DIGITALLY RECORDED

1 2 DIGITALLY RECORDED SWORN STATEMENT OF OIG CASE #: 2019-010614 DEPARTMENT OF JUSTICE OFFICE OF THE INSPECTOR GENERAL JUNE 21, 2021 RESOLUTE DOCUMENTATION SERVICES 28632 Roadside Drive, Suite 285 Agoura Hills, CA 91301 Phone: (818) 431-5800 APPEARANCES: OFFICE OF THE INSPECTOR GENERAL BY: BY: WITNESS: OTHER APPEARANCES: JASON FOY, ESQ. ERIC SARRAGA, ESQ. SERINE GREG 3 1 MR. The recorder is on. My 2 name is . I am a Senior 3 Special Agent with the U.S. Department of 4 Justice Office of the Inspector General New S York Field Office and these are my credentials. 6 This interview with Federal Bureau of Prisons 7 correctional officer is being 8 conducted as part of an official U.S. 9 Department of Justice Office of the Inspector 10 General investigation. Today's date is June 11 22, 2021 and the time is 10:09 a.m. This 12 interview is being conducted at - what is the 13 location - 15 -? 14 MR. FOY: 15 Bergen Street, Hackensack, 15 New Jerseii 16 MR. IIIIIIII : Thank you, sir. 17 MR. FOY: Bergen County Bar Association, 18 second floor conference room. 19 MR. : Okay. 20 MR. FOY: By the way, that was Jason Foy 21 speaking. 22 MR. Yes. Also present are 23 DO) OIG Special Agent 24 Correctional officer ; 25 attorneys, Jason Foy, and Eric Sarraga of Foy & 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 4 Seplowitz, LLC; as well as union representative Serine Greg of the Local 3149 with the BOP. This interview will be recorded by me, Senior Special Agent . Could everyone please identify themselves for the record and spell your last name. To starti_ again, I am DO) OIG Senior Special Agent DOJ OIG Special Agent MS. : I'm MR. FOY: Jason Foy, F-O-Y, attorney for MR. SARRAGA: Eric Sarraga, S-A-R-R-A-G-A, attorney for MS. GREGG: Serine Gregg, G-R-E-G-G, Local 3148. MR. : Thank you everyone. Ms. IIII, you are here today as a subject in this DOJ OIG investigation. This DO) OIG investigation concerns your alleged misconduct to include allegations of false statements, job performance failure, security failure, and reporting false information. This is an official DOJ OIG investigation and you are EFTA00117643 S 1 being asked to voluntarily provide answers to 2 our questions. Will you agree to a voluntary 3 interview with the DO] OIG? 4 MS. : Yes. 5 MR. : Alright. Great. And 6 then everyone that does voluntary interviews 7 with the DO] we provide them with these 8 voluntary interview forms. I don't know if you 9 guys were sent that at the time, but it says, 10 "United States Department of Justice Office of 11 the Inspector General, Warnings and Assurances 12 to Employee Requested to Provide Information on 13 a Voluntary Basis. You are being asked to 14 provide information as part of an investigation 15 being conducted by the Office of the Inspector 16 General. This investigation is being conducted 17 pursuant to the Inspector General Act of 1978 18 as amended. This investigation pertains to 19 your alleged misconduct to include allegations 20 of false statements, job performance failure, 21 security failure, and reporting false 22 information. This is a voluntary interview. 23 Accordingly, you do not have to answer 24 questions. No disciplinary action will be 25 taken against you if you choose not to answer 6 1 questions. Any statement you furnish may be 2 used as evidence in any future criminal 3 proceeding or agency disciplinary proceedings 4 or both. And of course, there's the DPA 5 waiver. I understand the warnings and 6 assurances stated above and I am willing to 7 make a statement or answer questions. No 8 promises or threats have been made to me and no 9 pressure or coercion of any kind has been used 10 against me. You can take a look at this and 11 review it. If you agree, there's a section 12 there for your name and signature. 13 MR. FOY: So the only thing that this is 14 actually subject to is the deferred prosecution 15 agreement. 16 MR. : Well so there's the 17 agreement that you had, so that's the part 18 where I'm talking about the specific part where 19 it says criminal. 20 MR. FOY: Mm-hmm. 21 MR. : That's something I think 22 that was worked out with the U.S. Attorney's 23 Office -- 24 MR. Exactly. 25 MR. : So -. 7 1 MR. FOY: I know there's no sort of 2 protection with regard to the disciplinary 3 internalliiiiiiiiiinistrative thing that -- 4 MR. : Correct. 5 MR. FOY: -- will happen at some point. 6 But I just wanted to make that clear. But go 7 ahead, yoiliiiiiiii IIII. 8 MR. : Now obviously, that is 9 pursuant to you answering questions truthfully. 10 MR. FOY: Right. Of course. That's the 11 exception to our agreement. 12 MR. : There's a line that says 13 employee si nature. 14 MS. . Mm-hmm. 15 MR. Alright. And the rest 16 will be filled out by the two of us. 17 MR. lila 18 MR. : Thank you, sir. 19 MR. Si 20 MR. : And thank you for signing 21 Ms. IIII. Alright. So I'm going to sign where 22 it says signature of the Office of the 23 Ins ector General S ecial Agent. Again, this 24 is 25 And Special Agent . I'm printing my name. , can you fill out the 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 8 rest for signature of witness, name of witness, date, time and place. MR. : This is Agent signing on the siinat eof witness. MR. : And then do you understand the form as ou read and you review? MS. : Yes, I do. MR. : Great. Thank you. Before starting the interview, I'd like to place you under oath. Can you please raise your right hand? Do you swear to tell the truth and nothing but the truth during this interview? MS. : Yes, sir. MR. Thank you, Ma'am. Alright. Please let me know if you do not understand any of my questions. I'll try to rephrase or ask it a different way. MS. : Okay. MR. : Alright. So this is something we ask everybody. Do you - what's your current home address? MS. MR. Thank you. What's your EFTA00117644 9 10 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 date of birth? MS. MR. your Social Securit MS. MR. Thank you. What's your highest level of education? MS. ,bachelor's degree. MR. : And what was your bachelor's degree in? MS. IIII: Criminal justice (Indiscernible *00:06:14) in law. MR. : And where did you receive that degree from? MS. John Jay. MR. : John Jay in New York City? MS. Yes, sir. MR. : And when did you graduate? MS. 1.7. MR. : Thank you. What did you do - just briefly - prior to working with the BOP? MS. IIII: Prior to working with the BOP I And your last four of number. 1 worked at the Post Office. 2 MR. : Okay. What did you do 3 there? 4 MS. : I was a mail handler. 5 MR. And for how long? 6 MS. six months. 7 MR. Six months? 8 MS. : Mm-hmm. 9 MR. And that was in 2016, 10 2016? When did you do that? 11 MS. : Yes. 12 MR. 2015 and 2016? 13 MS. No. At the post office, I was 14 there 2017. 15 MR. . Oh 2017. 16 MS. : '16, '17. Mm-hmm. 17 MR. Oh, okay. And do you 18 have any military service? 19 MS. : Yes. 20 MR. And what is that? 21 MS. : Military service? 22 MR. Yeah. Can you tell me 23 what the service? 24 MS. The Army. 25 MR. Army. And how long were 11 1 you in the Army? 2 MS. : Six years. 3 MR. : From when until when? 4 MS. 2008 to 2014. 5 MR. And what did you do with 6 the militar 7 MS. IIII: I was a patient administrative 8 specialist. 9 MR. 10 MS. 11 MR. 12 hospital? 13 MS. : Yes. 14 MR. : Okay. So you worked in a 15 hospital. And what was your rank when you left 16 the militar ? 17 MS. : E4 Specialist. 18 MR. : And did you leave - were 19 you honorabl , discharged? 20 MS. : Yes. 21 MR. : Okay. 22 MR. FOY: Can I - one second real quick? 23 For the post office, you said 16 - 17 but you 24 started MCC in 18. 25 MS. IIII: Yeah. And what is that? Patient admin. Patient as in like a 12 1 MR. FOY: So would it be 17 into 18? 2 MS. : 18 yeah. 3 MR. Oh you did start with the 4 BOP in '18? 5 MS. 6 MR. Not 7 MS. : No. That 8 (Indiscernible *00:07:49). 9 MR. FOY: Right. So it's '18, then she 10 left the Post Office in '17, going to - so I 11 think it's 16 -. No 17 - 18. 12 MS. IIII: '18 - Mm-hmm. 13 MR. FOY: Post Office. Then MCC. 14 MR. : Okay. And did you work 15 for anybody prior or in between your military 16 service and the post office? 17 MS. 18 MR. 19 MS. 20 MR. 21 that time? 22 MS. 23 MR. 24 to John Ja 25 MS. IIII: : No. No? Okay. Hm-mm. So you were unemployed at in '16? was an error in the No I was going to school. Oh that's when you went That's when I was going to John EFTA00117645 13 14 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Jay. Yeah. MR. when was MS. MR. Okay. Thank you. And our Enter on Duty Date with BOP? : June 24, 2018. Okay. And when did you graduate from BOP training down at the Federal Law Enforcement Training Center? MS. IIII: Um, I want to say September of 2018. MR. : Okay. But you did graduate from there? MS. Yes, I did. MR. That was a correctional officer training? MS. : Yes. MR. : Alright. And when and where was your first office assignment with the BOP? MS. Sa that again? MR. When and where was your first office assignment with the BOP? So where did you start - did you start working in MCC and work there the entire time? MS. : Yes, sir. MR. Okay. And what positions 1 have you held with the BOP? 2 MS. : Correctional officer. 3 MR. • Okay. The entire time? 4 MS. Yes, sir. 5 MR. : Alright. And when you 6 were there last, who did you report to? Who 7 was your direct supervisor? Or did you have 8 one? 9 MS. : Lieutenant 10 MR. : And do you know how to 11 spell that last name? 12 MS. 13 MR. Thank you. What is your 14 current -? Again, this is something we ask 15 everybody. We won't be contacting your client. 16 But what is our current cell phone number? 17 18 MS. MR. : Okay. And how long have 19 you had that number? 20 MS. : Years. 21 MR. • Years. 22 MS. Mm-hmm. 23 MR. • So for a long time. 24 MS. Yes. 25 MR. And to include in 2019? 15 1 MS. 2 MR. : Okay. Any other cell 3 phone numbers? 4 MS. 5 MR. • Okay. And your current 6 email address? 7 MS. 8 MR. . Okay. Great. And have 9 you had that one also for years? 10 MS. Yes. 11 MR. Okay. Any others? 12 MS. Yes. 13 MR. What are the others? 14 MS. 15 MR. . Same? 16 MS. Mm-hmm. 17 MR. You've had that for 18 years? 19 MS. Yes. 20 MR. Okay. Both in 2019? 21 MS. Yes. 22 MR. Okay. Thank you. Um, do 23 you have any current -? I should have asked 24 this. Ar2a2u currently employed right now? 25 MS. IIII: No. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. MS. MR. last work at MS. 16 By no other means? Okay. And when did you the MCC? August 10, 2019. MR. And was that the same supervisor that you mentioned? MS. : Yes. MR. : Okay. Briefly, what training have you attended or conducted during your employment with the BOP? You mentioned the correctional officer training at FLETC. What other trainings have they provided for you? MS. IIII: Um, their two-week training when you first start at BOP. I forget what it's called. IF training. Yes. MR. IF training? MS. Mm-hmm. MR. And any other training? MS. MR. Annual refresher training? MS. : I have one. MR. : Okay. So you've gone to EFTA00117646 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 17 annual. And what about like a SHU training course? MS. MR. Okay. But you did - and this is just - you guys can take a look at this if you would like. This is the training that we have for you. That we asked for your list of training. I'm not asking you to necessarily verify that you've conducted all of it, but it shows the last time you did your annual training was on 3/8/2019 was when you actually completed that week of training. MS. MR. MS. MR. • Yes. • Does that sound correct? Correct. Again, this just goes along with it. It shows -. It shows what the syllabus was as well as the sign-in sheet where Ms. signed in. Again, it's - we're not asking to ou MS. : Mm-hmm. MR. : For - if you want to take a look at it you can. It just shows that you did that training in March of 2019. And anything that I'm going to provide to you, can 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 18 you just initial and date? And that's just a way for us to verify that that's what we showed you. MS. IIII: Okay. MR. FOY: Each page or just to top? MR. Nope, just the top of each page. MR. FOY: Okay. Is (Indiscernible *00:12:34)? MR. No, you do have that. So just briefly, you don't have to like list off the course syllabus. But what did they cover during that annual training? MS. IIII: Um they spoke about different areas like dealing with inmates. They spoke about the issues on the job like dealing with shortages. They spoke about um, basically like mask fitted I remember. MR. MS. MR. • Mask fitting? Mm-hmm. • Was that back in 2019? People were wearing masks as well? MS. : No like um. MR. : It's for OC's sprays? MR. Oh, for OC spray. