DIGITALLY RECORDED

1 DIGITALLY RECORDED SWORN STATEMENT OF OIG CASE #: 2019-010614 DEPARTMENT OF JUSTICE OFFICE OF THE INSPECTOR GENERAL JUNE 14, 2021 RESOLUTE DOCUMENTATION SERVICES 28632 Roadside Drive, Suite 285 Agoura Hills, CA 91301 Phone: EFTA00061698 2 APPEARANCES: OFFICE OF THE INSPECTOR GENERAL BY: BY: WITNESS: OTHER APPEARANCES: NONE EFTA00061699 3 1 MR. : The recorder is on and 2 it's currently June 14, 2021 at approximately 3 9:37 a.m. 4 MR. : My name is 5 I'm a Special Agent with the U.S. Department of 6 Justice Office of the Inspector General New 7 York Field Office. And these are my 8 credentials. I'll show it to you again. 9 MS. : Thank you. 10 MR. : This interview with Federal 11 Bureau of Prisons Correctional Officer 12 Lieutenant . Did I get 13 that right? 14 MS. : That's correct. 15 MR. : And she is being interviewed 16 as part of an official U.S. Department of 17 Justice Office of the Inspector General 18 investigation. Today is June 14th and the time 19 is approximately 9:35 a.m. The interview is 20 being conducted on the third-floor telephone 21 monitor room of the Metropolitan Correction 22 Center. Also present is DOJ OIG Senior Special 23 Agent Can you pronounce your last name 24 please? 25 MR. . And EFTA00061700 4 1 these are my credentials. 2 MS. : Thank you. 3 MR. : And Lieutenant 4 . This interview will be 5 recorded by me, Special Agent 6 Can everyone please identify themselves for the 7 record and spell your last name. To start 8 again, I am DOJ OIG Special Agent 9 10 MR. : Senior Special Agent 11 12 MS. : Lieutenant 13 14 II 15 MR. : This is an official DOJ OIG 16 investigation into the death of inmate Jeffrey 17 Epstein and everything that surrounds that time 18 period. And you're being asked to voluntarily 19 provide some answers to our questions. Will 20 you agree to a voluntary interview with the DOJ 21 OIG? 22 MS. : Yes. 23 MR. : I'm going to provide you with 24 a form, DOJ OIG Form 3-226-2. The title of the 25 form is Warnings and Assurances to Employee EFTA00061701 5 1 Requested to Provide Information on a Voluntary 2 Basis. I'm going to read it out to you first. 3 And then I'll let you review it also. You are 4 being asked to provide information as part of 5 an investigation being conducted by the Office 6 of the Inspector General. This investigation 7 is being conducted pursuant to the Inspector 8 General Act of 1978 as amended. This 9 investigation pertains to job performance 10 failure and security failure. This is a 11 voluntary interview. Accordingly, you do not 12 have to answer any questions. No disciplinary 13 action will be taken against you if you choose 14 not to answer any questions. Any statement you 15 furnish may be used as evidence in any future 16 criminal proceedings, or agency disciplinary 17 proceedings, and/or both. Now this is the 18 waiver part. This is for you. I understand 19 the Warnings and Assurances stated above and I 20 am willing to make a statement and answer 21 questions. No promises or threats have been 22 made to me and no pressure or coercion of any 23 kind has been used against me. Do you 24 understand? 25 MS. : I understand. EFTA00061702 6 1 MR. : Do you want to move forward 2 with the interview? 3 MS. : Yes. 4 MR. : Please sign your name and 5 print your name. 6 MR. : Let's just say thank you 7 for signing and (Indiscernible *00:03:37). 8 MR. : Thank you for signing the 9 form. I myself am signing the form. I'm going 10 to print my name on it. And Agent is 11 also going to do it. 12 MR. : Thank you SA for 13 signing and dating 6/14/2021 at 9:38 a.m. This 14 is SSA and I am now signing as the 15 witness and printing my name as a witness. 16 MR. : Again, thank you, 17 Before starting the interview, I would like to 18 place you under oath. Lieutenant , can 19 you please raise your right hand? Do you swear 20 to tell the truth and nothing but the truth 21 during this interview? 22 MS. : I do to the best of 23 my knowledge and belief. 24 MR. : Thank you. Please let me 25 know if you do not understand any questions and EFTA00061703 7 1 I will repeat it or try to rephrase it. I ask 2 that you do not try to guess answers. If you 3 don't know, just say you don't know. 4 MS. : Okay. 5 MR. : Thank you. So we'll go 6 through a little bit of your background before 7 we get in. What is your current home address? 8 MS. 9 10 11 MR. 12 of birth? 13 MS. : Thank you. What is your date 14 MR. : And your Social Security 15 Number. 16 MS. 17 MR. : What is your current cell 18 phone number? 19 MS. 20 MR. : What is your highest level of 21 education? 22 MS. : I have some college. 23 MR. : What did you do prior to 24 working for the bop? 25 MS. : I was in the EFTA00061704 8 1 military. 2 MR. : Thank you for your service. 3 What branch? 4 MS. : The Navy. 5 MR. : How many years? 6 MS. : Eight. 7 MR. : Alright. And how long have 8 you served with the Federal Bureau of Prisons? 9 MS. : Twenty-six years. 10 MR. : Do you remember when you 11 started? What year you started? 12 MS. 13 MR. : When did you graduate from 14 bop training? It was soon after? 15 MS. : No. I went to 16 Glynco. I know it was probably six months to a 17 year after I started. 18 MR. : Okay. 19 MS. : I don't' remember the 20 exact date. But it was in `95. 21 MR. : '95? 22 MS. : Yeah, it was in 1995. 23 I don't remember the month. 24 MR. : That's fine. When and where 25 was your first office assignment with the BOP? EFTA00061705 9 1 MS. : FCI Terminal Island. 2 MR. : And after that, how long were 3 you at Terminal Island for? 4 MS. : For probably around 5 six to seven months. I resigned and took a 6 position in San Diego. 7 MR. : You resigned the position 8 altogether? Or did you get a transfer? 9 MS. : The way that they did 10 it was they had me resign and then they picked 11 me up in San Diego. 12 MR. : Okay. So -. 13 MS. : It's the way that 14 they had me do it. 15 MR. : Was there a break in 16 service? 17 MS. : No. There was no 18 break in service. No. 19 MR. : At Terminal Island, what was 20 your position? 21 MS. : I was a correctional 22 officer. 23 MR. : Okay. And then six months 24 alter you went over to San Diego. 25 MS. : As a correctional EFTA00061706 10 1 officer. 2 MR. : Okay. How long were you 3 there for? 4 MS. : A little over ten 5 years. 6 MR. : Ten years. 7 MS. : Yes. 8 MR. : San Diego. Okay. And what 9 other positions have you held with the BOP? 10 MS. : Correctional 11 Counselor and currently as a lieutenant. 12 MR. : When did you get promoted as 13 a counselor? 14 MS. : In I believe it was - 15 I started in I believe it was July of 2005. 16 MR. : July 2005. 17 MS. : Mm-hmm. 18 MR. : Alright. And then after 19 counselor, you got promoted as -. 20 MS. : A lieutenant. 21 MR. : Lieutenant. And when was 22 that? 23 MS. : That was in 2010. I 24 believe it was December 2010 that I 25 transferred. EFTA00061707 11 1 MR. : Where did you transfer? 2 MS. : FCI Jessup. 3 MR. : Jessant? 4 MS. : Jessup. 5 MR. : Jessup. 6 MS. : Jessup. In Georgia. 7 MR. : Georgia. Okay. In 2010 you 8 transferred and that was a promotion to 9 lieutenant? 10 MS. : Yeah. Well as a 11 counselor I was already a 9. So I just I guess 12 lateral over in a sense to a GS9 lieutenant. 13 MR. : Okay. In Jessup. Okay. 14 MS. : Right. 15 MR. : And how long were you in 16 Jessup for? 17 MS. : Up until I came here 18 in November of 2014. 19 MR. : November 2014. Have you been 20 here ever since or did you have any transfers? 21 MS. : Not without trying to 22 leave. But yes, I've been here since 2014. 23 Yes. 24 MR. : And were you transferred over 25 as a lieutenant? EFTA00061708 12 1 MS. : I was a lieutenant 2 when I was at Jessup. I went there as a 9. I 3 got my 11 and I just lateraled over here as an 4 11. 5 MR. : And have you been in that 6 position ever since? 7 MS. : That depends on what 8 you mean by ever since. Have I been working in 9 the position or have I held that position? 10 I've held that position. I'm currently still a 11 lieutenant. 12 MR. : Okay. And - bear with me. 13 On August 9th and 10th of 2019, what was your 14 position at the MCC? 15 MS. : I was a lieutenant. 16 MR. : Okay. And what shift did you 17 work on August 9th and 10th? 18 MS. : I believe it was the 19 morning watch shift. 20 MR. : What time does the morning 21 watch shift start? 22 MS. : At that time, we were 23 coming in I believe it was from 10:00 to 6:00. 24 I think that's it. We would relieve them 25 around 10:00 and then we got off - we got EFTA00061709 13 1 relieved at around 6:00. 2 MR. • 3 a.m. and -? 4 MS. • : So you would come in at 10:00 10:00 p.m. 5 MR. : 10:00 p.m. And leave at 6:00 6 a.m.? 7 MS. : Well it depends on 8 what time our relief came. But those were the 9 hours that we were working around. Around that 10 time. 11 MR. : Officially that's the 12 schedule? 13 MS. : Officially, our hours 14 were midnight to 8:00. But we would come in 15 and relieve around, you know, between the hours 16 of 10:00 and 6:00. I'll put it like that. 17 MR. : Understood. Okay. And who 18 was your supervisor when you worked at the MCC 19 on August 9th and 10th? Who did you report to? 20 MS. : Then I think it was 21 Captain . Yeah. I think it was Captain 22 We've had so many captains in and out 23 since I've been here, it's hard to keep track 24 sometimes. But yeah, it's Captain 25 MR. : As a lieutenant, where were EFTA00061710 14 1 you assigned during August 9th and 10th where 2 were you assigned? 3 MS. : I was operations 4 lieutenant. 5 MR. : Okay. And as an operations 6 lieutenant, what are your daily duties? 7 MS. : We supervise staff 8 and of course the inmate population. We're 9 responsible for the safety and security of the 10 inmate staff and the institution. We do - we 11 hire overtime. We make runs throughout the 12 institution. And do various other duties. We 13 have checks and balances that we have to do 14 throughout the night. 15 MR. : Okay. As a supervisor, who 16 did you supervise? 17 MS. : I supervised the 18 inmate population and of course the staff that 19 worked for me during that shift. 20 MR. : Do you remember who you r 21 staff was during that shift? 22 MS. : Ooh, all of them? 23 No. No I do not. 24 MR. : Any key people you 25 communicated with? EFTA00061711 15 1 MS. : I mean I communicate 2 with all my staff. 3 MR. : Okay. 4 MS. : There is not one 5 person during the course of a shift that I 6 don't communicate with. Especially when I'm 7 making rounds. And especially during that 8 time, I communicated with them even more 9 because we were below the bottom of the barrel 10 then when it came to staffing. So we really 11 didn't have a lot of -. We didn't have anybody 12 back then. We didn't even have enough staff at 13 that time to even respond to body alarms. Or 14 to do uses or forces. You know. Especially on 15 morning watch. It's already tight. But we was 16 even tighter. So that was one of those nights 17 when as much as -. Well that night as like 18 every other night. As much as possible I tried 19 to talk to staff because staff were doing back- 20 to-back mandations then. And you had staff 21 that were being mandated every day of the week 22 Monday through Sunday. Or Sunday through 23 Saturday as we say in Bureau. Because that's 24 when our week officially starts - Sunday. 25 MR. : When you say mandated what do EFTA00061712 16 1 you mean by that? 2 MS. : Mandations are 3 mandatory overtime. That's when you've 4 exhausted your overtime roster. That's the 5 people that sign up for overtime. You've gone 6 through that. There's no one available. Or 7 you get everybody from that list that wants to 8 do overtime or that's available. Then you 9 announce it over the intercom system. That's 10 voluntary. Whoever wants overtime outside of 11 that, you can assign them overtime from there. 