Text extracted via OCR from the original document. May contain errors from the scanning process.
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SWORN STATEMENT
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OF
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TOVA NOEL
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OIG CASE #:
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2019-010614
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JUNE 21, 2021
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Agoura Hills, CA 91301
Phone:
EFTA00117759
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APPEARANCES:
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BY:
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BY:
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WITNESS:
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TOVA NOEL
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JASON FOY, ESQ.
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SERINE GREG
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EFTA00117760
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
5
York Field Office and these are my credentials.
6
This interview with Federal Bureau of Prisons
7
correctional officer Tova Noel is being
8
conducted as part of an official U.S.
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Department of Justice Office of the Inspector
10
General investigation. Today's date is June
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22, 2021 and the time is 10:09 a.m. This
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interview is being conducted at - what is the
13
location - 15 -?
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MR. FOY:
, Hackensack,
15
New Jersey.
16
MR.
: 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
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DOJ OIG Special Agent
24
Correctional officer Tova Noel; Ms. Noel's
25
attorneys, Jason Foy, and Eric Sarraga of Foy &
EFTA00117761
4
1
Seplowitz, LLC; as well as union representative
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Serine Greg of the Local 3149 with the BOP.
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This interview will be recorded by me, Senior
4
Special Agent
. Could
5
everyone please identify themselves for the
6
record and spell your last name. To start,
7
again, I am DOJ OIG Senior Special Agent
8
9
MR.
: I am DOJ OIG Special Agent
10
11
MS. NOEL: I'm Tova Noel, N-O-E-L.
12
MR. FOY: Jason Foy, F-O-Y, attorney for
13
Tova Noel.
14
MR. SARRAGA: Eric Sarraga, S-A-R-R-A-G-A,
15
attorney for Tova Noel.
16
MS. GREGG: Serine Gregg, G-R-E-G-G, Local
17
3148.
18
MR.
: Thank you everyone. Ms.
19
Noel, you are here today as a subject in this
20
DOJ OIG investigation. This DOJ OIG
21
investigation concerns your alleged misconduct
22
to include allegations of false statements, job
23
performance failure, security failure, and
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reporting false information. This is an
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official DOJ OIG investigation and you are
EFTA00117762
5
1
being asked to voluntarily provide answers to
2
our questions. Will you agree to a voluntary
3
interview with the DOJ OIG?
4
MS. NOEL: Yes.
5
MR.
: Alright. Great. And
6
then everyone that does voluntary interviews
7
with the DOJ 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
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provide information as part of an investigation
15
being conducted by the Office of the Inspector
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General. This investigation is being conducted
17
pursuant to the Inspector General Act of 1978
18
as amended. This investigation pertains to
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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
EFTA00117763
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.
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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. FOY: Right. Exactly.
25
MR.
: So -.
EFTA00117764
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MR. FOY: I know there's no sort of
2
protection with regard to the disciplinary
3
internally the administrative 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, you can sign Tova.
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 signature.
14
MS. NOEL: Mm-hmm.
15
MR.
: Alright. And the rest
16
will be filled out by the two of us.
17
MR. FOY: Okay.
18
MR.
: Thank you, sir.
19
MR. FOY: Yep.
20
MR.
: And thank you for signing
21
Ms. Noel. Alright. So I'm going to sign where
22
it says signature of the Office of the
23
Inspector General Special Agent. Again, this
24
is
I'm printing my name.
25
And Special Agent
, can you fill out the
EFTA00117765
8
1
rest for signature of witness, name of witness,
2
date, time, and place.
3
MR.
: This is Agent
signing
4
on the signature of witness.
5
MR.
: And then do you understand
6
the form as you read and you review?
7
MS. NOEL: Yes, I do.
8
MR.
: Great. Thank you.
9
Before starting the interview, I'd like to
10
place you under oath. Can you please raise
11
your right hand? Do you swear to tell the
12
truth and nothing but the truth during this
13
interview?
14
MS. NOEL: Yes, sir.
15
MR.
: Thank you, Ma'am.
16
Alright. Please let me know if you do not
17
understand any of my questions.
try to
18
rephrase or ask it a different way.
19
MS. NOEL: Okay.
20
MR.
: Alright. So this is
21
something we ask everybody. Do you - what's
22
your current home address?
23
MS. NOEL:
Bronx, New York 10456.
25
MR.
: Thank you. What's your
EFTA00117766
1
date of birth?
2
MS. NOEL:
3
MR.
: And your last four of
4
your Social Security number.
5
MS. NOEL:
6
MR.
: Thank you. What's your
7
highest level of education?