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 19 MS. : Yes. MR. : Okay. Did they include things like ethics, standards of conduct? MS. • Yes. MR. Okay. What about like counts and rounds? MS. IIII: I don't recall them talking about counts and rounds. MR. : Okay. So did they go over like MCC policies and guidance? MS. : Yes. MR. : Okay. And did they ever provide you with the policies and guidelines or did they ust speak to you about it? MS. : For in this training? MR. MS. MR. Yes. : They just spoke about it. At another time did they provide you with the polices and guidelines? MS. IIII: Yeah. It's on like the computer. MR. Okay. MS. The -. MR. Do you have to certify that you've like received it and you reviewed 20 1 it? Polices and guidelines? 2 MS. IIII: I think I signed that like you 3 receive it. 4 MR. : Right. Okay. If you 5 don't mind, just -. 6 MR. FOY: You want it in the lower right? 7 MR. : Doesn't matter. Top or 8 bottom. You know wherever there's room. I 9 typically do top, but bottom is totally fine. 10 MR. FOY: This one, that one. 11 MR. : Today's date is lune 22nd. 12 MR. FOY: That's part of the same 13 document. 14 MS. IIII: Hm. 15 MR. FOY: And just the top page. 16 MR. : And now you mentioned 17 that you didn't quite remember them going over 18 training when conducting counts and rounds in 19 this training. Did you - were you - did you 20 ever receive training on conducting counts and 21 rounds? 22 MS. : Yes. 23 MR. : Okay. When would that 24 have been? 25 MS. IIII: In an IF training. EFTA00117647 21 22 1 MR. And what does IF stand 2 for? 3 MS. IIII: Rm. 4 MS. GREGG: You want some clarity? I can 5 tell you -- 6 MR. : Sure. 7 MS. GREGG: -- just what it stands for. 8 Institution Familiarization training. 9 MR. : Okay. Great. And that's 10 something that the MCC provided directly? 11 MS. : Yes. 12 MR. : Okay. Great. And then 13 you had mentioned - did you ever receive 14 policies on counts and rounds? 15 MS. : No. 16 MR. I know you said you 17 certified. Do you remember that specific 18 policy - like receiving that? 19 MS. IIII: Like specifically on counts and 20 rounds? 21 MR. : I'm not asking you to 22 like verbatim tell me what it was. I'm just 23 saying like were you provided and you reviewed 24 it. DO you remember? 25 MS. IIII: Not specifically on counts and 1 rounds. Just like a general - 2 MR. Right. 3 MS. Like -. 4 MR. Like you know the housing 5 orders or unit policies and things like that. 6 When you're supposed to conduct counts, when 7 you're supposed to do rounds, that type of 8 thing. 9 MS. : The post orders. 10 MR. : Post orders. Right. 11 Okay. Great. You mentioned you didn't 12 remember ever going to quarterly SHU training. 13 This is a sign-in sheet for quarterly SHU 14 training. I just want to -. Is this your 15 signature on there for June 26, 2019? 16 MS. IIII: You see how I'm the last one on 17 the bottom of all of them? 18 MR. : Correct. 19 MS. : Because I wasn't at the 20 training when I came -. 21 MR. : Did they provide it to 22 you one-on-one though? 23 MS. : No. 24 MR. So how come -? 25 MS. : Because when I came back from 23 1 an injury, the lieutenant asked me to sign 2 because when they had program review, they need 3 to show that I received the training. But I 4 never did. She just asked me to sign. That's 5 why I wonder wh 6 MR. Who asked to do that? 7 MS. : Lieutenant 8 MR. : So that supervisor you 9 mentioned was your first line supervisor asked 10 you sign without providing you the training? 11 MS. : Yes. 12 MR. : And she didn't' like 13 provide you anything to review? 14 MS. : No. 15 MR. She didn't go over 16 anything with you? 17 MS. : No. 18 MR. Did you discuss this with 19 her - that how can you sign something without 20 being provided the training? 21 MS. IIII: Well I just told her I wasn't 22 here. I was out on an injury. She said she 23 knows but she needed me to sign it because they 24 need it for ro ram review. 25 MR. : What's her first name? 24 1 MS. 2 MR. And is she a lieutenant? 3 MS. : She's a - I don't know what she 4 is now. But she's not at MCC anymore. She's 5 at somewhere in Jersey. 6 MS. GREGG: I'm sorry. Before you go, are 7 you done with that question? 8 MR. : Actually, let me um, I 9 didn't do this. 10 MS. GREGG: Because I want to 11 (Indiscernible *00:17:14) 12 MR. : And I did forget to do 13 this. There's an advisory to the union 14 representative. 15 MS. GREGG: Mm-hmm. 16 MR. : Can you review this? And 17 I do apologize. But since you're speaking up a 18 little bit, let me hand this to you. and then 19 you can review that. And then if you want to 20 just take a look. After you're done reviewing, 21 you may sign it if you agree. 22 MS. GREGG: Will you be able to give me a 23 copy of it? 24 MR. : Yes. I think it says on 25 there that we will forward you a copy of that. EFTA00117648 25 1 MS. GREGG: I didn't even see that part. 2 MR. : Should I continue asking 3 questions while she's reviewing that or do you 4 want to wait? 5 MR. FOY: Yeah, you can ask questions. 6 Absolutel 7 MR. . : Sure. So there's another 8 training that you - it says that you conducted 9 on also June 26, 2019 for SHU suicide 10 prevention training. Did you also not receive 11 that trainin ? 12 MS. Yeah. I didn't. 13 MR. You did not receive that 14 training? 15 MS. 16 MR. Did you receive - so 17 there's slides in the back that shows the 18 training and how they conducted it. Did they 19 provide you with those slides? 20 MS. No because I wasn't there. 21 MR. You weren't there? 22 MS. I was out on an injury. 23 MR. Okay. Can you -? When 24 were you out on the injury? What are the 25 dates? 26 1 MS. IIII: From March 2019 to - I came 2 back in June. So when I came back in June, 3 that's when I was told to sign this. 4 MR. Okay. 5 MS. Mm-hmm. 6 MR. Alright. Thank you for 7 signing the Advisory to Union Representative. 8 MS. GREGG: I signed it (Indiscernible 9 *00:19:02). 10 MR. : I am just going to sign 11 that form as name of OIG special agent. Again, 12 I do apologize for not providing that up front. 13 MS. GREGG: So I just -. 14 MR. : I'm sorry, what was your 15 question? 16 MS. IIII: I want to call because 17 (Indiscernible *00:19:15) I'm just saying that 18 well I know that the dynamics are that I should 19 interrupt you in the middle of a question. But 20 interrupt her answering a question. So I was 21 asking were you done because I wanted to just 22 step out for Oust one second. 23 MR. You want to step out? 24 MS. Mm-hmm. 25 MR. Okay. We don't want to 27 1 interrupt the interview because we have a lot 2 of questions to get through. 3 MS. GREGG: Mm-hmm. 4 MR. : If the attorneys ask 5 that, that's not really -. But if you would 6 like to -. 7 MS. GREGG: So based on the agreement we 8 just signiiiiiiiii 9 MR. : Sure. 10 MS. GREGG: It acknowledges the right to 11 have me representing her. And part of those 12 rights are the ability to assist in 13 representing her. Right? And so I don't want 14 to dispute and I don't want to hold up the 15 process at all. I just want to say something 16 to her. 17 MR. : Sure. We'll let that - 18 we'll do that this time, but if this continues 19 to happen, I'm going to have to give you a 20 different form that says you can stay here 21 voluntarily if you want, but we're going to ask 22 you not to interrupt the interview. And if you 23 do, then we're going to ask her if she wants to 24 continue with the interview without you. 25 MS. GREGG: So but that form says 28 1 somethingliiiiiiiiito what you're saying. 2 MR. : I'm going to give you a 3 different form that says that I'm going to let 4 you interrupt the interview now to talk to her 5 out there. And if you do it again, I'm going 6 to ask that you not be here any longer so that 7 we can continue with the interview. Obviously, 8 her attorneys would stay here. So I just want 9 to make sure that we don't just continue. 10 MS. GREGG: I just need clarity then. I 11 need clariiiiiiiiii 12 MR. : Sure. 13 MS. GREGG: So the representing of and 14 talking to the employee who I have the right to 15 represent is considered by you an interruption 16 of the interview? 17 MR. : We haven't even gotten 18 into the questions yet. So -. 19 MS. GREGG: Well -. 20 MR. : -- yes, we need to 21 continue with the interview. But we're now -. 22 I can allow you to do that now. I'm just not 23 going to be able to allow you to continue to 24 stop the interview and leave the room. 25 MS. GREGG: I'm just asking for clarity EFTA00117649 29 1 right. So it was kind of -. 2 MR. : Sure. Absolutely. 3 MS. GREGG: And I don't mean to be 4 difficult. It kind of was a yes or no. So 5 you're saying to me based on the document that 6 I signed -. 7 MR. I'm saying that you can 8 assist her. 9 MS. GREGG: I didn't get to -. 10 MR. : Sure. Go ahead. 11 MS. GREGG: Okay. So you're saying based 12 on the document that I signed, in my right to 13 represent the employee, which is asking to 14 caucus and say something to Ms. is 15 interrupting the interview even though I have 16 the right to do so based on the document I 17 signed? 18 MR. : It's more for her to be 19 able to ask you for a question. 20 MS. GREGG: So it's just a yes or no. 21 MR. : Oh, no-no. I'm the one 22 that's leading the interview here. So if she 23 stops and asks you for clarity, absolutely. 24 You stopping to inform her? No. 25 MS. GREGG: I never identified to you that 30 1 I would be informing her of anything. 2 MR. : Okay. But so yes. To 3 answer your question, you can be here to 4 represent here if she's asking you for the 5 information. I don't want you stopping our 6 interview. 7 MS. GREGG: Mm-hmm. 8 MR. : And then asking to leave 9 the room. I'm going to allow that this time. 10 After that, I will consider that an 11 interruption of the interview. 12 MS. GREGG: Mm-hmm. 13 MR. : And then we'll have to 14 proceed from there. And then there's a 15 different form to provide you. So does that 16 make sense? 17 MS. GREGG: No it doesn't. 18 MR. : Okay. So I'm asking you 19 not to interrupt -. 20 MS. GREGG: Wait. It doesn't make sense 21 but I'm not - that was -. 22 MR. : So I'm asking you not to 23 interrupt the interview. She may defer to you 24 and ask you for questions. 25 MS. GREGG: Mm-hmm. 31 1 MR. I'm asking you not to 2 interrupt my questions. 