12 And then we go to mandatory overtime. That's 13 when we have nothing else left. And we have to 14 utilize the staff that we have currently on 15 duty that's not officially on a double-shift. 16 That's not officially on 16 hours. 17 MR. : So I'm going to ask a couple 18 more questions. How many hours where COs 19 working during that time period? ON average? 20 MS. : Sixteen plus because 21 -. 22 MR. : Per day? 23 MS. : Per day. Yes. 24 Because there were days when staff would be 25 late. There were days when there wasn't EFTA00061713 17 1 anybody even after we mandated everybody on the 2 shift. We didn't have anybody to fill a bunch 3 of posts. We had vacated posts. We had a lot 4 of stuff. It was grueling during that time. 5 And I think we had been doing that for at least 6 a year if not more than a year. 7 MR. : Okay. 8 MS. : Mm-hmm. 9 MR. : Did you previously meet with 10 agents regarding the Epstein investigation? 11 MS. : I did. 12 MR. : Do you recall meeting with 13 them on August 14, 2019 in regard to the 14 matter? 15 MS. : I don't remember what 16 day it was. But yes, I recall meeting with 17 them. 18 MR. : I have a summary of the 19 report. What I'm going to do is I'm going to 20 read it out to you. And once I read it out to 21 you, we're going to have some follow-up 22 questions because there's some holes in there 23 that we would like to fill. This is like the 24 summary part. informed that she 25 had been employed with the Bureau of Prisons EFTA00061714 18 1 since and promoted to 2 lieutenant around 2010 and has spent her entire 3 career working at the Metropolitan Correctional 4 Facility. During the interview, 5 described the duties -. 6 MR. : Let her correct that. 7 It's not correct. So if you hear something 8 that's not correct -- 9 MR. : Yes, please. 10 MR. : -- just say that that's 11 not correct. 12 MS. : Okay. 13 MR. : If you hear anything, please 14 interrupt me and I'll -. 15 MS. : Okay. I was a 16 lieutenant prior to coming here. I had - as a 17 matter of fact, I was promoted. I was given a 18 temporary position not to exceed a year as a 19 lieutenant back in I think it was 2000, 2001 20 when I was at MCC San Diego in California. And 21 I did - even after that year expired, I 22 remained in the lieutenant's office for the 23 next three or four years after that until I 24 transferred. And so when I came here, when I 25 left there, I went to be a counselor. And then EFTA00061715 19 1 I picked up my lieutenant position again in 2 Jessup. When I came here, I was already a 3 lieutenant. I didn't get promoted to the 4 lieutenant rank coming here. 5 MR. : Okay. 6 MS. : And I haven't spent 7 my whole career here at MCC New York. This is 8 my fifth institution. 9 MR. : Okay. 10 MR. : You said you've been here 11 since 2014. 12 MS. : I've been here since 13 November of 2014. 14 MR. : Okay. I'm going to keep 15 going. If you hear anything wrong, please -. 16 MS. : Okay. 17 MR. : During the interview, 18 described the duties and 19 responsibilities of the position as well as the 20 guards she supervises at the MCC. 21 is assigned to the midnight shift to 8:00 22 a.m. shift, but routinely arrives at 10:00 a.m. 23 MS. : 10:00 p.m. 24 MR. : 10:00 p.m. Sorry, I read 25 that wrong. In addition to describing her EFTA00061716 20 1 administrative duties, described 2 how a count at the MCC works and that the 3 lieutenants are responsible for supervising one 4 count per shift. described that 5 during the count, two guards assigned to the 6 area are to unlock the main gate that separates 7 the cells from the open and common area where 8 the guards are. One guard will walk down range 9 and actually look into each cell and count the 10 number of prisoners inside. Once the count is 11 complete, the guard will return to the gate and 12 exchange places with the guard that was left to 13 secure the gate. That guard will then walk 14 down range and count the number of prisoners in 15 the cells. Upon completion, the guard will 16 return to the gate, secure it from the outside, 17 and record the numbers that came from their 18 count. Those numbers will be compared to the 19 master list of prisoners on record for being 20 assigned to the cells. In addition to the 21 numbers being recorded and compared to the 22 master list or the E-1 sheet, the guards will 23 call in or receive a call from internal and 24 give a verbal record of their count. And 25 internal. EFTA00061717 21 1 MS. : Wait a minute. What 2 is that again? 3 MR. : I'll repeat that back. In 4 addition to the numbers being recorded and 5 compared to the master list or E-1 sheet, the 6 guards will call in or receive a call from 7 internal. 8 MS. : That's not true. 9 MR. : Go ahead. You can tell me. 10 MS. : When the officers 11 take the count, once they have gone around to 12 each range and both of them had counted each 13 range, before they leave that range, they will 14 compare their count for that particular range. 15 And they would do that in each subsequent 16 range. When they've completed, they call the 17 control center. And they will call in their 18 unit. They will call in the count that they 19 got for that particular unit. They will give 20 them their name, who conducted the count, and 21 at that time, the control center will let them 22 know whether they have a good count or a bad 23 count. Internals position is to pick up those 24 count slips after each unit has counted and 25 place those counts slips out into their EFTA00061718 22 1 respective sally port to be picked up by 2 internal. They do not call. Internal has 3 absolutely nothing to do with their count 4 unless they get a bad count. Sometimes 5 internal, or if we have other extra staff, they 6 will go up there and they will assist them with 7 the count. You know just to see maybe if one 8 of them miscounted or something like that. 9 They would just be like an additional person. 10 A new set of eyes, basically, to assist them 11 with the count. 12 MR. : So before I continue, I had a 13 question for you. Can you say the difference 14 between internal and control? What exactly 15 their duties are? 16 MS. : The internal officer 17 is an officer who mans the elevator. He's 18 responsible for moving inmates around in the 19 institution. He has - they have checks and 20 stuff that they do throughout their shift. But 21 mainly they're responsible for moving inmates 22 up throughout the institution. They respond to 23 body alarms. They pick up the count slips. 24 And they just have general duties throughout 25 the night. They assist with the count EFTA00061719 23 1 throughout the night. But yes, once those 2 officers if they was to get a bad count, they 3 count again. And then if they get another bad 4 count, a subsequent bad count, then internal or 5 whoever else we have available at the time 6 that's not assigned to doing something else 7 will go in and conduct another count. But 8 internal would never just - they never report 9 to internal the results of their count. 10 MR. : I was just going to ask. 11 On this if she's able to identify during her 12 shift who was in internal. 13 MR. : Do you remember who was in 14 internal that night? 15 MS. : That night? No. 16 MR. : What about control? 17 MS. : No. I don't. And I 18 don't want to guess. 19 MR. : And that's why I gave him 20 This is the official duty roster from those 21 nights. See I didn't expect you to remember. 22 That's why I was just asking if you were table 23 to look at these 24 MS. : Yeah. 25 MR. : -- things and be able to EFTA00061720 24 1 determine who it is that actually -. I think 2 this is you. you were on the 10th. So -. 3 MR. : So we're going to present you 4 with two rosters. One from August 9th, 2019. 5 MR. : Well I don't think you 6 were on August 9th. Well I guess you were at 7 the 10:00 p.m. So -. 8 MR. : The 10:00 p.m. And III 9 worked an overnight too. Right? So from 10 August 9th and then also from August 10th. So 11 I'm going to mark it Exhibit 1 on August 9th. 12 And Exhibit 2 for August 10th. 13 MS. : Okay. This is August 14 10th. 15 MR. : Can you take a look and let 16 me know who the internal was and who the 17 control was for those nights? 18 MS. : For both nights? 19 MR. : Yes, please. 20 MS. : Okay. I'm currently 21 looking at the assignment roster for Friday, 22 August 9, 2019. 23 MR. : Let's start with that 24 afternoon. And then the evening. 25 MS. : You want day watch? EFTA00061721 25 1 MR. : Yeah. Again, you can go 2 through it. 3 MS. : Okay. On Friday, 4 August 9, 2019, the day watch. You wanted the 5 control room or you wanted -? 6 MR. : Let's do control room first. 7 MS. : The control room 8 number one was Officer 9 MR. : Please spell that. I don't 10 have it. Just for the record. Can you spell 11 the name on that? 12 MS. : Yes. 13 MR. : Okay. Officer 14 MS. : Yes. And his control 15 number two officer was Officer 16 II For the evening watch shift, 17 would have been the control number one officer. 18 It seems like it appears. And 19 , would have been the control two 20 according to this roster. 21 MR. : And those were the people 22 that they would have called with the numbers. 23 Correct? 24 MS. : They generally would 25 call the control number two. EFTA00061722 26 1 MR. : Okay. Control two. 2 MS. : Control two. Yes. 3 MR. : And who was that again? 4 MS. : On day watch that 5 would have been And on evening watch 6 that would have been 7 MR. : Now as far as the counts, 8 who would have picked up the slips from 9 internal? Who was that? 10 MS. : Internal during day 11 watch was Officer who was overtime. 12 And for the evening watch shift, you had 13 Officer and they had an internal 14 number two, - Officer 15 MR. : So they would have been 16 the people that like for instance would go to 17 the SHU and pick up the count slips? 18 MS. : They would go to each 19 floor -- 20 MR. : Sure. 21 MS. : -- and pick up all 22 the count slips for the entire institution. 23 MR. : To include for the 24 special housing unit though? 25 MS. : Everywhere. EFTA00061723 27 1 MR. : Great. 2 MS. : Yes. Everywhere. 3 Whether that be medical - wherever we had 4 inmates at that time, they would have been 5 picking up those count slips. Or sometimes if 6 unit team or somebody like that is here. And 7 they're on the unit at the time, you know, 8 they'll say if they're on their way down 9 they'll say I'll take the count slip down. So 10 it just depends on what day it is and what we 11 have going on during that specific time. But 12 for the most part, when no one else has 13 delivered the count slips down, it would be 14 Well, on this day, Friday, August 15 9th. It would have been between and 16 or both. 17 MR. : Great. Do you mind just 18 - this is only so that we know what document 19 you're looking at - do you mind just initialing 20 and dating and then circling the people that 21 you just discussed? 22 MS. : Do you want me to 23 date each one? 24 MR. : No-no. I'm sorry. Just 25 on the top of the form, just an initial and the EFTA00061724 28 1 date. And then you can just circle the names 2 of the people that you just said. Just for the 3 purposes of the documents that we discussed 4 will be attached to the transcript of this. 5 And it's just to make sure that we have the 6 right document. Thank you. We'll come back to 7 this. 8 MR. : So I'm going to also present 9 you with the roster for August 10, 2019. Can 10 you do the same for us again? Identify the 11 internal and the control officers? 12 MS. : Okay. 13 MR. : Do you want her to be 14 specific though between the hours of 6:00 and 15 8:00 a.m.? 16 MR. : Yes. So specifically, 10 17 p.m. 18 MR. : So between 10 p.m. and 19 6:00 a.m. 20 MR. : I think the roster -. What's 21 the time that starts on the roster for August 22 10th? Midnight? 