8
MS. NOEL: A bachelor's degree.
9
MR.
: And what was your
10
bachelor's degree in?
11
MS. NOEL: Criminal justice (Indiscernible
12
*00:06:14) in law.
13
MR.
: And where did you receive
14
that degree from?
15
MS. NOEL: John Jay.
16
MR.
:
John Jay in New York
17
City?
18
MS. NOEL: Yes, sir.
19
MR.
: And when did you
20
graduate?
21
MS. NOEL: 2017.
22
MR.
: Thank you. What did you
23
do - just briefly - prior to working with the
24
BOP?
25
MR.
:
Prior to working with the
EFTA00117767
1
BOP I worked at the Post Office.
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MR.
: Okay. What did you do
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there?
4
MS. NOEL: I was a mail handler.
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MR.
: And for how long?
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MS. NOEL: Uh, six months.
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MR.
:
Six months?
8
MS. NOEL: Mm-hmm.
9
MR.
: And that was in 2016,
10
2016? When did you do that?
11
MS. NOEL: Yes.
12
MR.
:
2015 and 2016?
13
MS. NOEL: No. At the post office, I was
14
there 2017.
15
MR.
: Oh 2017.
16
MS. NOEL: '16, '17. Mm-hmm.
17
MR.
: Oh, okay. And do you
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have any military service?
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MS. NOEL: Yes.
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MR.
: And what is that?
21
MS. NOEL: Military service?
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MR.
:
Yeah. Can you tell me
23
what the service?
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MS. NOEL: The Army.
25
MR.
: Army. And how long were
EFTA00117768
1
you in the Army?
2
MS. NOEL: Six years.
3
MR.
:
From when until when?
4
MS. NOEL: 2008 to 2014.
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MR.
: And what did you do with
6
the military?
7
MS. NOEL: I was a patient administrative
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specialist.
9
MR.
: And what is that?
10
MS. NOEL: Patient admin.
11
MR.
:
Patient as in like a
12
hospital?
13
MS. NOEL: Yes.
14
MR.
: Okay. So you worked in a
15
hospital. And what was your rank when you left
16
the military?
17
MS. NOEL: E4 Specialist.
18
MR.
: And did you leave - were
19
you honorably discharged?
20
MS. NOEL: 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. NOEL: Yeah.
EFTA00117769
1
MR. FOY: So would it be 17 into 18?
2
MS. NOEL: 18 yeah.
3
MR.
: Oh you did start with the
4
BOP in '18?
5
MS. NOEL: Yes.
6
MR.
:
Not in '16?
7
MS. NOEL: No. That was an error in the
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. NOEL: '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. NOEL: No.
18
MR.
: No? Okay.
19
MS. NOEL: Hm-mm.
20
MR.
: So you were unemployed at
21
that time?
22
MS. NOEL: No I was going to school.
23
MR.
: Oh that's when you went
24
to John Jay.
25
MS. NOEL: That's when I was going to John
EFTA00117770
1
Jay. Yeah.
2
MR.
: Okay. Thank you. And
3
when was your Enter on Duty Date with BOP?
4
MS. NOEL: June 24, 2018.
5
MR.
: Okay. And when did you
6
graduate from BOP training down at the Federal
7
Law Enforcement Training Center?
8
MS. NOEL: Um, I want to say September of
9
2018.
10
MR.
: Okay. But you did
11
graduate from there?
12
MS. NOEL: Yes, I did.
13
MR.
: That was a correctional
14
officer training?
15
MS. NOEL: Yes.
16
MR.
: Alright. And when and
17
where was your first office assignment with the
18
BOP?
19
MS. NOEL: Say that again?
20
MR.
:
When and where was your
21
first office assignment with the BOP? So where
22
did you start - did you start working in MCC
23
and work there the entire time?
24
MS. NOEL: Yes, sir.
25
MR.
: Okay. And what positions
EFTA00117771
1
have you held with the BOP?
2
MS. NOEL: Correctional officer.
3
MR.
: Okay. The entire time?
4
MS. NOEL: 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. NOEL: Lieutenant
10
MR.
: And do you know how to
11
spell that last name?
12
MS. NOEL:
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 your current cell phone number?
17
MS. NOEL:
18
MR.
: Okay. And how long have
19
you had that number?
20
MS. NOEL: Years.
21
MR.
: Years.
22
MS. NOEL: Mm-hmm.
23
MR.
:
So for a long time.
24
MS. NOEL: Yes.
25
MR.
: And to include in 2019?
EFTA00117772
1
MS. NOEL: Yes.
2
MR.