3 MS. GREGG: Okay. It doesn't make sense 4 to me. What I'm interpreting is my ability to 5 represent is only if the employee asks a 6 question that's what you're saying to me. 7 MR. : Correct. So her 8 attorneys are here. 9 MS. GREGG: I got it. I got it. 10 MR. : Her attorneys are here. 11 I'm asking if she has a question for her union 12 representative -- 13 MS. GREGG: Mm-hmm. 14 MR. -- she may at any time 15 ask you. 16 MS. GREGG: I got it. 17 MR. I'm asking you not to 18 interrupt. 19 MS. GREGG: I got it. 20 MR. These questions are not 21 for you. 22 MS. GREGG: Mm-hmm. 23 MR. They're not directed at 24 you. 25 MS. GREGG: Mm-hmm. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 32 MR. They're directed at Mrs. MS. GREGG: I'm not answering questions. I was just trying to -. I'm representing her. But I understand that there has been a determination of how I'm able to represent. And so I'll deal with that in a different venue. You can move forward. MR. : Alright. Let me read this real quick in this paperwork so that we're not going to have any disputes. MS. GREGG: We don't have to. You don't have to continue. Right. Because I don't want to interrupt. So you can go on ahead and move forward. MR. Okay. So it just says that you may not attempt to answer the questions. MS. GREGG: Mm-hmm. MR. Or dictate the employee's actions to question or otherwise take charge of proceedings. MS. GREGG: Mm-hmm. MR. : But affin, please feel free to go confer with Ms. EFTA00117650 33 1 MS. GREGG: I appreciate it. Thank you. 2 MR. : I am going to pause the 3 recording. It is currently 10:32 a.m. 4 [Whereupon, the above-entitled matter went off 5 the record and went back on the record.] Okay. 6 The recorder is back on. It is 10:38 a.m. 7 Tuesda lune 22 2021. This is Senior Special 8 Agent . We're resuming the 9 interview. Ms. I just remind you that you 10 are under oath and this is a voluntary 11 interview. I'm sorry. What was your question? 12 MS. GREGG: You need me to initial 13 (Indiscernible *00:24:24)? 14 MR. If you don't mind. And 15 again, it's just to show that you know, what we 16 are looking at. 17 MS. GREGG: Okay. 18 MR. Now since we took that 19 break, is there anything else we want to 20 discuss or -? 21 MS. FOY: No, we can move forward. 22 MS. : No thank you. 23 MR. : Thank you again very much 24 for your cooperation with this matter. Is 25 there anything else you wanted to -? No? 34 1 Alright. DO you know where we left off I=? 2 What was the last question that we asked? 3 MR. : It was what we asked for 4 (Indiscernible *00:24:53) about the injuries. 5 MR. : Okay. So you were 6 telling us you said March through June you were 7 injured? 8 MS. : Yes. 9 MR. : And you were not actually 10 working during that time? 11 MS. : No. 12 MR. : Do you remember around 13 when in March and when did it end? Was it the 14 beginning of March, end of March, middle? 15 MS. IIII: Um I'm not sure. I just know 16 it was March. 17 MR. Sometime in March? 18 MS. 19 MR. But when you came back, 20 was it around the 26th when they asked you to 21 sign those? 22 MS. IIII: I came back in June. I don't 23 recall the date exactly. 24 MR. Okay. 25 MS. : But I remember the day I came 35 1 into work and the lieutenant asked me to go see 2 Lieutenant . And she asked me to sign 3 and I said but I wasn't here. I was out on an 4 injury. And she said she's aware but they need 5 me to sign it for rogram review. 6 MR. Okay. 7 MS. I signed. 8 MR. : So both trainings when 9 you signed, they didn't actually even provide 10 you anythin 11 MS. : N 12 MR. : Verbally? 13 Electronically? Nothing? 14 MS. : No. 15 MR. : Okay. And that was on 16 the date that was signed that that happened? 17 MS. IIII: Actually she told me not to 18 date it. I remember when I was signing, she 19 said don't date it. 20 MR. : But you dated it anyway? 21 Did you have a conversation about that? 22 MS. : No. 23 MR. : After you dated it, she 24 didn't say why did you date it or anything like 25 that? 36 1 MS. : No. 2 MR. : Okay. Did you receive 3 that training though in the annual training 4 courses as well? Like the suicide prevention 5 or the - you know how to operate in the SHU 6 during MCC annual? Or the - I think you call 7 it the IF training? Or during the correctional 8 officer training at FLETC? 9 MS. IIII: Those trainings are like 10 general overall training. It's not 11 specifically speaking about SHU. Like SHU may 12 come up in the conversations, but it's not 13 specific to SHU or how to operate or run the 14 SHU. 15 MR. Okay. 16 MS. Mm-hmm. 17 MR. Do you know if they were 18 doing this with other employees as well? 19 Having them sign training that they weren't 20 actually conducting? 21 MS. : I don't know. 22 MR. : Okay. But did you do 23 this per the direction of your supervisor? 24 MS. : Su ervisor. Yes. 25 MR. So she - did she EFTA00117651 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 37 specificall you must sign this? MS. : Yes. MR. : Okay. And again, that was MS. MR. • . And you said - and I apologize. I don't know if we were interrupted when -. Where did you say she is currently? MS. IIII: She is in Jersey I know. I'm trying to_ MR. MS. MR. • At the FCI Fort Dix? Yes. Okay. MR. 10.iestion real quick. MR. : Absolutely. Do you want a more precise answer to when she was out and when she came back? MR. Uh, so far -. MR. FOY: Because I happen to know -- MR. Oh sure. If you'd like. MR. FOY: -- the approximate dates. MR. Sure. You can provide that. MR. FOY: And this is based on my review 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 38 of discovery and conversations with Ms. IIII. We're looEilg_2l_gout March 15 to June 24-ish. MR. IIIIIIIIII: Okay. MR. FOY: And I note that the execution was on the 26th. But I think there was some time, you know, it's not like the first minute she was there the had her sign the document. MR. : Okay. MS. : Right. MR. FOY: So those are the estimated times. I could be off by a day or two, but -. MR. : Perfect. MR. FOY: The 15th of March to June 24th. MR. And thank you attorney Foy. MR. iiiiiiiiiiroblem. MR. : During your time at the MCC, how often were you assigned to the special housing unit also known as the SHU? MS. : Mm. MR. And this is an approximate. I'm not asking you for like exact amount. MS. IIII: When I came back from the injury, my assignment was the SHU. So from 39 1 June 20-whatever to August 10th, I worked the 2 SHU. 3 MR. : Okay. And that was your 4 quarterly assignment was in the SHU from - for 5 that whole summer -- 6 MS. : Yes. 7 MR. -- in 2019? 8 MS. Yes. 9 MR. Okay. Thank you. So I 10 know that you said that you didn't - they 11 didn't provide you with the SHU training. Did 12 they provide you with the policies of the SHU? 13 MS. : No. 14 MR. : So you never received 15 those policies? Would it have been when you 16 received and you said you had to initial and 17 date something electronically? I think you 18 said when_ysT provided -? 19 MS. IIII: That's the employee code of 20 conduct. 21 MR. : Okay. 22 MS. : That's the - like the handbook 23 that's online. 24 MR. Should have they provided 25 you with the polices and post orders in the 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 40 SHU? MS. IIII: In the SHU there is post orders. MR. Oh, okay. So in the SHU there's the ost orders. MS. : Yes. MR. And were you provided a copy of that to review? MS. : Yes. MR. And had you reviewed that? MS. MR. : Okay. And when did you review that? MS. : When I came back. MR. So sometime in that June MS. So in June. MR. MS. MR. -- or July timeframe? Okay. So aside from hose post orders, did you receive any other SHU training? MS. MR. : No. And who was EFTA00117652 41 1 responsible for making sure that you actually 2 did receive SHU training? 3 MS. : I don't know. 4 MR. : You don't know was that a 5 lieutenant issue -- 6 MS. : I assumed -. 7 MR. • -- or your first line 8 supervisor? 9 MS. IIII: I would assume the lieutenant. 10 My supervisor. I don't know. 11 MR. And when you say the 12 lieutenant, who was the lieutenant in the SHU 13 at the time? 14 MS. : Lieutenant IIII. 15 MR. : IIII. Do you know his 16 first name? 17 MS. 18 MR. . Okay. And would he be 19 responsible for making sure that you were 20 training when you were in the SHU? 21 MS. IIII: I mean, I'm going to direct 22 that question to her. I don't know. 23 MR. : I don't want you to 24 direct a 222tion to her. 25 MS. fl: Okay. 42 1 MR. But if you need to like, 2 yeah, that's fine. 3 MS. : Mm-hmm. Yeah. 4 MR. : And if you don't know, 5 that's totally acceptable. 6 MS. : Yeah because I don't know. 7 MR. • Okay. No-no, that's a 8 totally acce table answer. 9 MS. : Mm-hmm. 10 MR. • So yeah, if you know - if 11 you don't know something or you do know 12 something, that's great. You don't really want 13 to ask other people for the answers. 14 MS. : Ri ht. 15 MR. : You know, obviously if 16 you need to confer, and you know with your 17 attorneys or your union representative, 18 absolutely fine. But we just want to try to 19 get away from them answering for you. 20 MS. : Okay. 21 MR. : Alright. And then from 22 your recollection though, you don't remember 23 receiving SHU training during the annual 24 refresher training? 25 MS. IIII: No. 43 1 MR. No. Okay. Did you 2 receive training on how to conduct rounds? 3 MS. : Yes. 4 MR. . And when was that? 5 MS. In IF. 6 MR. In IF? 7 MS. Mm-hmm. 8 MR. Okay. And what did it 9 teach you about conducting rounds? 10 MS. IIII: That you need two people to 11 count and conduct rounds. And one person goes 12 and counts. The other person goes and counts. 13 And then ou confirm the numbers of counting. 14 MR. : Okay. 15 MS. : And make sure when you're 16 counting that you're counting everybody's 17 standing at their bed when you're counting. 18 MR. : Okay. And did you 19 receive suicide prevention training during the 20 MCC annual refresher training? 21 MS. : I don't recall. 22 MR. You don't recall. 23 MS. : Mm-hmm. 24 MR. Okay. What was your 25 understanding if an inmate was placed, you 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 44 know, is suicidal or placed on suicide watch? What was your understanding of how you should treat those inmates? MS. IIII: If an inmate is placed on suicide watch, I don't deal with them. They go downstairs to suicide watch and they're being watched b other inmates. MR. : Mm-hmm. MS. : But and then when they're cleared, the come back to the unit. MR. : And are you trained - are you supposed to handle them differently when they come back to the unit? MS. • Uh no. MR. You're not? MS. You're not. MR. You're not supposed to handle them differently? MS. MR. MS. : No. Not at all? Because they're cleared to come back. MR. IIIIIIIIII: Okay. MS. : So once you're cleared, you're back to normal. EFTA00117653 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 45 MR. Okay. And were you assigned to the SHU on August 9th and 10th of 2019? MS. MR. • Yes. • Do you recall what time you began working on the SHU on August 9th? MS. : 4:00 to midnight. MR. : Four to midnight. And then on Amlt 10th? It was? MS. IIII: Midnight to eight in the morning. MR. Okay. You said, again, that was our quarterly bidded post. MS. • Yes. MR. Quarterly assignment. And what were your overall duties and responsibilities when you were assigned to the SHU? MS. IIII: It varies because I'm new and because I don't know how to run the SHU. I just always rely on the senior person that I'm working with. So even if the roster reflects that I'm the senior officer, because sometimes I'm assigned SHU 1, I don't do what SHU 1 is supposed to do because I don't know how to do 46 1 it. I rely on the senior officer that I'm 2 working with. 3 MR. : Okay. So you didn't 4 really know what your duties and 5 responsibilities were? Is that what you're 6 saying? 