23 MS. : Midnight. Yeah. 24 MR. : So let's identify from 25 midnight to let's say -. EFTA00061725 29 1 MR. : 8:00 a.m. The same shift 2 that you were on. 3 MR. : Yeah. 4 MS. : Okay. So I'm looking 5 at the assignment roster for Saturday, August 6 10, 2019. The control number one officer was 7 who is non-custody. She worked in 8 the R&D - Receiving and Discharge department 9 for - she was on overtime. For day watch, 10 control number one is Officer . Control 11 number two is Officer who was on 12 overtime. For evening watch, in the control 13 one position there was Officer and 14 control two was Officer who was also 15 non-custody. 16 MR. : Now when they - when the 17 SHU officers would call control for the counts 18 during that shift, who is it that they would 19 have called? And which counts would have been 20 called? For that shift? I think you said that 21 typically, actually it 22 MS. : Typically -. 23 MR. works from 10:00 p.m. 24 to 6:00 a.m. but it shows on their schedule 25 it's 12:00 to 8:00. EFTA00061726 30 1 MS. : Well the officers 2 were working those hours. 3 MR. : Okay. 4 MS. : The officers were 5 working -- 6 MR. : So just the lieutenants 7 were different? 8 MS. : -- 12:00 to 8:00. 9 Yes. It was just the lieutenants. 10 MR. : Okay. So if they 11 actually worked 12:00 to 8:00. 12 MS. : To 8:00, 8:00 to 13 4:00, and 4:00 to midnight. That's correct. 14 MR. : Okay. So who on the 15 schedule then when the special housing unit 16 officers would call in, who was it that they 17 would call into? 18 MS. : They would normally 19 call control two. Now this is not all- 20 inclusive because if control two is busy, 21 sometimes they would call control one. Because 22 control two would be you know sometimes 23 handling back-to-back calls. And plus, they're 24 responsible for answering outside calls and 25 stuff to that nature as well. I mean when EFTA00061727 31 1 people are calling in from the outside, they 2 don't care if they miss count time or not. But 3 the control number two officers work from 6:00 4 to 2:00 to 2:00 to 10:00. Those were their 5 hours. 6 MR. : Okay. 7 MS. : Okay? And um. 8 MR. : So 6:00 a.m. or 6:00 9 p.m.? 10 MS. : The day watch would 11 work - or the a.m. shift as we call it. They 12 would work from 6:00 a.m. to 2:00 p.m. 13 MR. : Okay. 14 MS. : And the p.m. shift 15 would work 2:00 p.m. to 10:00 p.m. 16 MR. : Okay. So specifically in 17 the hours that you were working there, who 18 would have been called by the special housing 19 unit? 20 MS. : Well like I said, 21 they would have been calling because I worked 22 morning watch. They would have been calling 23 There wouldn't have been a control two -. 24 MR. : So that's -. 25 MS. : Wait a minute. EFTA00061728 32 1 MR. : So that's so yeah. Let's 2 say for instance the 12:00 p.m. count, the 3:00 3 a.m. count, and the 5:00 a.m. count. Who would 4 have been called then on August 10th? 5 MS. : They would have been 6 calling control number one because I don't 7 think they had, um They would have been 8 calling -. I want to say they was calling 9 control number one. Because at this time, it 10 look like we had a control number two. Because 11 there was a time when internal number two would 12 fill in for the control number two. But it 13 doesn't look like this was during that time. 14 MR. : To your best guess, who 15 of the officers in the special housing unit, 16 who would have been called? For the 12:00, the 17 3:00, and the 5:00 a.m. counts, who would have 18 been called on those? 19 MS. : They would have been 20 calling the control center number one. 21 MR. : And who was that? 22 MS. : During the 12:00 to 23 8:00 shift that would have been Officer 24 who, like I said, was on overtime. She's non- 25 custody. She works in the R&D department. EFTA00061729 33 1 MR. : Okay. 2 MS. : That's where she's 3 assigned. 4 MR. : Okay. And then for those 5 same counts, 12:00 a.m., 3:00 a.m., and 5:00 6 a.m., who from internal would have collected 7 those slips? 8 MS. : It could have been 9 either one of them. 10 MR. : Okay. 11 MS. : Because on morning 12 watch, it looks like there was two. But I'm 13 trying to remember at that time if um -. 14 Because sometimes the internal two would assist 15 control because there were other things that 16 needed to be done. But you have for internal 17 there on morning watch there was Officer 18 and Officer who was on overtime. Officer 19 was on overtime for midnight to 8:00. So 20 between those two, they would have been picking 21 up the count slips. 22 MR. : Just can you repeat those 23 two again? 24 MS. : That's internal would 25 have been Officer . And internal number EFTA00061730 34 1 two was Officer . And he was on overtime. 2 MR. : Great. Thank you very 3 much. 4 MR. : Can you do the same with 5 that? Just circle. 6 MR. : Just circle the names 7 that you just mentioned and then just initial 8 and date on the top. 9 MS. : Oh, you know what I'm 10 doing? 11 MR. : It's -. 12 MS. : I'm putting the date 13 of the roster on here. 14 MR. : Yeah, I know. You want 15 to date it today. I'm sorry. So today is 16 6/14/21. Sorry. And I'm handing you back the 17 other roster so you can fix that. 18 MR. : So the August 10th roster I'm 19 going to mark as Exhibit 2. And August 9th 20 will be Exhibit 1. 21 MR. : I wouldn't. this is -. 22 If you're doing exhibits, this is Exhibit 1. 23 MR. : Alright. 24 MR. : If you want to do that. 25 MR. : Okay. EFTA00061731 35 1 MR. : Because we're probably 2 going to have to go back to this, I wouldn't 3 mark them as exhibits. 4 MR. : Okay. No problem. 5 MR. : Because this is always 6 going to be Exhibit 1. 7 MR. : I understand. Just to 8 clarify before we move forward. How many 9 counts take place at the MCC? Daily? 10 MS. : It depends. During 11 the week we have the Let's start with day 12 watch. Day watch we have the 4:00 p.m. count. 13 Evening watch we have the 10:00 p.m. count. 14 Morning watch we have the 12:00 a.m., the 3:00 15 a.m., and the 5:00 a.m. So five. On weekends 16 and holidays, we have an additional count of 17 10:00 a.m. which is added for weekends and 18 holidays. 19 MR. : Okay. Thank you. So I'm 20 going to go back and I'm going to continue 21 reading from that spot. So I'm going to reread 22 that line and we'll move forward. 23 MS. : Okay. 24 MR. : In addition to the numbers 25 being recorded and compared to the master list EFTA00061732 36 1 or E-1 sheet, the guards will call in or 2 receive a call from internal and give a verbal 3 record of the account and internal will compare 4 that number to the number that they have on 5 file and advise the count matches and is good 6 or does not match 7 conducted again. 8 explained how the 9 works. The count and a count needs to be You clarified that. You control and the internal slips prepared by the guards 10 are then placed in the area for pickup by 11 another guard assigned in the MCC and brought 12 to control for review. In addition to the 13 official counts that are to be conducted at 14 specific times during each shift, 15 informed that the guards are also 16 responsible for conducing rounds 17 minutes. During the rounds, the 18 walk the range and view that the 19 alive and in their cells with no every 30 to 40 guards simply prisoners are issues. The 20 number of prisoners is not recorded, but simply 21 the fact that a round was conducted. And the 22 officers who conducted it is. When asked, 23 stated that she has no knowledge 24 of rounds or counts not being conducted and 25 that no one would tell her if that were the EFTA00061733 37 1 case. 2 MS. : As far as the rounds 3 go, the rounds are irregular. So they're not 4 supposed to be done at the same time and 5 there's a reason for that. You know. So the 6 rounds are supposed to be conducted - are 7 usually conducted every hour and they're done 8 on an irregular basis. So that's how the 9 rounds are supposed to be done. 10 MR. : So you say every hour, 11 it's not every 30 minutes? 12 MS. : That would be in SHU. 13 MR. : Okay. 14 MS. : Special housing has 15 its own set of rules as far as the count goes 16 but on the other units, and even in SHU the 17 rounds are supposed to be irregular. 18 MR. : Sure. 19 MS. : They're not supposed 20 to be like every half hour or something like 21 that. 22 MR. : Is it correct that it's 23 every 30 minutes but it's supposed to be 24 between 30 and 40 minutes? 25 MS. : There's a little EFTA00061734 38 1 hangover just for that -- 2 MR. : Sure. 3 MS. : -- so that the rounds 4 can be irregular if you get tied up. Because 5 when you're making rounds, inmates will stop 6 you. They will hold conversations with you and 7 ask questions. You know and so it's hard to 8 keep those rounds within those guidelines 9 because there's always something to trip you 10 up. When you're making rounds you may notice 11 something out of place, so that would stop you. 12 But as far as those rounds getting conducted, 13 those rounds are supposed to be conducted on an 14 irregular basis. But do understand that there 15 are things that will trip you up. So sometimes 16 you may be on time. Sometimes you -. It's 17 hard to fall within those guidelines because 18 you're - it's live time. Everything is live. 19 So you can't predict what's going to happen 20 while you're making your rounds. 21 MR. : Understood. And that was a 22 summary of your interview. So as you can see, 23 we have a few questions we want to follow 24 MS. : Right. 25 MR. : And we've got -. EFTA00061735 39 1 MS. : You have medical 2 emergencies. You have inmates that are 3 complaining, wait until you start making your 4 rounds to complain about being in pain or 5 something that's hurting them. Or a lot of 6 general stuff. They'll ask you questions just 7 about anything when you're making rounds. 8 MR. : Understood. 9 MS. : Mm-hmm. 10 MR. : I'm going to go back to my 11 interview now and I have a few questions for 12 you. If there were instructions of guidance 13 from upper management, how would you receive 14 them? 15 MS. : It depends. During 16 that time, they made -. Whoever was in the 17 office may come and say something to the person 18 in the office. And it was left up to everybody 19 else to get that information from that 20 individual. 21 MR. : Who was in the office at that 22 point? I mean is a certain person assigned to 23 the office or it could be anybody in the 24 office? 25 MS. : Like the lieutenant. EFTA00061736 40 1 Like a - when I say the office, I'm talking 2 about like the lieutenants' office. So 3 sometimes they would just - and more often than 4 not - they would just say something to whoever 5 is in the office. And that's how everybody is 6 supposed to get that information. 7 MR. : If there were instructions 8 from the lieutenants, who would give it? 9 MS. : We would expect the 10 captain to give it. 11 MR. : Did the instructions that 12 would come from above the captain? Or was it 13 always from the captain? 14 MS. : Um.... I don't -. I 15 mean, from time to time, some of the AWs would 16 put things out. But the normal chain would be 17 through the captain because that was our 18 immediate supervisor. 19 MR. : Okay. If you had important 20 details to discuss with your subordinates or 21 COs who report to you, how would you 22 communicate that to them? 23 MS. : One more time. 24 MR. : If you had important details 25 or instructions you wanted to discuss with your EFTA00061737 41 1 subordinates or COs, correctional officers, who 2 report to you, how would you communicate those 3 instructions to them? 4 MS. : I usually did it when 5 I made my rounds. And I would tell them. But 6 you could also do a thing such as 3-3-3s. And 7 that way, that's when everybody come on the 8 line and you could do it that way. But you 9 really didn't have time. It was easier to just 10 tell everybody individually because that way 11 you're with them in person. And it's just 12 easier for you to do it at that time because if 13 they had questions, then they could ask you 14 questions. And when you're doing over the 15 phone at the hole, you're sitting in the 16 office. So you're really not getting anything 17 done, you know. At least if I'm making my 18 rounds, I'm getting my rounds done and I'm 19 doing my - passing down information to my staff 20 at the same time. And also it lets me know 21 that you got it. I'm telling you. it's just 22 you and me. There's no distractions in the 23 background. There's nothing else going on. 24 But it just depends on the person. 