. But it's done either or the way. MR. : Alright so you saw and who else? MS. IIII: 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 MR. MS. MR. What's - is MS. MR. - first name? MS. : I don't know the first name. MR. SHU? MS. MR. Is it MS. MR. MS. MR. MS. MR. *02:32:40). MR. FOY: It's a first or last name? MR. ? Is the first name 7 MS. M: M. 211 , is that the SOS No. A different a gentleman's name? Yes. • What's that person's name who worked in the Yes. : You mentioned before. Yes. Um. U: • : Say that again? 7 It's like (Indiscernible 1 MR. FOY: Oh. 2 MS. IIII: Yes. 3 MR. FOY: 4 MS. 5 MR. 6 those three 7 MS. 8 MR. 9 MR. 212 one else aside from 7 10 MR. ? Alright. So 11 in the recollections of the three people that 12 you named what did you observe them do? 13 MS. •: Fill it out after or fill it 14 out before. 15 MR. And was that on numerous 16 occasions? 17 MS. : Yes. 18 MR. Alright. So during your 19 time in the SHU, which I think was from around 20 June 24, 2019 through August 10th, was it on 21 many of those days that you were working in the 22 SHU - this is how it was done? 23 MS. : Yes. 24 MR. : Where the rounds weren't 25 conducted and they were prepopulated or EFTA00117695 213 1 populated at the end? 2 MS. : Yes. 3 MR. • And it was never spoken 4 of? 5 MS. : No. 6 MR. : And you never asked? Hey 7 why are we you know certifying that we're 8 conducting rounds that we're not actually 9 conductin 10 MS. I never asked. 11 MR. . Never asked? 12 MS. 13 MR. . And they never told you 14 to do that though? 15 MS. : Who? 16 MR. : No one ever told you that 17 this is the way that it's done? 18 MS. IIII: I mean that's the way that I've 19 seen them do it. But no one ever -. 20 MR. : You observed it. You saw 21 that people did that. 22 MS. IIII: Because I never asked so nobody 23 ever told me. But that's just what I saw. 24 MR. : So on August 9th, you 25 believe that's the first time you filled the 214 1 sheet out. No one actually directed you or 2 instructed you that's how we do it, you just 3 saw people do it that way? 4 MS. : Ri ht. 5 MR. : Alright. And this goes 6 back to -. I understand - your attorney did 7 say that ou know now that it was wrong. 8 MS. : Yeah. 9 MR. : But at the time, you 10 thought it was okay to certify times that you 11 know you conducted rounds when they weren't 12 conducted? 13 MS. IIII: Because that's the culture of 14 it there. I didn't consider it as being like 15 I'm falsifying a time or a document. No I 16 didn't. 17 MR. : Is this something that's 18 addressed in training and policy? Hey when you 19 conduct a round, it's documented? At the time 20 you conducted it. 21 MS. • No. 22 MR. So it's not in the policy 23 that I provided for you? 24 MS. IIII: I don't know if it's in the 25 policy. But in training, you're just told to 215 1 conduct rounds and counts. But if -. 2 MR. : And document it at the 3 time it's been conducted. 4 MS. : And document it. 5 MR. : Right. So it's a 6 cultural - it's a culture of falsification of 7 records? 8 MS. IIII: In MCC? Yes. Like the 9 lieutenant told me to sign I did SHU training 10 and I didn't. 11 MR. Absolutely. There's a 12 lot of it eah. 13 MS. • Yeah. 14 MR. • So my point being is it 15 sounds like this is a cultural problem. 16 MS. : Yes. 17 MR. : But you have to - as a 18 person who received a college degree. A person 19 that went to you know standard - conducted 20 ethics training. You have to know that -. I 21 understand other people are doing it. And 22 you're saying I'm going to do what they're 23 doing. But you have to know - you have to 24 question like hey. I didn't conduct this 25 training. I didn't conduct those rounds. So 216 1 you had to know that you shouldn't have done 2 it. 3 MS. : But -. 4 MR. You're saying that you're 5 doing it because that's how other people are 6 doing it. But you're all doing it wrong. 7 Correct? 8 MS. IIII: But -. But in a case like 9 this, who am I telling because like -. 10 MR. : I'm not asking you to 11 tell anybod 12 MS. IIII: No-no-no. When I say telling, 13 I'm like okay. If it's -. Okay. I understand 14 you're saying that I know that it's wrong. But 15 I'm saying like okay, like how the lieutenant. 16 Like when you said to me, does she know that I 17 didn't do the training? And I said yes she 18 knows that but she still told me to sign that. 19 MR. : Absolutely. 20 MS. : So again, I'm not going to 21 think. Like I said, I'm not thinking of this 22 as like I'm falsifying a document. It's just 23 the culture of MCC and I just followed. I'm 24 new. I don't know. I just lean on the senior 25 officer or the people that I'm working with for EFTA00117696 217 218 1 - to do what the do. 2 MR. Okay. 3 MS. Or to guide me so to speak. 4 MR. Let's ask it this way. 5 Did you know that you were supposed to conduct 6 rounds ever 30 minutes? 7 MS. : Yes. 8 MR. Yes. Did you know that 9 those rounds that are supposed to be conducted 10 every 30 minutes are supposed to be documented 11 on that sheet? 12 MS. . Yes. 13 MR. And they're supposed to 14 be documented on the time that you conducted 15 those rounds? 16 MS. IIII: No. Because nobody documents 17 it on the time. 18 MR. I understand that that's 19 why you did it. But do you understand that in 20 training, every 30 minutes and they're supposed 21 to be not as it's corrected, they're not 22 supposed to be on the exact dot 30 minutes. 23 You're supposed to do it within like a 30- to 24 40-minute window. Correct? So that's not a 25 regular occurrence? 1 MS. : Yes. Irregular rounds. 2 MR. : Irregular rounds. 3 Correct. So you know that you're supposed to 4 do them ever 30 to 40 minutes. 5 MS. : Yes. 6 MR. Two rounds and hour. And 7 those rounds are supposed to be documented. 8 MS. : Yes. 9 MR. On that sheet. 10 MS. On the sheet. 11 MR. So obviously that leads 12 to the training of they're supposed to be 13 documented when you conduct the rounds. 14 Correct? 15 MS. : Okay. 16 MR. So I'm - I do understand 17 that you're doing it because other people that 18 you just mentioned did it that way as well. 19 You have to know that you were supposed to do 20 it the wa I just explained. Correct? 21 MS. : I know now. 22 MR. : Well you had to know then 23 too because it's like you're supposed to do a 24 30-minute round and you've got to document when 25 you did the 30-minute round. Correct? 219 1 MS. IIII: I never seen nobody do that 2 that I've worked with. 3 MR. • So you never saw 4 or do it that way? 5 MS. : See like when -. 6 MR. And hey -. If 7 everybody's doing it wrong, obviously that's a 8 huge problem. 9 MS. IIII: No, but what I'm saying is like 10 I'm not next to them. Like okay, let's say if 11 they're doing the sign-in sheet, I'm not - 12 that's wiiiiiiiie how you're saying 13 like if is turning a sign-in sheet, I 14 don't necessarily have to be next to him. I 15 could only tell you the people that I've seen. 16 Do I don't know like I can't speak for 17 everybody on this -. On there that I see. 18 MR. : Right. But what I'm 19 saying is you know that you need to conduct 30- 20 minute rounds. You know those rounds need to 21 be documented. You know those rounds need to 22 be documented on that sheet. 23 MS. : Mm-hmm. 24 MR. Correct? 25 MS. : Correct. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 220 MR. . Therefore, you knew that what you were doing was false. Correct? MS. IIII: As in putting the time and the time that I conducted the round. And I didn't do that at that time. See again -- MR. So you knew it -- MS. -- with the time. MR. -- that what you were writing in there wasn't true and accurate as you wrote it. Correct? MS. : Correct. MR. : And the reason you did it was because the people that you observed in there before did it that way. MS. : Correct. MR. : Is that correct? I think that's how satisfies us. Any -?> So you knew it was wron you knew what you were -- MS. : But -. MR. -- writing was wrong, but you did it because it's how they did it. MS. IIII: Right. But didn't -. I'm not thinking it's wrong. Like specific to the times because I've never seen it done every 30 minutes - every 30 minutes - every 30 minutes. EFTA00117697 221 1 MR. Right. 2 MS. I've never worked -. 3 MR. : So it's always been 4 falsified. Ever since you've been there, it's 5 always been falsified record is what you're 6 saying. 7 MS. IIII: That - at the times that I've 8 worked and the people that I've worked with, 9 I've never seen it done every 30 minutes like 10 that. No. 11 MR. . Correct. 12 MS. I've never seen it. 13 MR. So you're trained on 14 conducting 30-minute rounds and documenting 15 when the 30-minutes -. Your experience has 16 taught you that that's not how they do it 17 there. They always falsify those records and 18 just put in whatever in order to satisfy the 19 30-minute re 20 MS. 21 MR. 22 MR. 23 MR. 24 MR. 25 first time. ui rement. : Correct. Okay. : Just one follow-up question. Yep. : You mentioned that was the Those two days were the first time 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 222 you filled out a round sheet in the SHU. Prior to the SHU, before you got to the SHU, did you fill out those round sheets? MS. Prior to working in the SHU? MR. : in the SHU. Did you fill out MS. IIII: On other units, we don't have um round sheets like this. MR. : DO you have to conduct rounds in the other units? MS. IIII: Yes. But it's not documented on a round sheet. MR. : But this was the first time you would have to? MS. IIII: In the SHU it's documented on the sheet. MR. : Alright. So is it the first two times that you can recall documenting? Are we going to find other round sheets that -? MS. IIII: The first two times that I can recall -- MR. These were the first two times these two times? MS. IIII: -- that I recall documenting. 223 1 MR. Alright. And did you -? 2 MR. FOY: You haven't gotten to this yet. 3 You know, I'm to lay back -- 4 MR. Absolutely. 5 MR. FOY: -- and let you do your thing. 6 MR. : Absolutely. 7 MR. FOY: But at some point you'll learn, 8 she never worked midnight to 8:00 -- 9 MR. : Yep. 10 MR. FOY: -- a.m. before. Right? 11 MR. : And we never -. 12 MR. FOY: And there's a reason. 13 MR. : And we have that. Do you 14 want to give her a duty roster - her daily 15 assignment -- 16 MR. Sit. 17 MR. -- roster so that she can 18 see -- 19 MR. FOY: 20 MR. 21 MR. FOY: 22 personal life 23 come in earl 24 MR. 25 MR. FOY: Ri ht. : -- where she -? So there were events in her . Because she used to do that I m i,oid being mandated. : Sure. But she couldn't do it that day 224 1 and got mandated. So now she's the officer in 2 charge for the first time at midnight with a 3 senior officer, even though he's really worked 4 there regularly. And he's not there for 5 guidance so to s eak. 6 MR. Sure. 7 MS. : And you know. 8 MR. So this one -. This was 9 your daily assignments and I see where it says 10 you're relieved without pay for a great amount 11 of time up until -. It looks like 6/26/2019 12 you were assigned SHU number three. And then 13 through - what we're looking at is 8/10, SHU 14 number one. So if you want to reference this 15 on days that you worked or -- 16 MS. : Mm-hmm. 17 MR. • -- assignments you were 18 on. 19 MR. FOY: Where? 20 MR. : That's that thing. So I 21 understand what you're saying is that this is 22 your first time and she was the one in charge 23 and she wasn't having an officer in charge to 24 confer with I guess. 25 MR. FOY: Right. EFTA00117698 225 1 MR. And that's why I'm 2 getting back to -- 3 MR. FO tiiit. 4 MR. : -- the fact that she 5 observed, you know, she knew that what she was 6 writing was false. But she did it because she 7 saw everybody else doing -- 8 MR. Sit. 9 MR. : -- falsifying records. 10 MR. FOY: So part of it is, right, and 11 you're not wrong when you say, "Well that's 12 falsification of documents." And all that. 13 Right. And I can understand and can appreciate 14 how it looks that way. 15 MR. : Sure. 16 MR. FOY: Right. And I'm not - we're not 17 disputing that. Okay. But I think there's 18 also another way. It's like well it's 19 inaccuratiiiiiiiiii 20 MR. : Mm-hmm. 21 MR. FOY: But that's not committing a 22 fraud to try to deceive the institution because 23 I just want to collect a paycheck and not do my 24 job. It's not for those reasons. It's just 25 because there's a BOP formal way and there's an 226 1 MCC way of doing things that she's assimilating 2 to that's not the proper way. That what should 3 happen - a person needs to have the strength to 4 step up apij@Litand be the -- 5 MR. IIIIIIIIII: Mm-hmm. 6 MR. FOY: -- whistleblower or whatever. 7 No. She didn't do that. Right? 8 MR. And I can so appreciate 9 that. 10 MR. FOY: Ri ht. 11 MR. : And that's why I say this 12 is a cultural, institution problem 13 MR. FOY: Right. 14 MS. : Mm-hmm. 15 MR. : And I agree with that. 16 MR. FOY: Ri 17 MR. IIIIIIIIII: And I'm saying this was 18 wrong that she observed this. And those people 19 that were doing that were absolutely wrong. 20 MR. FO'i tight. 21 MR. IIIIIIIIII: All I was trying to get 22 to is that we can all agree that that - you 23 know every 30 minutes is when the round is 24 supposed to be entered in there. 25 MR. FOY: So -. 227 1 MR. you know and she knew 2 that she was entering the wrong information 3 when she did it. 4 MR. FOY: We don't disagree. 5 MR. : Sure. 6 MR. FOY: She understood I didn't really 7 do a 6:03 round or whatever. Right? 8 MR. : Absolutely. 9 MR. FOY: But I don't know if she 10 experienced that as I'm falsifying records to 11 my job. 12 MS. IIII: Mm-hmm. 13 MR. Slit? 14 MR. : Right. 15 MR. FOY: Which she is in her mind doing 16 is well we're supposed to do rounds. But no 17 one ever really does them every 30 to 40 18 minutes. But you've got to fill out certain 19 paperwork that's required. So you fill out the 20 paperwork. Now I know from looking at the 21 discovery not every single officer did that. 22 Right? 23 MR. Sure. 24 MR. FOY: I saw in the discovery that 25 there were people who - there would be blanks 228 1 where the rounds should have been. So they 2 accurately reflected I suppose when they did. 3 But I think a lot more common is it's not that. 4 MR. : Absolutely. 5 MR. FOY: Right? So she followed the 6 strain. 7 MR. : Absolutely. 8 MR. FOY: She did not chart her own path 9 which is with - you know, why she's got to take 10 responsibilit for that part. 11 MR. : And that's also why we 12 discuss this isn't all about you. It's about 13 the institution. 14 MR. FOY: Yeah. Understood. 15 MS. : Mm-hmm. 16 MR. : And this seems like this 17 is an institutional problem. And that's awful 18 that you're one year on and this is what you've 19 observed -- 20 MR. Slit. 21 MR. : -- this entire time. 22 MR. FOY: And I only say that because I 23 feel like - in watching your interaction, 24 you're kind of talking past each other on your 25 focus on if it's the falsification knowing it's EFTA00117699 229 1 wrong. And she's like, well yeah, but I'm just 2 kind of doing. I'm not trying to commit a 3 crime. Like it wasn't like - and that's kind 4 of been my pitch the whole time. She wasn't 5 out to commit a crime. This isn't about hiding 6 my behavior because )eff Epstein died. 7 MR. : Mm-hmm. 8 MR. FOY: Right? It's all there. Right? 9 Even the theory of the case is when asked what 10 happened. We messed up. Right? That's the 11 like they tell the truth. There's no deceit - 12 deception -- 13 MR. : Mm-hmm. 14 MR. FOY: -- in frustrating the 15 investigation or the response. Now we're here, 16 we're trying to clear it up. We understand the 17 job that you have. You know address some of 18 the specifics here, but it's a much broader 19 vision. So we're trying to bring light to that 20 and she's doing the best she can to do it. I 21 think the issue is we're doing this almost two 22 years later. Ri ht? 23 MR. : Sure. 24 MR. FOY: That's the problem. And -. 25 MR. : And the next day might be 230 1 a little easier to address. 2 MR. FO`i iiit. 3 MR. : So -. And we can jump 4 right into that. 5 MR. FOY: 6 MR. : So on August 10th, is 7 that also in front of you? I can't remember at 8 this point what I provided you. The round 9 sheet for August 10th. 10 MR. FOY: The round sheet. 11 MS. Yeah. 12 MR. : Did you conduct any 13 rounds on Au ust 10th that are -- 14 MS. No I did not. 15 MR. -- not -. And did you 16 also prepo ulate that? 17 MS. Yes. 18 MR. Alright. So you knew 19 everything you wrote in there - again, I 20 understand that you said this is what you 21 observed. No one told you to do it this way 22 because you saw other people doing it this way. 23 But you knew that you didn't conduct any rounds 24 that you listed on that sheet. 25 MS. IIII: Yes. 231 1 MR. Correct. And what about 2 cell counts? And I'm only trying to move past 3 because we have a lot more to get through. 4 MR. FOY: Mm-hmm. 5 MR. : But if there's something 6 else we want to address on there. 7 MR. FOY: Yeah. No. We're good. 8 MR. : So the cell counts. When 9 did you conduct cell counts - sorry, inmate 10 counts during your shift in the SHU on August 11 9, 2019? 12 MS. : Oh, that's 9th? 13 MR. : August 9th. So we're 14 talking now the 4:00 p.m. and a 10:00 p.m. 15 MS. : 10:00. 16 MR. : Did you conduct those 17 counts? 18 MS. : 10:00. 19 MR. : lust 10:00? Not he 4:00 20 p.m.? 21 MS. : Not at 4:00. 22 MR. : Now you do recall 23 actually conducting the 10:00 as you're 24 supposed to do it? 25 MS. IIII: No because my partner was on a 232 1 triple. 2 MR. 3 triple shift? 4 MS. IIII: Yes. 5 consecutive shifts. 6 MR. 7 MS. 8 myself. 9 MR. 10 around and counted 11 MS. 12 MR. 13 count sli 14 MR. All of it? 15 MR. We'll start I guess with 16 just the August 9th because we don't want to 17 give her too many stuff. Alright. So what I'm 18 going to show you here is this first page is 19 going to be like the institutional count. And 20 it's going to show you like ZA. Is ZA correct 21 for the SHU? Do you know that that is what ZA 22 stands for? 23 MS. : I don't remember. 24 MR. Alright. So ZA is going 25 to be the number that's going to reflect for Okay. So he was doing a He worked three Okay. : So I conducted the 10:00 by : And you actually went every inmate? : Yes. And we want to show the EFTA00117700 233 1 the SHU. And then I'll tell you what the total 2 number is in this count. On this page it'll 3 say 75. And it looks like this was beforehand. 4 And then at the end, you're going to see that 5 actual count slips and I'm going to ask you - 6 you know who was on the count slip that you 7 filled out and who else was on there with you. 8 MS. : Okay. 9 MR. : In this instance I 10 believe it's on the second-to-last page. So 11 that you don't have to flip through all this. 12 But you can let me know if that's accurate. So 13 sorry. It looks like that one was the 4:00 14 p.m. and I believe this one is the 10:00 p.m. 15 MS. IIII: So let me (Indiscernible 16 *02:47:46). 17 MS. GREGG: You went (Indiscernible 18 *02:47:49 12221 __ 19 MR. IIIIIIIIII: This the 10:00 p.m. 20 MS. GREGG: Right? 21 MS. IIII: Mm-hmm. 22 MS. GREGG: When you call into the 23 control, this is how they determine that your 24 count matches their learning base count. 25 Right? So ZA is 9 South, ZB is 10 South. 234 1 MS. IIII: Okay. 2 MS. GREGG: They match. This is all of 3 our counts. Right. And then what they do is - 4 this is at the handwritten outcount from 5 employee. This is what they (Indiscernible 6 *02:48:16 entry. 7 MS. Mm-hmm. 8 MS. GREGG: This is what's keeping this 9 entry and it reflects on here. These are the 10 outcount areas an inmate could be. Right? So 11 5 South's count was 75. Their unit count is 12 78, three_2t2ple were in food service. 13 MS. IIII: Okay. 14 MS. GREGG: So when they actually counted 15 living, breathing bodies, they only had 75. 16 MS. IIII: Right. 17 MS. GREGG: So now just apply that to SHU. 18 This is your SHU count. You had a one inmate 19 outcounted to attorney conference. 20 MS. IIII: Okay. 21 MS. GREGG: Right? So you come down 22 here's one. So the actual count - the total 23 count that's supposed to be there is this 24 number. This is the inmate outcounted. And 25 this is what whoever counted called in. 235 1 MS. Mm-hmm. 2 MS. GREGG: Or should have called in. 3 MS. Mm-hmm. 4 MS. GREGG: That number is supposed to 5 match ... these are all outcounts. That number 6 is supposed to correspond with these count 7 slips for our respective housing unit. 8 MS. IIII: Okay. 9 MS. GREGG: Right? And then I guess she's 10 asking you to review your respective -. Tell 11 me if 12 MR. : Yep. 13 MS. GREGG: Review your respective count 14 slip for your unit on your shift. And then I 15 guess you wanted to confirm signature on the -? 16 MR. : Sure. I just wanted to 17 see the second. So one page back, that second- 18 to-last page, can you just find if there's a 19 count slip that you created or you signed in 20 there? 21 MS. IIII: I see here it says -. It has 22 my name on it. And it says 4:00 p.m. count. I 23 don't recall at 4:00. 24 MR. : Does that look like your 25 signature or your handwriting? 1 2 3 4 S 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 236 MS. : Where the is - no. MR. How about your signature? MS. : The signature looks like my signature. But where the IIII is - no. But I don't recall doing. I may have done the 4:00. I don't recall. But I know I did 10:00. MR. Alright. So you don't recall if ou did the 4:00 p.m. or not? MS. : I don't recall. MR. You can only recall doing the 10:00. And is that because you said you did it by ourself? MS. : Self. Yes. MR. : Do you believe you did the 4:00 MS. MR. MS. MR. : I don't remember. You don't recall. I don't remember. Alright. What is the number that's listed on there? On that count? MS. 75. MR. And that is your actual signature? MS. MR. : Alright. And it says 75? EFTA00117701 237 238 1 MS. : Yes. 2 MR. : Okay. What is there on 3 the first page. what does it say that the 4 number is? And that's the count for the SHU. 5 MS. 75. 6 MR. 75. Okay. So your 7 signature. 8 4:00 p.m. 9 MS. : I don't recall. 10 MR. Alright. And I'm sure 11 that in preparation for this did you discuss at 12 all or review or kind of - you know at two 13 years now, did I do that 4:00 p.m. count or 14 not? No? 15 MS. 16 MR. Okay. Do you remember 17 who called in that number? 18 MS. : No. 19 MR. : No. Alright. That's 20 fine. Now the 10:00 p.m. count is next to you. 21 MR. Silt here. 22 MR. : Can you do the same 23 thing? Co to that last page. it could 24 potentially be on the last page or potentially 25 the second-to-last. You're going to look for You're claiming you can't recall 239 1 out? I know it's your signature. But you said 2 it didn't look like your handwriting. But for 3 the 4:00 p.m. now we're talking about. I'm 4 just reverting back. Do you know who actually 5 completed that count slip? 6 MS. IIII: The count slip? Who filled it 7 out? I don't recall. 8 MR. No? But it was you and 9 that were on it? 10 MS. IIII: Just me and that's on 11 there. 12 MR. And this didn't look like 13 your handwriting? 14 MS. IIII: For the - no. For the 15 signature. 16 MR. : Right. For the - and I 17 think you're looking at the 10:00 right now. 18 I'm just reverting back to the 4:00. That 19 doesn't look like your handwriting as far as 20 counting out? It just looks like your 21 signature on it? 22 MS. : Yes. 23 MR. And you simply just don't 24 recall if ou did or did not do that count? 25 MS. IIII: I don't remember. 1 anything you recall, you signed, 2 documented. 3 MR. FOY: 4 *02:51:16 . 5 MS. 6 MR. 7 that you 8 MS. 9 MR. 10 apologize. Let 11 Who else was on 12 4:00 p.m.? 13 MS. 14 MR. 15 signed that one? Or you? 16 MS. : According to the sheet. 17 MR. : Do you know if they were 18 prepopulated? The 4:00 p.m. is that also how 19 you did the rounds? Did you also prepopulate 20 the count slips? 21 MS. IIII: On the midnight to 8:00. But 22 not on -. 23 MR. 24 MS. 25 MR. or you Look at (Indiscernible Here. Okay. Is there somewhere you signed on that? Yes. On the bottom. And who was - and I do me before I even go to that. the count slip with you on the Alright. Not that one? No, not on this one. Do you know who filled it 240 1 MR. Alright. The 10:00 p.m. 2 now we're looking at. Who was on that with 3 you? 4 MS. : Me and 5 MR. And who - can you tell by 6 looking at the handwriting who filled that out? 7 MS. IIII: I don't remember. But I 8 signed. And I know -. 9 MR. Does that look like your 10 handwritin that filled it out? Can you tell? 11 MS. No. 12 MR. : You're not able to 13 identify our handwriting? 14 MS. IIII: No. I'm saying this doesn't 15 look like my handwriting. But that's my 16 signature. 17 MR. : Oh that's your signature. 18 But it doesn't look like you actually completed 19 the slip. I'm asking did you complete that 20 slip? 21 MS. IIII: Yeah. I don't -. And this is 22 right here. The 73, I wrote that. But 10:00, 23 I don't write m numbers like this. 24 MR. : Okay. 25 MS. : So. Yeah. I don't put the So he EFTA00117702 241 242 1 zero-zero in a cross. So I don't. 2 MR. : Is that the (Indiscernible 3 *02:53:11 ? 4 MR. Is there anything next to 5 73 on that? 6 MS. I ut plus one. 7 MR. • What is that for? 8 MS. I don't remember. 9 MR. You don't know why you 10 put 73 plus one? 11 MS. : I don't remember. 12 MR. : Is that abnormal to write 13 73 plus one? 14 MS. IIII: I don't even know they there's 15 a plus one on there. 16 MR. : But you wrote 73 and 17 somebody else may have put the plus one? 18 MS. IIII: I don't remember. But the 73 19 is mine. 20 MR. : Okay. And you don't know 21 what plus one would mean? 22 MS. : No. 23 MR. : Alright. And then what 24 is the first page say - that the institution 25 counts were then for ZA? 1 MS. : 73. 