7 MS. IIII: In the SHU like um, to give out 8 food, to collect the trays, to give out linen, 9 collect linen. Whenever we would go down range 10 to give out those, we count that as a round to 11 make sure the inmates are good. You shower I 12 think ever other Count, that's it. 13 MR. : So rounds and counts are 14 a part of that though? 15 MS. IIII: Rounds and counts are a part of 16 it. But I've never worked in the SHU and 17 actually done rounds every 30 minutes. We go 18 down range to do stuff and we count it as a 19 round. 20 MR. Perfect. And that's 21 going to be something that we're going to 22 discuss. 23 MS. : Mm-hmm. 24 MR. : And ask you things like 25 who told you that and houses that, you know who 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 47 should have provided you with the proper training and information on how it was technicall supposed to be done. MS. : Mm-hmm. MR. : And were there any requirements - special requirements - for inmates who are assigned to the SHU? MS. : I don't know. MR. : That's fine. Do inmates in the SHU have cellmates? MS. : Yes. MR. : Okay. And are they required to have cellmates? MS. MR. MS. : I don't know. You're not sure? Hm-mm. MR. Are there any inmates that don't have cellmates? MS. : Yes. MR. : And do you know why they wouldn't have cellmates? MS. : I don't know. MR. : Did you ever - were you ever told it's because another inmate could harm that inmate? Or there were certain 48 1 classifications of an inmate? They never 2 discussed that with you? 3 MS. : No. 4 MR. : No? Okay. Did you ever 5 see training on medical emergencies? With 6 inmates? 7 MS. Mm. No. I just know like if 8 you are making a round and something happens to 9 an inmate, you call and you wait for somebody 10 to come before you enter the cell. That's all 11 I know. 12 MR. : Okay. But did you - were 13 you provided like CPR training or any kind of 14 like you know, if something were to happen in 15 front of y2lhow you would respond? 16 MS. IIII: Yes. We had CPR training 17 (Phoneticiiiiiiiiii5:08) 18 MR. : Okay. And when would you 19 conduct training like that CPR training or you 20 know if someone is trying to kill themselves or 21 something like that. When did you receive that 22 training? How you would respond to a medical 23 emergency? 24 MS. : That was in IF. 25 MR. IF as well? EFTA00117654 49 50 1 MS. : Mm-hmm. 2 MR. : Okay. So who is or was 3 Inmate Jeffrey Epstein? Reg number 76318-054? 4 MS. : Who was he? 5 MR. : Who was he? Was he an 6 inmate asst ned to the MCC? 7 MS. : Yes. 8 MR. : Was he assigned to the 9 SHU? 10 MS. : Yes. 11 MR. . Okay. Do you know what 12 he was at the MCC for and why he was 13 incarcerated by the BOP? 14 MS. IIII: Actually I didn't even know who 15 he was when I worked with him. It was the 16 other coworker that told me who he was. I 17 didn't know who he was. 18 MR. : And who -? 19 MS. : As in I knew his name but 20 didn't know like what he was there for and who 21 he actualireav 22 MR. : So and when you say the 23 other coworker told ou, who told you? 24 MS. 25 MR. 1 MS. : Uh-huh. 2 MR. : And what is first 3 name? 4 MS. EIM I 5 MR. 6 MS. : Mm-hmm. 7 MR. : And what did he inform 8 you? 9 MS. IIII: He basically said that this is 10 Jeffrey Epstein. You don't know who he is? 11 And I said no. And he was like he's in the 12 news every day. And I was like okay. I didn't 13 know. 14 MR. : Do you remember when you 15 had that conversation? Like at least if you 16 think about August 9th, August 10th? 17 MS. : Mm. No. 18 MR. : Was it obviously it was 19 then prior to August 9th? 20 MS. : Yes. 21 MR. : Okay. But you were 22 working in the SHU together? 23 MS. : Yes. 24 MR. : Okay. Was Epstein in the 25 SHU when you had that conversation? 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 51 MS. : Never. MR. : No. Was he with his attorneys? MS. : Mm-hmm. MR. : Okay. Do you remember anything else about that conversation when he told you about him? MS. : No. That was it. MR. Did he tell you why he was in? MS. : MR. : No? Just that he was famous and in the SHU? MS. MR. know why MS. MR. Did anyone ever tell you it was because he was a risk for suicide or safety concerns? MS. : No. MR. : No? We're going to get into this a little later, but do you know what the hotlist is? MS. IIII: Um.... Are those -? I think : Mm-hmm. Okay. Why was - do you stein was assigned to the SHU? : No. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 52 the hotlist is like um, how should I say, like inmates that are like -. Inmates that are like - mm. MR. I'm just going to show you this and ask you if you ever received this training either. MS. : Mm-hmm. MR. : Or if you've ever seen it. This will spell out exactly what the hotlist is. MS. : Mm-hmm. MR. : So this is the MCC New York special housing unit. Slides. (Indiscernible *00:38:01) MR. Ed sorry. MR. : This one is special housing unit management suicide prevention. MS. : Mm-hmm. MR. : So can you just have - there's two different tabs here which -- MS. : Mm-hmm. MR. : -- the first one is going to say -. I'll just read it for the record. SHU hotlist identifies inmates with mental health conditions who may become dangerous, EFTA00117655 53 1 self-destructive, or suicidal when placed into 2 the SHU. 3 MS. 4 MR. And that - did you know 5 that? 6 MS. 7 MR. • So do you know what I'm 8 talking about when I say hotlist? There was a 9 list in the SHU of -. 10 MS. IIII: No. I actually thought that 11 the hotlist was something else. Like that was 12 on the coiiiiiiiiiio. I don't know that. 13 MR. : Okay. And then it talks 14 about when someone is on the hotlist, it's 15 supposed to be a special notation on the 16 hotlist, a special notation on the cell door, 17 and there's also a special notation on the SHU 18 board. 19 MS. IIII: Mm. There was never none of 20 that. 21 MR. : So did you ever -? Can 22 you just take a look quickly? You don't have 23 to look throw h that. Just basically the -- 24 MR. : The two tabs. 25 MR. : -- two tabs as well as 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 the front. MS. MR. you? Did MS. MR. 54 : Mm-hmm. Was that ever provided to ou ever see this? : Hm-mm. No. No. Okay. MR. FO1 Dclou want her to initial? MR. : If you could. Yeah. Just so that we can -. You can do it on the top page. No-no. Sorry. The front page. MR. : ON the front page. MR. FOY: Just the first page. MS. : Oh. MR. And do you know who would have been re uired to provide you that -- MS. : No. MR. -- information? No? And no one discussed that with you? MS. : No. MR. : Did anyone ever discuss the hotlist with you? MS. : Na. MR. Had you ever heard of the term hotlist? MS. IIII: No. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 55 MR. You never even heard the term? MS. IIII: I thought that hotlist was like inmates that were like, um.... Like the inmates that were up on 10 South. Like those high inmates. Like El Chapo and those type of inmates. MR. : Sure. MS. : That's what I though hotlist was. MR. : Okay. And because you brought u 10 South, what's 10 South? MS. : The level above the SHU. MR. And is that a specialized unit that are even more secure than the SHU? MS. . Yes. MR. : And can you just explain to me a little bit about who goes there? What the cell makeup is? Are there cameras in each individual cell? MS. MR. MS. : I don't know. Oh, you don't know? Hm-mm. MR. Okay. Are inmates that are in those cells only one inmate per cell? 56 1 MS. : I think so. 2 MR. : And are they monitored 3 24/7? 4 MS. : Yes. 5 MR. : Okay. But you don't know 6 how they're monitored? 7 MS. : No. 8 MR. : Okay. But they're for 9 like a terrorist, high-profile, drugs -. 10 MS. : Yes. 11 MR. You know? 12 MS. : Mm-hmm. 13 MR. Okay. And that's one 14 floor above where the SHU is? 15 MS. : Yes. 16 MR. : Is it kind of in the 17 general location of the SHU though? 18 MS. : It's upstairs. 19 MR. Can you get to it through 20 the SHU? 21 MS. 22 MR. And would it be 23 considered as - I know it's 10 South and it's 24 unique. But is it also part of the general 25 SHU? EFTA00117656 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 57 MS. IIII: I mean when you come into the SHU, you iiiiiiiiiistairs and it's right there. MR. : Okay. Can you get to it by other means? MS. • No. MR. So you have to go thought the SHU -- MS. MR. MS. MR. Co through the SHU. -- to get -- Mm-hmm. -- into it? Okay. And how many correctional officers are placed in the 10 South? MS. MR. MS. MR. : Um, one. One? : Mm-hmm. And there's no way in or out other than through the SHU? MS. : Mm-hmm, through the SHU. MR. : Okay. So when they come in and out, do the officers that are working in the SHU - you know where you are working - are you the ones that have to allow them to get in and out of the SHU? MS. IIII: Yes. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 58 MR. Okay. Do you recall who was workin on 10 South on August 9th or 10th? MS. MR. ' In? MS. Mm-hmm. MR. Okay. Was that August 9th or 10th or both? MS. IIII: I don't know about the 9th but the 10th. MR. : That's fine. And some of this stuff I'll probably at some point give you a list of the people so you can refer to like the roster so you don't have to -. MS. : Okay. MR. : You know you can recall that way if you remember that those people were in (Indiscernible 00:41:35). MS. : Okay. MR. : But you did say Epstein was assigned to the SHU on August 9th and August 10th, 2019? MS. : Yes. MR. Okay. And he was assigned to the SHU on the days leading up to August 9, 2019? 59 1 MS. : Yes. 2 MR. : Okay. Do you know 3 approximately how long Epstein was assigned to 4 the SHU? 5 MS. : No. 6 MR. : Was he assigned to the 7 SHU for the most part of when you were doing 8 you assignments in the SHU? 9 MS. IIII: When I came back and I was 10 working there? 11 MR. : Correct. 12 MS. 13 MR. Okay. 14 MS. Mm-hmm. 15 MR. : Yes? Okay. So does July 16 and August sound about right? That he was in 17 the SHU? 18 MS. : Mm-hmm. 19 MR. : Yes? What was Epstein's 20 routine while he was assigned to the SHU? We 21 talked about it briefly. He was with attorneys 22 and stuff. So was that like a daily routine? 23 Can you just tell me when he would come and go? 24 And when he would be in the SHU and not be in 25 the SHU? 60 1 MS. IIII: Oh I come in at 2:00. And I 2 come in at 4:00. And when I come in he's not 3 there. He would come back like around after 4 8:00. 5 MR. 8:00 p.m.? 6 MS. 7 MR. Okay. And did you 8 typically work after 8:00? So you come in at 9 2:00 or 4:00. When would you typically work 10 until? 11 MS. IIII: 2:00 to 10:00 or 4:00 to 12 midnight. Mm-hmm. 13 MR. : And then would you 14 typically do overtime shifts after that? 15 MS. IIII: No because I usually do it on 16 the front end. 17 MR. Okay. 18 MS. : So I usually come in the 8:00 19 to 4:00 and do 4:00 to 12:00. 20 MR. : And when you would come 21 in 8:00 to 4:00, would he be gone already? 