: Okay. Any other cell
3
phone numbers?
4
MS. NOEL: No.
5
MR.
: Okay. And your current
6
email address?
7
MS. NOEL: Um,
8
MR.
: Okay. Great. And have
9
you had that one also for years?
10
MS. NOEL: Yes.
11
MR.
: Okay. Any others?
12
MS. NOEL: Yes.
13
MR.
:
What are the others?
14
MS. NOEL: Uh,
15
MR.
:
Same?
16
MS. NOEL: Mm-hmm.
17
MR.
:
You've had that for
18
years?
19
MS. NOEL: Yes.
20
MR.
: Okay. Both in 2019?
21
MS. NOEL: Yes.
22
MR.
: Okay. Thank you. Um, do
23
you have any current -? I should have asked
24
this. Are you currently employed right now?
25
MS. NOEL: No.
EFTA00117773
1
MR.
: By no other means?
2
MS. NOEL: No.
3
MR.
: Okay. And when did you
4
last work at the MCC?
5
MS. NOEL: August 10, 2019.
6
MR.
: And was that the same
7
supervisor that you mentioned?
8
MS. NOEL: Yes.
9
MR.
: Okay. Briefly, what
10
training have you attended or conducted during
11
your employment with the BOP? You mentioned
12
the correctional officer training at FLETC.
13
What other trainings have they provided for
14
you?
15
MS. NOEL: Um, their two-week training
16
when you first start at BOP. I forget what
17
it's called. IF training. Yes.
18
MR.
:
IF training?
19
MS. NOEL: Mm-hmm.
20
MR.
: And any other training?
21
MS. NOEL: No.
22
MR.
:
Annual refresher
23
training?
24
MS. NOEL: I have one.
25
MR.
: Okay. So you've gone to
EFTA00117774
17
1
annual. And what about like a SHU training
2
course?
3
MS. NOEL: No.
4
MR.
: Okay. But you did - and
5
this is just - you guys can take a look at this
6
if you would like. This is the training that
7
we have for you. That we asked for your list
8
of training. I'm not asking you to necessarily
9
verify that you've conducted all of it, but it
10
shows the last time you did your annual
11
training was on 3/8/2019 was when you actually
12
completed that week of training.
13
MS. NOEL: Yes.
14
MR.
: Does that sound correct?
15
MS. NOEL: Correct.
16
MR.
: Again, this just goes
17
along with it. It shows -. It shows what the
18
syllabus was as well as the sign-in sheet where
19
Ms. Noel signed in. Again, it's - we're not
20
asking to you -.
21
MS. NOEL: Mm-hmm.
22
MR.
: For - if you want to take
23
a look at it you can. It just shows that you
24
did that training in March of 2019. And
25
anything that I'm going to provide to you, can
EFTA00117775
18
1
you just initial and date? And that's just a
2
way for us to verify that that's what we showed
3
you.
4
MS. NOEL: Okay.
5
MR. FOY: Each page or just to top?
6
MR.
: Nope, just the top of
7
each page.
8
MR. FOY: Okay. Is (Indiscernible
9
*00:12:34)?
10
MR.
: No, you do have that. So
11
just briefly, you don't have to like list off
12
the course syllabus. But what did they cover
13
during that annu7a1 training?
14
MS. NOEL: Um they spoke about different
15
areas like dealing with inmates. They spoke
16
about the issues on the job like dealing with
17
shortages. They spoke about um, basically like
18
mask fitted I remember.
19
MR.
: Mask fitting?
20
MS. NOEL: Mm-hmm.
21
MR.
: Was that back in 2019?
22
People were wearing masks as well?
23
MS. NOEL: No like um.
24
MR. FOY: It's for OC's sprays?
25
MR.
: Oh, for OC spray.
EFTA00117776
1
MS. NOEL: Yes.
2
MR.
: Okay. Did they include
3
things like ethics, standards of conduct?
4
MS. NOEL: Yes.
5
MR.
: Okay. What about like
6
counts and rounds?
7
MS. NOEL: I don't recall them talking
8
about counts and rounds.
9
MR.
: Okay. So did they go
10
over like MCC policies and guidance?
11
MS. NOEL: Yes.
12
MR.
: Okay. And did they ever
13
provide you with the policies and guidelines or
14
did they just speak to you about it?
15
MS. NOEL: For in this training?
16
MR.
: Yes.
17
MS. NOEL: They just spoke about it.
18
MR.
: At another time did they
19
provide you with the polices and guidelines?
20
MS. NOEL: Yeah. It's on like the
21
computer.
22
MR.
: Okay.