2 MR. : 73? Alright. So again, 3 that plus one you're not sure. 4 MS. : No. 5 MR. : And now can you just 6 explain to me -. You said you do specifically 7 recall conducting that count? 8 MS. : 10:00 yes. 9 MR. : And you actually went 10 through and counted all of the inmates? 11 MS. : Every inmate. 12 MR. On ever tier? 13 MS. 14 MR. 15 count sli 16 MS. •: 17 to 8:00 in the 18 MR. 19 MS. 20 MR. 21 prepopulated? 22 MS. : No. 23 MR. You did that after you 24 conducted the count? 25 MS. IIII: Yes. But it was a prepopulated No. That was for the midnight morning. . Alright. We filled it out before. So 10:00 p.m. wasn't 1 MR. 2 another CO. 3 MS. 4 MR. 5 was supposed to have done it with you? 6 MS. 7 MR. And did sign it 8 even thou h he didn't? 9 MS. : Yes. 10 MR. • And did you have any 11 discussions with him at that time? 12 MS. IIII: He was tired. He was on a 13 triple. 14 MR. 15 say to you? 16 MS. : He was tired. 17 MR. Did he leave then? 18 MS. 19 MR. : Or did he just stand 20 there and watch you do it? 21 MS. : No. He was asleep. 22 MR. : He slept? Alright. So 23 he was slee ing when that was conducted? 24 MS. : Yes. 25 MR. : Okay. Do you know how 243 Alright. But not with And who was the CO that Okay. And what did he 244 1 long he s122I for? 2 MS. IIII: Until it was time for him to go 3 home. 4 MR. So like 10:00 to 12:00? 5 MS. roximately. 6 MR. Okay. But you're certain 7 you conducted that count? 8 MS. : Absolutely. 9 MR. : Okay. And are you 10 confident that that number is correct? 11 MS. : What the 73? 12 MR. Yep. 13 MS. 14 MR. Alright. Now let's show 15 the 12:00 a.m. Does this go there? 16 MR. : It's (Indiscernible 17 *02:55:07) 18 MR. Alright. So before we -. 19 I guess first, can you go to the back of the 20 thing and see the counts? Find the count slip? 21 Can you find if -. Are you on there? 22 MR. : Check the last page. 23 MS. : Yes. 24 MR. : And is this the one you 25 said you prepopulated? EFTA00117703 245 246 1 2 MS. .-. Yes. MR. : Okay. And did you fill 3 that count slip out? 4 MS. 5 MR. did? 6 MS. 7 MR. : And you signed it? 8 MS. 9 MR. So is the one that 10 prepopulated it? 11 MS. IIII: Yeah. We filled all of them 12 out. 13 MR. : Oh you filled out all but 14 three? 15 MS. IIII: Yeah. He wrote and I signed. 16 All. 17 MR. : Alright. So the 12 and 18 the 3 and the 5, you did it all at once? 19 MS. 20 MR. : Alright. And then what 21 number is written on there? 22 MS. M. 23 MR. : Now look at that first 24 page. What number is written on there? 25 MS. IIII: 72. 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 MR. : Alright. So what happened with that? MS. 11.1on't remember. MR. : At what point did an inmate di122pear? MS. IIII: I don't remember. I called in 73. MR. : If you called in 73, did you actuall count 73 people? MS. Well we didn't count at 12:00. MR. : I know but at 10:00 you did you MS. Did. Yes. MR. : So at 10:00 you did. But there's only 72 people there at 10:00. So did you actually do the count at 10:00? Did you call - dictylm actually count the inmates? MS. IIII: I actually counted all the inmates at 10:00. Absolutely counted all. MR. : And you counted at 73 of them. MS. IIII: I actually counted all the inmates at 10:00. MR. : So where did the one inmate go? 247 1 MS. : I don't know. 2 MR. : Do you remember any 3 inmate being removed from the SHU after 10:00 4 p.m.? 5 MS. : N 6 MR. : Alright. Can you show 7 her this count? Here's the 3:00 a.m. count. 8 Can you see that top sheet right there? Can 9 you find ZA? How many - what number is it on 10 that? 11 MS. : 72. 12 MR. : Alright. So 72 again on 13 that. That's the institution count. That's 14 how many people are actually in the SHU. What 15 does it sa on the count slip? 16 MS. : 72. 17 MR. : 72. So what happened 18 between 10:00 and 3:00? 19 MS. IIII: Why the numbers are -? I don't 20 know. 21 MR. Why are the number 22 different? 23 MS. IIII: I don't remember. 24 MS. GREGG: Let me see this again? 25 MS. IIII: Yeah. 248 1 MS. GREGG: It's in the (Indiscernible 2 *02:57:402a________ 3 MR. IIIIIIIIII: And I don't dispute that 4 maybe you did a round at 10:00. Are you sure 5 you did a count at -? 6 MS. : No. I did a count at 10:00. 7 MR. : You counted all the 8 inmates and it added up to 73. 9 MS. IIII: Because that's what on the -. 10 I wrote 73. 11 MR. : Right. And then if you 12 notice you wrote 73 a22.1Li2t 12:00. 13 MS. : That wrote it at -- 14 MR. : But there's actually 72. 15 MS. : 12:00 and then on the front 16 it says 72. But then the count -. But then if 17 the numbers didn't match, the count wouldn't 18 have cleared. 19 MR. : And that's what I'm going 20 to ask you. Did you have any conversations? 21 MS. 22 MR. : So here's the 5:00 a.m. 23 and this one also says 72 for the official 24 count. And I believe you guys wrote 72. So 25 did you discuss this with anybody that the EFTA00117704 249 250 1 counts were off? 2 MS. : Uh, no. I think 3 discussed. was on the phone with -. 4 Because the count wouldn't have cleared if it 5 said 72 and 73. So I think had a 6 conversation. But I didn't have a conversation 7 with anybod 8 MR. Did you have a 9 conversation with with regard to the 10 count bein off? 11 MS. : No. 12 MR. So if you did all the 13 prepopulating at 12:00, why does the 12:00 say 14 73 and the other two say 72 and 72? 15 MS. IIII: Because on the -. I remember 16 at the other one, had the count slips 17 all and I couldn't find - I couldn't find the 18 count slip. And I remember I rewrote it. But 19 as far as why the count changed to 72, I don't 20 remember 21 MR. : Well I can tell you why. 22 Because the count was off. 23 MS. : Mm. 24 MR. : So that's what I'm 25 asking. If you actually did that 10:00 p.m. 1 count, how did you get 73? 2 MS. : I don't know. 3 MR. But you're sure you 4 counted 73? 5 MS. I absolutely counted at 10:00. 6 MR. 7 10:00. 8 MS. IIII: No. I mean, I remember I 9 counted by myself. And I (Indiscernible 10 *02:59:23) counted with somebody and 11 compared the numbers. But I counted 12 MR. • Could have you 13 mistaken during your count? 14 MS. Probably. 15 MR. Do you believe that you 16 were probabl mistaken? 17 MS. : Probably. 18 MR. Okay. So you're certain 19 you conducted the count. 20 MS. : Yes. 21 MR. : But you think you 22 probably Lilt counted wrong? 23 MS. fl: Wrong. Maybe. Because it's 72 24 after. 25 MR. Okay. And you went But no inmates left after we at 10:00. been 251 1 through and you -. Tell me how a count works. 2 Do you add them up? 3 MS. IIII: Yes. Like I write it. Like K 4 Tier. And then I write it. L Tier and then I 5 write it. And then we add it up. 6 MR. : Alright. Do you want to 7 follow-up with that at all? 8 MR. : Do you recall that night that 9 during your evening shift? 10 MS. Mm-hmm. 11 MR. : So let's say from when you 12 came on from 4:00 p.m. Or did you come on at 13 2:00 p.m.? Mat you said. 14 S. 4:00. 15 MR. : 4:00 to midnight. Were there 16 any inmates removed from the SHU? 17 MS. : When I came on? 18 MR. : Yeah. 19 MS. Not that I know of. 20 MR. : If there were inmates removed 21 from the SHU, would you have been aware of it? 22 MS. I mean if I was there. Yes. 23 MR. : Do you recall -? And so you 24 don't -. Do you recall two inmates -? 25 MS. IIII: Going to suicide watch. Yes. 252 1 MR. : Do you recall about that? 2 MS. : Yes. 3 MR. : What happened with that? 4 MS. : Um.... I'm not really sure 5 because I remember told me. But I 6 remember the two inmates didn't go to suicide 7 watch but I don't recall as far as 8 (Indiscernible *03:00:58). 9 MR. : Did that happen during your 10 shift? Or did it happen before your shift? 11 MS. iDuring. 12 MR. : During your shift. Was that 13 after the 4:00 p.m. count? 14 MS. IIII: I don't -. I think if I would 15 have been after 4:00 p.m. because I came in at 16 4:00. 17 MR. : Okay. 18 MR. : If you look at 19 on the 4:00 p.m. count, does it - is 20 correct? 21 MS. 22 MR. 23 MR. 24 MS. 25 MR. the numbers it • (Indiscernible *03:01:12) It says 75. FOY: I don't think that's 4:00 p.m. : No. • It's at the bottom of page EFTA00117705 253 1 five. 2 MR. It's just -. 3 MS. Yes. 4 MR. Look at the time on the 5 bottom. 6 MS. : Yeah. 7 MR. : You'll be able to figure 8 it out. 9 MS. : It says 75. 10 MR. : And then two people went 11 to suicide 'hatch. Correct? 12 MS. . Correct. 13 MR. Alright. But no one else 14 left the SHU. Correct? 15 MS. : No. 16 MR. : So that's what we're 17 saying. Somewhere between 4:00 p.m. and 3:00 18 a.m., either an inmate went missing or the 19 counts weren't conducted or they were off. 20 MS. : The counts was off. 21 MR. : They were off. But if 22 your job was actually to count the inmates, how 23 were they off? Usually what you're saying is 24 you're just taking the number. You're 25 prepopulating this a lot of times saying what 254 1 number you believe it's supposed to be in 2 there. But if you actually conducted the 3 counts, you would actually know that there was 4 only 72. Correct? 5 MS. : I counted. 6 MR. : But you couldn't have 7 counted 73 because - 8 MS. IIII: Well I maybe -. That's what 9 I'm saying. Maybe there's where the error is. 10 But I counted. 11 MS. GREGG: No. See at 4:00 count. 12 MR. You counted but you 13 counted was. Is -. 14 MS. Yes, that's what I'm saying. 15 Because I absolutely counted. Because I 16 remember was tired. He was on a 17 triple and he was falling asleep. 18 MR. : Again, and I'm not saying 19 you didn't conduct a round -- 20 MS. : And then I went. 21 MR. : I'm asking if you 22 conducted a count. 23 MS. : And I went and I counted. 24 MR. Okay. And you're 25 positive of that? 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 255 MS. : That I counted? MR. Yep. MS. Yes. MR. . Okay. MS. : But the number could have been off. But I counted. MR. Okay. And that's why -. MS. : Because if I was counting with somebody. If I would have said 73, he would have counted and he would have got 72. That's why you'viiiiiiiiliount with two people. MR. : Sure. And at the 12:00 a.m. you said you remember speaking to someone -- MS. : On the phone. MR. who? MS. MR. • -- but you don't know • And did you have any conversations with at that time? MS. IIII: No. Except for he changed the count sli and I signed. MR. : He changed which count slip? MS. IIII: The one that has 72 on there. 256 1 MR. So he changed the 3:00 2 a.m. and the 5:00 a.m. at that time? 3 MS. IIII: He changed one of the count 4 slips and then I was looking of for the other 5 one and I couldn't find it. And then I did -. 6 I remember. I filled out one. 7 MR. : But if you -. So you're 8 saying -. I thought you said at 12:00 a.m. you 9 prepopulated all the count slips. 10 11 12 13 14 15 16 17 18 submitted and then he talked to you and then -? 19 MS. IIII: Well I believe that because 20 then it would have been - when it got submitted 21 it would have been that the count wouldn't have 22 cleared. It would have been off. So then it 23 would have been (Indiscernible *03:03:45). It 24 would have been had to have been changed. 25 MR. Okay. The count slip MS. : We did. MR. says 73. MS. : : Yes. So - but the 12:00 a.m. MR. say 72. MS. : : Ri ht. And the 3:00 and the 5:00 MR. : So is the 72 that was EFTA00117706 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 257 would have had to have changed is what you're saying. MS. : Yes. MR. : Is that the time -? MS. : If the count doesn't match what's on here, then it would have had to have been chaniii MR. iiiiii : If a count is off, like it was -. MS. Mm-hmm. MR. : What happens? MS. You redo the count slip. And redo the count. MR. In this case do you recall them telling you to redo the count? MS. : No. MR. : No. And did say that hey I just spoke to the lieutenant and they said to redo the count? MS. MR. MS. MR. : No. No? Hm-mm. Do you remember redoing that slip that says 73 whereas the institution count says 72? 258 1 MS. : Let me see. 2 MR. : Because I just want to 3 make sure because the video shows that no 4 counts were done at 10:00. I mean unless 5 you're just -. 6 MS. IIII: I saw that also in the 7 indictment. But I did count at 10:00. 8 MR. : And this is again part of 9 that whole under oath thing because there was 10 only 72 people on there. So if you're saying 11 you did the count, I just want to reconcile 12 that now before we have a potential problem in 13 the future. 14 MR. 15 you with 16 MS. 17 MR. 18 MS. 19 MR. 20 one? 21 MS. IIII: 22 that. 23 MR. 24 handwritiiiiiiihe plus one? 25 MR. : I don't know. : So never assisted the 10:00 p.m. count right? : No. : So you wrote 73 plus one. I wrote 73. : So you don't recall the plus The plus one, no I don't recall Does that look like your 259 1 MR. : You don't know. And when 2 did sign that? Would it have been 3 before he went to sleep? 4 MS. : Yes. 5 MR. : Would it have been much 6 before 10:00? 7 MS. IIII: I don't remember the exact 8 timeframe. 9 MR. When you wrote that count 10 slip, was the time accurate to when you 11 conducted the count? 12 MS. IIII: Yeah because you count at 13 10:00. 14 MR. : Okay. So the time that - 15 is there a time reflected on -- 16 MS. : But -. 17 MR. • -- the actual count slip? 18 MS. Yes. It says 10:00. 19 MR. : Alright. So if around 20 that time, he would have just signed it and you 21 went up. 22 MS. : And I went up. 23 MR. : And you actually did the 24 count. Not a round. But you did a count. 25 MS. IIII: I counted. 260 1 MR. Okay. And you just have 2 no explanation for why the count is off? 3 MS. IIII: You can miscount. So I'm not 4 saying that the number couldn't have been off. 5 But as far as the count, like I counted. It 6 could have been a miscount but I counted. 7 MR. : Alright. I've got a follow- 8 Do you recall an inmate being moved to dry 9 thatilight? 10 MS. IIII: Dry cell. No. 11 MR. FOY: Do you know what that is? 12 MS. IIII: Yes. 13 MR. FOY: Okay. 14 MR. : Do you remember an inmate 15 named Fernandez? 16 MS. No. 17 MR. : You don't recall. During 18 your shift. The inmate wasn't moved? 19 20 MS. B i No. I don't MR. : If an inmate was moved to -. 21 another cell. Let's just say dry cell. Where 22 is dry cell located? 23 MS. : I don't know. 24 MR. : Is it in - you know where R&D 25 is ? up. cell EFTA00117707 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 MS. MR. MS. : Yes. : Is it in R&D? I don't know. 261 MR. : Have you -? Okay. If an inmate was moved to R&D, would you still include the inmate as part of your count? MS. IIII: If the inmate was moved, I would think they'd be on the outcount. I'm not sure. MR. : But you wouldn't include because you can't see the inmate. MS. IIII: Right. They'd be on the outcount. MR. : Yeah. You only count the people that are physically present. MR. IIIIIIiiihresent. MR. : Right. And that's what number goes on that count slip. MS. • Count slip. MR. Right. MR. : Do you recall any instances of why anyone would write plus one? What was that plus one? We've been trying to figure out what the LI one is. MS. IIII: Plus one. I don't know. 262 1 MR. Yeah. I'm more concerned 2 with the 73 when there was only 72 people. Now 3 I'm not going to doubt that you counted at 4 least one tier. You counted all six tiers? 5 MS. : Yes. 6 MR. : And you added those up 7 and it equaled 73? 8 MS. : That's what I have on here. 9 MR. : Do you remember? I mean 10 I know you have that on there. But that's what 11 I'm saying. That's inaccurate. So I'm trying 12 to - 13 MS. : But I don't -. 14 MR. : I'm trying to reconcile 15 that. 16 MS. IIII: But see I don't remember that 17 at this point. Like I mean I wrote 73. I 18 counted. I remember having a 19 conversation. the number was switched to 72 20 but I don't remember like physically like 21 adding it up like I don't remember that. And 22 again, maybe I miscounted because I counted by 23 myself. This was before. But at 12:00 -. 24 MR. : And being that 25 signed before you did the count, do you think 263 1 you prepopi212ted that? And then counted? 2 MS. IIII: I could have been. I don't 3 remember. 4 MR. : So you may have written 5 the slip first and then counted? 6 MS. : I don't remember at this point. 7 MR. : Okay. But at the 12:00 8 a.m. count when you guys were told this count 9 is off, you didn't then go as you should have 10 recount. 11 MS. 12 MR. : And you do understand 13 that if a count's off you're supposed to do a 14 recount? Correct? 15 MS. : Recount. 16 MR. : Alright. So the 12:00 17 a.m. there's not dispute. The 12:00 a.m., the 18 3:00 a.m., and the 5:00 a.m. you guys didn't do 19 it. 20 MS. : Correct. 21 MR. : And you both signed those 22 slips knowing that the counts weren't done. 23 10:00 you're claiming that you did. You don't 24 know when you filled out the slip and you don't 25 know why it's inaccurate. 264 1 MS. : Ri ht. 2 MR. : And the 4:00 p.m. you're 3 just saying_you don't remember. 4 MS. IIII: The 4:00 yes. 5 MS. GREGG: Can I see the 10:00? 6 MR. : So you don't remember if 7 it was conducted or if it wasn't conducted. 8 MS. IIII: Well the 4:00 would have been 9 conducted because we feed at that time. 10 MR. Well that's not a count 11 though. Again, I'm talking -. I don't want to 12 say - 13 MS. : Like a -. 14 MR. : I want to make sure that 15 we're - 16 MR. Right but I don't 17 remember physically at 4:00 counting. I don't 18 remember. 19 MR. : Okay. So you don't 20 recall counting. You know that you did people 21 at 4:00. 22 MS. : Ri ht. 23 MR. : So that would be what you 24 call a round. 25 MS. IIII: Right EFTA00117708 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 265 MR. : What you classify your understandin of a round. But the count. MS. Ri ht. I don't recall. MR. : You don't recall conductin the 4:00 p.m.? MS. No. I counted -. MR. : Do you believe that you did conduct a count at 4:00 p.m.? MS. I don't know. MR. MS. MR. MS. : So you just can't recall. I don't remember. : Okay. I counted at 3:00 and 5:00 upstairs. MS. GREGG: That's incorrect at 10:00. MR. : In 10 South? MS. : Yes. MR. : Alright. MS. GREGG: Right? So this -. MR. : So you - is it safe to say that you did the feed, which you classified as a round but you didn't count at 4:00 p.m.? MS. know. MR. : You don't know. Okay. We're going to just move on. 266 1 MR. FOY: Let me do this real quick. I 2 just want to try to clarify this. Let me 3 because this is something we haven't discussed 4 in advance. 5 MR. : Of course. 6 MR. FOY: Because I didn't know there was 7 an off on the number. 8 MS. IIII: I didn't even remember that. 9 MR. FOY: Alright. So we can take this 10 out with plailLjaak on it real quick? 11 MR. IIIIIIIIII: Ah... 12 MR. FOY: want to keep it in here? 13 MR. : How about we leave and 14 let you discuss it in here? 15 MR. That's fine. 16 MR. : Does that work? 17 MR. FOY: Yeah. That's fine. 18 MR. : Just because I don't 19 really want to have documents removed. 20 MR. FOY: Yeah-yeah, okay. 21 MR. : Alright. So it's 1:38 22 m. This is Senior Special Agent 23 and I am pausing the recording. 24 [Whereupon, the above-entitled matter went off 25 the record and went back on the record.] The 267 1 recorder is back on. It is currentl 1:46 .m. 2 This is Senior Special Agent 3 I'm just reminding you Ms. you are under 4 oath and this is a voluntary interview. Thank 5 you again for your cooperation. So when we 6 took a break, is there anything that you wanted 7 to add from the last thing we were talking 8 about? The difference between the 4:00, the 9 10:00, and the 12:00, and the different 10 numbers. 11 MS. IIII: On the plus one. I don't know 12 where the plus one came from. I absolutely 13 counted at 10:00. I don't know why is there a 14 plus one. And then when the number changed, 15 like there's something that's sometimes it's 16 called like a ghost count. I don't know. I 17 don't remember if that's what happened. So 18 whereas, control will call you and say, put it 19 as a ghost count. So the inmate is not 20 physically there but they know there the inmate 21 is. Because they didn't redo the count sheet. 22 So that's the only thing I can think of - the 23 ghost count. 24 MR. : I could think it may be a 25 ghost count for the plus one. But if you're 268 1 writing the numbers and it's supposed to be -. 2 I mean when 3 MS. IIII: No. I'm talking about for the 4 73 and then how it changed to 72. As far as 5 the plus one, I don't know about the plus one. 6 I'm talkiiiiiiiiiiihe 73. 7 MR. : But when you do a count, 8 that you list on it, isn't it the physical 9 inmates that are there? 10 MS. : Yes. 11 MR. : You can't ever say that - 12 you can't list somebody that is not there on 13 that count. Correct? 14 MS. : Correct. 15 MR. : Right. So you see? 16 MS. : No but what I'm saying. Okay. 17 Like I'm like I said, I really don't remember, 18 but let's say if I counted 72. And they said 19 ghost count John. And I put 73. As far as the 20 plus one, I don't know. And I put 73 because 21 they know where the inmate is. And then after 22 for the next count they fixed the roster. 23 Because that's why it's called a ghost count 24 because they didn't move to where the person is 25 supposed to be. And then they fix it on the EFTA00117709 269 1 next one. That could have been how the count 2 went down in 72. But as far as the plus one, I 3 don't know where the plus one went. 4 MR. Alright. So who was in 5 the SHU at 10:00 p.m. when you conduct this 6 count? 7 MS. Me and 8 MR. Just the two of you? 9 MS. Yes. 10 MR. He's sleeping. 11 MS. Yes. 12 MR. What conversations did 13 you have with anybody about that count? 14 MS. IIII: That's what I'm saying. I 15 don't recall. That's the only thing that could 16 have happened. But I don't recall. 17 MR. : But if they told you to 18 do that at 10:00 p.m. as you just noticed, at 19 12:00 a.m., the count - that's when they catch 20 that the counts are wrong. 21 MS. : Ri ht. 22 MR. : So if I told you that -. 23 MS. : Well not at that time at the 12 24 time. I'm saying like when it changed from - 25 I'm not looking at the time but when it changed 270 1 from the 72 to the 72 at that time. 2 MR. : Right. So no inmate was 3 removed from the SHU after 10:00 p.m.? 4 MS. : No. 5 MR. : There's only 72 inmates 6 in the SHU at 10:00 p.m. 7 MS. IIII: I don't - as far as the numbers 8 go, I don't remember accurately the numbers, 9 but no inmate moved. 10 MR. Right. 11 MS. There was no movement. 12 MR. And that's just where 13 we're just trying to get to this. If you're 14 swearing up and down, you know under oath, I 15 conducted this count. 16 MS. : I did. 17 MR. : But there's only 72 18 people there. At 12:00 a.m., that's when the 19 lieutenant catches. Hey guys, there's only 72 20 people in there. You've got to redo this count 21 and give me a new count slip. When did - when 22 did this happen? 23 MR. FOY: Let me just say something on 24 here it says that at 10:00. I'm looking at the 25 10:00 that it was 73 on the outside. 271 1 MR. Correct. 2 MR. FOY: Right, so the control and her 3 slip matches. 4 MR. 5 the number -- 6 MR. FOY: Ri ht. 7 MR. : -- and right. So she's 8 calling in because somewhere before 10:00 p.m., 9 an inmate wasn't removed from the list. 10 MR. FOY: Ri ht. 11 MR. : Although they were not 12 present in the SHU. So if they're doing a 13 count -- 14 MR. FOY: Mm-hmm. 15 MR. : -- that's where it's 16 supposed to say that's the actual number that's 17 in here. 18 MR. Sit. 19 MR. : And at that point, 20 control would say we have 73. Where is the 21 problem here? But she called in 73 -. 22 MR. FOY: Ri ht. 23 MR. : Or yeah instead of the 24 72. 25 MR. FOY: Right. Right. So she calls in 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 272 MR. So you're right. The master list is off but so is the count slip. The count slip is provided first. MS. GREGG: But they're not off, right? Technically, at 10:00, the master list is that front page. MR. : The master list is wrong. MS. GREGG: It said 73. MR. : Correct. MS. GREGG: So there may be something you know that vie don't. MR. : Oh we've already talked to hundreds of people about this. MS. GREGG: I'm sure. MR. : So that's where - I mean not hundreds - by you know what I mean. MS. GREGG: A few people. MR. : A lot of people. So this is where we're just asking the only person that was there that was actually. You know the other guy was sleeping. There's only one person physically present in there. MS. GREGG: Mm-hmm. MR. And that was you Ms. EFTA00117710 273 1 MS. : Yes. 2 MR. : So that's why we're 3 asking you. Everyone else clear as day says 4 well it just shows - it's just proof that the 5 count wasn't conducted. That's what everybody 6 else says all the way up to the highest of 7 levels. So that's why if you're saying that 8 the count was conducted, you're just saying -- 9 MS. : I did do the count. 10 MR. : -- you just counted 11 wrong. 12 MS. IIII: I did do the count. 13 MS. GREGG: So I get -. And I'm asking 14 this because I think if we're confused, Ms. 15 is - might be confused. Correct me if I'm 16 wrong. 17 MS. IIII: Right. Like because I didn't 18 even -. 19 MS. GREGG: If she - if the employee - 20 let's use a simple number for the sake of it. 21 Right. I'm an employee. I count 4 living 22 breathing bodies on Unit A. 23 MR. : Mm-hmm. 24 MS. GREGG: And then I call you who is 25 located eight floors downstairs and I say I 274 1 have four bodies on Unit A and you say to me, 2 Ms. Gregg.L_IllatIll. good count. Right? 3 MR. IIIIIIIIII: Mm-hmm. 4 MS. GREGG: That's what these documents 5 imply took place. Because the front page is 6 prepared by a completely different person in a 7 completely different area. 8 MR. : Exactly. So what these 9 documents actually imply is that the 10 institution count showed that there were 73 11 people in there. 