22 MS. 23 MR. : Okay. But he would come 24 back around -? So he would be gone before 8:00 25 a.m. and come back around 8:00 p.m.? EFTA00117657 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 61 MS. : Mm-hmm. MR. : Would he eat when he was in the SHU? MS. IIII: He gets common fare. That's all I know. I don't know if he eats it. But he gets common fare. MR. : Would that be something you supplied after 8:00 p.m.? MS. : When he comes back. Yes. MR. : Okay. What time is typically feeding time? In the evening? MS. : Um...after 4:00? MR. : And so because he was away, does he get -? Would he get an individual tray that was saved for him or provided when he returned? MS. : Yes. MR. : Okay. And would you provide that try to him? MS. IIII: Not necessarily me just whomever. MR. MS. MR. : Did you ever? Yes. : Okay. Did you provide that to him on August 9th? 62 1 MS. Yes. 2 MR. : You were the one who did? 3 MS. : Mm-hmm. 4 MR. : Okay. Did you ever have 5 any communications with Epstein during his stay 6 at the MCC? 7 MS. 8 MR. 9 at all? 10 MS. 11 MR. : Okay. Did you even 12 verbal say hello - hello back? Anything like 13 that? 14 MS. Mm. He was in the shower to 15 make a phone call. And he was calling because 16 he wanted to come out of the shower. And I 17 told him that he had to wait because there were 18 other inmates out. And you can't move him and 19 them out at the same time. That's the only 20 conversation I ever had with him. 21 MR. : And we'll get into that 22 but was that phone call on August 9, 2019? 23 MS. • Yes. 24 MR. : Okay. But when you would 25 provide food or anytime he would come back : Never any conversations 63 1 after 8:00 p.m. - even when he was coming in or 2 out, you wouldn't even say hello? 3 MS. : No. 4 MR. : No? Okay. For the one 5 interaction you can think of with the phone 6 call, do you remember if that was a positive or 7 a negative interaction? Do you remember it at 8 all? Was it -? 9 MS. : It was regular. 10 MR. : Regular? 11 MS. Mm-hmm. 12 MR. : Did he seem upset? 13 MS. Uh, no. 14 MR. : No? Abnormal? Anything 15 out of the ordinary? 16 MS. : No. 17 MR. : No. What were your 18 instructions with regard to Epstein being 19 assigned to the SHU? 20 MS. : There was no instructions. 21 MR. : So no one said Epstein 22 was a high priority here? Pay closer attention 23 to him? 24 MS. : No. 25 MR. : Alright. So even when 64 1 you had that interaction with the one 2 individual who told you that he was a high- 3 profile person, that he was in the news all the 4 time, there was never a discussed that we need 5 to pay close attention to him? 6 MS. : No. 7 MR. And Lieutenant IIII, you 8 said was the lieutenant in the SHU, he never 9 told you to ay special attention to Epstein? 10 MS. : No. 11 MR. Okay. Was Epstein 12 assigned any cellmates when he was assigned to 13 the SHU? 14 MS. : Yes. 15 MR. And do you know when he 16 was assigned to the SHU was he always assigned 17 a cellmate? 18 MS. IIII: Um, I just know he had two 19 cellmates. 20 MR. Okay. Two different 21 ones? 22 MS. Yes. 23 MR. Alright. Did anyone ever 24 speak with you about Epstein needing a cellmate 25 when he was in the SHU? EFTA00117658 65 66 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MS. : No. MR. : No? Who was the officer in charge or the OIC in the SHU? MS. : Me. MR. Um, are you talking about at 12:00 a.m.? MS. IIII: Yes. On (Indiscernible *00:46:06) -. MR. In general, was there like one officer in charge that has like is considered the OIC in the SHU? MS. IIII: That's what I'm telling you. On paper, it says me. But I don't know how to run the SHU. So I rely on the senior officer. Well on the roster, it says that I was the OIC. And -. MR. MS. MR. I think I'm just not asking the question correctly. I'm not talking about like from 12:00 a.m. to 8:00 a.m. on August 10th. I mean in general. Like in July and August when you were in the SHU, was there one person that was considered the officer in charge? Like hot, there's one lieutenant of the SHU which was El? Was there also an officer 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 in charge of the SHU? MS. 1.1o. MR. : Do you know who - wasn't it Grill? MR. Mr MR. : Do you know who is? MS. : Yes. MR. : Would he be considered the officer in charge? MS. IIII: See I don't know. Because on the roster, it can be a differentiiiiiiii MR. : Okay. Did have like a desk or a computer area that he always sat in when he was there? MS. : No. MR. Specifically? MS. It's the one that we all sit at. MR. But he didn't have one specific location that he would sit at? Like - ? MS. : No. MR. : No, he would sit wherever? 67 1 MS. : Yes. 2 MR. : Can you give me just like 3 a layout? How many desks and computers were 4 there in the SHU where the officers sat? 5 MS. IIII: It was two desks. One this way 6 and one this wa . 7 MR. : So kind of like an L type 8 of formation? 9 MS. IIII: Yes. And computers, about 10 three. 11 MR. . About three computers? 12 MS. Mm-hmm. 13 MR. And had you sat at all 14 three of those computers at least one time 15 during your shifts? 16 MS. : Um, yes. 17 MR. Okay. So it's just - it 18 rotates. You can sit at each one? 19 MS. I mean you can sit at any one. 20 MR. And do you remember ever 21 there being a sign posted on any of the 22 computers saying that Epstein was required to 23 have a cellmate? 24 MS. : No. 25 MR. Alright. And then 68 1 2 MR. Am I pronounciiiiiiiiiright? : Yeah. 3 MR. How do you spell that 4 last name? Do you remember? 5 MR. 6 MR. Thank you Agent 7 So he didn't have a specialized computer where 8 he would have posted a sign on a computer? 9 MS. : No. 10 MR. : No? What about - do you 11 recall ever seeing a sign posted on Epstein's 12 door? 13 MS. : No. 14 MR. : Saying that he was 15 required to have a cellmate? 16 MS. : No. 17 MR. No? Oka . Who was 18 Inmate 19 IMI? 20 MS. Uh, his first um cellmate that 21 he had. 22 MR. 23 MS. 24 MR. 25 July of 2019? Epstein's first cellmate? Mm-hmm. Was that his cellmate in EFTA00117659 69 1 MS. IIII: I'm not sure about the month, 2 but that was his first cellmate. 3 MR. : Okay. Do you recall if 4 was already in the SHU or was he 5 brought in specifically to be Epstein's 6 cellmate? 7 MS. • I don't know that. 8 MR. : You don't know that? 9 MS. 10 MR. : Okay. Are you aware of 11 an issues that took place between Epstein and 12 when they were cellmates? 13 MS. No. 14 MR. : No. Were you aware that 15 on or around July 23 of 2019 um that Epstein 16 allegedly attempted to commit suicide? 17 MS. IIII: I wasn't at work that day but I 18 was told. 19 MR. : Okay. And were you told 20 anything else about the incident? 21 MS. No. 22 MR. : Are you aware if 23 was his inmate at the time? 24 MS. Yes. 25 MR. : And you said you didn't 70 1 have any involvement in that matter though? 2 MS. I wasn't at work. Hm-mm. 3 MR. : Do you know if 4 was removed as Epstein's cellmate? 5 At that point? 6 MS. After that he had another 7 cellmate: 8 MR. : And do you know why they 9 changed? 10 MS. • But I don't know why. 11 MR. : Okay. Do you know who 12 would have made that decision to change 13 cellmates? 14 MS. 15 MR. 16 that 17 MS. 18 MR. 19 rumor? 20 MS. 21 MR. : Okay. Do you know what 22 was used in the incident when Epstein attempted 23 to - alle edly attempted to take his life? 24 MS. : No. 25 MR. : No? : No. Had you ever heard attempted to harm Epstein? No. : You didn't even hear that 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 71 MS. : Hm-mm. MR. : Do you know if it was like linens or a shirt or any kind of -? MS. : I don't know. MR. • No? MS. MR. with you? MS. MR. • And you didn't ask anybody about it? MS. : N MR. Do you know if Epstein was placed on suicide watch or psychological observation? MS. IIII: I think he was placed after that. But I don't know which one. MR. : Okay. Is it usually that someone will go on suicide watch for about 24 hours? Then after that they would go on what's called ps chological observation. MS. MR. MS. MR. • No one discussed that : I'm not sure. • You're not sure? Hm-mm. Is that done in the SHU 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 or elsewhere? MS. : It's done MR. : And downstairs, what - do you MS. IIII: Where the Unit 2. MR. MS. MR. 72 downstairs. when you say know where? suicide watch is or • Okay. So second floor? Mm-hmm. And do you know who makes the determination to be able to place someone on suicide watch or psychological observation? MS. : No. MR. : No? Okay. Does it sound right that he was placed on suicide watch on or around July 23, 2019? And returned to the SHU on or around July 30, 2019? MS. : Yes. MR. That sounds about right? MS. Mm-hmm. MR. And at that time, was Epstein as si ned another cellmate? MS. MR. Who - which cellmate? MS. MR. EFTA00117660 73 1 MS. Mm-hmm. 2 MR. : On or around Sul 30th. 3 And who was Inmate ? 4 MS. His cellmate. 5 MR. : Do you know anything 6 about him? 7 MS. 8 MR. : Okay. But you do know he 9 was his cellmate 10 August 9, 2019? 11 MS. Yes. 12 MR. : Okay. And do you know if 13 Inmate was already in the SHU? Or was he 14 brought in specifically to be Epstein's 15 cellmate? 16 MS. I don't know. 17 MR. : You don't know if he was 18 already in 19 MS. 20 MR. : Now do you ever -? Do 21 you have any involvement with the inmates when 22 you're in there? Would you like converse with 23 24 25 1 2 3 4 was removed on August 9, 2019? 5 MS. : No. 6 MR. : So even on August 9th you 7 didn't know that he was removed? 8 MS. : No. 9 MR. : You knew that Epstein had 10 a cellmate. You just didn't know that he 11 didn't have a cellmate on that day? 12 MS. IIII: He had a cellmate. I didn't 13 know that the cellmate was removed and wasn't 14 coming back. 15 MR. : Okay. So you never 16 learned on August 9th or August 10th for that 17 matter, prior to 6:30 that there was no other 18 inmate within Epstein's cell? 19 MS. : No. 20 MR. : Oka And do you know if 21 anybody was aware that MI was departing the 22 MCC or SHU rior to August 9, 2019? 23 MS. : I don't know. 24 MR. : You don't even know that 25 - you know at this point- if anyone was aware? from that point until about them or do ou just kind of -? MS. : No. MR. : No? so you don't -. Did was removed? MS. : Yes. 75 MR. : And did you know that he 74 1 you ever know why people were specifically in 2 the SHU? 3 MS. 4 MR. : No. Do you know why 5 Inmate was removed from the MCC on August 6 9, 2019? 7 MS. 8 MR. So even at this point do 9 you know _ylEhe was removed? 10 MS. IIII: No. I didn't even know he was 11 removed. 12 MR. : No, I'm saying even today 13 do you know that? 14 MS. • Oh no. 15 MR. : You don't even know that 16 he was removed? 17 MS. No. I'm saying at that point 18 in time, I didn't know that he was removed. 19 MR. : Yeah. So I'm even saying 20 as of tod.iy_:. 21 MS. IIII: But for now, I don't know the 22 reason wh he was removed. 23 MR. : Okay. 24 MS. 25 MR. • But you do know that he 76 1 MS. : No. 2 MR. : No. Do you know if it 3 was antici ated or not an anticipated move? 4 MS. : I don't know. 5 MR. : No? So on August 9th 6 during your time from 4:00 p.m. even to just 7 12:00 a.m. That was not discussed with you at 8 all or within the SHU? That Epstein's roommate 9 was removed? 10 MS. Never. 11 MR. Never? 12 MS. Never. 13 MR. Okay. And are you pretty 14 confident about that? 15 MS. : Yes. 16 MR. : Okay. Are you aware if 17 Epstein should have been reassigned a cellmate 18 after Inmate was removed on August 9, 19 2019? 20 MS. 21 MR. So you're not aware? 22 MS. 23 MR. If he should have been? 24 MS. 25 MR. So your understanding was EFTA00117661 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 77 he had cellmates. You just didn't know if one of them was removed that he should be reassigned one? MS. : Exactly. Mm-hmm. MR. : Okay. Do you know who was responsible for assigning Epstein a new cellmate? MS. : I don't know. MR. No. Could SHU staff have assigned Epstein a new cellmate? Would you have the authority being - working in the SHU - if you knew someone was supposed to have a cellmate? Do you have the authority to place another inmate with that person? MS. IIII: See I don't know. Because I'm that new. MR. MS. Okay. : So like I said, I rely on the senior person a lot. So I don't know. like that would be a question I would ask them. So I don't know. MR. : When you were - during your time in the SHU, which you said I guess was from you know late June through August 9th or 10th. Did you ever see that happen before? 