25 MR. : Okay. EFTA00061738 42 1 MS. : How they got that 2 information to each individual staff. 3 MR. : Would you communicate that 4 directly with your COs or would you tell 5 another CO to pass on the message? 6 MS. : It depends on what 7 the information was. I mean things that you 8 want them to know and definitely. If it was 9 something that was a new policy or procedure or 10 something like that, you would definitely want 11 to tell them yourselves because at that time, 12 like I said, there wasn't anything coming out 13 in writing. That's generally how new policy 14 and procedure is put in place. You know you 15 either receive a memorandum saying starting 16 with this memorandum or starting with - 17 effective today or some other date, this is 18 what we're going to be doing. That's generally 19 how that information is put out. Or some type 20 of manual or something like that is updated. 21 Those are the ways that it's generally put out. 22 That way you have the information there and you 23 can refer back to it as needed. 24 MR. : What if it involved an 25 inmate? Like certain instructions for certain EFTA00061739 43 1 inmates. How would that come out? Would that 2 come out verbally or would that be written? 3 MS. : It depends on, like I 4 say, the person that's delivering the 5 information. It depended on that. 6 MR. : On August 9th when you came 7 on shift during that day, you said you were 8 working overnight. 9 MS. : Yes. 10 MR. : So technically, weren't you 11 on shift August 9th nighttime? Morning watch? 12 Do you remember? 13 MS. : August 9th going into 14 August 10th. 15 MR. : Okay. 16 MS. : So -. 17 MR. : Did you work the day before 18 too? You don't recall. 19 MS. : I don't know if I did 20 or not. I may have. 21 MR. : Let's try to focus -. 22 MS. : Yeah. I don't know. 23 MR. : No problem. So let's talk 24 about August -. 25 MR. : Um, so if you're asking - EFTA00061740 44 1 2 3 - MS. I work -- : What do you mean did 4 MR. : -- specifically August 5 9th -- 6 MS. : -- day watch or -? 7 MR. : It looks like she was on 8 from midnight to 8:00 the day before. 9 MR. : Day before too. 10 MR. : So that means you would 11 have left at 6:00 a.m. on August 9th. 12 MS. : Right. And came back 13 -. 14 MR. : And come back at 10:00 15 p.m. 16 MS. : That's correct. 17 MR. : So let's focus on 10:00 18 p.m. to 6:00 a.m. August 9th night going into 19 August 10th day. 20 MS. : Right. Because I 21 don't think I worked evening watch. 22 MR. : No there's a reason. Can I 23 ? 24 MR. : Sure. I'm just saying 25 she's done at 6:00 a.m. not at 8:00. EFTA00061741 45 1 MR. : Yeah, that's what I wanted to 2 ask. 3 MS. : Okay. 4 MR. : So I just want to clarify. 5 That day, I know you don't recall but according 6 to the schedule, what is that showing? What 7 time did you leave on August 9th morning? 8 MS. : Oh. I would have 9 left probably - it depends on who was relieving 10 me. I probably would have left probably before 11 6:00. 12 MR. : Before 6:00. 13 MS. : Mm-hmm. 14 MR. : Would you -? 15 MS. : 6:00 a.m. 16 MR. : 6:00 a.m. By 6:00 a.m., 17 would you happen to have heard if there was an 18 inmate being removed from the MCC? Or did that 19 come afterwards? Let's say they -. 20 MS. : What on August 9th? 21 MR. : August 9th. 22 MS. : I don't recall. What 23 day did Epstein die? Because I don't even 24 remember what day he passed. 25 MR. : August 10th. EFTA00061742 46 1 MS. : Okay. 2 MR. : Well that's when he was 3 found. 4 MS. : Okay. 5 MR. : He was found August 10th 6 morning. 7 MS. : So you said -. 8 MR. : August 9th. That would be 9 Friday morning. Right? You left the shift it 10 looks like 6:00 a.m. Right? 11 MS. : Which would have been 12 Saturday morning. 13 MR. : No-no. Sorry. I should 14 clarify. August 9th -- 15 MS. : Oh. 16 MR. : -- morning is Friday morning. 17 MS. : Okay. Friday 18 morning. 19 MR. : Friday morning, you did the 20 overnight shift. Then you left. And then you 21 came back August 9th, 10:00 p.m. and you worked 22 until 6:00 a.m. 23 MS. : Right. 24 MR. : Now I'm talking about August 25 9th -. Let's say August 8th 10:00 p.m. to EFTA00061743 47 1 August 9th -. 2 MS. : Oh my God. 3 MR. : The reason I'm asking is I'm 4 just trying to clarify. Would you have known 5 if any instructions came about inmates having 6 to be brought out for court or anything like 7 that. Would you have heard about it before you 8 left? 9 MS. : We're talking about 10 August -. 11 MR. : 9th. 12 MS. : I mean I may have. I 13 can't recall. 14 MR. : Okay. But does it happen 15 before 6:00 a.m. or it happens after 6:00 a.m. 16 normally? 17 MS. : You mean like inmates 18 that are going to court? 19 MR. : Going to court or being 20 removed from the prison for whatever reason. 21 MS. : I mean if it involved 22 me. Say if we had an inmate up on 10 South. 23 Because those inmates up there are generally 3- 24 man holes. So if there was an inmate that I 25 had to physically be involved in escorting, EFTA00061744 48 1 yes. They would notify me or the activities 2 lieutenant. It just depends. 3 MR. : No problem. Now I'm going to 4 keep going. Are you familiar with Inmate 5 Jeffrey Epstein? 6 MS. : Yes. 7 MR. : Okay. Did you work in the 8 SHU while Epstein was assigned to the SHU? 9 MS. : No. 10 MR. : Okay. Do you recall if 11 Epstein had a cellmate? 12 MS. : At some point he had 13 a cellmate. 14 MR. : Okay. Were you aware that 15 Epstein had attempted to commit suicide before? 16 MS. : Yes. 17 MR. : Okay. Do you recall around 18 what time - what date it was? 19 MS. : I know it was in 20 July. I can't remember the exact date. But I 21 know it was in July. 22 MR. : Were you there for that 23 incident? 24 MS. : Yes. 25 MR. : Okay. Quickly, do you EFTA00061745 49 1 remember? Like a short summary what 2 transpired? 3 MS. : Um, we were called to 4 the special housing unit. I think when we got 5 there and Officer Thomas was working that day. 6 When we got there, the officer informed us that 7 an inmate had tried to hurt himself. So we go 8 up to the cell and it's Epstein. 9 MR. : Okay. 10 MS. : And he's lying on the 11 floor seemingly out of it I guess you could 12 say. But when we tap him and we move him, we 13 could see him kind of looking up at us. But 14 then he would close his eyes like he didn't 15 want us to know that he was actually conscious. 16 MR. : Okay. 17 MS. : So we couldn't get 18 anything from him. He wouldn't respond to us. 19 But we knew that he was okay. He was 20 breathing. And like I said, he would look up 21 at us from time to time. When he didn't think 22 that we were looking at him. 23 MR. : Okay. 24 MS. : And -. 25 MR. : What happened after that? EFTA00061746 50 1 Was Epstein placed on suicide watch or psych 2 observation? 3 MS. : Yes. He was placed 4 on suicide watch. 5 MR. : Okay. 6 MS. : Officer Thomas was 7 assigned to watch him. And he literally stood 8 there at his cell all night watching him and 9 talking to him. 10 MR. : Who was? 11 MS. : Officer Thomas. 12 MR. : Okay. Same Thomas? 13 MS. : Yes. 14 MR. Thomas? 15 MS. : Yes. 16 MR. : Okay. 17 MS. : Yes. 18 MR. : How long - do you recall how 19 long he was on suicide watch? 20 MS. : I don't recall. 21 MR. : Okay. No problem. Now was 22 he eventually removed from suicide watch? 23 MS. : Yes. 24 MR. : What happened after suicide 25 watch? Was he placed on any of the EFTA00061747 51 1 observation? Or -? 2 MS. : I don't remember. I 3 don't remember if he went from suicide watch to 4 psych ops or if he went from suicide watch 5 straight back to the special housing unit. 6 MR. : So suicide watch - where does 7 that take place? 8 MS. : That's on the second 9 floor. 10 MR. : Second floor. What unit? 11 MS. : Medical. 12 MR. : Medical? 13 MS. : It's right out -. 14 It's like an extension to the medical unit 15 slash -. At that time, we had - there was a 16 female housing unit there. So it's adjacent to 17 the female housing unit. But the second floor 18 is our medical floor aside from the housing 19 unit. 20 MR. : Okay. 21 MS. : And the psych unit. 22 MR. : When Epstein was returned 23 back to the SHU. Do you recall any 24 instructions being given by upper management, 25 executive staff, regarding Epstein being EFTA00061748 52 1 assigned with a ceilmate? 2 MS. : No. 3 MR. : Okay. Did you -? I'm going 4 to go through each. Did you receive any 5 instruction from Captain in regard to 6 this? 7 MS. : No. 8 MR. : Okay. Do you recall? I'm 9 going to ask. Do you recall receiving an email 10 from psych instructing that Epstein needed a 11 celimate? 12 MS. : No. 13 MR. : I'm going to show you a 14 document. Right? Read that document. Who is 15 that email from? 16 MS. : This is from 17 18 MR. : And who is that? 19 MS. : She was a 20 psychologist here at the time. 21 MR. : Okay. And what is the 22 summary of that email? 23 MS. : It's says inmate 24 Epstein register number 76318-054 is being 25 taken off of psych observation and needs to be EFTA00061749 53 1 housed with an appropriate cellmate. 2 MR. : What's the date of that 3 email? 4 MS. : This is July 30, 2019 5 at 12:30 p.m. 6 MR. : Do you recall getting that 7 email? 8 MS. : I don't recall. This 9 is the first I've seen of this email. This is 10 the first time I've seen this email. 11 MR. : So if you flip through the 12 pages, it actually shows you the recipients. 13 Is your name on that? 14 MS. : If she sent it to the 15 lieutenants group, I'm sure - more than likely 16 -. 17 MR. : There's a -. 18 MS. : Yeah. 19 MR. It's in alphabetical order. 20 MS. : Yeah. Yes, I'm here. 21 MR. Is there a reason why that -? 22 I mean, you don't recall reading that email 23 yourself then. 24 MS. : I don't even remember 25 seeing this email. EFTA00061750 54 1 MR. : Okay. Did you ever 2 participate in executive committee meetings? 3 MS. : No. 4 MR. : Okay. That was just the 5 higher ups? You don't even know who -? 6 MS. : I don't even know 7 what that -. 8 MR. : Okay. No problem. 9 MS. : Yeah, I don't -. 10 MR. : Okay. So I'll move on. 11 MR. : Initial and date. 12 MR. : Yeah. Sorry. Can you 13 initial and date that document for me? I'm 14 going to mention some names. Can you just let 15 me know what, if any, conversations you had 16 with any of these people regarding Epstein and 17 Epstein needing a cellmate at all times? 18 Captain Lieutenant 19 MS. : Okay. What do you 20 want me to do? I'm sorry. 21 MR. : No. I'm going to through the 22 names. 23 MS. : Okay. 24 MR. : If you recall if you had a 25 conversation with any of these people in regard EFTA00061751 55 1 to Epstein and Epstein needing a cellmate. 2 MS. : Okay. 3 MR. : Okay? This is prior to the 4 incident. 5 MS. : Okay. 6 MR. : Captain 7 Lieutenant . Lieutenant 8 9 MR. : You need to let her say 10 yes or no after each one. 11 MR. : Okay. Sorry. Apologize. 12 Have you ever had a conversation with 13 Captain - in regard to Epstein needing a 14 cellmate? 15 MS. : No. 16 MR. : What about Lieutenant 17 18 MS. : No. 19 MR. : Lieutenant 20 MS. : No. 21 MR. : Lieutenant 22 MS. : No. 23 MR. : Lieutenant 24 MS. : No. 25 MR. : Lieutenant EFTA00061752 56 1 2 3 4 MS. MR. : MS. MR. : : No. Lieutenant : No. Now following that I have a 5 few more names. The rest are correctional 6 officers. Same thing. Have you had any 7 conversations with them about Epstein requiring 8 a cellmate? CO 9 MS. : No. 10 MR. : CO 11 MS. : No. 12 MR. : If I mispronounce the name, 13 please correct me. CO 14 MS. : No. 15 MR. : CO Michael Thomas. 