12 MS. GREGG: Yes. 13 MR. : There were only 72 people 14 in there. So what they imply is that the count 15 wasn't conducted. Because there were only 72 16 people in there and it was just based on the 17 number that should have been based upon the 18 system. The system showed there were 73, so 19 they wrote 73 on the slip. That's what the 20 documentation implies. 21 MS. GREGG: I get that (Indiscernible 22 *03:16:28 wron . 23 MR. : However, there were only 24 72 people in there. 25 MS. GREGG: Now I understand what you're 275 1 saying. 2 MR. So that's why I'm asking. 3 It's hard for me to get past this question if 4 you're sa in yes I counted 73 -- 5 MS. : I did. 6 MR. : -- bodies when there were 7 only 72 bodies in there. 8 MS. IIII: No. I absolutely counted. As 9 far as the number, like I said, in remembering 10 how much bodies I counted, but I counted. 11 MR. So you counted, you just 12 didn't -. 13 MS. : The count may have been off. 14 MR. : You didn't maybe have the 15 numbers u 16 MS. Ri ht or it was -. 17 MR. : And that's why I wanted 18 to make sure the difference between a round and 19 a count. 20 MS. : No. I counted. 21 MR. : You counted but -? 22 MS. : And the reason why that always 23 stood out to me because I remember he was on a 24 triple and he said he was tired. And I 25 counted. 276 1 MR. So just give me a little 2 more information on what you're just saying. 3 You know ya_counted but what? 4 MS. IIII: No. I'm saying I know I 5 absolutely counted. And that always stood out 6 to me because I remember he was on a triple and 7 he was tired. 8 MR. : Sure. 9 MS. : And I counted by myself which 10 I'm not supposed to. So I remember that. But 11 as far as the numbers go, I don't remember this 12 because I didn't even remember something about 13 a plus one until I seen the count slip. Like I 14 don't recall nothing about a plus one. 15 MR. : Right. 16 MS. : So as far as the numbers, I'm 17 not sure. But as far as counting, I absolutely 18 counted. 19 MR. Are you sure you counted 20 73? 21 MS. IIII: That's what I'm saying. As far 22 as the numbers go, I don't remember. But I 23 counted. 24 MR. : Let's see. You counted 25 what? So I mean what did you do with the EFTA00117711 277 278 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 numbers that you counted? MS. IIII: What I'm saying is, the count could have been off. But I'm just letting you know that I actually did count. As far as the actual number, that's where the discrepancy -- MR. MS. So -- -- comes in. MR. So did you count and then look at the - what the system showed was in there. And ou just decided -- MS. : I didn't -. MR. : -- to put what the system showed? MS. IIII: Because I don't know how to look for that. MR. You don't even know how to find -? MS. IIII: Look for the count in the system. No. MR. So where would you -? If you're prepopulating things, where do you get the numbers from in order to -? MS. IIII: When you come in, the person that you're relieving will be like I got 72 or I got 75. 1 MR. So someone who you 2 relieved would have told you that there were 3 73? 4 MS. : Correct. 5 MR. : Alright. And do you know 6 who would have told you that there were 73? 7 MS. : I don't know. 8 MR. : Would it have been 9 before he fell asleep? 10 MS. • I don't remember. 11 MR. : Alright. So again, just 12 help me try to understand if there's only 72 13 people in there, how you wrote 73 if you 14 counted? 15 MS. IIII: Again, that's what I'm saying. 16 I could have miscounted. I don't remember what 17 happened. As far as the actual number of the 18 count. I can only just tell you that I 19 counted. As far as the numbers go, I don't 20 remember. 21 MR. Right. So you counted 22 each tier. 23 MS. : Yes. 24 MR. And then you added each 25 of those counts up? 279 1 MS. IIII: Yes. I counted each tier. I 2 don't know if I added them up. But usually 3 when I'm counting, that's what I do. I write 4 it down, K Tier with the number, L Tier I put 5 the number, and I add them up. 6 MR. : Okay. 7 MS. : But if I miscounted, remember I 8 counted by myself. So if I miscounted, I would 9 have called control and I would have said 73. 10 They would have been like no, your count is 11 wrong. 12 MR. • Well that's the -. 13 MS. But on -. 14 MR. : It's weird that your 15 miscount just happened to show what the system 16 said that was what the system thought was in 17 there. 18 MS. : But at -. 19 MR. : That's where I'm having 20 difficulty because it's like the system says 21 73. So if you miscounted 73, and the system 22 said 73, but there's only 72, how are you 23 saying you actually counted? 24 MS. IIII: Bu there at 10:00, it's 73 on 25 here and it's 73 on here. 280 1 MR. Correct. Because that's 2 the - the institution count it off. 3 MS. : Ri ht but at -. 4 MR. : So -. 5 MS. : So - but I'm confused because 6 at 10 it says it's 73. 7 MR. FOY: But they're saying this is 8 wrong. This a er is wrong. 9 MR. : And it was caught at 10 midnight. 11 MS. IIII: Okay. But this is -. Well 12 then I don't know. I don't know. 13 MR. Do we want to continue on 14 this or kee wing? 15 MR. : Oh keep going. 16 MR. : Alright. So prior to 17 6:33 a.m. on August 10, 2019, when was the last 18 time that you conducted a round within the SHU? 19 Now we're talking about a round. 20 MS. IIII: I don't remember the time, but 21 I didn't conduct no round between 12:00 and the 22 12:00 to 8:00 shift. 23 MR. : So this - what we're 24 talking about - what you're calling a count 25 that you're saying would then that the last EFTA00117712 281 1 time be that you conducted either a round or a 2 count? 3 MS. : After 10:00. 4 MR. : Would that -? When we're 5 discussing at the 10:00 p.m.? Would have you 6 done something between then and 12:00? 7 MS. IIII: I don't remember. This is the 8 last that I remember with the count at 10:00. 9 MR. : So the last one that you 10 can recall is the one that we're discussing -- 11 MS. Yes. 12 MR. -- on the 10:00 p.m. 13 count? 14 MS. Yes. 15 MR. : Okay. So probably around 16 10:00 p.m. would have been the last. 17 MS. You can say that. 18 MR. : What time does that count 19 slip show? 20 MS. IIII: The count slips shows 10:00. On 21 here is sa s 10:30 p.m. 22 MR. : 10:30 p.m.? 23 MS. Mm-hmm. 24 MR. : Do you - no-no-no. 25 That's the institutional count. 282 1 MS. IIII: On the count slip, it says 2 10:00. It's always going to say that. Like 3 even if -. Like on the count slip, let's say 4 if I counted at 10:15, it's still going to say 5 10:00 because -- 6 MR. : Alright. 7 MS. -- it's the 10:00 count. 8 MR. : So -. 9 MS. So that's what I'm saying. A 10 round. 11 MR. : So this one -. I just 12 want you to try to kind of -. Because this 13 would have been if you actually conducted the 14 count and you actually looked at the people, 15 this would have been the last time you saw 16 Epstein. Correct? 17 MS. : Correct. 18 MR. : Alright. So I just want 19 you to consider that with all that's 20 surrounding this, you've got to kind of in your 21 mind think, "When is the las time that I saw 22 him?" 23 MS. : Mm-hmm. 24 MR. : Is this the last time you 25 can remember seeing him? 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 283 MS. MR. : Alright. So do you remember -? MS. : MR. MS. MR. Until the incident. • Right. Mm-hmm. • So would that - do you remember if that would have been at 10:00? A little after? A little bit before? And again, this is the last time you saw this big guy whose caused your life to flip upside down. MS. IIII: But I can't -. That's what I'm saying. MR. : But would he -. MR. : You just got to ballpark it. MR. : Okay. MS. : It's somewhere around after 10:00. MR. : So you just always write the time of the count. MS. IIII: Yeah. With the counts, even if -. Because remember, on the unit, you're waiting to count. So let's say you fill out the 10:00 slip. But let's say we didn't 284 1 actually go down range until 10:30. You don't 2 actually put 10:30. It's a 10:00 count. So 3 it's alwa s oin to say 10:00. 4 MR. : Okay. 5 MS. : So that's what I'm saying. 6 Just ball ark it. 7 MR. : So approximately 10:00 8 p.m. 9 MS. : Yes. Or after 10:00. 10 MR. : Okay. So on the round 11 sheet. Does that also say 10:00 p.m.? I mean 12 I know you said you prepopulated that one. But 13 what does that one say? And that's for August 14 9th. You already said August 10th, none of the 15 rounds were conducted. On August 9th, I guess 16 around the 10:00, you know that nothing after 17 10:00 was actually conducted on the round 18 sheet? 19 MS. : It has after 10:00 on here. 20 MR. Okay. So those ones. 21 Those ones from then on you know those weren't 22 conducted. 23 MS. IIII: Right. Remember I didn't fill 24 this out. 25 MR. You prepopulated it. EFTA00117713 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 285 Right. So I'm just - want to make sure we know that -- MS. • Yeah. MR. you conducted. MS. MR. ones you did. MS. MR. . -- you said some of them : Right. • You don't remember which Right. • But I just know that those ones weren't conducted. MR. : Right. MR. • After 10:00 p.m. MS. Ri ht. MR. Okay. Alright. So that last -. You're saying the last round and the count were one and the same. And was that an I authorized practice? Is a round and a count if you're doing a 10:00 p.m. count, does that also what you can document on the round sheet as something ou did at 10:00 p.m.? MS. : Yes. MR. : Okay. So they can overlap for that. MS. IIII: Yes. 1 MR. 2 present for any cell 3 SHU on either August 4 MS. : No. 286 Were any supervisors counts or rounds in the 9th or August 10, 2019? 5 MR. • No? Should any 6 supervisors have been present for any cell 7 counts or rounds in the SHU on August 9th or 8 August 10 2019? 9 MS. : No. 10 MR. : Is there a requirement -? 11 Or was there at that time that a supervisor - 12 every supervisor at least one per shift should 13 have conducted a round or a count with you guys 14 in the SHU? Not of you staff members, but of 15 the inmates? 16 MS. IIII: You're saying if the supervisor 17 should have did -? 18 MR. : Should a supervisor, you 19 know like a lieutenant -- 20 MS. : Mm-hmm. 21 MR. : -- observed or 22 participated in a round or a count of the 23 inmates during their shift? At least once? Do 24 you know of that? 25 MS. IIII: I think so. 287 1 MR. You think that they're 2 supposed to do that? 3 MS. : Yes. 4 MR. : And during your time in 5 the SHU, did a lieutenant ever participate or 6 observe a count or round while you were in the 7 SHU? 8 MS. did. 9 MR. did. 10 MS. did because she went 11 down on the tiers. But on the midnight to 12 8:00, Lieutenant didn't walk the 13 tiers. 14 MR. Okay. So when did 15 on August 9th, she actually walked the tiers 16 and checked -- 17 MS. . Yes she did. 18 MR. -- out the inmates? 19 MS. She did. 20 MR. She did? Okay. And 21 around would have that been? Do you remember? 22 MS. : I don't remember the time. 23 MR. : Did she do it by herself? 24 Or did she go with you guys while you were 25 conducting a round or a count? 288 1 MS. IIII: No. She didn't do anything 2 with us. 3 MR. So she did it by herself? 4 MS. Correct. 5 MR. She walked up and down 6 each of the six tiers? 7 MS. : She went down the tiers. 8 MR. : Do you know if that is a 9 requirement that a lieutenant does that in the 10 SHU? 11 MS. . I don't know. 12 MR. : Had you ever observed 13 anyone prior to August 9th - doing that? 14 MS. IIII: Observe a lieutenant going down 15 the tier? 16 MR. : Either do it themselves 17 the lieutenant do the round themselves - or 18 watch the staff members do it? 19 MS. IIII: Oh no, they never No they 20 never watch us do -. 21 MR. Never watched? Never 22 observed? 23 MS. 24 MR. Did they ever conduct it 25 with you? EFTA00117714 289 290 1 MS. : No. 2 MR. : But they would 3 occasional) it themselves? 4 MS. IIII: They'll make -. The 5 lieutenants will make a round. Yes. 6 MR. So not just pop into the 7 SHU, but the '11 actually go up and down the -? 8 MS. Yes. Some. Not all. 9 MR. Some? Alright. And 10 that's what I'm asking. Do you know if it's a 11 requirement that -? 12 MS. IIII: That I don't know if it's 13 required. 14 MR. So you don't know what 15 policy or -- 16 MS. IIII: I don't know what the 17 lieutenant -. 18 MR. -- rule or what they're 19 supposed to or not do? 20 MS. : What's supposed to do. 21 MR. : Alright. But that didn't 22 happen. Did that happen more often than not? 23 Or -? When they were actually doing a round 24 with the inmates. Lieutenants. 25 MS. IIII: If it happened that they walked 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 the tiers? MR. MS. MR. MS. Correct. Some of them do. Not all. Which ones would do it? . Lieutenant IIII was the SHU lieutenant so he walks the tiers all the time. MR. : Okay. MS. : And then the other lieutenants that's on, when they come, they sign the round sheets. MR. : But do they actually do rounds themselves? Or they just sign your sheet and check in with you? MS. IIII: They don't do it all the time. They sign the sheet. And they check in with me. And they'll say like is there anything going on. But they don't physically actually walk it all the time. MR. : Okay. So it's occasional) = MS. : Mm-hmm. MR. : Alright. But you don't - . Okay. MS. IIII: I don't know if it's a requirement. 1 MR. Alright. 2 you don't recall the 4:00 p.m. 3 You might not have. 4 MS. : I don't recall. 5 MR. : You just don't recall. 6 Alright. So 12:00 a.m., 3:00 a.m., 5:00 a.m. 7 We don't need to go into these specific things. 8 You said none of them were conducted. They 9 were false. You both signed them and submitted 10 them. Correct? 11 MS. : Correct. For the -. 12 MR. : And you knew that you - 13 and you knew that you had to do the count. You 14 just -. 15 MS. Yes. 16 MR. What conversations did 17 you have with about doing that? 18 MS. IIII: We didn't have a conversation. 19 He was exhausted and he was sleeping. 20 MR. 21 MS. Yes. 22 MR. So at 12:00 a.m. until -. 23 Because you said you filled them all out at 24 about 12:00? 25 MS. IIII: Yes. 291 You're saying You may have. 292 1 MR. And you didn't have a 2 conversation about filling them out at 12:00? 3 MS. IIII: No because we do that all the 4 time. Like when he came in, we filled them 5 out. And then, I think when the phone rang, he 6 had the conversation. And then there was 7 another time when I was looking of for the 8 counts slip, he had it and I couldn't find it. 9 So I had to like wake him up to resign the 10 count sli 11 MR. . : Now give me - can you 12 walk me through that? So he gets a call. You 13 already filled out the count slips. Was one 14 submitted? You put it through the door and 15 internal came and got it? 16 MS. : Yes. 17 MR. : And that's when they 18 called him back? 19 MS. IIII: And he spoke to whoever. And 20 then he wrote on the count slip. And we filled 21 it out. Ai,, t ic it back through the door. 22 MR. : For the corrected one 23 that said 73? Then you made it 72? 24 MS. IIII: I don't remember. But I know I 25 filled out a new one. EFTA00117715 293 1 MR. At 12:00 a.m.? 2 MS. Yes. 3 MR. : And did you have to at 4 that time fill out a new 3:00 a.m. and 5:00 5 a.m.? 6 MS. IIII: Yeah. Because I couldn't find 7 the count slips that he had and I filled it 8 out. And I woke him up and he filled it. I 9 remember that. 10 MR. : So this was later? So he 11 gets a call. He falls asleep. And then later 12 you have to wake him up to resign? 13 MS. IIII: No. He gets the call, he does 14 it. And then he falls asleep. When he gets 15 the call to change whatever, we change it. And 16 then he falls asleep. 17 MR. : So you only changed the 18 12:00 a.m. He falls asleep and then you have 19 to wake him up to change the 3:00 a.m. and the 20 5:00 a.m.? 21 MS. : Yes. 22 MR. : Okay. And you just never 23 talked about what you were doing? 24 MS. IIII: No we didn't talk about it. As 25 far as like -. 1 MR. 2 common practice 3 MS. IIII: 4 slips before? 294 Because that's just there? What? To fill out the count 5 MR. To prepopulated count 6 slips. You're supposed to count inmates to 7 make sure that they're there. And write the 8 number of what you counted. 9 MS. : Yes. 10 MR. : You just -. Common 11 practice is you just fill that out first. And 12 you said that you don't have access to what the 13 count number is supposed to be. It's just -- 14 MS. IIII: I never said I don't have 15 access. I don't know how to. I don't know if 16 I have access. I don't know how to find what 17 it's supposed to be. 18 MR. : So how do you get the 19 number that write on the slip? 20 MS. IIII: We're not -. The number that I 21 wrote on the sli the officer gave it to me. 22 MR. : So whoever you replace, 23 they tell ou what number to write? 24 MS. : They -. 25 MR. : You prepopulated that 295 1 number. Is that correct? 2 MS. IIII: Correct. And you fill it out. 3 Even on a regular housing unit, I fill it all 4 out. And then I count. Because even if it's 5 wrong, you can ust rewrite it. 6 MR. : Right. 7 MS. : Because even if I come in and 8 you say it's 72. And I fill it out and I put 9 72 on all of them. I know nobody there's no 10 movement between 12 and 8. So even if I did 11 that and I put 72, and I counted and it's 12 wrong, I could just change it. So that's the 13 way I've it. 14 MR. : Does that sound weird to 15 you? Or List me? 16 MS. : What? 17 MR. : That that's the way it's 18 done. That you prepopulated all these numbers 19 and then you just change them later if they end 20 up being off? 21 MS. IIII: No. Because they're usually 22 not off. 23 MR. • Um. 24 MS. : And then like if I'm working a 25 unit -. If I work that unit and I did a double 296 1 there, I counted, so I know that's what it is. 2 So it doesn't sound crazy that I fill it out. 3 MR. : Well in this instance it 4 does because your count was wrong - the one you 5 said that ou counted. 6 MS. IIII: Okay. But that's that case. 7 But I'm saying like it's not -. If I worked a 8 double on 11 North and I've been there the 9 shift before and the shift after, and I filled 10 it out. I know there's no movement. So no, 11 it's not craz that I filled it out. 12 MR. : Right. So. Had you 13 worked with prior to this instance? 14 MS. : Never. 15 MR. You never did? 16 MS. 17 MR. And there was no 18 conversation with him about these not doing the 19 counts or rgopulating these count slips? 20 MS. IIII: No. About prepopulating the 21 count slips, he came in, he filled it out and I 22 signed it. It wasn't a conversation about 23 that. When it was time to do the - when it was 24 time to conduct the count, I tried to wake him 25 up and he was really tired. He was like I'm EFTA00117716 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 297 tired. And I didn't - we didn't conduct the count. MR. : Alright. And that was at - what time was that? At 12:00? MS. : I don't remember what time. MR. : What count would have that been for that you tried to wake him up he said he was tired? MS. : I don't know. MR. : You don't know? MS. MR. • Would have it been the 12:00? Because you're already -- MS. IIII: It could have been the 12:00, it could have been the 3:00, I don't know. MR. Alright. MS. was tired. MR. So that was the one conversation -- MS. IIII: Because I counted upstairs. Like why would I go upstairs and count a unit and leave my unit? So I woke him up. He was tired. So I went upstairs and I counted with MR. And what time was that? 298 1 MS. : 3:00 and 5:00. 2 MR. 3 5:00 with 4 MS. 5 MR. 6 1:00 in your unit? 7 MS. : Ri ht. 8 MR. Okay. Um. Um. I'm just 9 -. The only problem I -. I'm trying to 10 reconcile the fact that you've never worked 11 with before. You didn't have any 12 conversation with him about it. 13 MS. : No. 14 MR. : He didn't -. That's why 15 I'm saying it sounds like it must be just 16 common practice. 17 MS. : Yes. 18 MR. : You just don't conduct 19 counts. You just fill out eh forms. 20 MS. IIII: We didn't have a conversation 21 about filling it out. No because that's common 22 in there. 23 MR. : Alright. So it's very 24 common. Is it very common from like 12:00 a.m. 25 to the 5:00 a.m. count? Those three? Not to Yes. You did the 3:00 and the You just didn't do the 299 1 conduct the counts and just write them? 2 MS. : No. 3 MR. : No it's not common or is 4 it common? 5 MS. IIII: You're saying if it's not 6 common to conduct the count or if it's common 7 to (Indiscernible 03:33:51) it? 8 MR. : Is it common not to 9 conduct the counts at night or the early 10 morning hours? 11 MS. IIII: I don't know because that's my 12 first time ever not doing it. So I don't know 13 if it's common not to conduct the count. But 14 it is common to fill it out before. 15 MR. FOY: You need to make that more 16 clear. Did you ever work midnight to 8:00 a.m. 17 to have an experience to say what happens? 18 MS. No. Not in the SHU. 19 MR. IIIIIIIIII: So you've never worked : 20 midnight to 8:00 a.m. prior to this instance? 21 MS. : In the SHU? No. 22 MR. : Okay. On the other times 23 you were in the SHU, was it common to fill out 24 count slipl_that weren't conducted? 25 MS. IIII: In the other times that I've 300 1 worked in the SHU we fill -. 2 MR. : So you're saying you've 3 never worked in the SHU and we got the schedule 4 in front of you if you want to take a look to 5 just help refresh your memory. Um. When you 6 were in the SHU, was it common to fill out 7 count slipl_that weren't conducted? 8 MS. IIII: Count slips, we fill them out 9 and the counts were done. The rounds, it was 10 common to fill them out and the rounds weren't 11 all conducted. 12 MR. : So you're saying it's 13 common to fill them out ahead of time, but it's 14 not common not to conduct the counts? 15 MS. : The counts. Correct. 16 MR. Okay. How often were 17 they - when you 'worked in the SHU, how often 18 were the counts not conducted? 19 MS. : They were done. 20 MR. : They were always done 21 when you were in there before? 22 MS. : Yes. 23 MR. : And this is again one of 24 those things if we go back to video from the 25 days prior, because we had to get video from EFTA00117717 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 301 these days. If we review that, are we going to - it's going_to show you conducting the counts? MS. IIII: Yeah. I don't have to conduct the count because if I'm working with two more people, they could have did the count. So it doesn't necessarily have to be you're going to see me on the video, but you will see the counts bein done. If you get what I'm saying. MR. : No I understand what you're saying. MS. IIII: If three of us are working, those two could have did it. It doesn't have to be me. MR. So when you were in the SHU, did -. If you didn't do it, did the two other peo le MS. MR. always do it? : Yes. Alright. Were you ever on count slips - your assigned count slips - that you ersonally didn't conduct? MS. : The - no. MR. : So you never signed MS. : But they're -. If I ever signed the count slips but that the night before the round sheet, I did. 302 1 MR. : I'm sorry, what was that? 2 MS. : The rounds sheets I did. The 3 count 4 MR. : The rounds sheets you did 5 what? 6 MS. IIII: On the 9th, when I filled out 7 the entire count slips, I didn't conduct every 8 single round. 9 MR. You didn't conduct every 10 single round. 11 MS. : N 12 MR. So what about on previous 13 incidents? We can switch over to rounds, 14 that's fine. In previous instances when you 15 worked in the SHU, were the rounds conducted as 16 displayed on the count sheets? 17 MS. : No. 18 MR. : But the counts you're 19 saying they were always conducted when you 20 worked in the SHU? 21 MS. : Yes. 22 MR. So this was just a rare 23 instance. 24 MS. IIII: It wasn't a rare. It was 25 because he was exhausted. And he was tired and 303 1 he didn't want to count. So we didn't count. 2 MR. But then you also say 3 at 10:00 p.m. also was exhausted? 4 MS. : Yes. 5 MR. So -- 6 MS. And -. 7 MR. -- that's -- 8 MS. And -. 9 MR. -- not a -. 10 MS. : And -. Yes and I know because 11 I did it and I wasn't supposed to do it. 12 That's why I didn't continue to do it. Because 13 I'm really not supposed to count - to go down 14 range by myself. So I didn't continue to do 15 it. 16 MR. You didn't continue to do 17 what? 18 MS. : The count by myself. 19 MR. : Alright. But you did the 20 entire count at 10:00 p.m.? 21 MS. : Yes. 22 MR. : Were there other 23 instances that you worked in the SHU where 24 other people were too tired to conduct their 25 rounds? 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 304 MS. : No because I usually -. MR. : Or the counts - not rounds. Counts. MS. IIII: Because I usually come in on the shift prior. I don't work that so I don't know what goes one. Because that's the tired time. MR. MS. I don't have MR. Right. • So I usually come in before so to deal with that. Alright. But it was just MS. : It was just that one day. MR. : It's the one day. No conversations were had. You try to wake him up. He didn't wake up. So you just didn't do them. And then you didn't even have to say like hey man, we need to do these things. Or like there was just an unspoken thing that he was tired. So you weren't just going to do them? MS. : Sa that again. MR. : I'm just trying to like it sounds like it would be common practice to do this if there's no conversations that were EFTA00117718 305 1 had. Usually, it would be like hey if this is 2 the first time I'm not going to do something. 3 I would say like, hey is it cool that we're not 4 going to do this? Or some kind of a 5 conversation. Unless it was something that you 6 had learned or experienced in the past. That 7 like we don't do counts at this time. 8 MS. IIII: But I never worked the SHU at 9 that time. 10 MR. FOY: This is calling for to 11 explain your interaction with 12 MS. IIII: Mm-hmm. 13 MR. FOY: As it relates to the count in 14 particulaL__EigbI2 15 MR. IIIIIIIIII: Correct. 