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 78 SHU staff assign inmates with other inmates? MS. IIII: When an inmate comes, they place them with another inmate. MR. : And would they do that based upon their own responsibilities and duties or would someone tell them to do that? MS. MR. MS. : See I don't know. You don't even know? Hm-mm. MR. Okay. So you saw people be assigned with other ones, but you don't know how -- MS. MR. -- that was determined? MS. Yeah. MR. Okay. So you don't even know if you could have assigned Epstein a new cellmate? MR. MR. No. : I don't know. : Do you know if SHU staff should have assigned? You know like -. Or I guess you just answered that. So you said you know. And again, on August 9th, no one notified ou that was gone from the SHU? MS. IIII: No. 79 1 MR. And you were working in 2 the SHU. 3 MS. : No e. 4 MR. Do they typically tell 5 you when an inmate in the SHU is - has left and 6 is not comm back? 7 MS. IIII: Nobody said anything to me. I 8 don't know. 9 MR. : Because don't you have to 10 be able to keep your counts correct? And be 11 able to know how many people are in the SHU? 12 So if someone is removed, don't they have to 13 tell you? This person's not coming back so 14 your count is going to be lower. 15 MS. IIII: Mm-hmm. But it wasn't told to 16 me. So I don't know. 17 MR. : Um okay. Do you know who 18 the MCC staff psychologists were in August of 19 2019? 20 MS. : N 21 MR. : Do you have any dealings 22 with them at all? 23 MS. : No. 24 MR. Does the name Chief 25 ring a bell? 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MS. MR. psychologist MS. MR. MS. MR. dealings MS. MR. MS. the unit. MR. : Okay. Prior to August 10th did ou have any dealings with her? MS. : No not really. MR. No. What about a Samantha MS. MR. MS. MR. with her? MS. MR. : So only with 2 80 No? How about staff Mm-hmm. I know her. Okay. Who is she? She's one of the psychologists. Okay. And did you heave with her? : I had dealings with her after. You after August 10th? : Like on August 10th she came to Demisa? Yes I know her. And who is she? sychologist. Did you have any dealings EFTA00117662 81 82 1 MS. IIII: Yes but she came after the 2 incident. 3 MR. : But what was your dealing 4 with her after the incident? 5 MS. : She just asked was I alright. 6 MR. : Okay. Did she ask you 7 anything about Epstein or his cellmate or 8 anything like that? 9 MS. No. 10 MR. : No? So it was specific 11 to you? 12 MS. Yes. 13 MR. : Okay. Are you aware was 14 Epstein meeting with staff psychologists during 15 his stay at the MCC? 16 MS. No. 17 MR. : No. Would have he met 18 with them I guess during suicide watch and 19 psychological obviously? 20 MS. : Yes. 21 MR. : Okay. So that. Did you 22 know that he did meet with them then? 23 MS. IIII: I don't know if he did, but I'm 24 going to assume he did. 25 MR. : Okay. But you do know 1 that he was laced on suicide watch? 2 MS. Yes. 3 MR. : And they never - no one 4 from psychology ever provided you instructions 5 with regard to when he returned - how he was to 6 be treated? 7 MS. • No. 8 MR. : Or that he was - needed 9 to have a cellmate at all times. 10 MS. • No. 11 MR. : Or that you needed to 12 watch him? 13 MS. 14 MR. : Do you know who placed 15 him on suicide watch? 16 MS. No. 17 MR. : No? So what is your 18 understanding of suicide watch? When someone 19 is on suicide watch and comes back. What is 20 your understanding of how you're supposed to 21 treat those people? Now my understanding is 22 that you would have received this training you 23 know. Now I know you said you didn't do the 24 SHU training. But the other trainings that you 25 attended - the IF, the MCC annual, and the 83 1 correctional officer training at FLETC. Did 2 they discuss suicide? 3 MS. IIII: I mean if someone is like 4 explains to you that they're feeling a certain 5 kind of way or they want to harm themselves, 6 then you report it to them. They will place 7 them on suicide watch. But as far as when they 8 return, there's no - nothing special that we're 9 told to do when someone returns from suicide 10 watch. 11 MR. So they don't tell you 12 like this person's on suicide watch, he's 13 returning, he needs, you know a high likelihood 14 of attemptin to harm himself. 15 MS. : No. 16 MR. We should place him with 17 another cellmate. 18 MS. : No. 19 MR. That we should watch him. 20 MS. 21 MR. Or make sure that he 22 hasn't harmed himself. 23 MS. : No. 24 MR. : Or pay special close 25 attention to that individual. 84 1 MS. : No. 2 MR. : You said suicide watch 3 though, that is on the second floor? 4 MS. : Yes. 5 MR. : Okay. So you're not 6 aware that the requirement that if someone is 7 returned to the SHU that they're required to 8 have a cellmate if they were on suicide watch? 9 MS. : No. 10 MR. : Do you know the 11 difference between suicide watch and 12 psychological observation? 13 MS. : No. 14 MR. • No? Are they both done 15 in - on the second floor? 16 MS. : Yes. 17 MR. Okay. But you don't even 18 know what that is? 19 MS. : No. 20 MR. . Did you know that Epstein 21 was also on sychological observation? 22 MS. : No. 23 MR. • No? Just suicide watch? 24 MS. : Mm-hmm. 25 MR. And to you it's one and EFTA00117663 85 86 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 the same thing? MS. MR. MS. MR. : Yes. : Okay. Mm-hmm. • And I did ask about suicide watch, but do you know who placed Epstein on sychological observation? MS. : No. MR. : No? And you don't know - . Are inmates that come from psychological observation required to have a cellmate? MS. No. MR. : You don't know? MS. I don't know. MR. : So were you aware of any inmates that are in the SHU that were on suicide watch - came from suicide watch and psychological observation? MS. : No. MR. : And again, that hotlist. Did you say that you do remember there being one? MS. : No. MR. : In the SHU? MS. : No. 1 MR. So you don't even 2 remember there being a hotlist in the SHU? 3 MS. : No. 4 MR. : Would you like look 5 around at the boards and look at the walls and 6 see different things? 7 MS. : There is no board. 8 MR. No? There's no like -- 9 MS. 10 MR. -- where the post orders 11 are - where are they kept as -. 12 MS. : It's on the desk. 13 MR. : Was there also on the 14 desk something called the hotlist? 15 MS. : No. 16 MR. : Was there a list on the 17 desk that had like inmate's names and anything 18 next to them? Like a description? 19 MS. : There's a roster. 20 MR. : A roster like of all the 21 inmates in the SHU? Total? 22 MS. : Yes. 23 MR. : Well what about like - 24 and I only say this because I know that there 25 was one. So you don't recall saying like - 87 1 seeing like one list where there's special 2 people assigned to that list called the 3 hotlist? 4 MS. 5 MR. • No? And you did work 6 there all June, July, and August? Or not all - 7 end of June July, and then it's August. 8 MS. : Yes. 9 MR. : Did any staff 10 psychologist visit the SHU? 11 MS. : Yes. 12 MR. Did they ever visit 13 Epstein in the SHU? 14 MS. No. 15 MR. No? What time typically 16 would they come to the SHU when they would 17 visit? 18 MS. IIII: Um like after -. When I worked 19 the 8:00 to 4:00. I don't know. Sometime in 20 the day like ma be around 12:00. 21 MR. : And would they not have 22 come to the SHU to see Epstein because he 23 wasn't there at 12:00? 24 MS. : Because he wasn't there. 25 MR. Do you know if they ever 88 1 visited him when he was with his attorneys? 2 MS. : I don't know. 3 MR. : You don't know. So did 4 anyone - so psychologist, peers, supervisors, 5 or anyone else - ever tell you that Epstein was 6 required to have a cellmate? 7 MS. : Nobody. 8 MR. : Nobody. Did you ever 9 receive any emails? So any type or form of 10 communication? So not just verbal. Emails and 11 writing, text messages - anything? 12 MS. : No. 13 MR. : No? Do you have that 14 email? This isn't an email that was sent to 15 you. I just want to see if you - if someone 16 ever forwarded this to you. Did anyone ever 17 forward you -? This is -. First of all, this 18 is an email from . It says 19 suicide watch / psychological observation 20 update. It's what was sent on July 30, 2019. 21 It says inmate Epstein is being taken off 22 psychological observation and needs to be 23 housed with an appropriate cellmate. Did 24 anyone ever forward this information to you? 25 Being that you worked in the SHU where he was EFTA00117664 89 1 assigned? 2 MS. 3 MR. : No? So no one ever 4 discussed that with you in the SHU? Like none 5 of the other employees in the SHU that would 6 have received this? 7 MS. . No. 8 MR. Do you know why other 9 employees would have received this and you 10 wouldn't have? 11 MS. IIII: I'm not going to say that they 12 received it and I didn't. 13 MR. : Well if you look at the 14 back it's all the people that it was sent to. 15 So if you go to the last page, do you recognize 16 any of the people on there that worked in the 17 SHU with you? The names. Look at the last - 18 sorry, that middle page and toward the bottom. 19 The following page I think. Middle, toward the 20 bottom. 21 MS. . That's the lieutenant. 22 MR. . Do you recognize 23 Lieutenant on there? 24 MS. . Yes. But this is not sent 25 This is not the workers. 1 2 3 4 S 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 90 MR. : None of those people were assigned to the SHU? Towards the bottom of that? MS. : No. MR. : No? Okay. So just the only person that you see on that is Lieutenant IIII? MS. : Lieutenant IIII. MR. : And he never discussed that matter with you? MS. : No. MR. : If you don't mind, could you initial and date it? MS. : I initialed. MR. And date. MS. Ten.... MR. : The 22nd. 6/22/21. MR. Agent just has a couple questions on that. MR. Here. MR. : During your time in the SHU MS. Mm-hmm. MR. : Did any new inmates come in during your shift? 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 91 MS. III': On that specific day or in general? MR. : Yeah. From June to August. When you worked in the SHU. Did the SHU receive an new inmates? MS. : Yeah. MR. : When they came in, how did you assign the inmates? MS. IIII: I didn't. The senior officer did. MR. : Senior officer. Did you see them assigp_inmates? Assign a cell to them. MS. IIII: Like they put them in a cell? Yes. MR. : Were they ever put by themselves? MS. : I don't remember. MR. : Do you recall any inmates being placed by themselves in the SHU? MS. IIII: I think there was one inmate by himself. MR. by himself? MS. : I don't know. MR. So of all the inmates, : Any reason why he was placed 92 1 there was only one that was by themselves? 2 MS. IIII: I think it was an inmate by 3 himself on C tier. 4 MR. : Now you mentioned that day 5 were you on August 9th you were notified that 6 was removed. But during your time 7 in the SHU, were you ever notified if an inmate 8 was ever removed from the SHU for whatever 9 reason? Were you notified about it? 10 MS. No. 11 MR. : How would you find out if the 12 inmate was supposed to be in the SHU or not? 13 MS. IIII: How would I find out if an 14 inmate isiiiiiised -? 15 MR. : Let's say the morning 16 started. 17 MS. Mm-hmm. 18 MR. : You came on shift at 2:00 19 p.m. or possibly 4:00. After that, there's 20 counts and rounds. When you do the counts, 21 right. I just want to know in terms of how 22 would you know if an inmate was removed or not? 23 MS. IIII: When I count and he's not 24 there. 