23
MS. NOEL: The -.
24
MR.
: Do you have to certify
25
that you've like received it and you reviewed
EFTA00117777
20
1
it? Polices and guidelines?
2
MS. NOEL: 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 June 22nd.
12
MR. FOY: That's part of the same
13
document.
14
MS. NOEL: 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. NOEL: Yes.
23
MR.
: Okay. When would that
24
have been?
25
MS. NOEL: In an IF training.
EFTA00117778
21
1
MR.
: And what does IF stand
2
for?
3
MS. NOEL: Hm.
4
MS.
: You want some clarity? I can
5
tell you --
6
MR.
: Sure.
7
MS.
: -- 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. NOEL: Yes.
12
MR.
: Okay. Great. And then
13
you had mentioned - did you ever receive
14
policies on counts and rounds?
15
MS. NOEL: No.
16
MR.
: I know you said you
17
certified. Do you remember that specific
18
policy - like receiving that?
19
MS. NOEL: 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. NOEL: Not specifically on counts and
EFTA00117779
1
rounds. Just like a general -
2
MR.
: Right.
3
MS. NOEL: 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
MR.
: 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. NOEL: You see how I'm the last one on
17
the bottom of all of them?
18
MR.
: Correct.
19
MS. NOEL: 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. NOEL: No.
24
MR.
: So how come -?
25
MS. NOEL: Because when I came back from
EFTA00117780
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 why.
6
MR.
: Who asked you to do that?
7
MS. NOEL: 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. NOEL: Yes.
12
MR.
: And she didn't' like
13
provide you anything to review?
14
MS. NOEL: No.
15
MR.
: She didn't go over
16
anything with you?
17
MS. NOEL: No.
18
MR.
: Did you discuss this with
19
her - that how can you sign something without
20
being provided the training?
21
MS. NOEL: 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 program review.
25
MR.
: What's her first name?
EFTA00117781
24
1
MS. NOEL:
2
MR.
: And is she a lieutenant?
3
MS. NOEL: 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.
: 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.
: 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.
: 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.
: 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.
EFTA00117782
25
1
MS.
: 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
Absolutely.
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 training?
12
MS. NOEL: Yeah. I didn't.
13
MR.
: You did not receive that
14
training?
15
MS. NOEL: No.
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. NOEL: No because I wasn't there.
21
MR.
: You weren't there?
22
MS. NOEL: I was out on an injury.
23
MR.
: Okay. Can you -? When
24
were you out on the injury? What are the
25
dates?
EFTA00117783
26
1
MS. NOEL: 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. NOEL: Mm-hmm.
6
MR.
: Alright. Thank you for
7
signing the Advisory to Union Representative.
8
MS.
: 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.
:
So I just -.
14
MR.
: I'm sorry, what was your
15
question?
16
MS. NOEL: 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 just one second.
23
MR.
:
You want to step out?
24
MS. NOEL: Mm-hmm.
25
MR.
: Okay. We don't want to
EFTA00117784
27
1
interrupt the interview because we have a lot
2
of questions to get through.
3
MS.
: Mm-hmm.
4
MR.
: If the attorneys ask
5
that, that's not really
But if you would
6
like to -.
7
MS.
: So based on the agreement we
8
just signed, right?
9
MR.
: Sure.
10
MS.
: 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.
let that -
18
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.
: So but that form says
EFTA00117785
1
something contrary to 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.
: I just need clarity then. I
11
need clarity.
12
MR.
: Sure.
13
MS.
: 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.
: 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.
: I'm just asking for clarity
EFTA00117786
1
right. So it was kind of -.
2
MR.
: Sure. Absolutely.
3
MS.
: 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.
: I didn't get to -.
10
MR.
: Sure. Go ahead.
11
MS.
: 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. Noel 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.
: 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.
: I never identified to you that
EFTA00117787
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 gout
6
interview.
7
MS.
: 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.
: Mm-hmm.
13
MR.
: And then
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.
: No it doesn't.
18
MR.
: Okay. So I'm asking you
19
not to interrupt -.
20
MS.
: 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.
: Mm-hmm.
EFTA00117788
31
1
MR.
:
I'm asking you not to
2
interrupt my questions.
3
MS.
: 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.
: 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.
:
Mm-hmm.
14
MR.
: -- she may at any time
15
ask you.
16
MS.
: I got it.
17
MR.
: I'm asking you not to
18
interrupt.
19
MS.
:
I got it.
20
MR.
: These questions are not
21
for you.
22
MS.
:
Mm-hmm.
23
MR.
: They're not directed at
24
you.
25
MS.