16 MR. FOY: He asleep. What's the 17 interaction? What did you say? What did he 18 say? Did you ask one time? Did you ask 19 multiple times? Did he affirmatively say no? 20 Or did he just continue to sleep? That's the 21 level of detail they're asking for. 22 MR. : Yeah. We're asking, 23 to explain all of your interactions with 24 with regard to these counts. 25 MS. IIII: Well when it was time to count, 306 1 because remember I'm going upstairs to count. 2 So I wake him up to count. And he was like I'm 3 tired. He was like we have the count slip. 4 I'm tired. He went back to sleep. When the 5 lieutenant came, I woke him up because the 6 lieutenant was coming. He fell back to sleep 7 in front of the lieutenant. She said hey, you 8 need to stay awake. He couldn't' stay awake. 9 I went upstairs and I counted again. 10 MR. FOY: Go back to the lieutenant. 11 Explain that in more detail. There's details 12 leaving out of the interaction between 13 and the lieutenant with respect to him 14 sleeping. 15 MS. IIII: Oh. I woke him up. The 16 lieutenant came. She came, she found the round 17 sheet. He fell back asleep in front of her. 18 She said, hey you need to wake up. She had 19 papers and she hit him. She says, hey you need 20 to wake up. 21 MR. FOY: That's what I'm talking about. 22 MS. IIII: She hit him with a stack of 23 papers. So saying that to say like everybody 24 knows like because we're understaffed and 25 overworked. So let's say if I was to tell on 307 1 that's who I would have told it to. 2 She was there. And she saw it. 3 MR. : So she knew. So you 4 didn't as far as like if you were going to 5 report someone sleeping on duty, she's -. You 6 didn't' need to report it because she saw it 7 with her own eyes. 8 MS. : Exactly. 9 MR. And he was literally - 10 fell aslee in front of her? 11 MS. : In front of her. Yes. 12 MR. How long was she there? 13 MS. be like five, then minutes. 14 MR. And that little brief 15 interaction he actually went to sleep in front 16 of her? 17 MS. Yes. 18 MR. Okay. So no discussions 19 with . Just when you would wake him up 20 he just said he was tired. 21 MS. Yes. 22 MR. Did you try to wake him 23 up for each count? 24 MS. IIII: I tried to wake him up for the 25 12:00 and the 3:00. I don't remember if I 308 1 tried to wake him up for the 5:00. Because by 2 that time he went ugltiirs. I remember he went 3 upstairs to relive IIIII. And I don't remember 4 what happened between there as far as waking 5 him up. 6 MR. : Alright. And as far as 7 the inaccuracy of the one count, specifically 8 now we're talking about the 12:00 a.m. that it 9 was actually - it's off. He got a call but he 10 didn't talk to you about what was said on the 11 other line? 12 MS. IIII: No. He just said we got to 13 change the count slip. And he wrote it. And 14 he changed it. And I signed. 15 MR. : Alright. 16 MS. : But he didn't say like oh the 17 lieutenaniiiiiiiiiipened or that happened. No. 18 MR. : Alright. And have you 19 ever experienced previous instances where the 20 count was off from when it was called in? Like 21 if you give the number and they say no that's 22 not right? 23 MS. : Yes. 24 MR. And what happened in 25 those instances? EFTA00117719 309 310 1 MS. : You recount. 2 MR. : You actually did a 3 recount? 4 MS. IIII: On - not in the SHU. In other 5 units. 6 MR. In other units though. 7 But do you know that that's what is supposed to 8 be done? You need to do - if you call in a 9 wrong number, you're supposed to do a recount? 10 MS. IIII: Right. But I don't think that 11 was the case with that. Like they called in 12 and gave -. Okay. That was a case where like 13 if I counted wrong, and then they'll say no 14 it's wrong. And then I recount and I get the 15 right number. But in this case, they gave him 16 the number because of whatever I guess they 17 knew where the inmate was or was supposed to be 18 or wasn't moved. That's what I'm saying. I 19 don't know what happened between the 73 an the 20 72. But when he changed the number, he said 21 the lieutenant said so I just signed it. 22 MR. : But he didn't tell you 23 the lieutenant said do a new count? 24 MS. : No. 25 MR. He never informed you of 1 that? 2 MS. : No. 3 MR. : Okay. So you didn't 4 really get into detail about what he said. 5 MS. : No. 6 MR. : Okay. But you do believe 7 at 12:00 a.m. a new slip was created. Just not 8 that one. That's not attached to that. The 9 one that actually says 72. 10 MS. IIII: (Indiscernible *03:42:12) Is 11 that a 12? At 12 here it says 73. 12 MR. : Correct. But that was 13 actually - the top page says 72 and I thought 14 that's the one that you said they made you 15 recreate a count slip. 16 MS. : Ri ht. 17 MR. And that's not -. You 18 don't see that -- 19 MS. That count slip. 20 MR. : -- new count slip on 21 there. Correct? Alright. And I know -. 22 Did they have the conversation with 23 because at 12:00 a.m. he called that count 24 number in and they said he was wrong? Is that 25 when he had that conversation with the 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 lieutenant? MS. MR. the count MS. 311 No the phone rang. Alright. So who called 12:00 a.m.? Me. MR. And did you call - also call the 3:00 a.m. and the 5:00 a.m. in? MS. : Yes. MR. : Alright. And obviously you called it in without actually conducting the counts. Correct? MS. : Yes. MR. : Alright. Now it sounds like your attorney has - and you have had this conversation but what was the reason you didn't conduct the counts? MS. IIII: I didn't conduct the count in my area because he was tired and we're supposed to do theiliiiiiiii. So I just didn't do them. MR. : Okay. So would have you done them if he was awake? MS. IIII: Yeah. Because I did them upstairs. MR. : Okay. And you're saying that you never worked that night shift before, 312 1 but all the other counts you had conducted that 2 you've documented from previous. 3 MS. : Yes. 4 MR. : Documented. You're 5 saying you may have worked with three other 6 people and two of them may have done the 7 counts, but there are - when you've been 8 present in the SHU, all the counts have been 9 conducted. 10 MS. : Yes. 11 MR. : Okay. And do you know of 12 any other COs or employees that have falsified 13 count sli s? 14 MS. : Count? No. 15 MR. No. SO you don't know 16 any other. I know you said you prepopulated 17 them in a sense. But like as far as -- 18 MS. : As far as other units. 19 MR. : -- not conducting the 20 counts and actually writing a number when a 21 count -. Do you know? 22 MS. : Oh. No. 23 MR. : So all counts that have 24 been submitted to this point when you're in the 25 SHU - someone conducted them. EFTA00117720 313 1 MS. : Yes. 2 MR. : And you said you've never 3 actually had a conversation with anyone about 4 counts and how they're documented. You just 5 observed as well like on the round sheets? 6 MS. IIII: As far as having a 7 conversation? 8 MR. : Did anyone ever train you 9 on how to write count slips? 10 MS. No. 11 MR. : No. 12 MS. Hm-mm. 13 MR. : So you just from watching 14 other people fill them out - that's how you 15 learned? 16 MS. IIII: Yeah because it's just your 17 name and the number of the count. 18 MR. : Sure. 19 MS. Mm-hmm. 20 MR. : Okay. You want to take a 21 break now? 22 MR. FOY: Mm-hmm. 23 MR. : Okay. 24 MR. FOY: We've got to eat. 25 MR. : It is 2:21 p.m. This is 314 1 Senior Special Agent and I am 2 pausing the recording. [Whereupon, the above- 3 entitled matter went off the record and went 4 back on the record.] Okay. The recorder is 5 back on. It is 2:28 p.m. Again Ms. MI you 6 are under oath and this is a voluntary 7 interview. Thank you for your cooperation. 8 Alright. So if you don't mind, just all the 9 documents I have in front of you, can you just 10 initial and date those just again so that we -- 11 MR. FOY: Yeah. Just on the first page. 12 MR. : -- know what it is that 13 you were looking at during this interview. 14 Thank you very much for initialing and dating 15 all of those. 16 MS. : Mm-hmm. 17 MR. : Alright. We're just 18 going to talk briefly about the SHU layout. 19 These are papers that have the SHU layout. Now 20 are the - just for your reference if you need 21 to look at them. Are the COs assigned to the 22 SHU located together on one social - one 23 centralized location? Sorry, so the officers 24 that are working in the SHU. Are you all 25 together? You mentioned there's a desk in the 315 1 shape of an L. 2 MS. : Yes. 3 MR. : Is everybody together at 4 that location when you're not doing rounds and 5 counts? 6 MS. IIII: I mean no not really. Somebody 7 could go ita. sto the bathroom. 8 MR. : Okay. During your shift 9 on the 10th. 10 MS. : Mm-hmm. 11 MR. : Is that where ou and - 12 aside from when you said you hel ed out. 13 Is that were the two - you and were 14 located at that -- 15 MS. : Yes. 16 MR. -- one central area? 17 There's not another officer station though, 18 correct? 19 MS. : N 20 MR. There's just one 21 officer's station? 22 MS. : There's one. 23 MR. : Okay. And approximately 24 how many corn uters are there at that station? 25 MS. IIII: About three. 316 1 MR. Three? And you said no 2 one had like an assigned computer like the -- 3 MS. : No. 4 MR. OIC doesn't have one 5 computer? 6 MS. : You -. 7 MR. : Everyone just uses one 8 computer? 9 MS. : Mm-hmm. 10 MR. : What can you see from 11 that desk in the SHU? Can you just mark on 12 there where is the actual L desk setup located? 13 So it's the two floors - the two layers. I 14 don't know if you're able to look at the L Tier 15 where Epstein was. That might give you like a 16 what's the first and what's the second. Is it 17 correct that he was on the second level? 18 MS. : Yes. 19 MR. : And was he in L Tier? So 20 that might help you out to be able to 21 differentiate between - you see where the cells 22 start with like a letter and then the numbers? 23 MS. : Yes. 24 MR. : So that will probably 25 help you to be able to decipher what's the EFTA00117721 317 1 first level and what's the second level. 2 MS. GREGG: Do you know what you're 3 looking at? 4 MR. : So each of the cells have a 5 letter in front of it. 6 MR. : That's to identify the 7 tier. That will be the letter. And then the 8 numbers will be the cell numbers. 9 MS. : Uh-huh. Okay. 10 MR. : So by - can you figure 11 out by looking at that? So if the one that 12 begins with L that would be the second level. 13 Do you follow that? 14 MS. : Yes. 15 MR. : And then there's the 16 first level. Is there actually almost like 17 third level where the officers sit? It is like 18 two different - the way it's tiered. 19 MS. : No. It's on the main level. 20 MR. : Okay. So where the first 21 set of inmates are. 22 MS. IIII: See it's stairs. You've got to 23 go down and ou've got to go up. 24 MR. : Right. Okay. 25 MS. : So it's not where we're 318 1 sitting. You've got to go down and you've got 2 to go up iiiiiiiiiithe cell. 3 MR. : Okay. So on that looking 4 at like the first level of inmates, can you 5 just kind of identify where it is that that L 6 shape setu is? 7 MS. : Over here. 8 MR. : Can you just mark it? 9 Maybe like an X or a circle or something. 10 Okay. Thank you. And from where you're 11 sitting can you see all the cell doors from 12 there? 13 MS. : Not all. 14 MR. : Not all. 15 MS. Hm-mm. 16 MR. Could you see the door to 17 Epstein's cell from there? 18 MS. : Yes. 19 MR. : Alright. Can you mark on 20 there where you recall Epstein to have been? 21 Alright. Thank you. And does that have a cell 22 number on it? 23 MR. : I think those numbers 24 correspond with this. 25 MR. That's fine. 319 1 MS. IIII: Um. 2 MR. FOY: Because I'm thinking is it? 3 Because you have to be able to see in here. 4 MS. GREGG: This is your unit entrance. 5 This is where you enter. This is L Tier. 6 Right. The - you walk in. L, M, 3, K. So if 7 this is 3, this is you walking into your 8 housing unit. 9 MS. IIII: (Indiscernible *03:51:16) by 10 turning left. 11 MS. GREGG: Yes. So. 12 MR. : And maybe put X and a 13 circle just so I know what it is that you just 14 changed. 15 MR. FOY: Put a circle around that X and 16 that will be the desk. 17 MR. : Perfect. 18 MR. FOY: Alright? 19 MR. : Alright. And then you - 20 is it correct where you identify where -? 21 MS. E stein 22 MR. Epstein. What number was 23 that? 24 MS. : 988. 25 MR. : You believe that he was 320 1 in - was that L988? 2 MS. IIII: I don't remember the number 3 that he was in. I just know when you go up the 4 stairs, it's the first one on the right. 5 MR. : Let me just so that we're 6 not. I just want to make sure that we're not - 7 . Huh. Okay. So they don't actually 8 correspond with the numbers. 9 MS. : No (Indiscernible *03:52:08). 10 MR. We have that. 11 MR. : Do you remember what room he 12 was in? 13 MS. On L Tier? 14 MR. : Yeah. L Tier. 15 MS. The first cell on the right. 16 MR. : The room number by any 17 chance? 18 MS. Oh I don't know the room 19 number. 20 MR. Okay. 21 MR. : Um. Okay. But you could 22 see his actual door from where you were 23 sitting? 24 MS. : Yes. 25 MR. : Yes. Okay. And could EFTA00117722 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 321 you see inside his cell from where you were sitting? MS. MR. No. Approximately again we're talking about like that's where the shower was - what you were talking about. Approximately how far was Epstein's cell from where you were seated? MS. IIII: Mm. To like where that chair is. MR. . Ten to 15 feet? MS. Probably. MR. Okay. Alright. So the reason why I'm asking that. Did you or anyone else ever go in or out of Epstein's cell on August 10, 2019? MS. . No. MR. And would have you known if someone did? MS. : Yes. MR. Okay. While you were physicall resent in the SHU of course. MS. : Yes. MR. And you said the only times you weren't present in the SHU on August 323 MS. : Yes. MR. : Although he may have been sleeping. MS. : Mm-hmm. MR. : Okay. And are you - of the people that we've talked about, you said that the lieutenant visited the SHU iiiiiiiii atel , 4:00 a.m. That was Lieutenant MS. Yes. MR. Who else from 10:00 p.m. until 6:33 a.m. were in the SHU? MS. (Indiscernible MR. Well so -. MS. MR. left at around 10:00. MS. : Mm-hmm. MR. left around 12:00 a.m. Anyone else? MS. : No. MR. : What about when came thought the SHU? So I just want to make sure you're -. I know we've kind of discussed some of this stuff. 322 1 -. Or let's talk from you said 10:00 p.m. is 2 the last time - around 10:00 p.m. is the last 3 time you saw him. 4 MS. : Yes. 5 MR. : From 10:00 p.m. until 6 approximately 6:33 a.m., what times did you - 7 when did you leave the SHU? I know one time 8 you said you helped with the counts up in 10 9 South. And you may have said you were gone in 10 the bathroom around. 11 MS. : Indiscernible *03:53:38) 12 MR. : When would have those 13 times have occurred? 14 MS. IIII: Um 3:00 or right after 3:00, 15 5:00 or around after 5:00, going to the 16 bathroom I don't remember the times. 17 MR. : Okay. So around 3:00 18 a.m., around S:00 a.m., and then one other time 19 to use the restroom? 20 MS. : Yeah. 21 MR. : And where is the restroom 22 located in the SHU? 23 MS. : U stairs where I iiiiiicount. 24 MR. : Okay. But was 25 present any time you were not there? 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 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 324 MS. IIII: Oh you're talking about the people that's working there? MR. : Everybody that's been in the SHU. So there's you, there's . Who else was actually in the SHU from 10:00 p.m. - the last time you saw Epstein - up until about 6:30 when he was discovered? MS. , Lieutenant and MR. • And ? MS. He left at 10:00. MR. At 10:00. So at 10:00 he left. The 're the only other people there? MS. : That's It. MR. Okay. No one else? MS. No one else. MR. And you're confident positive about that? MS. : Yes. MR. : Alright. And did any of those individuals that visited the SHU go near Epstein's cell? MS. : No. MR. So no one even went near it? EFTA00117723 325 1 MS. 2 MR. Let alone go in it. 3 MS. 4 MR. No one went in it? 5 MS. 6 MR. : Okay. That's all we need 7 to talk about with the SHU. Do you mind just 8 initialing and dating that? And are you aware 9 -? I guess the one other thing I'll ask. I 10 know I asked when you were there. But when you 11 were gone to do the counts in 10 South as well 12 as use the restroom, are you aware of anyone 13 visiting the SHU during those times? 14 MS. : No. 15 MR. : No? Okay. 16 MR. I have a follow-up question. 17 MR. Go ahead. 18 MR. : When you left to go assist, 19 did you take the keys with you? 20 21 MS. ies. MR. : So could Mr. have let 22 anyone in and out? 23 MS. : No. 24 MR. Oh so he wouldn't have 25 even had the ability to let anyone in based 326 1 upon you having the keys the whole time? 2 MS. : Yes. 3 MR. : And did you have the keys 4 because you were SHU officer number one? 5 MS. IIII: I guess. I mean I just had 6 them. 7 MR. Okay. There wasn't a 8 discussion -- 9 MS. 10 MR. -- like I'm SHU one, I 11 get the ke 12 MS. 13 MR. Do you know that SHU one 14 is supposed to be the one who has the keys? Do 15 you know that (Indiscernible *03:56:05)? 16 MS. : I think so. 17 MR. : Okay. Do know if you 18 have any conversations with about if you 19 had the ke s or he had the keys? 20 MS. : No. 21 MR. : Okay. Anyone that 22 entered or exited the SHU that day, are you the 23 one that let them in or out? 24 25 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 327 in or out? MS. : No. MR. : Okay. Are you aware of any cameras were not recording within the SHU on August 9th or 10th 2019? MS. : No. MR. : You're not aware? Are you aware at this point? Not just at the time. But are you aware now if any cameras were or were not recording? MS. : I mean I'm aware now. MR. : That's what I mean. What is your - what are you aware of now? MS. IIII: Oh I don't know like what specifically. I just heard that some of the cameras were not working. As far as which ones MR. But you don't know which ones? MS. : -- or no. MR. : Okay. And at the time you didn't know? MS. : No. MR. So you don't know if they weren't working when they stopped working? 1 2 3 you have the ability to monitor cameras from 4 the SHU? 5 MS. : No. 6 MR. So if you're sitting in 7 there, there's not like camera down range that 8 you can like - you can see what's going on in 9 each range? 10 MS. • No. 11 MR. No? Do you know if 12 someone is live monitoring either - anywhere in 13 the SHU during operations? 14 MS. : I don't know. 15 MR. : You don't know if you're 16 being monitored or the inmates are being 17 monitored? 18 MS. IIII: I don't know. I know there is 19 cameras on the tiers. 20 MR. : Right. Do you know if 21 anybody's live monitoring them? 22 MS. : Oh. I don't know. 23 MR. : You don't? And do you 24 know if there's any cameras pointed at you in 25 the desk area? MS. MR. : Yes. didn't let anybody 328 MS. : No. MR. : Are there any like - do EFTA00117724 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 329 MS. : Oh, I don't know. MR. : And you don't know if anybody is monitoring those either? MS. : I don't know. MR. : (Indiscernible *03:57:54) MR. : I think it will be fine. So you are not - we can just skip the rest of those questions. You're not aware of any cameras at the time not working? MS. : No. MR. : So no one reported that to you aniLy2u didn't report it to anyone else? MS. IIII: No. I didn't know anything about cameras. MR. : Alright. And we talked a little bit about sleeping on duty. So it sounds like was asleep pretty much the entire shift then? MS. : Yes. MR. From pretty much 12:00 a.m. until he -. MS. MR. : Until he went upstairs. • Until he went upstairs? Went upstairs to do what? To feed? MS. IIII: To relieve 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 330 MR. To relieve M .? Alright. I might be getting_gpfused. I thought you were relieved IIIII. Then MR. She went up there to do the count. T% reached out to her to ask her to relieve him. She called the lieutenant. Verified with the lieutenant and then Mr. weiiiiiiiiiieliye him. MR. : Okay. And around what time was that? MS. : After S:00. MR. : Okay. So basically from 12:00 to about 5:00 he was sleeping? MS. IIII: I mean in intervals. Like I tapped him. He kind of woke up. Right. he went back to sleep. Okay. But he wasn't duties. He was sleeping. : Correct. Did you sleep during the MR. MS. MR. doing his MS. MR. shift? MS. : No. MR. : You didn't sleep at all? MS. : No. 331 1 MR. For the period that you 2 were sitting at the desk for like two hours 3 without moving were you awake? 4 MS. : Yeah on my computer. 5 MR. : You were on the computer? 6 Were you and seated next to one another? 7 MS. : No. We were seated next to 8 each other but not facing each other. Like he 9 was facediiiiii wa iiii I was faced the other way. 10 MR. : Okay. Close proximity to 11 one another? 12 MS. IIII: Yeah. Like he's there and I'm 13 here. 14 MR. : So about three or four 15 feet from each other? 16 MS. IIII: Yeah. But the back is turned 17 because he's that way and I was that way. 18 MR. Okay. But you were not 19 sleeping? 20 MS. 21 MR. : Now are you guys 22 authorized to sleep in the SHU? 23 MS. : No. 24 MR. : No? And have you ever 25 fallen asleep previously while on duty at the 332 1 MCC? 2 MS. : Not in the SHU. 3 MR. : Not in the SHU but other 4 places? 5 MS. Yes. 6 MR. 7 did you slee 8 MS. 9 MR. 10 MS. 11 MR. 12 MS. 13 MR. Can you just give me a 14 little more information on that? What do you 15 mean? Were ou allowed to sleep there? 16 MS. : No. 17 MR. : And where were 18 (Indiscernible *04:00:15)? 19 MS. IIII: Like I worked consecutively 20 like five days of overtime. And I would like 21 doze off - caught myself like that. But not 22 sleep. 23 MR. : Okay. So you've fallen 24 asleep in other housing units. 25 MS. IIII: Like dozed off. Where would you - where at other places? : Where did I fall asleep? Mm-hmm. a regular housing unit. The regular housing unit? EFTA00117725 333 1 MR. Right. Because you were 2 overworked? 3 MS. IIII: Yeah when I work like three or 4 four days of 16 hours, yes. 5 MR. And how often would that 6 happen? 7 MS. IIII: Every - how often would I fall 8 asleep -- 9 MR. Yeah. 10 MS. -- or the overtime? 11 MR. How often would you fall 12 asleep? 13 MS. IIII: Oh that was like for one or two 14 times. But I don't -. 15 MR. : I understand. But in the 16 SHU you had never fallen asleep before? 17 MS. IIII: No because I don't work that 18 graveyard shift. 19 MR. : Well I just mean even 20 during your regular shifts -- 21 MS. : Ri ht. 22 MR. : Because it sounds like 23 you guys were working a lot. 24 MS. . Yes. 25 MR. Um so but in the SHU, you 334 1 didn't fall asleep that night and never before 2 in the SHU? 3 MS. IIII: In the SHU no because it's 4 daytime I'm on. 5 MR. You said that was your 6 first time working with =? 7 MS. : Yes. 8 MR. : Was that ever with 9 or ust in the SHU? Did you ever work with 10 outside of the SHU? 11 MS. : No. 12 MR. : Would you ever like - met 13 with him or interacted with him -- 14 MS. : Yes. 15 MR. -- prior to this? Just 16 socially or -. 17 MS. IIII: He brings inmates to the units 18 to give out stuff. So we've spoke and said 19 hello. 20 MR. : Okay. Do .oi cnow if 21 - have you ever heard of sleeping 22 on the job revious to this incident? 23 MS. : I don't know. 24 MR. : No? And you said you did 25 try to wake him up a couple times? 335 1 MS. : Yes. 2 MR. : But he said he was just 3 tired? 4 MS. : Yes. 5 MR. : And you said you didn't 6 report the matter to a lieutenant because he 7 actually fell asleep in front of the 8 lieutenant? 9 MS. • Yes. 10 MR. • And at that time, she hit 11 him with a iece of paper and said wake up. 12 MS. : Yes. 13 MR. : And how did he respond to 14 that? 15 MS. : He woke up. 16 MR. Was there a conversation 17 at all? Did he say oh I'm just exhausted? 18 MS. IIII: Well he didn't say that. But 19 she said that. She was like that's the problem 20 in here. The overwork and the understaff. 21 MR. : So with him falling 22 asleep that's how she responded? 23 MS. Lieutenant 24 MR. Yeah. 25 MS. : Yeah. But she didn't respond 336 1 like that to him. She was saying that to me. 2 That's the problem in MCC. Everybody's 3 overworked and understaffed. 4 MR. : Okay. After she left did 5 he fall back asleep? 6 MS. : Yes. 7 MR. : Have you ever witnessed 8 any other staff member fall asleep at the MCC? 9 MS. IIII: No because you're in a unit by 10 yourself. 11 MR. : You're in what - the 12 housing units or the SHU? 13 MS. IIII: Yeah. Like when I'm in the 14 housing unit -. Remember I don't work the SHU 15 that time, so I wouldn't know if people are 16 sleeping at that time. In the housing unit 17 you're by ourself. So I can't witness nobody. 18 MR. : Okay. And you have your 19 own little office there -- 20 MS. : Yeah. 21 MR. : -- when you're in the 22 housing unit. And that's where you might be 23 able to doze off? 24 MS. : Yeah. 25 MR. As far as in the SHU did EFTA00117726 337 1 you ever experience anyone else sleeping aside 2 from 3 MS. : that day before. 4 MR. : Okay. And I do 5 apologize. It's just been so long now. How 6 long did he sleep for? 7 MS. : Who 8 MR. Yeah. 9 MS. : From about after 10:00 until it 10 was time for him to go. 11 MR. : So 10:00 to 12:00? Okay. 12 And did you try to wake him up at all? 13 MS. : No because he was on a triple. 14 MR. : Okay. Alright. Now 15 we're going to do -. You said you were on the 16 internet. Are you authorized to use the 17 internet when you're in the SHU? 18 MS. IIII: I don't know if I'm authorized 19 to use the internet in the SHU but I did. I 20 don't know if I'm authorized. 