25 MR. : You wouldn't be notified any EFTA00117665 93 94 1 other way? 2 MS. No. 3 MR. : That's all I have. 4 MR. : And I know we discussed 5 the cellmates, but were you ever told you 6 needed to keep a close watch on Epstein -- 7 MS. : No. 8 MR. : -- when he was there? 9 No? Who was the MCC warden in July and August 10 of 2019? 11 MS. 12 MR. : Is that ? 13 MS. Yes. 14 MR. : Okay. What 15 communications did you have with the warden 16 with regard to Epstein being housed within the 17 MCC or the MCC SHU? 18 MS. : None. 19 MR. : None. And he never 20 provided you special instructions with regard 21 to Epstein? 22 MS. 23 MR. : Did the warden ever tell 24 you that Epstein was required to have a 25 cellmate? 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MS. : No. MR. : Did the warden ever visit the SHU during Epstein's stay at the MCC? I don't know. Not on my shift. : Not during your shift? MS. MR. MS. MR. : No? Okay. Do you know if the warden ever met with Epstein during his stay? MS. • I don't know. MR. : Who were the MCC associate wardens in August of 2019? MS. Um, associate warden was MR. MS. Yes. MR. aware of? MS. : Anyone else? That you're MR. : Okay. And what communications did you have with or the other AW with regard to Epstein being housed within the MCC or the MCC SHU? MS. IIII: None. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 95 MR. None? Would you have communications with any of the AWs? MS. . No MR. : No? So did you not even ever speak with them? MS. : Not in the SHU. MR. • Not in the SHU. When would you_laak with them? MS. IIII: On the regular housing unit when they made rounds. MR. So in July and August did you ever s eak with them that you recall? MS. : No. MR. • No. So not since you were assi ned to the SHU at the end of June. MS. : Mm-hmm. MR. Okay. What about the warden? Is that the same thing? MS. . Mm-hmm. MR. No communications? MR. FOY: Don't know. MS. : No. MR. : No? MR. FOY: Don't answer if you don't know. MS. IIII: Okay. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 96 MR. FOY: Oka MR. : Do you know if any of the AWs ever visited the SHU during Epstein's stay? MS. .lon't know. MR. : You don't know. Not during your watch though? MS. MR. : Okay. Do you know if any of the AWs ever met with Epstein during his stay at the MCC? MS. : I don't know. MR. : You don't know. But not when you were in the SHU? MS. : Not on my shift. MR. Who was the MCC captain in July and August of 2019? : Captain . Is that Yes. MS. MR. MS. MR. Okay. And what communications did you have with Captain with regard to Epstein being housed within the MCC or the MCC SHU? MS. : None. MR. None? And did he ever EFTA00117666 97 1 provide you with special instructions with 2 regards to E stein? 3 MS. : No. 4 MR. Captain 5 MS. 6 MR. 7 you that Epstein was required to have a 8 cellmate? 9 MS. 10 MR. 11 captain ever visit the SHU during Epstein stay 12 at the MCC? 13 MS. : Not on my shift. 14 MR. : Not during your time? 15 Okay. And do you know if the captain ever met 16 with Epstein during his stay at the MCC? 17 MS. : I don't know. 18 MR. : You don't know. So who - 19 ? I'm going to give you now just because -. 20 Uh okay, where are the rosters? I'm going to 21 ask her about some of the supervisors that were 22 on duty. So are you familiar with these 23 rosters? Like just by looking at it are you 24 able to decipher who was on duty and who 25 wasn't? Or who was on duty on August 9th and 7 Did the captain ever tell In the SHU? No? Did the 98 1 10th? I'm giving you the MCC New York daily 2 assignment roster. So there's August 9th and 3 August 10th. So who were the MCC supervisors 4 on duty with responsibility for overseeing the 5 SHU on August 9th and 10th? Do you recall if 6 Lieutenant was there on August 9th or 7 10th? 8 MS. : I don't recall. 9 MR. You don't recall. 10 MS. 11 MR. Okay. So he wasn't 12 there. So if he's not there, who has oversight 13 over the SHU? 14 MS. : I don't know. 15 MR. : Do you - would it be the 16 operations lieutenant or the activities 17 lieutenant? 18 MS. : I don't know. 19 MR. : You don't even know who 20 is - that would have responsibility if the 21 lieutenant of the SHU wasn't there? 22 MS. : No. 23 MR. : Would anybody if 24 Lieutenant wasn't there check in with you? 25 MS. : I mean the other lieutenant 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 99 would make a round. MR. What other lieutenant would that be? MS. IIII: Whoever was on. You mean that day? MR. Yes. On August 9th and August 10th. I'm wondering who had responsibility of the SHU? If Lieutenant IIII wasn't there. He was the SHU lieutenant. MS. IIII: In the daytime, it was a regular officer acting. MR. • Okay. MS. : From the when I was on at 4:00 to 12:00. MR. : Okay. MS. : And then from midnight it was Lieutenant MR. Okay. So would that other person that you're referring to. Do you know who that was? MS. : The acting? That was acting? MR. Acting. MS. MR. SOS =? MS. : Say that again. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 100 and MS. MR. • Okay. What about by looking at that. Would the - do you see where it says 7 MS. MR. . Would that person have oversight over the SHU from - does it say that that person was the operations lieutenant? MS. IIII: That's what it says here but I didn't see Lieutenant MR. : And do you know as being the operations lieutenant would they be responsible for overseeing the SHU? If -? MR. Was it SOS Senior Officer Specialist MS. Yes. MR. Is that MS. (Indiscernible *01:11:25) MR. I might be saying that name wrong,__ MS. IIII: I'm not sure of her first name, but -. those are the tw That's fine. Oki. o that you remember: MR. 2 Was Acting in the day. Yes. Yes EFTA00117667 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 101 MS. : I don't know. MR. : You don't even know that? Okay. So you don't know if after -. Is it true that after replaced him as the operations lieutenant? MS. : According to this, yes. MR. : Okay. And you're not aware that that person would have oversight over the SHU? MS. • I don't know. MR. : You don't know. No one ever talked to you about isn't there. Who should you go to if there are any problems or who would check in with you? MS. IIII: No. I would call downstairs to the lieutenant's office. MR. : And would you just talk to whoever answered? MS. Yes. MR. : And who would sit in the lieutenant's office? MS. The lieutenants. MR. : All of them? MS. MR. : So it wouldn't be like 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 102 the operations lieutenant and the activities lieutenant? MS. • No. All the lieutenants. MR. : Okay. They all just sit in there to ether? MS. Mm-hmm. MR. : Not one of them specificall answers the phone though? Just -? MS. No. Anybody. MR. : Okay. Do you remember -? Again, Lieutenant was reportedly off on August 9th and August 10th. MS. Mm-hmm. MR. : Do you recall ever seeing him on Au ust 9th or August 10th? MS. Hm-mm. MR. : Where would Lieutenant sit? When he was at the MCC? MS. : U stairs. MR. : When you say upstairs, upstairs where? MS. IIII: There's an office right next to 10 South u stairs there. MR. : Within the SHU? MS. : Yes. 103 1 MR. Okay. So he was 2 physicall in the SHU? 3 MS. Yes. 4 MR. . Alright. So when he 5 wasn't there, would any other lieutenant come 6 visit the SHU? 7 MS. : When they make rounds. 8 MR. : Okay. When they make 9 rounds. And do you remember if that person was 10 the acting or the operations lieutenant or the 11 activities lieutenant? The person that would 12 do those rounds? 13 MS. : I don't know. 14 MR. : You don't know. you just 15 knew that they were a lieutenant. 16 MS. : Yes. 17 MR. : Okay. So would you even 18 be provided that information where there's a 19 duty agent roster? Is that something that 20 would be like, hey. It's up. If I need to get 21 in contact with somebody, I can look at that 22 roster and see who is where? 23 MS. IIII: No. Just call the lieutenant's 24 office. 25 MR. Just call the 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 104 lieutenant's office. MS. : Yes. MR. : Okay. And I believe you answered this, but did you have an communications with Lieutenant IIII regarding Epstein at all? MS. : No. MR. So he never provided you any special instructions with Epstein? MS. : No. MR. And you never - Lieutenant never told you Epstein was required to have a cellmate in the SHU? MS. MR. No. Operations Lieutenant I" know who was from August 9th? Do you know that individual? MS. : Yes. MR. • But as the operations lieutenant, you don't know that he was responsible for overseeing the SHU on August 9, 2019? MS. : I don't know. MR. : Did you have any communications with Lieutenant regarding EFTA00117668 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 105 Epstein bein housed at the MCC or in the SHU? MS. : No. MR. : He never did - did Lieutenant ever provide you with special instructions with regard to Epstein? MS. : No. MR. : Did Lieutenant ever tell you that Epstein was required to have a cellmate while he was assigned to the SHU? MS. IIII: No. I'm going to ask you these questions with a couple people. So I just want you to like really think about those people and they're goin to be repetitive. MS. : Okay. MR. : Because I know you can just simply say I didn't have any communications. But I want you to really think about that individual and any communications you had with that person with regard to Epstein and the SHU and your assignments. Okay? MS. : Okay. MR. Who is Lieutenant 7 MS. : A lieutenant. MR. : A lieutenant. By looking 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 106 at that roster, was he on it on August 9th? MS. : No. MR. : No. Do you know if he was physically present at -? Do you recall if he was ph sically present on August 9th? MS. MR. leave. I there. MS. • Okay. MR. : So you don't recall having an communications with him? MS. : No. MR. Alright. And did Lieutenant ever provide you with special instructions with regard to Epstein? MS. : No. MR. : No. Did Lieutenant ever tell you that Epstein was required to have a cellmate while he was assigned to the SHU? MS. MR. And then this is who you were just referring to. Who was senior officer specialist just want : I don't recall. He was reportedly on sick to make sure that he wasn't No. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 107 MS. : An officer. MR. : And on August 9th, was she the acting lieutenant responsible for overseein2_1be SHU? MS. IIII: I don't know if she was responsible for overseeing the SHU, but I know she was the acting lieutenant. I don't know for the whole building. MR. But you said she -- MS. But she -. MR. -- conducted a round? MS. She did. MR. Okay. So if she conducted a round, would that lead you to believe that she was probably -? Hey, Lieutenant isn't there, she's conducting the round here, she's probably got oversight over the SHU? MS. IIII: I don't know. It could be another lieutenant also. I don't know. MR. SHU on Au MS. MR. Okay. Did she visit the ust 9, 2019? : Yeah, she did. And what time was she on duty on August 9th? By looking at that roster. 108 1 Can you tell? 2 MS. : It says 8:00 to 4:00. 3 MR. I think it would just be 4 on that first age. 5 MR. : Is that August 10th or 9th? 6 MS. This is 9th. 7 MR. It just says 8:00 to 8 4:00? 9 MS. Yes. 10 MR. : Can you check on the 11 lieutenants column up top? 12 MS. • (Indiscernible *01:17:34) 13 MR. : Is there a name? 14 MR. It should be under 15 activities lieutenant. 16 MS. : Oh yeah. 4:00 to midnight. 