16 MS. : No. 17 MR. : CO Tova Noel. 18 MS. : No. 19 MR. : CO 20 MS. : No. 21 MR. : CO 22 MS. : No. 23 MR. : CO 24 MS. -'- 25 MR. : Yeah. EFTA00061753 57 1 MS. : No. 2 MR. : How about SOS 3 4 MS. : No. 5 MR. : Okay. When did you become 6 aware of Inmate being removed from 7 the MCC? Do you know who 8 is? 9 MS. : I don't even know who 10 that is. 11 MR. : Okay. Do you recall who was 12 Epstein's cellmate? 13 MS. : When? 14 MR. : During that period? After he 15 came back from suicide watch? 16 MS. : No. 17 MR. : Okay. 18 MR. : Do you remember if he had 19 one after that? We're talking about July 30th 20 when he came back. Are you -? 21 MS. : I didn't know if he 22 had one or not. 23 MR. : Okay. 24 MS. : Um. No. I didn't 25 know if he had a cellmate or not to be honest EFTA00061754 58 1 with you. No. 2 MR. : And you're not aware of any 3 requirements of him having a cellmate either? 4 MS. : I wasn't even aware 5 that they had sent out some information 6 regarding the fact that he needed to have a 7 cellmate. I would think that they would be 8 that that would be something that they would 9 verbalize. 10 MR. : Okay. 11 MS. : That they would make 12 sure that we individually -. That they would 13 check to make sure that we all read that 14 message. 15 MR. : Okay. 16 MS. : I mean if it was 17 something that was critical -. Because he was 18 on suicide watch. And because of the 19 circumstances that surrounded him. I would 20 expect for them to follow-up and make sure that 21 we all read that email and we were all aware 22 that he was to have a cellie. 23 MR. : Who would you expect to do 24 that? 25 MS. : 1 would expect for EFTA00061755 59 1 psychology to follow-up with us. I would 2 expect for definitely the captain to get with 3 us individually and tell us. 4 MR. : Okay. 5 MS. : Hold a lieutenant's 6 meeting or something to let us know that we 7 were to make sure that he had a cellmate. 8 MR. : Okay. If - let's say. Have 9 you ever dealt with an inmate that required a 10 cellmate before? 11 MS. : Not directly, no. 12 No. 13 MR. : But do you -? Okay. You 14 never have. But if let's say an inmate was 15 required to have a cellmate. And that cellmate 16 was removed for whatever reason. Do you know 17 what the procedure would be? 18 MS. : If an inmate was 19 required to have a cellmate. And everybody 20 knew. Because when you're talking about an 21 inmate that needs a cellmate, it's not just the 22 lieutenants who work with that inmate. The 23 officers are the ones who are assigned to that 24 inmate housing unit. Around the clock, 24/7. 25 So you would definitely want that information. EFTA00061756 60 1 That should be an all staff email to be honest 2 with you. Because that way everybody in the 3 institution knows that there's an important 4 reason why that inmate needs a cellmate. And 5 that way if at some point in time it's not 6 happening or there's a lapse in that, everybody 7 knows. So you've got - because you have staff 8 making rounds around the institution on the 9 housing units and all of that stuff all the 10 time. You know, different members of the 11 institution staff. So that would be an all 12 staff email just to alert everybody in the 13 institution that, you know, if you're ever in 14 that area and you come across this inmate and 15 he doesn't have a cellie, then you need to 16 follow-up, ask why, make sure somebody knows 17 that that inmate don't have a cellie. 18 MR. : I'm going to clarify. Based 19 on the fact that based on what we - our 20 investigation. Inmate was assigned 21 as a cellmate for Jeffrey Epstein. 22 MS. : Okay. 23 MR. : And he was required - 24 according to psychology - he was required to 25 have a cellmate. Now Inmate was EFTA00061757 61 1 removed from the MCC on August 9th morning 2 during the day watch. Now based on - I'm going 3 to read you the names again. Right. And you 4 just tell me. You might not know it directly, 5 but who would be responsible to take what 6 action when they found out that was 7 removed. If there was a requirement, that 8 Epstein had to have a cellmate at all times, 9 and his cellmate was removed, who would be 10 responsible to take action? And I'm going to 11 mention the names. Let me know what their role 12 would have been and what action they should 13 have taken. 14 MS. : You're telling -. 15 You want me to tell you that. That's if in 16 fact they knew -. 17 MR. : Yeah. If in fact they knew. 18 MS. : Yeah. If in fact 19 they knew that he was supposed to have a 20 cellie. 21 MR. : Yes. 22 MS. : You know. Not 23 assuming that he had a cellie. 24 MR. : And so we don't have to 25 go back and circle back to this. Not only - so EFTA00061758 62 1 if he's naming a name, say what action should 2 have they taken and who should have told them 3 the information with regard to the need to have 4 a cellmate. 5 MS. : Well I would have to 6 know what position those officers had -- 7 MR. : Sure. 8 MS. : -- at the time that 9 this occurred also. Because -. 10 MR. : We can hand you the roster 11 again. 12 MR. : So this is the August 13 9th. I'll give you that one first. 14 MR. : But just start with 15 (Indiscernible *00:58:18). 16 MR. : Again, so he was removed 17 from his cell let's say around 8:30 a.m. and I 18 think he was removed from the institution 19 somewhere around 1:30 p.m. So 8:30 is when he 20 went to a court. And then by 1:30 he was gone. 21 MR. : They were pretty much 22 notified he's not coming back. 23 MS. : Mm. 24 MR. : So I'll start with Captain 25 EFTA00061759 63 1 MS. : Yes. Captain 2 should have known. 3 MR. : How would he have known? Who 4 should have made him aware of it? 5 MR. : Let's just - instead of 6 going through it, let's just first start with 7 going from the bottom up. Who should have 8 known that he was removed? And how should the 9 chain of command have gone up? Looking at that 10 duty schedule roster. 11 MR. : Yeah. Based on that. Who 12 should have initially known that he was 13 removed? 14 MS. : Well R&D should have 15 known initially that the inmate was removed. 16 Now whether or not they would have known that 17 he was Epstein's cellie is something different. 18 MR. : Okay. 19 MS. : Like I said, if this 20 information had put out because Epstein was a 21 high-profile inmate. He had just attempted 22 suicide. That should have been an all-staff 23 email. That should have alerted everybody. 24 And not only that, but when that happens. 25 First of all, when Epstein originally arrived EFTA00061760 64 1 to the MCC, Epstein should have been placed on 2 10 South. That's our - what they consider the 3 maximum-security unit here. He never should 4 have been placed on 10 South anyway because 5 you're not guaranteed that anybody in this 6 building is going to maintain a cellie because 7 it's an administrative institution. Inmates 8 come and go all the time. So there's - they 9 don't have a sentence date. And with that 10 said, that means that at any point and time 11 while we're sitting here, the courts can 12 release somebody and that inmate is gone right 13 now. So to put out an email to certain 14 individuals and not make that an all-staff 15 email so that it would -. And I guess we have 16 to go back and say what was the intentions of 17 that? If it's something that you feel is 18 concerning and that absolutely needs to happen 19 because you still feel that this inmate is at 20 risk, then you say to yourself, well why is he 21 being released from suicide watch? Or psych 22 ops. Why, you know? If you feel that this 23 inmate still needs this type of supervision. 24 And if the answer to that is yes, he still 25 needs that type of supervision, then you would EFTA00061761 65 1 recommend that, you know, why don't you keep 2 him?? Why aren't you maintaining him? You 3 know. On watch? If he requires that type of 4 supervision? Or why - since you didn't do it 5 to begin with - which they should have done. 6 Considering he was high-profile, he was an at- 7 risk inmate, just the fact that he was a high- 8 profile inmate, he should have been placed on 9 10 South. After he attempted suicide and they 10 determined that they was going to remove him 11 from that and required him to have a cellie. 12 Then they should have either made it an all- 13 staff email, made sure everybody was aware - 14 everybody. Not just -. And it's difficult 15 because people are on days off, people are on 16 vacation, people are on sick leave, you see 17 what I'm saying? 18 MR. : Okay. 19 MS. : So for somebody like 20 Epstein. Epstein should have automatically 21 gone to 10 South where he would have had 24- 22 hour monitoring on him at all times. 23 MR. : Okay. Assuming that the CO - 24 . Let's start with the COs. Assuming the COs 25 in the SHU knew that this was a requirement. EFTA00061762 66 1 In day watch. If he was removed at 8:30, who 2 is responsibility would it have been to notify 3 upwards? 4 MS. : It would have been 5 any of their responsibility if they were there 6 at the time and they were aware that he was 7 being moved or if they knew that he was even 8 supposed to have a cellie. 9 MR. : So who was the COs on for the 10 SHU? 11 MS. : On -? 12 MR. : Day watch for August 9th. 13 MS. : Day watch on August 14 9th would have been Officer , Officer 15 , and 16 MR. : Okay. And what would - if 17 they knew that Epstein was required to have a 18 cellmate, what should they have done? 19 MS. : If they knew that 20 Epstein required a cellie, and his cellie was 21 released, if they knew he wasn't coming back. 22 I mean I don't know if they knew that when the 23 cellie left that he was never coming back. I 24 don't know what any of these people were told. 25 So I'm just assuming here. If his cellie was EFTA00061763 67 1 released, and they knew for a fact that he 2 wasn't coming back, and if they knew that he 3 was supposed to have a cellie, which I doubt. 4 Because I didn't even know it. So -. 5 MR. : Let's just assume they knew. 6 Let's just go from there. If they knew. 7 MS. : Then one of them 8 should have called. 9 MR. : Called who? 10 MS. : The captain, 11 psychology, the lieutenant's office. One of 12 them. 13 MR. : Okay. And let's just say 14 they called the lieutenant's office. What 15 would the lieutenant's office have done? 16 MS. : They would have 17 followed up. They would have been like okay, 18 if they didn't know already, they would have 19 determined what's the status of this cellmate. 20 What is -? Is he coming back? They probably 21 would have moved Epstein out of that cell or 22 immediately put another inmate in the cell with 23 him. 24 MR. : Okay. 25 MS. : But when you're EFTA00061764 68 1 talking about somebody like Epstein, you just 2 can't just put any inmate in that cell with 3 Epstein. So you know, you kind of have to seek 4 guidance on that and tell - let somebody know 5 what you have going on so they can determine 6 who they want in the cell with Epstein. Which 7 is why it goes back to 10 South. That's why he 8 should have been on 10 South because you can't. 9 He's not one of those inmates that you can just 10 put anybody in his cell with him. 11 MR. : Who would you have - seeked 12 guidance from? 13 MS. : Me? 14 MR. 15 MS. 16 MR. : Yeah. As a lieutenant? To assign - get a new inmate 17 for Epstein. Who do you think? Because you 18 said he's high profile. Who would you have -? 19 MS. : I would have informed 20 the captain 21 MR. : Okay. 22 MS. : -- that you know the 23 cellie that he had had been released and asked 24 him you know how do you want us to move 25 forward? EFTA00061765 69 1 MR. : Okay. 2 MS. : Who do you want the 3 SHU officers to place in that cell with him? 4 MR. : So as per whoever the CO is 5 they should report it to the lieutenant or the 6 captain and they would have brought it up and 7 someone higher up should have assigned a 8 cellmate. 