21 MR. : Alright. And did you 22 conduct internet queries when you were assigned 23 to the SHU on August 10, 2019? 24 MS. IIII: What do you mean? Like 25 internet searches. 338 1 MR. Did you like Google 2 things or look things up when you were in 3 there? 4 MS. : Yeah. 5 MR. : Well just tell me. What 6 did you search for? 7 MS. IIII: Well yeah that's what - I was 8 looking at um a benefit page for something. I 9 was checking for one of my benefits. And -. 10 MR. FOY: Continue with it. I've just got 11 to - this is call. 12 MR. : Okay. So attorney Foy is 13 stepping out. However attorney is it Sarraga? 14 MR. SARRAGA: Yep. 15 MR. : Sarraga is still present. 16 MS. : Yes. And then I think I looked 17 at I think it's furniture. 18 MR. : Okay. Did you do any -? 19 Do you remember conducting any internet queries 20 related tp_Epstein? 21 MS. IIII: No. I don't remember doing 22 that. 23 MR. : So you don't remember 24 actually conducting queries on Epstein around 25 4:00 or 5:00 a.m.? 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 339 MS. : Hm-mm. MR. : On August 10th? No? Okay. Does that surprise you for me to ask that question? MS. : If I don't remember doing that? MR. : I don't know. Had you queried him before? Had you looked up Epstein previousl ? MS. : I don't recall looking him up. MR. : No? MS. : No. because when you open the computer, and when you click on it, like he's there in the - in the Google search. Like he's there. MR. MS. Epstein is? : Like when you click on the browser. You know like if you open it Emerson or Google, like how it has that little news piece. Like one time he was there. MR. : And was that on August 10th? MS. IIII: No. I don't recall that being on August 10th. I don't remember. But I don't recall itiiiiiiiiilAugust 10th. MR. : So as in like maybe 340 1 somebody else was looking him up and it just 2 prepopulated when you turned on the computer? 3 MS. IIII: I don't think it does that. 4 Like on the searches, like the current news 5 will be there. So he's in the current news, so 6 he'll be there. 7 MR. : Oh. Alright. 8 MS. : It won't like load the page. 9 Like when you click on like Internet Explorer 10 or you click on like Firefox or whatever. When 11 the page loads the news is there, weather. 12 MR. IIIIIIIIII: Okay. So if you 13 prepopulated something and then you searched on 14 that day, Epstein at the MCC, that possibly 15 could have been something that was like on a 16 news feed? 17 MS. IIII: When you say prepopulated, like 18 that as soon as you click it like it was there. 19 Not like oi. r ida search. 20 MR. : So you weren't. Yeah. 21 Like a search. Like you were actually looking 22 at it. Or if like a news feed. 23 MS. IIII: Oh yeah. Like I'm looking at 24 it because it's there. But not like typing it 25 in. EFTA00117727 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 MR. So actually going to Google of a search engine and -- MS. : No. MR. MS. 341 you're not like or Yahoo or some kind -- saying Epstein? MR. • Alright. Do you remember reviewing news articles on Epstein -- MS. : Yeah. MR. : -- on August 10th? MS. : On August 10th? I don't recall if it was August 10th but I remember when I saw it I like scrolled and read it. MR. : Okay. And what was the purpose of that? MS. : What was the purpose of that? MR. Yep. MS. : Because he's in there. I just scrolled and -. MR. Sure. So you're trying to learn about the inmate that was -. MS. MR. MS. : And read it. • Okay. : Because remember, I was asked like do I know who that was. And I was like 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 342 no. and they was like he's always in the news. So when I saw it, I just briefly like skimmed to see like what he was in the news for but -. MR. : Okay. And do you recall at 5:42 to 5:52 on August 10, 2019 looking at articles related to Epstein? MS. MR. You do not recall that? MS. MR. Do you remember searching for him? MS. MR. with when MS. MR. Or having anything to do ou're on the internet? : No. With Epstein in (Indiscernible *04:07:02)? MS. : No. MR. : S:52? MS. MR. • No? Does it surprise you to hear that you know internet searches would show that that's what you were doing from 5:42 to 5:52 a.m. on August 10, 2019? MS. IIII: Yeah. 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 MR. MS. MR. would not MS. MR. accurate or not MS. IIII: accurate. MR. It wouldn't be accurate? You do not believe that you actually conducted those searches? MS. : N MR. : Okay. And since you had the keys, no one could have visited the SHU without you knowing. Correct? MS. MR. South - 343 That does surprise you? Mm-hmm. So do you think that accurate then? Yes. You think it would be be accurate? Oh no. It wouldn't be : Correct. And the individual on 10 - or anyone else. Are they able to access the SHU without someone in the SHU allowing them in? Can they get out of 10 South and enter the SHU by themselves? Or does someone from the SHU like you and need to authorize them entry? MS. IIII: He needs to call like I have to 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 344 call cont." that door. MR. : So he has to call control? MS. IIII : Because there's a door that lets you into 10. You have to call control. MR. : And then is it like the entrance? Is there also a second door that you have to use a key for? MS. : Yeah. MR. So there's also two into 10 South? MS. MR. that the one MS. MR. key? Or is it just MS. IIII: No upstairs. MR. open his own? MS. : Ri MR. And that second door is don't have the key for. So he would also have a I don't have the key for Alright. So he needs to ht. • And then control pops it MS. IIII: Pops it. EFTA00117728 345 1 MR. -- to then allow him into 2 the SHU? 3 MS. Yes. 4 MR. . So he could theoretically 5 get into the SHU without your knowledge? 6 MS. IIII: No. I have to call control to 7 pop me into the SHU. 8 MR. : Yeah-yeah. I'm saying 9 ' ability to get into the SHU where you 10 and were. 11 MS. : Be he can't do that because he 12 can't leave unless -. Because remember 13 has to go up to relive him. So is 14 getting the door popped. But he can't just 15 come out and get the door popped because he 16 would leave the unit with nobody up there. 17 MR. : Right. What I'm saying 18 is like could he? Does he have the ability to? 19 Not policy dictates that he can't do it. I'm 20 saying would he be able to if he wanted to? 21 Take polic out of the way. 22 MS. : Call for them to pop the door? 23 MR. : Right. So like point 24 being, could have he accessed the SHU 25 theoretically without you and 346 1 knowledge? 2 MS. IIII: Yes. Because he could go and 3 pop the door. 4 MR. : Right. But he would have 5 had to call control in order to do so. 6 MS. : Yes. 7 MR. : Alright. And does 8 anything allow control to know if that door was 9 never locked or closed or anything behind him? 10 MS. : I don't know. 11 MR. : You're not sure? Would 12 an alarm sound if a door wasn't closed or 13 anything? 14 MS. I don't know. 15 MR. You're not sure. Who was 16 the last person to see Epstein alive prior to 17 August 10, 2019 at 6:33 a.m.? 18 MS. IIII: The last person to see him 19 alive? I would uess me. Because I got -. 20 MR. You were? 21 MS. Because I counted at 10:00 - or 22 after 10:00. 23 MR. And on that occasion, you 24 didn't actually enter his cell you said? 25 MS. IIII: No. 347 1 MR. Who was that last person 2 to have ph sical contact with Epstein? 3 MS. 4 MR. would have? And 5 when would have that been? 6 MS. : When he was feeding. 7 MR. No-no-no. 8 MS. You mean like a time? 9 MR. had physical 10 contact with Epstein during his shift on August 11 10th prior to 6:30? 12 MS. IIII: Oh no. Not prior to the 6:30 13 a.m. I'mliiiiiiiiibout at the 6:30. 14 MR. : Right. So you're the 15 last person to see him. 16 MS. : Mm-hmm. 17 MR. : Who was the last person 18 to have phylical contact with him? 19 MS. IIII: Oh! Whoever put him in the 20 cell. When I went to the bathroom. 21 MR. Okay. So you're not 22 sure? 23 MS. 24 MR. Alright. When you saw 25 him, please explain in detail like -? Or I 348 1 guess you already did. You said when you saw 2 him he just ut his hand up. 3 MS. : Mm-hmm. 4 MR. And then he - you said he 5 also asked for -. 6 MS. : CPAP machine to be plugged in. 7 MR. : And that is something 8 that he has every night? 9 MS. : Yes. 10 MR. : Yep? Did he seem - did 11 anything seem unusual with him? 12 MS. IIII: No. See there's exceptions 13 being made for Epstein because it's Epstein. 14 You're not supposed to have -. A CPAP machine 15 has a long cord. So other inmates don't have a 16 CPAP machine in the SHU. Like you're not 17 supposed to have that. Who authorized it, who 18 gave it t2hills_igon't know. 19 MR. IIIIIIIIII: Okay. And that's kind of 20 what I was asking earlier - and this was much 21 earlier - about like where like did Epstein was 22 he treated differently than others? 23 MS. : I mean -. 24 MR. : Were there other 25 instances that you can think of like people EFTA00117729 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 349 said pay him special attention because he's different from eh other inmates? MS. IIII: No. Just the CPAP machine and one time he wanted two mattresses. MR. : He wanted two mattresses? MS. MR. Was he provided two mattresses? MS. MR. mattress? MS. : Mm-hmm. MR. : So the only thing you can think of is that? MS. : Is that. MR. Is it like C-P-A-C? MS. What the CPAP? C-P-A-P. MR. CPAP. MS. Yes. MR. Okay. MR. : Is it the one with like a mask that's attached to your face? MS. : Yeah. MR. : And there's actually like a cord that goes with that? No. : So he just had the one 350 1 MS. IIII: Yeah. The cord has to be 2 plugged in. 3 MR. : Now do you consider that 4 like a safer issue or anything like that? 5 MS. IIII: But see that's the thing. I 6 don't authorize those things. 7 MR. : Sure. 8 MS. : That's why I said when a person 9 -. You see how the question was asked when 10 somebody comes back from suicide watch. Like 11 is there like something like special being 12 said. Like no because he's cleared. Because 13 if there was then why would he be allowed to 14 have that in his room? So once you're cleared 15 and you come back, you're back. 16 MR. : Okay. Were there any 17 other issues with any inmates on August 10th 18 from 12:00 a.m. to 6:33 a.m.? 19 MS. : No. 20 MR. No? So there was no 21 disturbances? 22 MS. 23 MR. • Were there any inmates 24 complaining about the lights being left on or 25 anything like that? Do you recall? 351 1 MS. : Not that I know of. 2 MR. : No? And do you recall if 3 any other inmates were on - came from suicide 4 watch? 5 MS. 6 MR. So you don't remember any 7 other inmates being handled differently than 8 others? 9 MS. 10 MR. 11 instructions with regard to this inmate or that 12 inmate. 13 MS. : I don't know. 14 MR. : And you don't remember 15 inmates con laining about the lights you said. 16 MS. : No. 17 MR. How do the lights work? 18 Do they stay on in the range all times - uh 19 24/7? 20 MS. : The -. 21 MR. • In each tier? 22 MS. : I don't know. But the light is 23 in the hallway room. 24 MR. : So for an interior room. 25 What about the down the hallway to each for • No? Or like special 1 each tier? 2 MS. 3 MR. 4 MS. 5 MR. 6 lights off? 7 MS. 352 : Oh yeah. It stays on. Were they on 24/7? Yeah. Do they ever turn those 8 MR. No? Okay. Now we're 9 going to get into a little into more of the 10 specific stuff. Was there a medical emergency 11 in the SHU in the morning of August 10, 2019? 12 MS. : Yes. 13 MR. : Why was the medial 14 emergency called? 15 MS. : Because when I opened the grill 16 and went to go feed, he knocked on the 17 door. He got no response. And he opened the 18 door. And then he started saying get the 19 cutter. And I heard -. I was on the grill. I 20 heard when he ripped something and he started 21 CPR. 22 MR. Okay. When was the 23 medical emer ency called? 24 MS. : At that time. 25 MR. : How soon after um EFTA00117730 353 354 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 entering -- MS. IIII: When he opened the door, he yelled get the cutter. MR. -- the cell? MS. I had the audio on. MR. . Was he already in the cell at that time? Or had he not yet gone in? MS. : He was in the cell. MR. : So he walked into the cell and he yelled out? Did he come back out of the cell and yell to you? MS. : No. MR. He yelled from within? MS. Yes. MR. Could you see him at that time? MS. Could I see him? No. MR. . No? And from eh time that he was discovered to the time of your call, about how much time passed from him saying - entering the cell - and the time that the medical emergency was called by you. MS. : A - MR. Are we talking about like five seconds -- 1 MS. : Yeah. 2 MR. -- one minute or -? 3 MS. A second. As soon as he said 4 it I did it. 5 MR. Oh so like there's just 6 button that ou hit? 7 MS. : Yeah. 8 MR. : So you -. 9 MS. : Because the button is on my 10 radio. 11 MR. And did you call it in at 12 that time? 13 MS. IIII: No once you hit it, everybody's 14 coming. 15 MR. : Alright. So there's 16 nothing that you call in. You just push a 17 button. 18 MS. : Yes. 19 MR. : Alright. So at the 20 second he told you get the cutter, you hit the 21 medical emer ency? 22 MS. : Yes. 23 MR. : Did he say anything about 24 what he saw? 25 MS. IIII: When he got - when he entered 355 1 the room, and he said get the cutter, before I 2 got the cutter, I heard him tear something. 3 And then when he lowered him to the floor, 4 that's when I saw him and he started CPR. 5 MR. : Alright. So he never 6 said like Epstein hung himself or what he saw. 7 He just said get the cutter. 8 MS. IIII: He said get the cutter. And 9 then he started CPR. And he kept saying, 10 "Breathe, Epstein, breathe!" And he was like, 11 "We're goiiiiiiiiiiin so much trouble." 12 MR. : And where were you when 13 he was doin that? 14 MS. : On the grill. 15 MR. . Were you in a position to 16 be able to see anything in there? 17 MS. : No. 18 MR. . At any time did you see 19 anything in there? 20 MS. : No. 21 MR. Did you ever see Epstein 22 in the cell? 23 MS. 24 MR. So you never even went 25 over to like look in? 356 1 MS. 2 MR. : Okay. So you didn't 3 actually have to call anything over the radio. 4 It was just a simple push of a button. 5 MS. : 6 MR. 7 you say E 8 MS. 9 MR. 10 MS. : 11 they fed him in 12 8:00 or 9:00. 13 MR. 14 9:00 p.m.? 15 MS. IIII: When I came back from the 16 bathroom. 17 MR. And who was it that fed 18 him? 19 MS. 20 MR. You fed him. 21 MS. 22 MR. And did you say at that 23 point did ou actually talk with him? 24 MS. : No. 25 MR. : Okay. And did you or A button. And around what time did was last fed? After 10:00. : After 10:00 p.m.? I mean - not after 10:00. When the cell around - I guess after Sometime between 8:00 and EFTA00117731 357 1 anyone else recover his food tray? 2 MS. IIII: I don't know if somebody did. 3 Not me. 4 MR. : Okay. But you didn't do 5 it? 6 MS. : No. 7 MR. : Who else could have done 8 it if it wasn't you? 9 MS. IIII: I don't know because after the 10 medical emergency, nobody's allowed to go in 11 the room. So. 12 MR. : So you're just not sure 13 if by the time you fed him, in that medical 14 emergency if it was ever recovered? 15 MS. : Ri ht. 16 MR. : Okay. Alright. So when 17 you fed him - can you just again refresh my 18 memory - what is it that you saw with Epstein 19 when you ave him the food? 20 MS. IIII: He gets like microwaveable 21 food. So I just handed it to him. Through the 22 slot. And he took it. 23 MR. : Okay. And any instances 24 where you saw him from the shower to the last 25 time you said you saw him between 10:00 and 358 1 10:30 or whatever that was. Anything unusual? 2 MS. No. 3 MR. : Nothing that caught - 4 raised sus 5 MS. 6 MR. : No like distress or 7 anything like that with him? 8 MS. : No. 9 MR. : And you're sure when you 10 saw him at 10:00 - 10:30 he was alive? 11 MS. Yes. (Indiscernible *04:17:41) 12 MR. : I'm sorry what? 13 MS. Yes. He put his hand up. 14 MR. : He put his hand up. 15 MS. Mm-hmm. 16 MR. : And he wasn't like 17 hanging a ainst the bed when he put it up? 18 MS. No. 19 MR. : Where was he located? 20 MS. on the floor. On a mattress. 21 MR. : So he was like sleeping? 22 MS. He was laying on the floor on 23 the mattress and he had the machine. 24 MR. : And he had the machine on 25 him? 359 1 MS. : Mm-hmm. 2 MR. : Okay. 3 MR. : When you looked through his 4 window. 5 MS. Mm-hmm. 6 MR. : Right. What of his body 7 could you see? 8 MS. IIII: Um his head, his hand, and like 9 maybe to mid-there. 10 MR. : The best of the body was -? 11 MS. Like under his head. Mm-hmm. 12 MR. : So he was laying facing the 13 wall? 14 MS. IIII: Yeah. He was facing like this 15 big (Indiscernible *04:18:24) is this way. The 16 mattress was here on the floor. Like in front 17 of the bunk on the floor. 18 MR. : And the CPAP machine was it 19 already attached to him? 20 MS. : Yeah. He had it on. 21 MR. : I'm not following what 22 you're saying about that. So the mattress was 23 laying like -. 24 MS. IIII: The mattress was like how you 25 just take it off the bunk and you put it on the 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 360 1 floor. 2 MR. : Yep. 3 MS. : Well he shoves it to the 4 corner. 5 MR. : And he was laying on - 6 was he laying on it like the direction of the 7 mattress lines? 8 MS. IIII: That the mattress is going. Yeah. MR. : Alright. So he wasn't like L or a T shape -- MS. MR. MS. MR. No. • -- with the -. Alright. So he was like MS. : Direction of the mattress. MR. : Okay. You want to ask more on that? MR. M.o. lust had that quick. MR. : And you said to your knowledge, no one else saw him between the time you last saw him and when discovered him. MS. IIII: Right. EFTA00117732 361 1 MR. Did you hear anything 2 from Epstein's cell between 10:30 p.m. and 6:33 3 a.m.? 4 MS. : No. 5 MR. : No like movement, 6 talking, or a crash? 7 MS. No. 8 MR. Anything like that? And 9 about how far were you from Epstein's cell when 10 went in? 11 MS. IIII: I don't know. The grill is 12 right here and the door is right here. 13 MR. So I mean is it like - so 14 this is a foot, this is two feet, this three 15 feet. 16 MS. : A foot. 17 MR. A foot? 18 MS. : From the grill to the door 19 right here. But he's inside. So. 20 MR. Right. 21 MS. . I'm not in there. So from the 22 grill to the actual door about a foot. 23 MR. • Only about a foot? 24 MS. Yes. 25 MR. Now was the grill door - 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 362 is that a door that is closed? Was it closed or was it_aptn? MS. IIII: I opened it. And then goes in. MR. when MS. Okay. So was it open entered Epstein's cell? I opened it. I opened the grill for him in. MR. : Right. open? MS. MR. behind you? MS. IIII: No. open. MR. away from MS. MR. MS. MR. didn't you look in? MS. IIII: Because usually the door is not open. His intentions is to feed. So he would just open the slot and put the food in. When And did it remain but I'm -. Or did you close it I'm standing there so So you're only a foot E stein's cell door though? Yes. it's And you never looked in? Was it because - why 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 363 he knocked, he didn't get no answer. So that's when opened the door and went in. I stood on the grill. And as soon as he opened the door and he went in, he started screaming, "Get the cutter!" So I hit the body alarm because I have to - when everybody's coming, I have to let them in. I never went in. MR. : Okay. So after he made the call, did you go get the cutter and bring it back to him? MS. IIII: No. I didn't get the cutter because he didn't need it. MR. Because he ripped something? MS. : Yes. MR. : And you actually heard it rip? MS. : I heard the rip. MR. : Okay. And the reason why - and then you left the grill to go let people in? MS. : Yes. MR. : Alright. So how long after Mike went into the room did you leave the grill station door that was a foot 364 1 away from E stein's door? 2 MS. : Ma be like two three minutes. 3 MR. So you were there for two 4 or three minutes while he was conducting CPR? 5 MS. Yes. 6 MR. And at that time, never 7 once did you actually look in to see what he 8 was doing? 9 MS. : No. 10 MR. : Even though it was just a 11 foot away? 12 MS. Ri ht. 13 MR. And that's what I'm 14 asking you. 15 MS. IIII: No by that time, when he's 16 conducting CPR, I can see because he lowered 17 him to the floor and I could -. 18 MR. : And that's what I'm 19 asking. So you could see him lower him to the 20 floor? 21 MS. IIII: Yeah. I could see when he 22 lowered him to the floor. 23 MR. : This is where I want to 24 make sure that we're -. I'm asking you what 25 could you see inside? EFTA00117733 365 1 MS. IIII: Oh no. I can't see inside the 2 cell. I could onl just see doing CPR. 3 MR. : But you saw him lower him 4 to the floor? 5 MS. IIII: Yes. He lowered him to the 6 floor and I -. 7 MR. : So this is what I want to 8 know. What did you see? So what you could see 9 from where you were standing? What could you 10 see? Everything. Because I'm getting confused 11 with what you're telling me. I thought you 12 said you never looked in. You never saw 13 anything. What did you see? From the moment 14 the medical emergency occurred. So he walked 15 to the door -. 16 MS. : When he -- 17 MR. : -- what do you see? 18 MS. : -- goes in the door first, I 19 don't see anything. I hear the rip and then he 20 lowers him to the floor -- 21 MR. : Okay. So just back up -. 22 What do you mean by lowering him to the floor? 23 Did you watch him rip or just heard? 24 MS. : I heard the rip. 25 MR. Okay. 366 1 MS. IIII: I only see -. It's just like 2 this. He's holding him like this. And he puts 3 him to the floor to start CPR. 4 MR. : Did he put his arms 5 underneath_Lestein's arms? 6 MS. IIII: I don't remember how he held 7 him directly. But he just lowered him to the 8 floor. I don't remember how he - the details 9 of how he lowered him to the floor. 10 MR. : So he - somewhere on his 11 upper body then lowered him to his like butt to 12 the floor? 13 MS. : Yes. 14 MR. : And then he then allowed 15 him to dri2p?_ Or did he place him -? 16 MS. IIII: No. He didn't allow him to 17 drop. He had him all the way. 18 MR. : So at all times he 19 maintained control of Epstein's body and brough 20 him to the floor? 21 MS. : Yes. 22 MR. : And you witnessed all of 23 this? 24 MS. IIII: I just only witnessed when the 25 top part of his body went to the floor. 367 1 MR. Okay. And at any time 2 did like - and we have to ask this just because 3 of you know, the autopsy and things like that. 4 Did his head smash against the floor? 5 MS. • No. 6 MR. Alright. So everything 7 was like a entle like -- 8 MS. • Yes. 9 MR. -- fluid movement? 10 MS. Yeah. 11 MR. . From you heard it rip. 12 Did you ever hear like [sound)? Hear him like 13 land on the floor? 14 MS. • No. 15 MR. . So you didn't hear like 16 alright, he ripped this thing. So you think he 17 ripped it and then maintained control of him? 18 MS. IIII: Probably. I didn't see that 19 part. I iiiiiiiiiiheard the rip. 20 MR. : Alright. But you did see 21 -. Did you see his body after the rip hit the 22 floor? 23 MS. 24 MR. Alright. So he's on the 25 floor. Maybe like his butt's on the floor and No. 368 1 his upper body is up. And that's when you 2 witnessed him now bringing him down to the 3 floor? 4 MS. IIII: He brought him down to the 5 floor. I can't see that other half of his 6 body. So I don't know. lust -. 7 MR. : What part of his body do 8 you see? 9 MS. IIII: Just the top part like torso up 10 and he's brio in him down. 11 MR. : Alright. And then did 12 you see him -? When you say CPR, what kind of 13 CPR was he iving him? 14 MS. : Chest compression. 15 MR. Any kind of mouth-to- 16 mouth of breath? 17 MS. • No. 18 MR. Did he ever check for his 19 vitals? Did he ever check to see if he was 20 alive first? 21 MS. I don't know. 22 MR. . You don't know. Did you 23 witness him check for breath or check for a 24 pulse? 25 MS. IIII: I didn't see that. EFTA00117734 1 MR. 2 MS. : No. 3 compressions. 4 MR. 5 like try to wake him 6 like that? 7 MS. No. 8 MR. 9 communication with 10 this? 11 MS. : No 12 MR. What were you saying 13 about we're going to be in so trouble. When 14 was that -? 15 MS. Eir said that. 16 MR. That's what I'm asking. 17 Did you have a conversation - did you have any 18 communication with -? 19 MS. Oh no. No. 20 MR. Well you did have that 21 right? 22 MS. IIII: No he said we're going to be in 23 so much trouble. I didn't say anything. 24 MR. Okay. So what statements 25 did he make to you? 369 You didn't see either? I just seen him giving Alright. Did you see him up or hit him or anything lust compressions. Did you have any while he was doing 370 1 MS. IIII: Get the cutter. And then I 2 heard the rip. He lowered him to the floor. 3 He was doing CPR. He said, "breathe Epstein 4 breathe" and he said we're going to be in so 5 much trouble. But I never said anything. 6 MR. You didn't respond to 7 "we're goin to be in so much trouble"? 8 MS. : No. 9 MR. Do you know why he said 10 you're goin to be in so much trouble? 11 MS. Because we didn't the count. 12 MR. Okay. 13 MS. GREGG: I think it's important though 14 that you convey to him like - that you didn't 15 understand the magnitude of what had just taken 16 place. Right? Because that's something that 17 you had expressed. So like not knowing what a 18 cutter was. And maybe that gives insight into 19 why there wasn't a more in-depth conversation. 20 I think it's important that -. 