17 MR. : 4:00 to midnight? Okay. 18 So you knew that - you do recall having an 19 interaction with her. Did she have any 20 communications with - we're talking 21 about now - with regard to Epstein being housed 22 within MCC or the SHU? 23 MS. : No. 24 MR. No? And did she provide 25 you with any special instructions with regard EFTA00117669 109 110 1 to Epstein? 2 MS. 3 MR. : Did SOS ever tell 4 you that Epstein was required to have a 5 cellmate when he was assigned to the SHU? 6 MS. : No. 7 MR. : Okay. Now we're going to 8 go on to some staff members. Who was present 9 in the SHU when you worked in the SHU on August 10 9, 2019? So you said you were from 4:00 to 11 midnight on that August 9th. Do you recall who 12 that was? 13 MS. and 14 MR. IIIIIIIIII: Just and 15 When you arrived to the SHU was anybody else 16 there? 02_2u recall replacing? 17 MS. IIII: I don't remember who I 18 relieved. 19 MR. Do you know a 20 IIIIIII? 25 MS. 23 LPL . MR. MR. 24 MS. : Yes. . . 21 MR. 22 : Alright. And 1 2 MS. : Yes. 3 MR. Were either of them in 4 the SHU on August 9 2019? 5 MS. 6 MR. 7 MS. Mm-hmm. 8 MR. But while you were there, 9 not 10 MS. I don't remember. But I 11 remember because he spoke to me. 12 MR. Okay. So 13 are the people that you 14 remember that were in the SHU? 15 MS. : Yes. 16 MR. Okay. And you said that 17 you remember speaking with you? 18 MS. 19 MR. About what? 20 MS. : He told me he placed Epstein in 21 the shower to use the phone. And he called and 22 told me to take the phone from him. 23 MR. : Can you give me a little 24 more detail on that? What do you mean? 25 MS. IIII: So because he -. 2 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 111 MR. lust walk me through. This one is one of those ones I'll ask you to explain a little more. Can you just from eh start of the conversation to what you did with Epstein to the finish. MS. IIII: Okay. So Epstein stays in attorney conference all day. So I guess when it's time to use the phone, he's not present. So when he came upstairs, gave him the hone in the shower to use the phone. And then left. He called on the phone. I happened to answer and he said, "Hey can you take the phone from Epstein? Because the time is up." So -. MR. : So when he gave him the phone he left and no one else was present with Epstein when he was on the phone? MS. : No. Nobody was there. MR. : Do you know that to be a legitimaq_pfactice? MS. IIII: I mean it's in the SHU, so yeah. MR. So is no one supposed to be - because is the SHU a recorded line? MS. IIII: I don't know. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 112 MR. So do you know if someone is calling from a non-recorded line, are you supposed to take notes of that call? MS. : I don't know. MR. : Do you know if you're supposed to log the telephone call in any kind of a logbook? MS. : N MR. Okay. So your understanding is gave him - plugged in the line, ave him the phone, and then left? MS. : Yes. MR. No one was there to monitor? MR. Okay. So he -. MS. : We were in the SHU, but nobody was monitiiiiiiiiii MR. : How far away from you was he when he was making this call? MS. IIII: He was on C tier. And like that's far from the desk. MR. : Approximately - do you know how to like -? MS. : I don't know. MR. Is it like from here to EFTA00117670 113 1 like that fire extinguisher over there? Or is 2 it further? 3 MS. IIII: No. Maybe from the wall by the 4 AC to over there. 5 MR. : Okay. So approximately 6 25 feet? 7 MS. : Mm-hmm. 8 MR. : Could you hear his 9 conversation from there? 10 MS. No. 11 MR. : And were you asked to 12 listen to his conversation? 13 MS. No. 14 MR. : Prior to placing the 15 call, did speak to you at all? 16 MS. No. 17 MR. : So just after he placed 18 the call, he called you and what did he say? 19 MS. IIII: He said to take the phone from 20 him because the time is up. 21 MR. : Do you know how long he 22 was on that hone? 23 MS. No. 24 MR. : Were you watching him 25 while he was on that phone? 115 1 the call in the shower, cell closed behind him, 2 it was approximately 25 feet from you but you 3 didn't hear anything? 4 MS. : No. 5 MR. • And he didn't - and 6 didn't instruct you? 7 MS. : No. 8 MR. Did you ever experience 9 that prior to that instance? Where an inmate 10 would do that in the SHU? 11 MS. IIII: Yeah. If they have to use the 12 phone and where there cell is, it's not 13 working. They place them in there because they 14 have to plug it close to where they can have 15 access to the hone. 16 MR. : Okay. So in their cells 17 do they have cell lines that they can typically 18 call from? 19 MS. N 20 MR. Are the inmates provided 21 anything to be able to make calls? 22 MS. : No. 23 MR. : Some kind of a card pass 24 or number or like something to be able to -? 25 MS. IIII: Oh, like a pack and - yeah. 114 1 MS. 2 MR. : Was it abnormal for an 3 inmate to be out by himself on the phone in the 4 SHU? 5 MS. : No. 6 MR. : So they can just freely - 7 that's not an abnormal circumstance? 8 MS. IIII: No because he wasn't free. He 9 was in a cell. He was in a cell on the phone. 10 But he -. 11 MR. : Oh so he was in a cell? 12 MS. : Yeah but he was - he was in the 13 shower because the jack - where his cell is, 14 the jack didn't work. So he was placed in the 15 shower to use the phone there. But the shower 16 is like a cell. 17 MR. : Okay. So was the door 18 closed -- 19 MS. Yes. 20 MR. -- in the cell? So he 21 was in the shower area. Was he by himself? 22 MS. Yes. 23 MR. : Were showers running? 24 MS. 25 MR. : He was just - he placed 1 MR. 2 what that is? 116 : Okay. Can you explain 3 MS. IIII: I mean I don't know too much 4 about it. I just know that they have a PIN 5 that they use to use the phone. 6 MR. : Okay. Do you know if 7 Epstein had that PIN to use the phone? 8 MS. : I don't know. 9 MR. : But specifically with 10 regard to the shower, having an inmate call 11 from the shower, have you ever experienced that 12 before? 13 MS. : Yes. 14 MR. When was the last time 15 you had eaLienced that prior to August 9th? 16 MS. IIII: If the jack is not working. 17 The jack that's closest to their door. If it's 18 not working, then it's being plugged at the 19 bottom where the shower is. So you place them 20 in the shiiiiiiiiiiso they can reach the phone. 21 MR. : And do you know if that 22 was an authorized practice? 23 MS. : I don't know. 24 MR. : Okay. And did you ever 25 place anybody in the shower to do that? EFTA00117671 117 118 1 MS. 2 MR. No? 3 MS. 4 MR. . Who typically does that? 5 MS. The officers. 6 MR. Okay. But not you, 7 right? 8 MS. 9 MR. Would you ever allow 10 inmates to lace calls? 11 MS. : When -. 12 MR. • You personally. 13 MS. • When I come on, they have 14 already like of their phone calls. 15 MR. : Oh, okay. So it's not 16 typically one of your responsibilities? 17 MS. : No. 18 MR. : What was unique about 19 this situation with Epstein? 20 MS. IIII: Well I guess because he's 21 always downstairs, so they made an exception 22 for him to make a call. 23 MR. : Okay. Do we need to take 24 a break? 25 MR. FOY: DO you need to use the bathroom 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 or anythin MS. IIII: No. MR. FOY: We can continue. were MR. : Great. Alright. So what instructions. You said that he's - his time is up. So what's - how much time is he allotted? MS. : I don't know. MR. : Do you know how long he was in that shower? MS. : Mm.... I don't know. MR. : You don't know. Was it like 5 minutes, 10 minutes -? MS. IIII: It wasn't 5 minutes. He was in there for ma be 20 minutes. MR. 20 minutes? Okay. And where was 7 MS. He was gone. MR. Like left the SHU altogether? MS. Mm-hmm. MR. So he placed him in there MS' MR. : -- left the SHU, and then 119 1 where did he call you from in order to say get 2 the phone from him? 3 MS. IIII: A phone in the building. I 4 don't know where because it doesn't say where. 5 Like the phone rang and I answered. And he 6 just told me to take the phone from Epstein. 7 His time is .. 8 MR. : Is that weird to you at 9 all? That he again, he gave someone a phone, 10 put them in the shower and then left? 11 MS. 12 MR. That's not weird? 13 MS. 14 MR. • Okay. But without 15 filing anybody -. Did you know if he - 16 - provided anybody instructions prior 17 to him de arting the SHU? 18 MS. • I don't know. 19 MR. You don't know. 20 MS. 21 MR. else was in the SHU 22 with you 23 MS. 24 MR. And did you recall when 25 around that took place? 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 120 MS. Like the time? MR. : Yep. MS. : It had to have been about after 8:00 because that's the time he comes back from attorney conference. MR. Okay. So around 8:00 p.m. - ish? MS. MR. MS. MR. look? Was gave him his MS. MR. That's fine. : After. After 8:00 p.m. - ish? Mm-hmm. Okay. Are you able to assigned to the SHU when he phone call? : No. Where was he assi ned? Do you know what - why went to the SHU in the first place? Was the escorting Epstein back from his attorneys? MS. MR. reason wh MS. MR. : I'm not sure. So you don't know the he actually entered the SHU? : No. I don't know. And you -? Do you remember if he walked into the SHU with Epstein EFTA00117672 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 121 and immediately placed him into the shower area? Or do you think that he went and retrieved_Lpitein from his cell? MS. IIII: No. He didn't retrieve him from his cell. He came in and said that he was going to ive him a phone call. MR. : So he was with him at the time? MS. IIII: Yes. And he placed him in the shower. MR. So do you recall then if he walked in the SHU with Epstein? MS. IIII: I don't know if he walked in with him. But after because you could come in and he could have been -. There's a holding cell there. That's why I'm saying I don't know. And then he came in after with him. But from that door to the shower, he walked in with MR. Okay. So Epstein wasn't in his own cell? MS. : No. MR. He could have potentially been in a holding cell? MS. IIII: Yes. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 122 MR. Alright. But you don't know who brough Epstein -- MS. : No because -- MR. : -- back there? MS. -- somebody could have brought him up and then - so I don't know. MR. : Okay. Now in order to i et tto the SHU though, either you, or MS. : Had to open the -. MR. : -- open the door. Do you remember who opened the door on that day? : I don't know. It was not you? MS. MR. MS. MR. Okay. And I'm sorry, you may have said this and I do apologize. What time did M I a n g I I I I I I I I work there until? MS. IIII: .= was 4:00 to 12:00 and was 2:00 to 10:00. MR. : Okay. And what was the hierarchy with the three of you that were present at that time? Is there someone that was in charge as an officer in charge? Or how does that work when you're working together 123 1 with those two other individuals? 2 MS. IIII: I don't know who was in charge. 3 We just kind of worked together that day. But 4 I don't know as far as who is the -. 5 MR. : Is everyone considered 6 equals? When you're working together? 7 MS. IL Well I'm the newest person 8 there, so and - I don't know how 9 long they've been there, but -. 10 MR. : Does it - does then when 11 you work with someone else, is it based upon 12 how long the 've been with the Bureau? 13 MS. : No. 14 MR. : So is there -. I know 15 you're saying you're the newest. So you might 16 ask them questions. But is there like when 17 there's three of you in there, is there someone 18 that's supposed to be in charge? Or are you 19 all equaljy_:? 20 MS. IIII: On the roster it'll say who is 21 supposed to be in charge. 22 MR. : Okay. So (Indiscernible 23 *01:28:25) -. 24 MS. IIII: But that doesn't necessarily - 25 that's not necessarily the