9 10 11 12 13 that he was supposed to have had a cellmate and 14 based upon that email that I just saw for the 15 first time, I'm sure they didn't - in this 16 group here. Oh they would have contacted 17 somebody. 18 MR. : Okay. 19 MS. : These guys definitely 20 were not you know 21 , these cats - they wouldn't have ignored 22 that. They would have told somebody. If they 23 knew, they would have definitely reported it to 24 somebody. And um -. 25 MR. : How soon should have an MS. knew. MR. : Yeah. : The officers if they MS. : If they were aware EFTA00061766 70 1 inmate been assigned to that cell? Normally, 2 what's the procedure? How soon after would 3 they -? 4 MS. : I say that Epstein 5 should have been on 10 South. 6 MR. : Okay. 7 MS. : So I mean, as quick 8 as possible. 9 MR. : Okay. That's it. 10 MS. : Yeah. As quick as 11 possible. 12 MR. : I'm not going to go through 13 names. You just explained this from the bottom 14 up. We just wanted to clarify. 15 MS. : Okay. 16 MR. : I'm going to move on. Did 17 you conduct on August 9th evening from 10:00 18 p.m. to August 10th the next day? Did you 19 conduct any rounds in the SHU during your 20 shift? 21 MS. : Yes. 22 MR. : What rounds did you do. Do 23 you recall? What count or rounds did you do in 24 the SHU? 25 MS. : I don't remember what EFTA00061767 71 1 rounds. 2 MR. : Okay. 3 MS. : I think it was 4 probably mid-morning I think. What do you mean 5 by rounds? Do you mean did I conduct my 6 lieutenant rounds? 7 MR. : Yeah. Lieutenant rounds. 8 MS. : Yeah. Yeah. 9 MR. : Mid-morning? 10 MS. : I think it was mid- 11 morning because there was a lot going on that 12 night. 13 MR. : No problem. 14 MS. : So I was running 15 behind. 16 MR. : Let's clarify this 17 because you weren't there mid-morning. 18 MR. : Mid-morning you mean 19 overnight. 20 MS. : Yes. Overnight. 21 MR. : Okay. So when you say 22 mid you mean like 4:00 a.m. on August 10th is 23 what you're saying? 24 MS. : Yeah. Probably. 25 That sounds about right. EFTA00061768 72 1 MR. : Okay. 2 MR. : Now I just have two 3 questions. Why do COs have to conduct rounds? 4 MS. : To make sure that the 5 inmates are safe. That they're still 6 breathing. That there is nothing illegal or 7 unauthorized going on inside the institution. 8 Just to make sure that everything is okay. 9 MR. : Okay. Is it -? Why do COs 10 have to conduct counts? 11 MS. : To account for all 12 the inmates. 13 MR. : Okay. Is it mandatory to 14 conduct counts and rounds? 15 MS. : It's part of your 16 duties. 17 MR. : Okay. Is it policy? 18 MS. : Yes, it's policy. 19 MR. : Okay. And you explained in 20 your previous interview about who is 21 responsible for conducting the rounds. As a 22 supervisor, you mentioned in your previous 23 interview that the supervisor should also 24 conduct one round per -. One count or one 25 round? I mean what are they -? EFTA00061769 73 1 MS. : Each lieutenant is 2 required to make rounds during their shift. 3 Whether that be the operations lieutenant or 4 whether that be the activities lieutenant. 5 Just a lieutenant. It doesn't have to be both. 6 If I'm operations lieutenant and I have an 7 activities lieutenant assigned, both of us 8 don't have to make rounds. The lieutenant - a 9 lieutenant just have to make rounds during each 10 respective shift. 11 MR. : Is there specific units that 12 they have to go to or can it be anything? 13 MS. : I mean if you're 14 making rounds, the idea is to go to each 15 housing unit. 16 MR. : Okay. 17 MS. : Now depending on what 18 you have going on during the night, sometimes 19 you may get that done. Sometimes you don't. I 20 mean there may be a lot going on at the 21 institution that you may not get around to 22 making the rounds done during your shift. 23 MR. : Okay. I want to take a quick 24 detour. I'm going to show you two documents. 25 Can you show me what that is a map of? EFTA00061770 74 1 MS. : I have no idea. 2 MR. : If you don't understand it -- 3 MS. : Yeah, I don't -- 4 MR. then just say it. 5 MS. : -- know what this is. 6 MR. : Okay. No problem. How many 7 tiers are there for the SHU? 8 MS. : I haven't been up 9 there in a while. I'm going to say there is 10 two. There's four tiers. I mean if you're 11 talking about upstairs and downstairs, there's 12 two tiers. 13 MR. : Two tiers. 14 MS. : Mm-hmm. And then you 15 have 10 South. And then you have Lower 10 16 South. So. If you count each individual tier, 17 I guess you would say five tiers. Because you 18 got Lower 10 South up there as well. 19 MR. : Okay. Five tiers. 20 MS. : Mm-hmm. 21 MS. : Thank you. I'm going 22 to move on. I'm going to show you a document. 23 Can you tell me what that is? 24 MS. : This is the E-1. 25 MR. : What's an E-1? EFTA00061771 75 1 MS. : The E-1 is a 2 computation of all the housing units. Well it 3 includes all the housing units and how many 4 inmates they have on their unit at the time in 5 which this is actually printed. 6 MR. : What time is that for? 7 MS. : It says August 10, 8 2019 at 12:35 -- 9 MR. : 12:35. And can you -? 10 MS. : -- a.m. 11 MR. : Can you find the count for 12 the SHU in there? You can flip through it. 13 You can 14 MS. : Yeah. It's -. 15 MR. : What units are they reflected 16 by? What do they call the units on the 17 document? Are they referred to as the SHU? Or 18 are they referred to by a different name? 19 MS. 20 by alphabets. 21 MR. They're referred to What alphabets? 22 MS. : For special housing 23 unit, it would be ZA. And their count is - at 24 this time - on August 10, 2019 at 0035, it was 25 72. EFTA00061772 76 1 MR. : If you flip through it, it 2 will tell you there might be more documents. 3 Keep going. It'll tell you who did the counts. 4 Do you recall who -? Based on the document, 5 can you tell me who did the count for the SHU? 6 Which SHU unit - ZA or ZB - was Epstein housed 7 in? 8 MS. : Epstein was in ZA. 9 MR. : ZA. And who did the count at 10 12 midnight? 11 MS. : There was an issue 12 with the count at midnight. 13 MR. : What was the issue? 14 MS. : There was an inmate 15 that they had removed from the unit and he was 16 on - he was being housed in the receiving and 17 discharge in one of the holding cells in R&D on 18 the third floor. And -. 19 MR. : Do you recall if that was 20 Inmate 21 MS. : I don't know what. 22 MR. : Okay. 23 MS. : I don't remember what 24 his name was. 25 MR. : Okay. EFTA00061773 77 1 MS. : But they were for 2 some reason I want to say. I don't know if 3 he was on dry cell or what his status was. 4 MR. : Was -? 5 MS. : I don't think he was 6 on suicide watch. I can't remember. 7 MR. : You said dry cell. Now dry 8 cell. Is that in R&D? 9 MS. : No. That's not in 10 R&D. Usually dry cell is done in the special 11 housing unit. So I can't remember what his 12 status was but he was -. I can't remember if 13 he was on dry cell or if he was on - if that 14 was an extension of the suicide watch. I can't 15 remember, but there was an inmate down there. 16 And he was being housed down there with the 17 watch on that particular night. And they were 18 counting him on the unit because they hadn't 19 received any guidance as to how he was going to 20 be counted. Because R&D, mind you, is the 21 intake unit. It's not a housing unit. 22 MR. : Okay. 23 MS. : So inmates are 24 theoretically are not supposed to be staying - 25 spending the night down there. EFTA00061774 78 1 MR. : So R&D. So they do mainly 2 intake you said. Right? 3 MS. : That's what they do. 4 Yeah. 5 MR. : If they move an inmate to R&D 6 what would it be for? Are they leaving the 7 (Indiscernible *01:14:14)? 8 MS. : Yeah because they're 9 leaving or they're going to court or something 10 like that. 11 MR. : On that sheet, what would you 12 identify the area - the unit - as for R&D on 13 there? 14 MS. : RA. 15 MR. : RA? 16 MS. : Yes. 17 MR. : Okay. Now based on that, you 18 said there was an issue with it. 19 MS. : Right. Because if 20 you have an inmate in RA, then it's going to 21 interfere with the special housing unit count. 22 If this inmate that's here on RA is from 23 special housing. Okay. 24 MR. : Yeah. 25 MS. : When this - um. EFTA00061775 79 1 Their count was originally 73. But then you 2 have an inmate in RA from special housing. 3 MR. : Okay. 4 MS. : So that would bring 5 it down to 72 because this inmate This is 6 an outcount. You do an outcount when an inmate 7 is in a different area than where he is housed. 8 Okay. 9 MR. : Okay. 10 MS. : And you can't have 73 11 inmates. If 73 is your base, if you've got an 12 inmate from that area on outcount, then that's 13 not a good count. 14 MR. : Right. So the count. So 15 let's get it right. According to the records, 16 how many inmates should have been at the 12:00 17 p.m. count. How many inmates should have been 18 in the SHU? 19 MR. : 12:00 a.m. 20 MR. : 12:00 a.m. Sorry. 21 MS. : Well that depends 22 because when they initially did this, that's 23 how they was counting the inmates. It wasn't 24 until I started doing that count that I 25 realized that something wasn't right. So EFTA00061776 80 1 that's how we got around to there's an inmate 2 in R&D. You know that's being housed down 3 there on watch. You know. That's how we got to 4 that. So it's like oh, so there's an inmate in 5 R&D. You know. And then you start asking 6 questions. Why is he there? What's the deal 7 with him? Because none of this information was 8 passed down. 9 MR. : Okay. 10 MS. : So I've got to ask 11 the staff what's going on. 12 MR. : I'm going to clarify. I'm 13 going to go back. My question is at midnight, 14 who did the count for the SHU? 15 MS. : According to this, it 16 says Thomas and Noel. 17 MR. : Alright. If they did the 18 count and how many people are supposed to do 19 the count? 20 MS. : Two. At least two. 21 MR. : Two. If they went through 22 the SHU and they did a head count, right. How 23 many people should they have down? 24 MS. : They should have 25 gotten 72. But what I'm telling you is when EFTA00061777 81 1 this count was done, they were counting this 2 inmate that was in R&D on that count because no 3 one had told them that the inmate was actually 4 somewhere else. And he was being counted in 5 that area. So they were logging -. So what I 6 understand - and that's how they understood it. 7 That that inmate was being carried on to their 8 count. 9 MR. : Even though they didn't get 10 eyes on the inmate? Even though they don't 11 know physically. If they physically cannot see 12 the inmate, they're allowed to put it in their 13 count? 14 MS. : Because the inmate is 15 being ghosted. They could call R&D and ask and 16 say he is the inmate there. Because there was 17 a staff member on the inmate. The problem was 18 not how many inmates they had or what's 19 counted. The problem was the status of this 20 inmate that was in R&D. 21 MR. : Okay. 22 MS. : They didn't' know the 23 status of the inmate in R&D whether he was 24 going to be -. Whether he was staying there 25 altogether or how they were supposed to EFTA00061778 82 1 indicate him on their count slip. They didn't 2 know any of that. That wasn't until they 3 brought this to my attention. And this was the 4 original count slip. There was another count 5 slip that they supposed to have been 6 completing. And place that in the Sally port, 7 but apparently nobody picked it up. So this 8 was the original count slip that was submitted. 9 MR. : Okay. 10 MS. : But they were 11 supposed to -. Once we corrected this issue, 12 with the dude in - with the guy in R&D and put 13 him on an outcount. And place him in R&D, then 14 they were supposed to go back, recount. They 15 were supposed to recount and then they was to 16 submit another count slip. 17 MR. : Okay. That's what I'm 18 getting to. 19 MS. : Yes. 20 MR. : So who found out that there 21 was an error with the count? Did they notify 22 you or did you found -? 