21 MS. IIII: Yeah. When he said to get the 22 cutter, like I would have to go try to look for 23 where a cutter was. But he didn't need it 24 because I heard the rip. And then when he said 25 we was going to be in so much trouble, like I 371 1 still wasn't thinking like the trouble that 2 we're in now. I was just probably thinking 3 because I know we didn't do the count. But I 4 never responded because all the inmates by this 5 time are on the door. 6 MR. 7 watching? 8 MS. Yeah. 9 MR. This all take place? 10 MR. : I've got a question. 11 MR. Yeah. Go ahead. 12 MR. : You said you opened the -- 13 MS. The grill. 14 MR. -- the grill. Did he have 15 keys to o en Epstein's cell? 16 MS. Who 17 MR. 18 MS. : Yeah. He as the door keys. So 19 there's two separate set of keys? 20 MS. Yes. 21 MR. : So he - that's the keys that 22 stayed with him the whole time? 23 MS. Yes. 24 MR. : But those door keys -. So on 25 the keychain that you have. What does that Because they're all 372 1 open? 2 MS. : The grills. 3 MR. : That's it? 4 MS. : There's other keys. The grill, 5 the front door, that middle door, but not the 6 inside cell door key. 7 MR. : That's with 8 MS. Yes. 9 MR. : Now when you look inside the 10 cell, you said you could see only Epstein's 11 upper body__Where was he hanging? 12 MS. IIII: I don't know. I didn't see 13 that part. 14 MR. : And when you heard the thud, 15 or you know, the rip and then the body landing. 16 Did you look inside to see what he was doing? 17 MS. IIII: When he - when the body -. 18 Because when he lowered the body, he stepped 19 back like to come like it's almost like he was 20 backing up because you're bringing him down. 21 So that's how come I was able to just see that 22 part. But I didn't like to go look in the 23 cell. I was still on the grill. 24 MR. : So that's what I was trying 25 to understand. Where exactly was he hanging? EFTA00117735 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 373 MS. IIII: I don't know that because I don't know where he took him down from. I just only heard the rip and then when he was walking the body like down. MR. : So he was - basically his arms were behind Epstein? MS. IIII: Right. And he was bringing him -. MR. : And he was pulling him up? MS. -- bringing him down. MR. : Was there a mattress on the floor? MS. IIII: Well I'm assuming because the mattress was on the floor earlier. But I don't know. MR. standing, MS. MR. like on to MS. MR. So from where you were ou couldn't see the actual mattress? : Mattress? No. SO he wasn't doing CPR of the mattress? : No. Not that I can remember. Do you remember what Epstein was wearing? From what you could see from his -? MS. IIII: He didn't have a shirt on. 374 1 MR. So not even like a ripped 2 shirt? Nothing was on? 3 MS. : He didn't have a shirt on. 4 MR. : Okay. At that time when 5 you saw him, did you see anything around his 6 neck? 7 MS. : N 8 MR. And when you say no, are 9 you saying_/here was nothing around his neck? 10 MS. fl: No. There was nothing around 11 his neck. 12 MR. : So there was nothing 13 around his neck? Okay. What did he look like? 14 MS. : Blue. 15 MR. : He looked blue? Did he 16 look like bloated or puffy or anything? 17 MS. No. 18 MR. Did he look like he was 19 deceased? 20 MS. : His face looked blue. But. 21 MR. Any reason for you to 22 believe that he was alive? 23 MS. 24 MR. No? Did you see any kind 25 of breath or anything? 375 1 MS. : No. 2 MR. : No? What did his cell 3 look like from what you could see? 4 MS. IIII: I wasn't really looking at his 5 cell. By that point I was just looking at 6 doing CPR. I didn't look in there to 7 see what was oin on. 8 MR. : Okay. So you didn't 9 notice an thing like unusual in his cell? 10 MS. : No. 11 MR. : When went to his 12 door, did you notice if he actually had to use 13 his key to open it? Or was it - do you know if 14 it was actually already -? 15 MS. : He used a key to open it. 16 MR. : So are you confident that 17 that door was locked? 18 MS. IIII: Yes. Because he knocked. And 19 then he used the key to open it. He knocked. 20 He knocked. He didn't get a response. And 21 then he used the key to open. 22 MR. : Was there any indication 23 that any of the other inmates could have gotten 24 out of their cells? 25 MS. IIII: No. 376 1 MR. : And you said you don't 2 know if actually checked to see if he 3 was alive? 4 MS. : Yeah. I don't know. 5 MR. : You just know he went 6 straight into compressions. And did you say 7 you were two or three minutes that you stood 8 there? How long were you actually at the grill 9 when they walked into the door? 10 MS. IIII: When I went to go get them to 11 come in the door? Between the time - 12 MR. : So you let -. 13 goes in. He goes into the room. He's making 14 these - you know you're watching him do some 15 compressions. He makes the statement, "we're 16 going to be in so much trouble." How long are 17 you standiag_there while you're observing this? 18 MS. IIII: About one to two minutes. 19 Because I'm waiting for - the radio is going to 20 tell me when everybody's -. Because remember, 21 once I hit that button, everybody's coming. So 22 the radio is going to tell me when everybody's 23 at - when they're at the door. And then when I 24 pop the door and let them in. So I go to the 25 door. EFTA00117736 377 1 MR. And you never entered 2 Epstein's cell? 3 MS. . No. 4 MR. : Who was the second person 5 to enter E stein's cell? 6 MS. IIII: That I don't remember because 7 everybody came right at the time I don't 8 remember. 9 MR. Okay. So you don't 10 remember the first person on the scene? 11 MS. : No. 12 MR. Did you assist at all 13 with the medical emergency? 14 MS. 15 MR. . No? So what actions did 16 you take after people arrived? What did you 17 do? 18 MS. IIII: Nothing. They told me to get 19 out the wa . 20 MR. : So did you like leave the 21 tier? 22 MS. IIII: I was on the bottom of the 23 stairs. Mm-hmm. 24 MR. Like observing? 25 MS. : Mm-hmm. Yes. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 378 MR. Okay. What did you observe from the bottom of the stairs? When people arrived? MS. IIII: They got a stretcher. And they put him on the stretcher. And brought him out. MR. Did anyone take over for the CPR efforts that was doing? MS. : I don't remember. MR. You don't remember seeing this? So this isn't something that's vivid in your memory? You know like this whole big occurrence. You're not almost like you're playing it in slow motion? MS. MR. MS. : No. The details of it? : No because when was doing CPR. Then when they came, they took the stretcher and put him on the stretcher and left. As far as when they're -. Remember it's a lot of people. So I'm not really seeing like who's twoliiiiiiiiihey're coming out with him. MR. : About how many people responded? MS. IIII: Mm. I don't know. Maybe 10, 15. 379 1 MR. And they didn't know what 2 they were responding to? They just knew it was 3 a medical emergency. It wasn't announced that 4 it was Epstein. 5 MS. IIII: No. There ain't nobody that 6 (Indiscernible *04:31:48). 7 MR. : And is that typical for 8 10 to 15 people to respond? To a medical 9 emergency? 10 MS. IIII: It - there's no number. It's 11 when - whoever is in the building and the body 12 alarm goes off once you're not in a post - 13 because when you're on a post you can't leave 14 your post. But everybody else in the building 15 responds. 16 MR. And they just leave 17 wherever the were? To respond? 18 MS. : Yes. 19 MR. Okay. 20 MR. I've got a question. 21 MR. Go ahead. 22 MR. : When a body alarm is hit, who 23 gets notified? 24 MS. : Control. 25 MR. : And how do they differentiate 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 380 between an inmate altercation versus a medical emergency? MS. IIII: I mean the person that's hitting the body alarm can say it. But there's no differentiation. So either way the response is the same. MR. : So you could have said it. You ,Ls didn't say anything. MS. IIII: Like when I hit the button, I could have said a medical emergency on the radio. Yeah I could have said that. MR. But you didn't. MS. No because it's the same response. MR. Right. MS. Mm-hmm. MR. Has anybody ever hit it accidentall MS. MR. MS. MR. Yes. And same thing. And people just rush? Everybody comes. Yes. Okay. Alright. You said you stood there for a little while on the bottom of the steps. You observed some people going in. You don't know who took over CPR. EFTA00117737 381 1 You just saw 2 MS. : I don't know. 3 MR. -- who put up. Do you 4 remember who put him on a stretcher? 5 MS. : I don't know. 6 MR. Did you see the body like 7 fall or an thing going on the stretcher? 8 MS. : No. 9 MR. Did he ever fall off of 10 the stretcher? 11 MS. : 12 MR. Did anyone drop the 13 stretcher? 14 MS. 15 MR. . When they were moving 16 him, did you see him like get knocked or 17 anything like that? 18 MS. : No. 19 MR. : No? Anything then - did 20 you notice anything that could have caused 21 additional injuries to his body aside from what 22 the hangin would have caused? 23 MS. : No. 24 MR. : No? What did do 25 after people responded? 382 1 MS. IIII: After they took him out on the 2 stretcherj_tg_l_tL 3 MR. IIIIIIIIII: So not after the 4 stretcher. Once at least one person showed up. 5 Do you know what did? 6 MS. IIII: No because I'm at the bottom of 7 the stairs. So I don't know. Because they're 8 - remember they're on the top. I'm at the 9 bottom. So I don't know. 10 MR. : So could you even see in 11 at all at that point? 12 MS. IIII: No. I could only see when they 13 coming down with him on the stretcher. Because 14 I'm at the bottom. I can't see up there now. 15 MR. : Okay. So after you were 16 standing there when you let people in, you 17 really couldn't see in the door anymore? 18 MS. : No. 19 MR. Okay. What happened 20 after the came out with the stretcher? 21 MS. They left out of SHU with him. 22 MR. Did you go with them? 23 MS. I had to stay. 24 MR. You stayed in SHU? Did 25 anyone stay with you? 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 383 MS. MR. . So you were there alone? MS. Alone. MR. And what did you do at that time? MS. IIII: I kept calling control. Like what's going on? And they was like somebody's going to come like to help you. Because remember we were supposed to feed. MR. Who was it -? How long were you in the SHU by yourself after they left? MS. Um... Maybe like 20 - 15 or 20 minutes. MR. So just -. Do you remember if -? Now I want to say these names to make sure that they were actually there. Do you remember if the fir2I22Lon to arrive in the SHU was Lieutenant =I M? Does that help spark a recollection of who arrived first since you were the one that let them in? MS. IIII: When the medical -. I don't know who arrived first. But he was in there. MR. : Because you're the one that had to let them in. Right? 384 1 MS. IIII: Yeah. But I don't remember who 2 came in first. But he was there. When 3 was there I remember 4 MR. 5 MS. Yes. 6 MR. Do you know how to spell 7 that last 8 MS. 9 MR. Okay. And did you say 10 anything to the people that arrived? 11 MS. : No. 12 MR. : You didn't say like it's 13 Epstein of_&2stein hung himself or anything? 14 MS. IIII: No. The only thing they asked 15 -. Because when they come on, they want to 16 know where the emergency is. So I just pointed 17 up the stairs. 18 MR. : Okay. Did you make any 19 statements to anybody about saying we didn't do 20 rounds at 3:00 a.m. and 5:00 a.m.? 21 MS. IIII: No. After Lieutenant IIII 22 asked me what happened. When I was getting 23 ready to answer him, came off the 24 elevator and was like, "Oh it's not her fault. 25 We fucked up." EFTA00117738 1 MR. 2 "We didn't do 3 MS. 4 MR. 5 it's not your 6 messed up? 385 So at first did you say, rounds at 3:00 a.m. -- No. -- and then he responded fault we didn't do the rounds we 7 MS. : No. I didn't say that. 8 MR. So that's not your 9 recollection that you saying we didn't do the 10 3:00 a.m. and 5:00 a.m. rounds? 11 MS. : No. 12 MR. : Okay. So they're saying 13 that you said that. Do you think that they're 14 mistaking? That you told them that? 15 MS. : I don't recall saying that. 16 MR. : Okay. So you don't 17 recall. But is it possible that you could have 18 said that? 19 MS. IIII: Probably but I don't recall 20 saying that. I remember Lieutenant asked 21 me what happened. And I was getting ready to 22 tell him what happened. And came off 23 the elevator and said that. But I don't recall 24 saying that. 25 MR. And this is after 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 386 came back from bringing Epstein down? MS. IIII: Well he went down with them. Yes. MR. : And then he came back? So when you say by the elevator where was the elevator? MS. : In the hallway. MR. SHU? MS. IIII: Like right the door the first Outside the SHU? In the door. CThe MR. : The first door of what? MS. : SHU. MR. : So is that outside of the SHU? MS. IIII: Like right outside the door. The SHU door. MR. Outside of the second outer door? MS. : Yes. MR. So right outside of the outer door? This is where you had a conversation with who? MS. : Lieutenant IIII. MR. Who else was present? 387 1 MS. IIII: Nobody else. Just me, him, and 2 3 MR. Okay. And he asked you 4 what happened? 5 MS. IIII: He asked me whatt!pkened. And 6 the elevator door opened. And came off 7 the elevator. I was getting ready to answer 8 him. And said, "It's not her fault. We 9 fucked up." 10 MR. 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 And do you know why he made that statement? MS. IIII: I think because we didn't do the counts. Or he -. MR. : But why did he say it wasn't your fault? MS. IIII: Because I kept waking him up. So maybe that's why he said that. MR. : Was he trying to take more of the responsibility? MS. 'Suess so. MR. : Would that be? Um. Alright. Is it true that if the count is not done and the round sheet which is filled out after 30 minutes also cannot be completed? MS. IIII: If the -? 388 1 MR. From 12:00 a.m. to 6:33 2 a.m. That's not actually my question. From 3 12:30 to 6:30 a.m., none of the rounds or 4 counts were completed. Correct? 5 MS. : Correct. 6 MR. : Alright. Is it true that 7 end of the shift the supervising lieutenant 8 signs and sends the completed log of the inmate 9 movements from the day? Do you know if that's 10 true? 11 MS. IIII: I don't know what they sign, 12 but they sign something. I don't know what it 13 is. 14 MR. 15 instance the 16 sign that? 17 MS. 18 MR. 19 count sli s do they? 20 MS. : No. 21 MR. 22 MS. 23 MR. Okay. And what is your 24 belief or understanding of how Epstein died? 25 MS. IIII: Mm. He hung himself. Do they sign like for round sheets? Do the lieutenants : Yes. They sign that. But they don't sign the lust the round sheets? EFTA00117739 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 MR. took his own life? MS. : Yes. MR. Epstein's life? MS. : N MR. • Did with takin his life? = MS. : No. MR. : Did life? MS. : N MR. . Did with takin his life? MS. : Na. MR. : Did with takin his life? = MS. : No. MR. : Did life? 389 MR. So you believe he was dead upon entering into the cell? MS. : I don't know. Because I just assumed he hung himself. Because I read the (Indiscernible *04:38:24). So do you believe Epstein Did someone else take anyone assist Epstein take Epstein's assist Epstein you assist Epstein you take Epstein's 390 1 MS. : No. 2 MR. : Did you have any part in 3 Epstein's death? 4 MS. : No. 5 MR. Prior to Epstein dying, 6 did you have any communications - verbal, 7 electronic, handwritten, or otherwise - with 8 anyone - BOP staff members or otherwise, about 9 the safet and wellbeing of Epstein? 10 MS. : No. 11 MR. : Alright. Do you need me 12 to -? That was pretty long. Did you catch 13 everythin I just asked you there? 14 MS. : Yes. 15 MR. : This is going to be 16 another long one. Prior to Epstein dying, did 17 you have any communications - verbal, 18 electronic, handwritten, or otherwise - with 19 anyone - BOP staff members or otherwise -. And 20 when I say otherwise I mean like civilians, 21 inmates, ou know anybody on the streets. 22 MS. : Okay. 23 MR. : About the death of 24 Epstein or taking Epstein's life? 25 MS. IIII: No. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 391 MR. Did anyone ever offer you anything such as something of value or favors with regard to harming Epstein or taking his life? MS. : No. MR. : Did anyone ever threaten you in exchange for harming Epstein or taking Epstein's life? MS. : No. MR. Do you know anyone else that those uestions would have applied to? MS. : No. MR. Do you know of anyone else being offered anything to hurt Epstein or taking his life? MS. : No. MR. No? Why wasn't Epstein in his assi ned cell on August 10, 2019? MS. That was his cell. MR. It wasn't. This is the first you're hearing of that? MS. MR. So he wasn't in his assigned cell. MS. IIII: What? I never knew that. 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 reviewing - as your assignment, duties, and 392 MR. Did you - but it kind of doesn't surprise me because you said that you didn't even know who was in what cell. You just looked to see if people -. So Epstein is assigned to the cell across the hall. He wasn't in the cell that he was actually assigned to. Do you -? MS. IIII: Wait. You said across the hall? So like not in SHU? MR. The same tier. But you know -- MS. 0 MR. -- they do inmate cell rotations? MS. MR. • So you do not know that inmates are moved from different cells? MS. IIII: Yeah. I know that. They move you said if I know how they do that? I don't know that. MR. • Do you know how often? MS. : Often they do that? I'm not sure. MR. Are you responsible for EFTA00117740 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 393 responsibilities within the SHU - of verifying that the inmates are in the cells that they're assigned to? MS. IIII: I don't know if I'm responsible for but there is -. Their ID cards are on the door. MR. : Was Epstein's ID card on his door? MS. No. Not all of them. MR. : Okay. Was there anything else on the door? MS. No. MR. : Was there anything on the door that said something about him being required to have a cellmate? MS. : No. MR. : So you don't know anything about him not being in his assigned cell? MS. : I never knew that. MR. : Okay. So this is the first you're even hearing about it even since the incident? MS. Ri ht. MR. : So you -? 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 394 MS. IIII: So you said he was assigned to the cell across from him? Because that had people in it. MR. : He was - yeah. Because of cell rotations. It doesn't mean that -- MS. : Oh okay. MR. : I think as far as you were concerned, he was in that cell. You didn't move him to a different one. But administratively, he was in a different cell and was moved and the assignment didn't follow him. MS. MR. Oh, okay. : So on paper, he was supposed to be in one cell. In reality he was in another. MS. : Okay. MR. : So if you look in the system and find out hey where was Epstein supposed to be? He was supposed to be over here from the paperwork in the book. MS. Oh okay. MR. : He was physically located over here. MS. IIII: Okay. 395 1 MR. Did you ever have any 2 dealings with that? 3 MS. I never even knew that. 4 MR. so is this the one he was 5 s actuall 6 MR. : Yeah. 7 MR. : So he was in cell 220. 8 He was assi ned to cell 206. 9 MS. : Mm. 10 MR. : But that's not something 11 you dealt with? 12 MS. . No. 13 MR. Did you ever deal with 14 rotating the inmates into different cells? 15 MS. . No. 16 MR. Do you know who deals 17 with that? 18 MS. : No. 19 MR. : Do you ever see them get 20 rotated? 21 MS. : On the 8:00 to 4:00. 22 MR. : While - yeah. That's 23 what I'm asking. I'm not saying just for 24 Epstein. I'm saying like in general, have you 25 ever witnessed inmates being rotated to 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 396 different cells? MS. : One time. MR. : One time? And how was that - how does that playpjf__ MS. Il think - the day when I saw it, was doing it. Like I don't know. They told them to pack up. They pack up they stuff, two people move them, and they go to the cell that they supposed to go. MR. : And then do you know what they're supposed to do at that point with - in order to make sure the paperwork follows them - MS. MR. MS. MR. : Oh. I don't know -- -- to that cell? • -- about the paperwork. Do you know who is responsible for that? MS. : No. MR. : Would it be the lieutenant in your opinion? Or you just don't know. MS. I ust don't know. MR. Okay. And is that anything you've ever dealt with as far as like EFTA00117741 397 398 1 training or that you recall? 2 MS. : The cell rotation? No. 3 MR. : Do you know if it's 4 supposed to be every certain amount of days? 5 MS. IIII: I know it's supposed to be 6 every certain amount of days, but I don't know. 7 MR. : Do you remember Epstein 8 ever bein2_21signed to cell 206? 9 MS. IIII: I don't know where cell 206 is. 10 That's the one across from where he was at? 11 MR. : They're both on L Tier, 12 so I'm just assuming. 13 MS. : Oh. 14 MR. : Because there's the 15 paperwork that shows that's not even the 16 number. 17 MS. IIII: Yeah. The number is not on 18 here. I don't know what cell is 206. But -. 19 MR. : So when you're in the SHU 20 in July and August when he was - when Epstein 21 was assigned to the SHU. Do you recall him 22 ever being in a different cell than the cell 23 you found him in - or round him in on 24 August 10th? 25 MS. IIII: Yes. He was downstairs. 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 MR. MS. : Downstairs? On I think M tier with . Because that was his cellmate first. MR. : Alright. So what about on L Tier? You ever remember him being in a different cell up there? MS. No. MR. : No? MS. MR. : Alright. So. So the incident happened on July the 23rd. He comes back on July 30th. From your recollection from eh time that he came back and he was with , he was always in that same cell? MS. IIII: And in that (Indiscernible *04:44:20 cell? MR. : Alright. So maybe he wasn't rotated but on paper it was rotated? MS. : Ma be. MR. : But you don't know anything about it? MS. I don't know anything. No. MR. : Okay. Do you know what 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 399 BOP database tracks that? MS. : No. MR. : Why were there pill bottles found on the top bunk of Epstein's cell? MS. : I don't know. MR. : Do you know anything about like medication or what was found in there? MS. : No. MR. : Do you have any idea what was even -? Did you ever go in Epstein's cell prior to this incident? MS. : No. MR. : Do you know if Epstein was authorized to have pills in his cell on the SHU? MS. : I don't know. MR. : Do you know if that's like abnormal or are inmates allowed to have medications in the SHU? MS. MR. MS. MR. : No. • They're not allowed to? : They're not allowed. Even if it's prescription 400 1 medication? 2 MS. : I don't know. 3 MR. Do you ever provide 4 inmates prescription medication when you're 5 working in the SHU? 6 MS. : No. The nurse does. 7 MR. The nurse comes around? 8 MS. Yeah. 9 MR. So is that surprising to 10 hear that there were medication in his cell? 11 MS. : Yes. 12 MR. : And you knew nothing 13 about that being in there? 14 MS. : No. 15 MR. : Is it SHU policy for 16 things like medication - is it different than 17 the other housing units? 18 MS. IIII: Yes because I think on housing 19 units they can have prescription medication in 20 their cell. 21 MR. Okay. 22 MS. But in SHU they can't. 23 MR. And do you know that to 24 be a fact? Or is that just your belief? 25 MS. IIII: I don't know it to be fact. EFTA00117742 401 1 MR. Okay. Do you know if any 2 other inmates in the SHU are allowed to have 3 medications in their cell? 4 MS. : I don't know. 5 MR. : How many changes of 6 clothing and linens are inmates allowed to have 7 in the SHU? 8 MS. : I think one. 9 MR. It's supposed to be a 10 one-for-one exchange? 11 MS. : Yes. 12 MR. for both linens and 13 clothing? 14 MS. IIII: For linen. I'm not sure with 15 clothing. 16 MR. Okay. Why did Epstein 17 have extra clothing and extra linens in his 18 cell -- 19 MS. I don't know. 20 MR. -- on August 10th? 21 MS. I don't know. 22 MR. : You don't know. But you 23 said that was something that you did though? 24 As far as your duties? Is to be able to 25 provide people with linens and clothes? 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 402 MS. IIII: I never gave out linen. Ever. Because that's done on the shift prior. MR. : What shift is that? MS. : 8:00 to 4:00. MR. : And did you ever work the 8:00 to 4:00 shift? MS. IIII: Yes. But I worked the 8:00 to 4:00. When I come in to do overtime before. But it's ncnaya in SHU. MR. IIIIIIIIII: Okay. So have you ever worked 8:00 to 4:00 in the SHU? MS. : I think I have. MR. : And do you remember doing giving - doing the linens? : I never gave linen. : You never gave linens. Never. What about the clothing? e. Never. When is that done? I give toilet paper. Say that MS. MR. MS. MR. MS. MR. MS. again? MR. done? MS. When is the clothing I don't know. 403 1 MR. No? And did you ever 2 provide Epstein with additional clothing or 3 linens? 4 MS. : Never. 5 MR. : Do you know of anyone 6 that has? 7 MS. 8 MR. You never witnessed 9 anyone provide him anything extra? 10 MS. : No. 11 MR. : Do you know if providing 12 inmates with extra clothing and linens is a 13 security risk? 14 MS. : I don't know. 15 MR. : No? If you saw that an 16 inmate had extra clothing or linens, would you 17 do anythin about it? 18 MS. : I mean I'd ask. 19 MR. : Who would you ask? 20 MS. The officer I'm working with. 21 MR. : And did you ever have to 22 do that? 23 MS. : No. 24 MR. : So you never witnessed 25 anybody? 