23 MS. : Right. Right. When 24 they called. I think we kind of hashed it out 25 together. EFTA00061779 83 1 MR. : Okay. 2 MS. : You know because they 3 were saying that they had an inmate that was 4 not on the unit. And they was like well what 5 do we do? 6 MR. : Okay. 7 MS. : Because I guess -. I 8 don't know what had happened, but they knew 9 that the guy wasn't on the unit. So they was 10 trying to get it corrected. 11 MR. : Okay. 12 MS. : And of course we 13 started asking questions. Where is this inmate 14 at? What is he doing there? How long he's 15 been there. Dah-dah-dah-dah. But again, this 16 is count time. So you've just got to do the 17 best you can because we've got a count to 18 clear. You know. 19 MR. : Do you recall. Sorry. You 20 had a question. 21 MR. : I just want to make sure 22 that we're clear. So did they call in 73 23 without saying this is 73 with a guy that's not 24 actually here. Or did they just call in 73 and 25 someone said how is this 73 if you guys only EFTA00061780 84 1 2 3 4 have 72? MS. : They called saying that their count was you know that they had the count issue was 73. But they had an inmate 5 that had been removed that had been taken off 6 the unit and was taken to R&D. 7 MR. : Okay. So they knew that 8 when they called in the count? It wasn't like 9 10 MS. : I mean -- 11 MR. : -- they said -- 12 13 MS. calling -. : -- they weren't 14 MR. : -- hey we've got 73 and - 15 - 16 MS. : No-no-no-no-no. 17 18 MR. you have 73 for -- someone said how do 19 MS. : No. 20 21 MR. : there? -- someone that's not 22 MS. : No-no-no-no-no. When 23 they called in the count, they was like I have 24 73 but one of the inmates up here is in R&D. 25 MR. : So they knew that there EFTA00061781 85 1 was only 72 in SHU at the time. They made note 2 of the fact -- 3 MS. : Right because 4 MR. : I'm calling in 73 5 because that's what our numbers are supposed to 6 be, but one guy is not here. 7 MS. : And they didn't know 8 the status of that inmate. 9 MR. : Sure. 10 MS. : They didn't know -. 11 MR. : So it wasn't like after- 12 the-fact. Like somebody like you're saying -. 13 MS. : Like I caught them? 14 MR. : Yeah. Like wait, how are 15 you calling 73 -- 16 MS. : No. 17 MR. if one guy's not here. 18 MS. : No. No-no-no-no-no. 19 They -. 20 MR. : So they brought it to 21 your guys' attention rather than the other way 22 around? 23 MS. : And I said so how 24 many bodies do you have on the unit? And he 25 said I have 72. EFTA00061782 86 1 MR. : So that's a good answer. 2 So he - so Thomas is the one who called that 3 count? Rather than Noel? 4 MS. : I think it was 5 Thomas. I don't think I spoke to Noel about 6 the count. 7 MR. : So you don't remember 8 specifically though. But you -- 9 MS. : I think it was 10 Thomas. 11 MR. : -- believe it was Thomas. 12 MS. : It was a guy. 13 MR. : Okay. 14 MS. : And I said well how 15 many inmates do you have on your unit right 16 now? How many bodies? And he said 72. And I 17 said well let me call because I need to call 18 and make sure that this other body is where 19 it's supposed to be. I need to see this body. 20 I need to make sure somebody -. I need to know 21 what's going on with this body. Is a person 22 sitting on it? Is this guy somewhere in a room 23 by himself? 24 MR. : Okay. And you 25 specifically recall that? EFTA00061783 87 1 MS. : I told - and I said 2 go back. Go back around. Do another count. 3 And then send me a new count slip. 4 MR. : That says 72 versus 73? 5 MS. : That says 72. Yes. 6 MR. : So you instructed them to do 7 a recount. 8 MS. : Right. 9 MR. : Do you know if they did the 10 recount? 11 MS. : I don't know if they 12 did a recount because like I said -- 13 MR. : Okay. 14 MS. : I was in the 15 process. I had to continue with the count. I 16 had to verify and get some information 17 regarding this inmate in R&D. But I have no 18 reason to disbelieve that they didn't do the 19 count. 20 MR. : Now what if they -? If 21 they already knew there was 72 and one guy, 22 would they be required to actually do a new 23 count? Or just fill out a new count slip? 24 MS. : I told them to do a 25 new count. Just to make sure. EFTA00061784 88 1 MR. : So you told them to 2 actually do a new count? 3 MS. : Yeah. I told them to 4 do a new count. 5 MR. : And they were 6 instructions you provided to Thomas - or a 7 male. You don't know specifically if it was a 8 males voice? 9 MS. : Right. 10 MR. : Okay. 11 MS. : Right. But yeah, I 12 said, you know, what did you all count. He 13 said we counted 72. And I was like well you 14 know, count again. And then send me - redo 15 your count slip and just send me another count 16 slip. Because I'm going to - while I verify 17 this other information. 18 MR. : Okay. And the fact that 19 there's only the two people in the SHU - Thomas 20 and Noel - you believe it to have been Thomas. 21 MS. : Right. 22 MR. : Okay. 23 MS. : And to be honest with 24 you, I'm giving myself some time so that I can 25 figure out whether or not -. I want to know EFTA00061785 89 1 whether or not this guy is actually in SHU. 2 MR. : Sure. 3 MS. : Or um, in R&D. So 4 I'm like you know just count again and make 5 sure just in case. I'm saying to myself. I'm 6 not saying this to him. I'm thinking to 7 myself, just in case, I called. And there's 8 nobody down there. I wanted to make sure that 9 this is actually the count. 10 MR. : Sure. 11 MS. : There. 12 MR. : And I want to make sure 13 so that something else is clear. When you as a 14 lieutenant are conducting rounds, that you're 15 required once per shift, that's rounds for 16 employees. Not conducting rounds with the COs 17 for inmates. So is your round to go around to 18 your employees to make sure? That's your 19 round? As opposed to participating in a count 20 or a round with the COs conducting of inmates? 21 Do you follow 22 MS. : We're not -. 23 MR. : -- what I'm asking? 24 MS. : We are not required 25 to go to each individual cell and look at the EFTA00061786 90 1 inmates. When we make rounds, we get with the 2 officers. We make sure that -. I mean if we 3 choose to do that we can. But -. 4 MR. : But there's no 5 requirement? For your requirement, that one 6 per shift of round. That's to do rounds with 7 your officer - or with your staff - as opposed 8 to conducting a round with them? 9 MS. : No. There was 10 nothing here said to us or in policy telling us 11 that we needed to go around -- 12 MR. : Sure. 13 MS. : -- on each housing 14 unit to each individual cell and check on the 15 inmates. If we chose to do that based upon 16 something that we knew wasn't right or 17 something that we had heard or something like 18 that during the course of our shift. Then that 19 - and we felt as though we needed to double 20 check on it. Because our officers are our eyes 21 and ears. And during that time, we didn't' 22 have a whole lot of time. We would spend half 23 of our shift just trying to fill overtime. At 24 that time. 25 MR. : So are you supposed to EFTA00061787 91 1 though? So if they do a count, are you 2 supposed to do a count with them during your 3 shift? 4 MS. : I can't remember at 5 that time if we were required to do at least 6 one count because one count per shift is what 7 we're required to do as a lieutenant. 8 MR. : One count with inmates? 9 MS. : No. One count in the 10 control center. 11 MR. : Okay. So you -. You're 12 not putting -. You're never putting your eyes 13 on the inmates doing a count with -. For 14 instance, in this case, if Noel and Thomas are 15 in the SHU, they're doing a 12:00 a.m. count, a 16 3:00 a.m. count, and a 5:00 a.m. count. Are 17 you doing any counts with them? 18 MS. : No I'm not doing any. 19 MR. : Okay. 20 MS. : I'm not - and it 21 wouldn't be for just SHU. It would be for any 22 housing unit. 23 MR. : Sure. 24 MS. : Period. But -. 25 MR. : But for this instance, EFTA00061788 92 1 specifically, I'm talking about the 12:00 a.m. 2 count, a 3:00 a.m. count, and a 5:00 a.m. 3 count. Is there any requirement for any 4 lieutenants that are on that you have oversight 5 over the SHU to do a count with them? 6 MS. : No. 7 MR. : No. 8 MS. : No. 9 MR. : And there wasn't at that 10 time? 11 MS. : No. 12 MR. : And you hadn't done one 13 at that time with them? 14 MS. : No. 15 MR. : So your requirements are 16 geared toward staff members not toward inmates? 17 MS. : Our -. 18 MR. : Because you're an officer 19 -. You're responsible for the staff. The 20 staff are responsible for the inmates. 21 Correct? 22 MS. : As a lieutenant, we 23 were required to do one count per shift in the 24 control center. We're required to take one 25 count. EFTA00061789 93 1 MR. : Sure. And this is the 2 one you did. You did the 12:00 a.m.? 3 MS. : This is the one count 4 -. 5 MR. : And this is why you 6 reviewed it and said, I've got the get this 7 thing right. 8 MS. : Well during the 9 course of taking this count, that came up. 10 MR. : Okay. 11 MS. : And of course we had 12 to address it because we can't house the count 13 saying one thing in some area and it's not 14 adding up. I can't have an 15 MR. : So are they -- 16 MS. : -- inmate -. 17 MR. : -- calling you that day 18 then So Thomas is calling you and providing 19 your count and that's the count that you did? 20 MS. : That's the I was 21 taking this count 22 MR. : So he didn't call control 23 - or he called control, but you were the person 24 he spoke with. 25 MS. : Right. EFTA00061790 94 1 MR. Gotcha. 2 MS. : Right. Right. 3 MR. : Do you recall that night, did 4 you participate in the 10:00 p.m. count? 5 MS. : Did I do what? 6 MR. : Did you participate - were 7 you there when the 10:00 p.m. count happened? 8 MS. : No. Hm-mm. 9 MR. : So you came on shift after? 10 MS. : I don't know if, I 11 probably was here during -- 12 MR. : But not participating. 13 MS. : -- the 10:00 p.m. 14 count. Yeah. But I didn't take the 10:00 p.m. 15 count. 16 MR. : Question. Do you know when 17 that inmate was removed to R&D? What time? 18 MS. : I have no idea. I 19 have no idea. That was done prior to me 20 getting there. 21 MR. : Now let's say the inmate was 22 removed prior to the 10:00 p.m. count. Would 23 the 10:00 p.m. count have been wrong? If they 24 reported? 25 MS. : I have no - I can't EFTA00061791 95 1 answer that. I don't know. 2 MR. : No-no. But you fixed it. 3 They called you, they asked for the -. Let me 4 show you the 10 - two more documents. Let's do 5 Take a look at this document. What is 6 that? 7 MS. : This is the E-1 for 8 August 9, 2019 at 9:33. 9 MS. : Okay. And what's the 10 count for the SHU at that point? 11 MS. : It's 73. 12 MR. : 73? 13 MS. : Mm-hmm. 14 MR. : And what's the count for RA? 15 RA being the R&D? 16 MS. : It's saying zero. 17 MR. : Okay. If the inmate was 18 moved prior to this count, to R&D, would 19 technically the count for the SHU have been 20 wrong? 21 MS. : That depends on what 22 the officers were told because like I said, RA 23 is not a housing unit. So no officer would 24 have been moving an inmate to RA on their own. 25 Something -. EFTA00061792 96 1 MR. : Okay. 2 MS. : There had to have 3 been some guidance that - whereby they was told 4 because this inmate was there all night with a 5 watch on him. 6 MR. : Which inmate? The one in 7 R&D? 8 MS. : The inmate that was 9 taken to 10 MR. : R&D? 11 MS. : R&D. Yes. The 12 inmate had a watch. There was a staff member 13 on the inmate. You can't -- 14 MR. : What was the watch for? 15 MS. -- just put an inmate 16 in R&D and just leave him there. There's 17 nobody to watch him. R&D staff leaves at 18 10:00. So you can't just leave an inmate there 19 with nobody watching him. 20 MR. : So Maybe I'm saying this 21 wrong. I'm just trying to get clarification. 22 When you do - when a CO does a count - can they 23 account - but in their count - can they account 24 for an inmate that they do not get their eyes 25 on? EFTA00061793 97 1 MS. : Depending on who gave 2 them the instruction as to how that inmate was 3 going to be accounted for. 4 MR. : What about? 