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 404 MS. : Because I never saw it. No. MR. : Okay. And when you're looking in doing your counts and your rounds, are you looking for things like that? Of like MS. : Not really. MR. : You're just looking for the person? You're not looking to see what's going on in their cell? MS. IIII: Correct. Sometimes they don't even let you see their cell. They're like standing in the window blocking the window. MR. : But it's your understanding though it's supposed to be a one- for-one exchange? MS. : Yes. MR. Do you know what material was used to take Epstein's life in August of 2019? MS. MR. : I don't know. • Do you know if Epstein was given any special privileges to have extra clothing? MS. : I don't know. MR. : If he was, do you know EFTA00117743 405 1 who would rovide that? 2 MS. • I don't know. 3 MR. : Do you know if there was 4 anything else that was in Epstein's cell that 5 should not have been here? 6 MS. : Only the CPAP machine. 7 MR. : Okay. Tell me about cell 8 searches. What are the requirements for when - 9 you said your typical shift is I guess the 10 afternoon shift? Right? Or do you call it 11 evening shift I guess? 12 MS. Yes. 13 MR. Is that the 4:00 to 14 10:00? 15 MS. : 4:00 to midnight. 16 MR. : 4:00 to midnight. Sorry. 17 What are the cell search requirements during 18 that shift? 19 MS. I don't know. 20 MR. Did you ever read the 21 post orders with regard to that? 22 MS. : No. 23 MR. : But they're in the SHU? 24 You just didn't read them? 25 MS. IIII: Right. 406 1 MR. Do you want to - have 2 any? We're almost there. Well while I'm going 3 thought the uestions can you just find that? 4 MR. : Yeah. 5 MR. : Have you ever heard that 6 during your shift you're supposed to conduct 7 five cell searches? 8 MS. : No. 9 MR. Random cell searches? 10 MS. 11 MR. . Did you ever witness 12 anybody conducting cell searches when you -- 13 MS. • No. 14 MR. 15 MS. 16 MR. No. Do you know if any 17 cell searches were conducted on August 9th or 18 August 10th? 19 MS. 20 MR. Do you know what a cell 21 search is? 22 MS. IIII: When you go in there and search 23 their cell. 24 MR. Right. Of an inmate. 25 And you never observed that in the SHU? -- were working the SHU? 407 1 MS. : No. 2 MR. : Did they ever teach you 3 that during training that you're supposed to do 4 that? 5 MS. : Mm. I don't recall. 6 MR. : You don't recall? It's 7 just something that you never-ever witnessed? 8 MS. : Never. Never saw it. 9 MR. : Even when you were 10 working that like earlier shift? You know when 11 you're doing your OT or your regular shift? 12 Never once witnessed a cell search. 13 MS. : Never. 14 MR. : And do you know - of 15 things that you do know in there, would any of 16 that be considered contraband? That was in 17 there? Now that you know that medication was 18 in there. The CPAP machine. Or the extra 19 linens. Or the extra clothing. 20 MS. : In his cell? 21 MR. Mm-hmm. 22 MS. 23 MR. • Do you want to show her 24 some of these pictures just so she can get a - 25 know what we're talking about here? So is this 408 1 L Tier as we're referring to? And is the outer 2 gate that you were standing at that you were 3 talking about? 4 MS. : Yes. 5 MR. : Alright. And then when 6 you say you're staying at the lower part of the 7 steps, is it about right there that you were 8 standing? 9 MS. : I was standing over here. 10 MR. : Over there? Do you have 11 a pen? Do you just mind marking it? So that's 12 where you were standing? Alright. And in that 13 picture, can you see where Epstein was? 14 MS. : From down here? 15 MR. : No-no-no. I'm sorry. Is 16 his -? I'm assuming -. 17 MS. IIII: Oh! No-no-no. Because he's on 18 this side. 19 MR. : Right. So we can see 20 part of the two when it's crossed. But does 21 this look like Epstein's door? 22 MS. IIII: This is the first door on the 23 right. Yeah. 24 MR. And from what you can see 25 from where you were standing, did that look EFTA00117744 409 1 like what ou saw? 2 MS. IIII: I didn't see all of this. I 3 saw like here. Because I'm on the door. So 4 he's doing CPR like here. So I didn't see all 5 that. 6 MR. : Alright. So you couldn't 7 see all that extra clothing and linens right 8 there? 9 MS. No. 10 MR. : Does that look like a lot 11 of clothin and linen to you? 12 MS. • Yes. 13 MR. : Here's a couple extra 14 pictures of some different like advantage 15 point. Does that all look like extra clothing 16 to you? 17 MS. IIII: Yes. And there's the machine 18 right here. 19 MR. : That's the CPAC machine? 20 CPAP? 21 MS. Yes. 22 MR. : Okay. Again though, you 23 don't know what he actually hung himself with? 24 MS. I don't know. 25 MR. : Is this the way that he 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 410 would usuall lay on his bed? MS. Yes. MR. : Was he the top bunk guy then? And do you know where would usually slee MS. I don't know. MR. : Is it only like -? MS. Because he's always on the floor. MR. : Okay. But I see that the top one doesn't actually have it. It doesn't look like it has a -- Right. A mattress. -- mattress. So do you would sleep like right next to MS. MR. know if him? MS. MR. I don't know. • You don't? Did you ever check in on them when you were - or that was the first ni ht you said you -? MS. • That was it. MR. : So did you ever observe him in a sleep state before? MS. IIII: Because he's never really there. Epstein 411 1 MR. Yeah-yeah-yeah. I'm 2 saying during sleeping hours. Did you ever see 3 Epstein prior to this instance? Prior to 4 August 9th have you ever seen Epstein sleeping 5 in his cell? 6 MS. IIII: When he comes back he lays 7 there on the floor. On the mattress on the 8 floor. 9 MR. 10 that, would you see where 'has? Prior to 11 this incident? 12 MS. IIII: Oh be up. So I never 13 seen like where is. Like is always 14 up. 15 MR. 16 that room? 17 MS. : It was these two. 18 MR. 19 bunkbed? 20 MS. : Yeah. One. 21 MR. : So if I'm assuming if 22 he's sleeping on the floor then would be 23 sleeping next to him. 24 MS. IIII: There. But I don't know if 25 this was because wasn't there. Or he SO wiiiliou would observe Is there only one bunk in Yeah. So the one 412 1 could have been on top. I don't know. 2 MR. Okay. So if this is 3 where took him off of, is that what you 4 couldn't see that from the door form that 5 vantage point? 6 MS. : Yeah. I can't see that. 7 MR. : You couldn't see that. 8 Okay. So did you ever notice that type of 9 medication in there before? 10 MS. : No. 11 MR. : And that's 12 believe that shouldn't have been 13 though? 14 MS. • Yes. 15 MR. Does anything here look 16 out of the ordinary to you? With what -? 17 MS. IIII: What's in the (Indiscernible 18 *04:54:17 ri ht here? 19 MR. : I don't know. I'm asking 20 you. Does any of that look out of the ordinary 21 to you? 22 MS. IIII: Yeah. There's couple. 23 Whatever's in the bag. 24 MR. : Okay. But you never went 25 in there. You never saw any of this? something you in there EFTA00117745 413 1 MS. : No. 2 MR. : And cell searches were 3 never conducted. So no one even went in to 4 ever check to see what was in these cells. 5 MS. : Correct. 6 MR. : Here's three additional 7 pictures if you want to look. Does any of this 8 stuff look abnormal to you? 9 MS. • All these. 10 MR. Everything? Looks 11 abnormal? 12 MS. The medication. 13 MR. the medication? And it 14 was never discussed with anyone about cell 15 searches? Ever. In the three - you know two 16 and a half months that you were in there? 17 MS. IIII: That (Indiscernible *04:55:35) 18 in there. 19 MR. Okay. And did you ever 20 get to see what it was that Epstein used to 21 hang himself? 22 MS. 23 MR. • No. Alright. Rather 24 than have you do all those individual, I'm 25 going to just separate this. If it's okay with 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 414 your attorneys. Just have her do the top one. Unless you prefer to -. MR. FOY: No. That's fine. Initial that one. MR. Here. Keep these away from that. I'll just keep everything next to her anywa MR. : And the -. MR. That's fine. (Indiscernible *04:56:07) she didn't know about it anyway. How were Epstein's interactions with other inmates? MS. : I don't know. MR. Did you ever see him interact with other inmates? MS. : He's never there. No. MR. Did you ever see him interact with his cellmates? MS. : No. MR. No. You said -. But the last time you interacted with him was just that one raisin of the hand. MS. : Yeah. MR. : Was it surprising you to notice that there was no cellmate in there with 415 1 him? 2 MS. : No. 3 MR. : So did it even cross your 4 mind that there was always a cellmate with him 5 prior to that time? 6 MS. : No. 7 MR. : Did you ever -? Were you 8 ever told that was removed from the 9 institution? 10 MS. 11 MR. . And is that something - 12 being that's the high-profile nature that he is 13 that like -? Is that something that you would 14 notice though? That like hey this guy usually 15 has a cellmate. He's not in there right now. 16 Where is he? 17 MS. : N 18 MR. : Did even cross -? 19 MS. Cross my mind? No. 20 MR. Didn't cross your mind. 21 You're just looking at the people in there and 22 you're not worried about who is in there. The 23 people in there are alive. That's all you're 24 worried about? 25 MS. IIII: Yes. 416 1 MR. Did Epstein ever complain 2 about anything? 3 MS. : Not to me. 4 MR. : Do you know if he 5 complained about anything to anyone else? 6 MS. IIII: lust the time when he asked for 7 the mattress. The extra mattress. 8 MR. . That was a request 9 though. 10 MS. Yeah. 11 MR. Was it a complaint? Did 12 he say anything along with asking for an extra 13 one? 14 MS. IIII: Well how it was relayed that he 15 was complaining that he needed another 16 mattress. 17 MR. Okay. 18 MS. I don't know if you want to 19 take that as 20 MR. : Did you ever hear him 21 complainin about other inmates? 22 MS. : No. 23 MR. No. Never complained 24 about bei2g_in the SHU versus somewhere else? 25 MS. IIII: No. EFTA00117746 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 417 MR. : So no complaints other than that mattress. MS. • No. MR. : Do you know if there were any threats made to Epstein? MS. : I don't know. MR. : Do you know at the time did you know why Epstein was in prison? MS. : Well he -. MR. : You said you did some internet searches or you saw some things but -. MS. IIII: Right. After the fact. But initially no. MR. : Didn't you say there were things that would populate on the computer? MS. IIII: Yeah. That's why I said after. When he initially first came in there, no. I didn't know. MR. 9th or Au MS. MR. MS. MR. : And did you have any specific feelings with regard to why he was in : I mean prior to August ust lOth. Oh. Yeah. : Yeah? Mm-hmm. 418 1 prison? 2 MS. 3 MR. : Did you ever speak about 4 Epstein with other inmates? 5 MS. : No. 6 MR. : In your opinion when the 7 medical emergency was discovered, did you and 8 act appropriately, per BOP policy? Now 9 that you've had time to reflect on it. 10 MS. IIII: Um I know now that when there's 11 a medical emergency, you're not supposed to 12 enter the cell until everybody gets there. So 13 that would be the only thing that I would say 14 like that wasn't done correctly. But as far as 15 everythin else -. 16 MR. : Now was that per 17 MS. What I'm saying or -? 18 MR. : Yeah. So the one thing 19 that you know that was incorrect. What about 20 what you did? Was there anything that you did 21 that wasn't correct? 22 MS. : If it was I don't know. 23 MR. • No-no-no. I'm asking. 24 MS. Oh now. 25 MR. : It's a genuine question. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 419 It's not a trick. MS. : Hm-mm. MR. : So you're not aware of you doing an MS. MR. Alright. But you know that went into the cell before he was supposed to. MS. : Yes. MR. • He was supposed to actually wait for someone to come and respond? MS. Yes. MR. And why is that? MS. Wh did he go in? MR. No. Why does he need to wait for them to respond? MS. IIII: Oh I don't know. That's the rule. I uess. MR. : Okay. And by you standing outside at that gate, he still wouldn't be allowed to go into the room? MS. MR. MS. : Who me? • So even the way you did. : Oh because I was there. No. From what I understand, you're supposed to wait 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 420 until peoplfjEL_ And then go in. MR. IIIIIIIIII: Okay. And how did you learn that? MS. IIII: After. That's what I heard them sayia9 MR. IIIIIIIIII: That's what people were telling you on August 10th? MS. : Yes. MR. MS. That you -. . Not telling me but just in conversation. Like after. MR. : What conversations did you have with people after? MS. IIII: I didn't have no conversations. I just heard them saying should have never went in there by himself. I don't even remember who said it. But somebody that was in the SHU. MR. : Did anybody say anything about your reactions? MS. : No. MR. No. Do you know if he needed to just wait for one person or a bunch of people? How does that - what did you hear with regard to that? EFTA00117747 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 421 MS. Illiiiiiiiidn't hear nothing else. MR. : When I said you I mean MS. : Oh. I don't know. MR. • Do you believe that acted appropriately? Being that you were there and you observed it. MS. IIII: What the stuff that he did? Yes. MR. : Yeah. Do you think he should have waited for someone or you think it's like - there was a medical emergency and - ? MS. IIII: I think it was a medical emergency and he was just trying to get to try to help him. MR. : Alright. And did you and know that Epstein was the only person in the cell then? Or did you not know if was in there or not? MS. IIII: When I counted, I knew that he was in there b himself. MR. : Okay. lust for background, I believe the reason why you're supposed to wait is in case it's a ruse and 422 1 someone wants to trick you to get in and then 2 you - the other person overpowers him. And now 3 has a -. 4 MS. : Ri ht. 5 MR. : So that's my point. Do 6 you know if was aware if anyone else was 7 in there? 8 MS. I don't know. 9 MR. You don't know. Not 10 something ou discussed with though? 11 MS. : No. 12 MR. : Did any supervisors or 13 staff talk with you about the incident? 14 MS. • No. 15 MR. Aside from that one when 16 Lieutenant 17 MS. Lieutenant asked me. 18 MR. . Okay. So I just want to 19 - again, when I ask you these questions just 20 make sure we say like aside from this or that. 21 So any other things aside from that instance 22 where they asked you what happened. And you 23 said you don't recall saying we didn't do the 24 3:00 a.m. and 5:00 a.m. rounds. But you do 25 recall saying it wasn't her fault. 423 1 MS. : Yeah. 2 MR. : We didn't do the rounds. 3 MS. Yeah. 4 MR. Any other questions other 5 than that? 6 MS. IIII: Um they asked me to go 7 downstairs to the lieutenant's office. And 8 then I waiiiiiiiiiinding down there. 9 MR. : But no one spoke with 10 you? 11 MS. : No 12 MR. • Did anyone even ask you 13 how you were? 14 MS. IIII: Oh the psychologist asked me 15 how I was. 16 MR. : Okay. So but did she ask 17 you about the information -? 18 MS. IIII: No. They didn't ask me 19 anything about that. 20 MR. It was just about your 21 mental wellbeing? 22 MS. : Yeah. 23 MR. : And what time did you 24 stay at the institution until on August 10th? 25 MS. IIII: I left like around after 8:00. 424 1 MR. A little bit after your 2 shift? 3 MS. Yes. 4 MR. : You didn't have to stick 5 around for anything else? 6 MS. : No. 7 MR. : Did you have to sign any 8 paperwork? 9 MS. 10 MR. You were left right 11 around the end of your shift. Did they tell 12 you to leave? 13 MS. IIII: My shift was over. They said I 14 could go. 15 MR. I just mean like did they 16 instruct you to go home. You just had a 17 traumatic experience. Or it's just your shift 18 was ended. And you left. 19 MS. IIII: My shift was ended and I asked 20 can I go now. And they said go. 21 MR. Okay. And who was that 22 who said o 23 MS. : The lieutenant. 24 MR. Do you remember which 25 lieutenant? EFTA00117748 425 426 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 MS. MR. not M? MS. MR. Okay. But you didn't have any other conversations with IIIIIII? MS. MR. Okay. Did you ever handle or touch Epstein's paperwork? Epstein's file or paperwork? Prior to your departure from the MCC on August 10th? MS. : No. MR. : So in that time from - you said you were there by yourself for 20 minutes. Did you ever go near his file? MS. IIII: I don't even know where his file is. No. MR. : Alright. Do you know if they keep files on inmates? I think they're called like - what is it a 292 or something like that? MR. : Yeah. MS. Eh no. MR. Do you know what's kept in a 292? 1 MS. : No. 2 MR. : Like when you feed an 3 inmate or when you give them -. 4 MS. IIII: Oh that's like when you log 5 into and iiiiiiiiiikay. 6 MR. : Is there also paperwork 7 that follows that or is it just logging into 8 the BOP sy/fm? 9 MS. IIII: That's logging in to the 10 system. 11 MR. : Okay. When you - during 12 the time that you were on your shift at all on 13 August 10th did you ever log into that system? 14 MS. : No. 15 MR. : So you never had to enter 16 than you fed him or you went into -? 17 MS. : No. 18 MR. : And you checked on him or 19 anything like that? 20 MS. No. 21 MR. : When would that be done? 22 MS. : At the earlier part of the day 23 or when you feed. 24 MR. So around what time? 25 MS. : After 4:00. 427 1 MR. After 4:00 a.m.? 2 MS. No 4:00 p.m. 3 MR. : 4:00 p.m. So when you 4 say the earlier part of the day, you mean the 5 later part of the day? 6 MS. IIII: No like when the shift starts 7 at 4:00 after you feed. That's the time I see 8 them like log in to say okay they've been fed. 9 But I've never really -. One day, I actually 10 like was in there because was showing me 11 how to do it. But I don't necessarily do that. 12 Somebody else will do it. 13 MR. : And what was he showing 14 you how to do? 15 MS. : How to log it. 16 MR. : So what is it that you're 17 supposed to log? You know in the system? 18 MS. IIII: I vaguely remember because I 19 don't did it - he only showed me that one time. 20 I think you're supposed to like log if they 21 showered, log if they were feeding, and I don't 22 know, if you gave out stuff. I guess. I don't 23 know. 24 MR. : But you don't - you're 25 not aware of an actual paper file? 428 1 MS. : No. 2 MR. : Where those things are 3 monitored or tracked? 4 MS. 5 MR. And you never did that 6 for any inmates? 7 MS. : No. 8 MR. : You never filled out 9 paperwork or kept files for inmates? 10 MS. : No. Never. 11 MR. : So obviously you never 12 handled or touched Epstein's paperwork? 13 MS. : Never. 14 MR. : Or his file? Did you 15 ever remove any of Epstein's paperwork from his 16 file? 17 MS. : N 18 MR. : Did you ever remove or 19 destroy an of Epstein's paperwork? 20 MS. : No. 21 MR. : Did you ever remove or 22 destroy - that's a repetitive question. Did 23 you ever remove or destroy any signs related to 24 Epstein to include signs that said he was 25 required to have a cellmate? EFTA00117749 429 430 1 MS. 2 MR. . Did you access any BOP 3 databases such as BOPWARE, SENTRY, TRUVIEW, 4 after Epstein was discovered on August -- 5 MS. No. 6 MR. -- 10, 2019? That was 7 no? 8 MS. 9 MR. Did you report - was that 10 the last time you reported to work? On August 11 10th? 12 MS. : Yes. 13 MR. : Were you placed on 14 administrative leave? 15 MS. : Yes. 16 MR. : By whom? 17 MS. : Mm. I don't know. I got a 18 phone call saying that I was placed on 19 administrative leave, but I don't remember by 20 who. And then the letter. 21 MR. : Did you ever receive an 22 explanation verbally? 23 MS. : No. 24 MR. : No? So the person told 25 you that you were on administrative leave -? 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 MS. : Yes. MR. : That was the extent of the conversation? MS. IIII: And then I said so when do I come back? And they was like you'll get a call like when or if ou're supposed to come back. MR. : Okay. And what did that administrative leave change to a different type of leave? MS. : Suspended without pay. MR. : Indefinite suspension? Was that it? Is that what you're on right now? MS. Yes. MR. communicate with Oka .id you after Epstein's body was discovered? MS. No. MR. Did you communicate -? MS. : We communicated never because we was not allowed to communicate. Even - well before -. MR. : What about -? I'm talking about right after the body was discovered. People respond. And then did you communicate? You talked about the one instance 431 1 outside of the elevator. 2 MS. : Yeah-yeah-yeah. No. 3 MR. : But you guys didn't 4 actually converse? You were just both talking 5 to the lieutenant? 6 MS. : Ri ht. 7 MR. : And at no point also did 8 you ever converse? 9 MS. : No. 10 MR. 11 somewhere 12 MS. 13 MR. Since then? Like outside 14 of work? 15 MS. 16 MR. You don't recall anytime? 17 So if he says that you guys talked it up, you 18 don't remember that? 19 MS. IIII: We never spoke until we had a 20 union meeiiiiiiiii, 21 MR. : That's what I'm asking. 22 Ever. 23 MR. : Oh never spoke until that 24 union meeting. That was just like two weeks 25 ago. But we never ever spoke. • Didn't you guys talk 432 1 MR. That's kind of like - 2 when I say EVER, that means ever. Any time 3 from then until this moment? 4 MS. IIII: From then until the union 5 meeting, we never spoke. 6 MR. : Alright. So what was 7 discussed at the union meeting? 8 MS. IIII: That we're going to have an 9 investigation and the union is there for us. 10 They're su ortin us. Stuff like that. 11 MR. But did you discuss this 12 with 13 MS. What? 14 MR. The investigation? 15 MS. 16 MR. Did you ever discuss like 17 what you were going to tell us? 18 MS. : No. 19 MR. Or what you were going to 20 say durin an interview? 21 MS. : No. 22 MR. So what did your 23 communication entail? 24 MS. IIII: With =.? It wasn't with 25 . But he was present. So basically the EFTA00117750 433 1 union was saying you know they're fighting for 2 us. They're there for us. They're supporting 3 us. You know that was along the line. We're 4 going to have to meet with you guys to be 5 investigated. lust tell the truth. That was 6 along the line. 7 MR. • Okay. 8 MS. : But my conversation wasn't 9 directly with . It was - we were both 10 being told. 11 MR. So aside from the union 12 and with that interaction with , was 13 anybody else that you discussed the Epstein 14 incident with since August 10th? 15 MS. : No. 16 MR. 17 attorneys? 18 MS. : More or less. Mm-hmm. 19 MR. • Is there anything else 20 that you want to add to anything we've talked 21 about? Being and just keep in mind the - under 22 oath. What you just said. The union said just 23 tell the truth. The way that you get in 24 trouble from this point forward is basically if 25 you don't tell the truth. You know, anything • No. Aside from your 434 1 that we need to clarify. Anything that you can 2 think about. Like maybe I should provide some 3 additional background information regarding 4 that. 5 MR. FOY: No. I don't of know anything. 6 MR. : Okay. So everything good 7 for - because I just want to pass it over to 8 see if there's anything that Agent wants 9 to ask. 10 MR. : You mentioned there was an 11 office in the SHU for the lieutenant. 12 MS. Yes. 13 MR. : Where is that located? 14 MS. : Upstairs outside of the door 15 for 10 South. 16 MR. : Who normally sits there? 17 MS. The lieutenant. 18 MR. : Who would that be? 19 MS. Lieutenant IIII. 20 MR. : Have you ever been in that 21 office? 22 MS. No. 23 MR. : Do you know anyone else that 24 utilizes that office? 25 MS. IIII: No. 435 1 MR. : After the incident happened, 2 you -? After Epstein was removed, did you 3 any lieutenants at the MCC? 4 5 MS. Did I see any lieutenants? MR. : Yeah. Which lieutenants 6 you see at the MCC? 7 MS. IIII: Lieutenant IIII, 8 there? 9 MR. : Yeah whoever's 10 you actuaIly_see. 11 MS. IIII: Lieutenant 12 , Lieutenant 13 but she came like to help feed. 14 MR. : She came back to help 15 MS. Yes. 16 MR. : Did you 17 with her? 18 MS. : Lieutenant 19 MR. : Yeah. 20 MS. No. 21 MR. : How did you know she came 22 back to hel feed? 23 MS. : I was there. 24 MR. : And where was she when -? 25 MS. : Where was she when? did see have a did but who was present. Did Lieutenant getting off feed? conversation 436 1 MR. : Yeah. When you were leaving. 2 Where was she? 3 MS. : In the SHU. 4 MR. : Okay. She was in the SHU 5 physicall in the SHU? 6 MS. : Helping feed. 7 MR. : Okay. 8 MR. What time are we talking 9 about? 10 MR. This is after the incident. 11 MR. : Oh, okay. 12 MR. : This is just for 13 clarification purposes. 14 MS. Okay. 15 MR. : I know you mentioned this 16 before, I'm just going to clarify it. A couple 17 of questions. Did you ever assist any inmates 18 with makin hone calls? 19 MS. : No. 20 MR. : Do you know that if an inmate 21 wanted to make a phone call, how would they go 22 about it? 23 MS. : They use their PIN number. 24 MR. : Is every inmate assigned one? 25 MS. : Yes. EFTA00117751 437 1 MR. : Can they call anybody they 2 wanted to? 3 MS. I don't know. 4 MR. : Is there a restriction on 5 certain peo le that they are allowed to call? 6 MS. I don't know. 7 MR. : Okay. Did you know that 8 inmate calls are monitored? 9 MS. Yes. 10 MR. : Do you know the difference 11 between a monitored line and the legal line? 12 MS. Meaning.... 13 MR. : So there was one line that's 14 used to make legal phone calls that's just for 15 attorneys. 16 MS. : Okay. 17 MR. : So those - that line is not 18 monitored. 19 MS. Oh 20 MR. : But the other line is any 21 calls that they make is recorded. 22 MS. IIII: Okay. But I don't know where 23 like which line is which. But I am aware that 24 there's the recorded line and the other line. 25 But I don't know which one is which. Or where 438 1 the legal line is. 2 MR. : Okay. You said it was not 3 weird Epstein was left alone with the phone. 4 Has this happened before? 5 MS. IIII: Where an inmate is in the tier 6 using the hone? Yeah. 7 MR. : Who - to your recollection - 8 which other inmates were allowed to make phone 9 calls like that? 10 MS. IIII: I don't have a name, but it's 11 not because they're allowed to make a phone 12 call like that. It's only if where their cell 13 is located, the jack's not working. So it's 14 not like they put inmates in the shower to have 15 private phone calls. It's just that if where 16 your cell is that, the jack's not working, they 17 put you -. Because they can't put you with 18 another - in another inmate's room. And they 19 can't leave you out in the open. So they place 20 you over there because the jack is closest to 21 it to make the phone call. 22 MR. : So you know who could set up 23 a call like that? Can anyone - any CO just 24 plug it in? Or does it have to be a specific 25 person who plugs it in? 439 1 MS. IIII: That I don't know. If any CO 2 could jusiii it in. I don't know. 3 MR. : You don't know. Would you 4 happen to know if Epstein had a PAC and PIN 5 assigned to him? 6 MS. IIII: I would think he would. But I 7 don't know for sure. 8 MR. : Do you recall that night when 9 set up the phone call. Did he tell you 10 who Epstein was supposed to be speaking to? 11 MS. : No. 12 MR. : That's all I have. 13 MR. : And then the two final 14 follow-ups. Just because we discussed it and I 15 kind of gave it to you from memory. But this 16 is the special housing unit post orders 17 regarding cell rotations and cell searches. It 18 just quickly says, "All SHU staff are expected 19 to conduct searches of the special housing 20 unit. The morning watch officers will conduct 21 searches of the common areas and document their 22 findings in the search section of the True 23 Scrub Program. (Phonetic Sp. *05:14:00) The 24 day watch officers will conduct a search of 25 every inmate's cell who attends recreation. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 440 The evening watch officers will conduct a minimum of five cell searches during their shift." And that's what I was just trying to get (Indiscernible *05:14:13). Just to make sure and that's just to -. If you want to just initial it and date. And also when I do need to clarify when I said the getting in trouble thing. I was talking about legally. When I said about that being truthful. MR. : So these things that you initialed. Can you date them also? Because this first set doesn't have a date on them. MR. -? MR. : There's no dates. Next to her initials. On there. MR. : Do you care if it has a date? I don't want her to have to go through everything again. She just wrote her initials. MR. FOY: Yeah. It doesn't matter. Especiall if e're only meeting one time. MR. : Okay. Sure. So just next to where you wrote your initials, do you mind just dating? I don't know if there's a reason to provide this here. I would just -. What is that you want her, EFTA00117752 441 1 You might not -. You don't have to provide it 2 to her. 3 MR. Yeah. 4 MR. Just read it after she's 5 done that. 7 subsequently that wrote a memo pretty : Weriii aware -? Maybe 6 MR. 8 much stating that he was notified -. He was 9 notified 1:50 p.m. that inmate was not 10 coming back to MCC. And he actually notified 11 Officer , SOS , and Officer 12 that inmate needed - that a cellmate needed to 13 be assigned to Epstein. 14 MS. •• I'm not aware of that. 15 MR. : Did you ever get instructions 16 like that? 17 MS. : No. 18 MR. : When you came on shift, were 19 there any instructions that came down about 20 going in and removing Inmate ' belongings 21 from the cell? 22 MS. No. 23 MR. : If an inmate was removed. 24 Let's say someone was going WAB. Do you know 25 what that is? 442 1 MS. : Um yeah. 2 MR. : With All Belongings. 3 MS. Belongings. 4 MR. : If an inmate let's say had to 5 go to court and it was notified that the inmate 6 is not coming back and was being removed by 7 WAB. Does an officer in the SHU have to go in 8 and remove all the belongings? 9 MS. IIII: Um I don't know. Because I 10 only know in the regular unit when they're 11 going WAB the bring their stuff. 12 MR. : They don't bring their stuff? 13 MS. No they do. 14 MR. : If they were. But what if 15 that person - let's say that inmate wasn't 16 notified that they're not coming back until -. 17 MS. IIII: Oh if it wasn't. Then yeah. 18 The officer would have to go in and take it 19 out. 20 MR. : And there was no instructions 21 for you gu s to go remove it? 22 MS. : No. 23 MR. : And I may have just 24 missed this, but you do not recall anyone 25 coming in and retrieving ' belongings? 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 443 MS. No. MR. : No? And would have that happened during your shift? Before the 12:00? MS. : I don't know. MR. MR. anything about MS. MR. MR. to initial documents. MR. : Yeah. They're all - I just gave them to her. Anything else before we end this so that hopefully this will be a one- and-done? MR. M.Jothing else. MR. : Nothing else that we should talk about that we missed? That we can handle now rather than having to circle back? MR. FOY: Uh nothing. I can't think off of the toiliiiiiiiiad. MR. : We're trying to cover a lot so. MR. FOY: I am at the end. MR. Yep. From the union is : If it was? : You just don't know leaving or -? I don't know. Anything? Okay. : Get all this signed we'll go 444 1 there anything that you can think of that we 2 should be discussing? Or 0? 3 MS. GREGG: I mean I -. If OIG really 4 wants to know what led up to the death of Mr. 5 Epstein. I think that there needs to be a 6 thorough investigation of the Metropolitan 7 Correctional Center and it's pitfalls. I'll 8 just you know kind of leave it at that. And 9 I'm sure you're getting a little bit of insight 10 into what the MCC is. Not just staffing but 11 conditions for inmates as well. It failed a 12 new employee. Yes there are some things that 13 she absolutely should be taking responsibly 14 for. But what led up to the unfortunate death 15 of Mr. Epstein wasn't just August 9th and 16 August 10th. 17 MR. : Referring to the fact 18 that she was trained on people not conducing 19 rounds and counts? 20 MS. GREGG: It's a cultural issue at MCC 21 New York. Falsifying of documents to pass 22 program reviews. Inadequate training of 23 employees. Um an employee may go through an IF 24 training but most of that training is three 25 weeks or so. Most of the time, you'll find EFTA00117753 445 1 yourself sitting down in the training center I 2 believe because they don't have someone to 3 actually train you. But they'll tell you sign 4 the training sheets. So if something like this 5 comes up, it implies that the employee received 6 the training. When actually I was present to 7 receive the training but nobody taught me. The 8 same thing is you know for annual refresher 9 training. There's a cultural issue at the 10 Metropolitan Correctional Center. Is it 11 agency-wide? I don't know. I've only been at 12 MCC New York. But there are some pitfalls. 13 There have been inmates that's prior to Mr. 14 Epstein and since Mr. Epstein and I believe the 15 inadequate managing of the building plays a big 16 role in those deaths. Assaults of staff and 17 inmates. And you guys, I guarantee you've seen 18 it. I'm sure there's something you've seen 19 that you're like, wow that's a little bit crazy 20 what just seems very egregious it's because 21 it's not being run the correct way. It's 22 failing staff and inmates every day. 23 MR. : Well thank you for that. 24 On that note, I know we talked about you know 25 how you observed other staff members like 446 1 pretty much not conducting the round sheets the 2 way they did it, as well as the supervisor that 3 told you to sign the training that you never 4 actually attended. Can you think of anything 5 else that you were asked to do like that from 6 anyone? Or observed anyone else? As like a 7 training or an experience that was - now that 8 you're thinking back on it - wrong? 9 MS. IIII: Um.... I mean I haven't really 10 been there that long. So the only thing I 11 could recall was Lieutenant III was oh. I 12 think when I had my probationary year, like I'm 13 supposed to get reviewed like every quarter. 14 Like to get before I get off probation. I've 15 only got it one time. I think it's supposed to 16 be done three times. I've only got it one 17 time. 18 MR. : And were you asked to 19 sign on a quarterly basis that you received 20 that evaluation? 21 MS. IIII: I know I signed it one time 22 that I got it. But I never got the other two. 23 So just biiiiiiiiigust showing how -. 24 MR. : But they didn't actually 25 ask you to sign something? 447 1 MS. IIII: No. Ask me to sign for that. 2 No. 3 MR. : Is there any instances 4 you can think of that you like needed to sign 5 for something that you thought oh I shouldn't 6 sign for that. I didn't take this training. I 7 didn't conduct these rounds. Is there anything 8 else like that that you can think of that's 9 happened while you were at the MCC? 10 MS. IIII: I mean, like for example, like 11 she said in IF training, there's a roster with 12 a whole bunch of stuff that we're signing next 13 to. But like let's say, lieutenant so-and-so 14 is supposed to teach that class and they didn't 15 show up. But I already signed that I received 16 it. But I didn't get the actual training. So 17 I'm signing that I'm present and I'm here for 18 the trainin but I didn't actually get it. 19 MR. : So you're showing up at 20 training -- 21 MS. But I can't remember -. 22 MR. -- and they're actually 23 not conducting it and they're certifying 24 they're -- 25 MS. IIII: Right. Yeah. 448 1 MR. -- conducting the 2 training? 3 MS. IIII: Yeah. There were a couple of 4 training that we didn't get because there was 5 nobody there to teach the class. 6 MR. : And they certified that 7 they actuall - 8 MS. IIII: Yeah. I remember when I was in 9 IF, they would tell me stuff. But I never 10 walked. You're supposed to get a tour of the 11 building for when you sit in training and in 12 the SHU blah-blah-blah - you have a visual. 13 They never even did that. Like they would 14 explain like when they say down range, you have 15 to just imagine what's down range because I 16 never been in that jail and I didn't know. 17 I'm saying that to say like the training is not 18 -. You guys probably look at oh I signed or 19 you're saying this training or that she should 20 know this. But I don't actually necessarily 21 have to know it because it wasn't like taught. 22 And if I kind of learn as you go along, that's 23 why I said like it's wrong, but I tried to 24 mimic or follow what I see. Other people do. 25 And yes I've exercised poor judgment on things, EFTA00117754 449 1 but even sometimes you ask people and they tell 2 you the wrong thing. That's MCC. So even if I 3 don't know and I call and I say hey how do you 4 do this? The like oh just do this. 5 MR. : And what do you - now 6 that you've experienced this, what do you blame 7 that on? Do you also blame it on like poor 8 management or like a lack of manpower? What is 9 your thougils1 on that? 10 MS. IIII: It's both but every time 11 something happens, the officers get in trouble. 12 And the problem is it starts from the top. 13 Because if my supervisor is telling me to 14 falsify documents and I do it, I'm in trouble. 15 But Lieutenant got promoted. You 16 understand? Like the problem starts from eh 17 top. And it comes all the way down. It's not 18 being managed correctly and the manpower is 19 also not there. Like you can't take somebody 20 and tell them to work 16 hours. And remember, 21 it's a thing where I'm on probation, so I can't 22 say, no I'm not working it. So you asked me to 23 work 16 hours every day. I'm a human being. 24 I'm not a robot. I fell asleep plenty of times 25 going home. I come to work. I remember one 450 1 time I called the lieutenant's office. Like I 2 can't keep my eyes open because that's just the 3 reality of it. By the time you go home, it's 4 time for you to -. Some people don't even go 5 home. They try to sleep in the locker room 6 because the manpower is not there. And it's 7 absolutely ridiculous. For me, I started in 8 June of 2018. The indictment said 2016. 9 That's not true. To December. That's only 6 10 months. And I made my base pay because of all 11 that overtime. 12 MR. : Okay. Thank you. That's 13 all great insight. Anything else we want to 14 add? 15 MS. IIII: Mm. Nothing else. 16 MR. FOY: The only thing I can think of, 17 which you've kind of alluded to, is what it 18 feels like as a new employee. The culture. 19 The friendliness or lack thereof. The fact 20 that in a way, your trust in your colleagues is 21 undermined through your colleagues. Right? I 22 mean which makes it a difficult thing. I mean 23 if you want to talk about that part of it. 24 Right. Because it's all related. It's not I 25 just one thing. So I mean if you want to speak 451 1 on it, this would be the time to say it. 2 MS. IIII: I don't know what -. 3 MR. FOY: Hm? 4 MS. IIII: (Indiscernible *05:25:37) 5 MR. FOY: Your experience of was it a 6 friendly experience? Did you feel supported by 7 your co111222es? Like -. 8 MS. IIII: Oh. No. 9 MR. FOY: Right? Did you like it there? 10 Did it feel safe? Like -. 11 MS. IIII: Oh. No. Absolutely not. 12 Absolutely not. 13 MR. FOY: But you've got -. 14 MS. IIII: I was actually trying to - like 15 from the moment I started there, I didn't like 16 it there and I was trying to get out of there. 17 But I'm not going to quit a job and go sit at 18 home. So. The atmosphere was - like to me, I 19 didn't feel safe because if you don't have 20 enough people to work the units and something 21 happens and you hit a body alarm, who's 22 responding? If there's no nobody there. So 23 that's a problem in itself. There's been times 24 where you got one officer working two units. 25 So what if somebody died on the other unit and 452 1 the officer is on the other unit? But there's 2 been - and that's all not supposed to happen. 3 But like I said, when nothing happens it's okay 4 because nobody died. Nothing happened. But 5 when something happens, then that officer 6 working the two units gets in trouble not the 7 lieutenant that said hey I'm assigning you to 8 work these two units. And yes, we know we're 9 not supposed to work the two units. But again, 10 I don't feel like I can override my lieutenant 11 or I can override the senior officer because 12 the instruction that's being passed on from the 13 top is not correct. But who am I going to 14 tell? Because everybody in that building knows 15 from the warden all the way down knows we don't 16 have enough people. We don't have enough. 17 From day one I entered that building, that's 18 all I've been hearing. We don't have enough 19 people. We don't have enough people. People 20 get hurt because there's not enough staff to 21 respond to certain. Like when I'm on a unit 22 and inmates are fighting -. Like if the 23 inmates really wanted to take over and harm 24 you, they could have. And then who's 25 responding fast enough because maybe you hit EFTA00117755 453 1 the body alarm sometimes only three people 2 come. 3 MR. : So with all this in mind, 4 is there anything that you can think of as a 5 way to rectify these issues? 6 MS. IIII: They need staffing. And I 7 don't know if people don't stay there because 8 like the culture of MCC is just -. It needs to 9 start over. Like it needs to be cleaned out 10 and start over. And people need to follow the 11 rules and reinforce and show people the correct 12 things. Then maybe - maybe it could get 13 somewhere. But when you have new people coming 14 in and we're taught bad - and again, I'm not 15 blaming everything on me being taught bad. 16 It's what I see. What I know. And again, yes 17 I could sit and read an employee handbook. 18 Sometimes you ready stuff in the context of -. 19 Like I'm not in a camp. I'm in a high rise. 20 So the context of what you're reading in an 21 employee book refers to like you know those 22 types of institutions and not MCC. So 23 sometimes when you try to put it into 24 perspective -. 25 MR. You keep on saying camp. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 454 Do you mean like an FCI or a penitentiary? Or MS. : Yes. MR. Or are you talking about? MS. MR. Okay. MS. : Yes. Versus a high-rise building. So it's - the procedures are a little bit different. So that's why I rely on the people inside to teach me. And you'll always hear this being said. There's the BOP way and there's the MCC way because at MCC, they do it their way. MR. : Okay. Good to know. MS. : There's been -. And again because I don't know because they probably don't give you the roster. Every single time that I've came to work, I've called to switch with somebody else because I don't want to work SHU. Because I don't know how to work SHU. And it's very annoying that you have to keep having to ask somebody. There's plenty of times that I called across like somebody working 9 North, like hey you want to switch with me? And I switch. Because on a regular 455 1 housing unit, I know what I'm doing. In the 2 SHU, I don't know what I'm doing. And I was 3 even told usually they don't put probationary 4 staff to work SHU. But again, because of 5 seniority, that's all that's available. So 6 that's what I have to get. 7 MR. : Okay. Anything on that? 8 MR. liro you recall any specific 9 instances of policy violations by staff or any 10 actions that you could bring into questions 11 about other staff members at MCC? Any specific 12 instances. 13 MS. IIII: Um no. 14 MR. FOY: You're talking about like 15 contraband stuff like that? 16 MR. IIIIII: Anything. Overall. 17 MR. FOY: (Indiscernible *05:29:50) 18 MS. : I mean it comes in some -. 19 MR. : I think what he means 20 more along the lines though of like a 21 supervisor directing you to falsify a record. 22 Like that's pretty big. If they're telling you 23 sign this because you needed to take quarterly 24 SHU train . Anything else like that. 25 MS. IIII: I mean one time I got a drop 456 1 note that said an inmate wanted to rape me. 2 And I forward the email to the lieutenant and I 3 never got a call back. And I called and I said 4 -. Because that inmate is still on the unit. 5 So if the inmate really wanted to rape me, then 6 I guess he would have. So I called and I'm 7 like did you get my email? And she was like 8 yeah I got it, but that inmate ain't going to 9 do nothing to you. These are the type of 10 things that happen at MCC. How do you know 11 that inmate's not going to do anything to me? 12 What you should have did was remove me from 13 that unit or remove that inmate, but that 14 wasn't done. Inmates have threatened me. And 15 they're supposed to remove them out of the 16 building but they don't. Inmates have 17 threatened me and I have sent them to SHU. And 18 then they'll release them and then they came 19 right back to my unit. So again, it's like who 20 are you telling or complaining to at MCC? 21 Because from the top there's no help. And I'm 22 literally at the bottom. I was the last 23 officer at the time. 24 MR. : Now do you know of 25 (Indiscernible *05:31:04) corrupt officers like EFTA00117756 457 1 bringing in contraband? Is that like a problem 2 at the MCC? 3 MS. IIII: It is a problem. But I don't 4 know who brings it in. I just always wonder 5 like how did -? As far as smoking. Like 6 there's smoking all in the building. I get 7 headaches daily because of the smoking. So it 8 comes in some way. But as far as who or how it 9 comes in, I don't know. 10 MR. : And I would think it's 11 kind of easy to identify who is smoking. 12 Correct? 13 MS. IIII: Oh - the - you'll be sitting in 14 your officer's station, and you smell smoke. 15 But remember they're inmates. So by the time I 16 get out, they always have a watch person. So 17 by the time I feel like okay I smell it, it's 18 coming from here. Let me go walk the tier this 19 way, they'll be like, she coming. So they 20 already done -. 21 MR. : Now what are you 22 smelling? What kind of smoke? Is it marijuana 23 or is it -? 24 MS. : K2. 25 MR. : K2? 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 458 MS. 1.2. MR. : And you can - you know the distinct smell of K2? MS. MR. MR. MS. Yes. : Um. : Was this on the SHU also? . Yes. MS. GREGG: It's the entire building and you know, I would welcome, right, if OIG said we want to tour the institution. (Indiscernible *05:32:11) and judges do. Attorneys do. Law clerks do. Right. Because it gives you a little bit of - you can actually put a visual besides seeing the photos. You can get a visual. You actually get to see what it is to be an employee there or even an inmate there. And the drug problem is absolutely rampant. The institution has no control over it. Right. So it boils down to that employee saying okay if you guys don't stop smoking, I'm locking everybody behind a door because it's making me sick. Or it's making me -. It's that kind of thing. Like they're not holding inmates responsible for incident reports. None of that stuff is happening. And it just makes 459 1 it a very bad place to work. And it makes it a 2 poor place for a new employee to work. Right? 3 And I say that wholeheartedly understanding 4 that there is some onus on Ms. There's 5 just some things as an adult you have to say, I 6 take responsibly for it. I don't think she's 7 ever come out of taking that res 8 that MCC New York failed Ms. IIII, Mr. 9 and Mr. Epstein regardless of what he was in 10 jail for, I don't believe anybody deserves loss 11 of life behind the walls of a jail especially 12 in that manner. Right? And there's just so 13 man things so when you ask questions to Ms. 14 such as, "Are there any instances of 15 falsifying documents," you're not going to say 16 to me, but I guarantee you that in reviewing 17 rosters and training records, I'm sure you guys 18 have questionable discrepancies. I'm sure 19 you've caught rosters not reflecting what 20 videos show. I'm sure you've caught employees 21 on rosters - not on rosters but attending a 22 training, but the roster says they're on sick 23 leave or annual leave. I would bet my next low 24 paycheck that that's absolute to what you guys 25 have probably seen or experienced in 460 1 investigating this whole thing. Is this 2 falling on deaf ears? I don't know. I would 3 like to hope that the death of an inmate leads 4 to some chan e. But we're two years out and -. 5 MR. : Sure. Well part of that 6 has to do with we had to wait to interview. 7 But yeah. 8 MS. GREGG: Yeah. 9 MR. : Do you have ...? 10 MR. : Yes. 11 MR. : It just made me think of 12 something. I just want to make sure just going 13 back like we were talking about to make sure 14 that we've got the like - as truthful a 15 statement as we possibly can with regard to the 16 August 9th 10:00 p.m. count. Talking about 17 video and things like that. When you remember 18 doing that count -- 19 MS. : Mm-hmm. 20 MR. : -- although the count 21 number was wrong, did you do the count from the 22 outside grill or did you actually walk down the 23 range? 24 MS. : No. I walked down the range. 25 MR. : And you're -? EFTA00117757 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 461 MS. : And I know like for example, like in statement, he probably was like, I don't know if she did the count. Or I'm going to say she didn't do the count because it needed to be done with me and I was sleeping. He was sleeping, so he don't' know if I did the count or not. MR. : Yeah. I'm just trying to reconcile the review of -- MS. • He signed, but -. MR. : -- of the video. MS. : But no because I saw a lot of stuff. Even in the indictment. There's a lot of things in there that's not true. Like the one thing I know I did do was that 10:00 count. For a fact. MR. : But you just don't know how they reconcile the fact that -- MS. : The numbers no. MR. • -- the numbers are off. MS. But the count. I did do that. MR. Was that just - and again, that's going to be one of those big things that's like well how do we -? If you're saying you did the count, and the numbers are 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 462 wrong, that's the -. We're going to have to - MS. : Yeah. Like I don't remember -. MR. . -- review that video and MS. -- what happened between like the 73 and the 72 and the phone call and what was said I did do that count. MR. : And again, we're not confusing a count with a round. MS. : Rounds. No. MR. : Okay. Anything else? Well I just want to thank you all so very much for the cooperation. And to the union, I want to kind of apologize for the initial interaction. MS. GREGG: Mm-hmm. MR. : I think that now talking with you, I think that you're actually - I was maybe misunderstanding maybe what you were doing. I just wanted to make sure that we weren't going to be stopping this interview every time there was a question. But you were extremely helpful. So thank you for your participation. MS. GREGG: No problem. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 463 MR. And yeah. It is -. MS. GREGG: I've got something. Can I just get iiiiiiiiiithe document that I signed? MR. : Absolutely. MS. GREGG: Or unless you just want me to take a picture of it. Whatever's easier. MR. : Um yeah. I'll get you a copy. Either a photocopy or a picture. That's fine. Okay. It is 4:20 p.m. on Tuesday, Lune 22 2021. This is Senior Special Agent and I am turning off the recorder. 464 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 EFTA00117758