5 MS. : If that - say - if 6 that. If that inmate was in R&D at the 10:00 7 count, depending on how they were guided 8 because I mean they know that an inmate can't 9 be in R&D by himself either. So depending on 10 how that inmate was being counted, they may 11 have been given instructions by somebody to 12 ghost him. And count him in SHU. I don't 13 know. I can't explain that. 14 MR. : So COs have the ability, it's 15 not per policy, COs have the ability to do 16 that? 17 MR. : To do what? 18 MR. : If they don't have eyes on, 19 if they can get instructions from another 20 person saying no, report it as your count? 21 MS. : That would have to be 22 someone in their chain of command that would 23 advise them to do that. 24 MR. : Who? Do you know? 25 MS. : It would be someone EFTA00061794 98 1 over the lieutenant's head because no 2 lieutenant is going to - that I knew at the 3 time - that I worked with at the time - would 4 have an inmate in a different area knowing that 5 that inmate was not going to be coming back to 6 that housing unit. 7 MR. : So the key right now is we 8 don't know when the inmate was moved. Right? 9 MS. : I don't know when. I 10 can't tell you when the inmate was moved. That 11 happened before I got there. What specific 12 time he was moved, I don't know. 13 MR. : Let's say the inmate was 14 moved and they didn't' get the authorization 15 from the captain. Would the count have been 16 wrong? 17 MS. : I don't -. You know 18 as far as I know, it could have been someone 19 above the captain. I don't know. I can't 20 provide you with an adequate answer because -- 21 MR. : No problem. 22 MS. : I don't 23 MR. : We're going to go past that. 24 MS. : Okay. 25 MR. : So I'm going to show you. EFTA00061795 99 1 This is just for clarification purposes, just 2 for our records. I'm going to show you one 3 more document. What is F? 4 MS. : This is an E-1 for 5 August 9, 2019. The time is 1541. 6 MR. : Okay. And that should be the 7 4:00 p.m. count? 8 MS. : Yes. This would have 9 been for the 4:00 count. 10 MR. : What is the lineup on top? 11 It says A-T-T-Y. What is that? 12 MS. : What? 13 MR. : Up here. Up here it says A- 14 T-T-Y. 15 MS. : Oh, that's attorney 16 conference. 17 MR. : Okay. And what is outcount? 18 On - towards the right. Over here. 19 MS. : Well.... 20 MR. : This one right here. 21 MS. : The outcount is the 22 This is for that section that you're 23 pointing to. That would be the number of 24 inmates that are not in their respective 25 housing units from these areas - the different EFTA00061796 100 1 areas that are designated here. 2 MR. : Is it possibly because 3 they're leaving? 4 MS. : From the different 5 housing -. I have It could be a number of 6 things. 7 MR. : Okay. At 4:00 p.m. what was 8 the count in the SHU? 9 MS. : Um, 75. 10 MR. : 75? 11 MS. : Yes. 12 MR. : Okay. And what is the count 13 for RA? 14 MS. : Zero. 15 MR. : Okay. So that's R&D. 16 There's nobody there. Where is - according to 17 that if you flip through it. Where is Epstein 18 at that point? 19 MS. : It looks like he's in 20 attorney conference. 21 MR. : Okay. No problem. We're 22 going to keep going. 23 MS. : Okay. 24 MR. : Um.... On August 10th. 25 Right. When did you go to the SHU? EFTA00061797 101 1 2 3 4 MS. : Like I said earlier, I think it was -. MR. : Can you do me a favor? Can you sign it and date it just like before? 5 MR. : Initial and date on the 6 top. 7 MR. : Initial. 8 MS. : Which one? 9 MR. : All of them. 10 MR. : Oh. Since I showed you. 11 MS. : Okay. 12 MR. : I'll take that. When did you 13 -? Did you make a round into the SHU on August 14 10th? 15 MS. : Yes. 16 MR. : What time? 17 MS. : I don't remember what 18 time. It was like halfway between my shift 19 later on in the morning. 20 MR. : Did you speak to -? 21 MS. : Probably about 4:-- 22 something. Between 4:00 and 5:00 I guess. 23 MR. : Do you recall who the COs 24 were on duty? 25 MS. : Yes. Thomas and EFTA00061798 102 1 Noel. 2 MR. : Okay. Did you speak to them? 3 MS. : Yes. 4 MR. : Okay. And everything was 5 good? Did they say have any complaints or 6 anything like that? 7 MS. : No. They were fine. 8 MR. : Do you recall your 9 conversation at all? 10 MS. : I don't recall my 11 conversation with them, but I spoke to them for 12 a minute because I stopped there. I went up to 13 10 South and I made my rounds up there. And I 14 came back and I spoke with them again before I 15 left. 16 MR. : So you spoke with them 17 twice? 18 MS. : Yeah. I spoke with 19 them initially. And I told them you know when 20 I get back out -. I'm going to run up to 10 21 South and make my rounds and sign my books and 22 stuff up there. And then I'll get back with 23 you guys. I'll come back on my way down. 24 Because I needed to sign their round sheets. 25 MR. : Okay. EFTA00061799 103 1 MR. : Now you mentioned that you 2 don't know - you never heard of the requirement 3 for Epstein needing a cellmate. Right? 4 MS. : Right. 5 MR. : So you didn't know. 6 According to what you said before, you didn't 7 even know the COs knew that requirement. 8 MS. : If I didn't know, I 9 know they didn't know. And according to that 10 because I don't even see -. Where is that 11 email? Because I want to see who did they 12 actually send that to. If it says on the email 13 who they sent that to. 14 MR. : It looks like they sent 15 it up to all the officers, lieutenants and. 16 MS. : This says suicide 17 watch/psych observation update. 18 MR. : So on or around July 19 30th, Epstein came off of the suicide 20 observation and was placed back into the SHU. 21 And this was supposed to be the email saying 22 that he was required to have a cellmate while 23 he was in the SHU. 24 MS. : Yeah, but this isn't 25 MYM all. EFTA00061800 104 1 MR. : Right. So you said you 2 think it should have gone to all staff. 3 MS. : Yeah-yeah. 4 MR. : So I guess what I'm 5 MS. : This is only 6 addressed to suicide - whoever is in that 7 group. It looks like a group that they made 8 up. Because I never heard of that group 9 before. Suicide watch/psych -. 10 MR. : You never got the email from 11 them? 12 MR. : Sure. So -. 13 MS. : Slash psych 14 observation update. I guess that's a group. 15 MR. : So these are the -. So 16 the one - pages one through three. These are 17 the people that they I guess placed in that -- 18 MS. : That they placed in 19 that group. 20 MR. -: group. And it looks 21 like it's all the lieutenants and the officers 22 in the institution as opposed to the COs 23 themselves. 24 MS. : You mean specific 25 officers? Specific staff? Because I can EFTA00061801 105 1 assure you that's not all of them. 2 MR. : That's not all of them. 3 Yeah. So I don't know how they actually chose 4 it. But you said you know you were on it but 5 you don't recall receiving it. 6 MS. : I do not recall 7 receiving that. 8 MR. : Now do you know -? I 9 don't know how it works here. I mean are you 10 in front of your computer? Do you read your 11 emails? How is that? 12 MS. : During that time, I 13 will be honest with you. I didn't have time to 14 read any emails because in addition to not 15 having a lot of staff, we had a bunch of 16 incidents that were going on during that time 17 as well. 18 MR. : Okay. 19 MS. : A bunch of body 20 alarms and stuff like that that was going on. 21 And because of the fact that we were so short- 22 handed, you didn't have time to read emails and 23 stuff at the time. You just had too much to do 24 with the time in your shift. It was just way 25 too much. EFTA00061802 106 1 MR. : Sure. 2 MS. : It was way too much. 3 MR. : So although this was sent 4 to you, you don't think you probably even 5 clicked on it? 6 MS. : I got a lot of emails 7 during that time that I can assure you I didn't 8 read. 9 MR. : Sure. Alright. So you 10 were unaware. How does it work -? Just can 11 you walk me through specifically on, you know, 12 if the cellie. Did you know that Epstein 13 had a cellmate? 14 MS. : I didn't know Epstein 15 had a cellmate. 16 MR. : So you didn't even know 17 he had a cellmate at all? 18 MS. : I didn't know if he 19 had a cellmate or not. 20 MR. : Okay. 21 MS. : When all of this 22 happened, it, of course, later came out that he 23 had a cellmate and the inmate was removed. But 24 as far as me having personal knowledge of 25 whether or not he had a cellmate, I didn't know EFTA00061803 107 1 if he had a cellmate or not. I assumed he had 2 a cellmate. 3 MR. : Now being that you know 4 they sent this email. You said who should have 5 advised you at least at some point, hey he 6 needs a cellmate. Where was the communication 7 breakdown there? 8 MS. : It wasn't just me. 9 It should have been everybody. 10 MR. : Sure. So what my question 11 is though, who is responsible for that? 12 MS. : The - you would think 13 that psychology would have called us or 14 somebody should have been making sure. 15 MR. : Okay. So let's go 16 through that. From psychology, who should 17 who dropped the ball here? 18 MS. : Well I'm not going to 19 say anybody dropped the ball because it's all 20 about responsibilities to -. 21 MR. : But somebody - psychology 22 I guess made the note. So is it the person 23 that's on the email, this 24 Should have she gone around and aside from 25 sending this email should have she spoken to EFTA00061804 108 1 people or had a meeting? What should have 2 happened? 3 MS. : I mean if that's what 4 she -. I just feel as though they that - to 5 communicate Like I said originally. My 6 whole thing was Epstein should have been placed 7 on 10 South to begin with because he was that 8 type of inmate that checked all the boxes for - 9 10 MR. : Sure. 11 MS. : -- someone that 12 should have been placed on 10 South. 13 MR. : And that's going to be 14 one of my follow-up questions is what the 15 difference between the SHU and 10 South. But 16 specifically to this, like what should have 17 psychology done differently? 18 MS. : I would have made 19 sure - I just would have -. I just would have 20 made sure that everybody -. I never even would 21 have sent Epstein back to -. I would have 22 never even put him back in that position again. 23 MR. : So if he had -. 24 MS. : If he had a cellmate 25 because even saying that he had a cellmate. EFTA00061805 109 1 Even telling somebody that he should have had a 2 cellmate. Still wouldn't have prevented him 3 from trying to harm himself. We had just went 4 through that. 5 MR. : Sure. 6 MS. : We - that was a 7 scenario when they got him. That got to the 8 memo being done. 9 MR. : Okay. So -. 10 MS. : You know? He had a 11 cellmate then. 12 MR. : The other lieutenants 13 though in this case, they knew that he was 14 required to have a cellmate. Correct? 15 According to -- 16 MR. : Yes. 17 MR. : -- there? So it sounds 18 From reviewing the other interviews, it 19 looks like you were the one that didn't know. 20 Everyone else knew. Do you know why that would 21 have been? Who should have made sure you knew 22 that he needed a cellmate? 23 MS. : I would think whoever 24 knew that he needed an inmate. 25 MR. : So that's what I'm EFTA00061806 110 1 saying. Everyone else know. So like all the 2 other lieutenants and the captain. They all 3 said that they were aware that he was required 4 to have a cellmate. So the question -. So I 5 don't know if they got the information from the 6 email, if there was an all-hands. Who should 7 have made sure that you knew that he had a 8 cellmate? 9 MS. : Okay. So if they 10 knew that. If everybody is saying that they 11 knew he should have had a cellmate, then why 12 didn't he have one? 13 MR. : That's the -. 14 MS. : How did we get to 15 that? 16 MR. : That's the reason why 17 we're talking with you. That is the big issue 18 of why didn't he have one? Who? Where was the 19 comm