:
Mm-hmm.
EFTA00117789
32
1
MR.
: They're directed at Mrs.
2
Noel.
3
MS.
: I'm not answering questions.
4
I was just trying to -. I'm representing her.
5
But I understand that there has been a
6
determination of how I'm able to represent.
7
And so
deal with that in a different
8
venue. You can move forward.
9
MR.
: Alright. Let me read
10
this real quick in this paperwork so that we're
11
not going to have any disputes.
12
MS.
: We don't have to. You don't
13
have to continue. Right. Because I don't want
14
to interrupt. So you can go on ahead and move
15
forward.
16
MR.
: Okay. So it just says
17
that you may not attempt to answer the
18
questions.
19
MS.
: Mm-hmm.
20
MR.
: Or dictate the employee's
21
actions to question or otherwise take charge of
22
proceedings.
23
MS.
: Mm-hmm.
24
MR.
: But again, please feel
25
free to go confer with Ms. Noel.
EFTA00117790
33
1
MS.
: I appreciate it. Thank you.
2
MR.
: I am going to paus 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
Tuesday, June 22, 2021. This is Senior Special
8
Agent
We're resuming the
9
interview. Ms. Noel 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.
: 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.
: Okay.
18
MR.
: Now since we took that
19
break, is there anything else we want to
20
discuss or -?
21
MS.
: No, we can move forward.
22
MS. NOEL: 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?
EFTA00117791
34
1
Alright. DO you know where we left off
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. NOEL: Yes.
9
MR.
: And you were not actually
10
working during that time?
11
MS. NOEL: 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. NOEL: Um I'm not sure. I just know
16
it was March.
17
MR.
: Sometime in March?
18
MS. NOEL: Yes.
19
MR.
: But when you came back,
20
was it around the 26th when they asked you to
21
sign those?
22
MS. NOEL: I came back in June. I don't
23
recall the date exactly.
24
MR.
: Okay.
25
MS. NOEL: But I remember the day I came
EFTA00117792
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 program review.
6
MR.
: Okay.
7
MS. NOEL: So I signed.
8
MR.
: So both trainings when
9
you signed, they didn't actually even provide
10
you anything?
11
MS. NOEL: No.
12
MR.
: Verbally?
13
Electronically? Nothing?
14
MS. NOEL: No.
15
MR.
: Okay. And that was on
16
the date that was signed that that happened?
17
MS. NOEL: 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. NOEL: No.
23
MR.
: After you dated it, she
24
didn't say why did you date it or anything like
25
that?
EFTA00117793
1
MS. NOEL: 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. NOEL: 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. NOEL: 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. NOEL: I don't know.
22
MR.
: Okay. But did you do
23
this per the direction of your supervisor?
24
MS. NOEL: Supervisor. Yes.
25
MR.
: So she - did she
EFTA00117794
1
specifically you must sign this?
2
MS. NOEL: Yes.
3
MR.
: Okay. And again, that
4
was
5
MS. NOEL:
6
MR.
And you said -
7
and I apologize. I don't know if we were
8
interrupted when
Where did you say she is
9
currently?
10
MS. NOEL: She is in Jersey I know. I'm
11
trying to -.
12
MR.
: At the FCI Fort Dix?
13
MS. NOEL: Yes.
14
MR.
: Okay.
15
MR. FOY: Question real quick.
16
MR.
: Absolutely. Do you want
17
a more precise answer to when she was out and
18
when she came back?
19
MR.
:
Uh, so far -.
20
MR. FOY: Because I happen to know --
21
MR.
: Oh sure. If you'd like.
22
MR. FOY: -- the approximate dates.
23
MR.
:
Sure. You can provide
24
that.
25
MR. FOY: And this is based on my review
EFTA00117795
38
1
of discovery and conversations with Ms. Noel.
2
We're looking at about March 15 to June 24-ish.
3
MR.
: Okay.
4
MR. FOY: And I note that the execution
5
was on the 26th. But I think there was some
6
time, you know, it's not like the first minute
7
she was there they had her sign the document.
8
MR.
: Okay.
9
MS. NOEL: Right.
10
MR. FOY: So those are the estimated
11
times. I could be off by a day or two, but
12
MR.
: Perfect.
13
MR. FOY: The 15th of March to June 24th.
14
MR.
: And thank you attorney
15
Foy.
16
MR. FOY: No problem.
17
MR.
: During your time at the
18
MCC, how often were you assigned to the special
19
housing unit also known as the SHU?
20
MS. NOEL: Mm.
21
MR.
: And this is an
22
approximate. I'm not asking you for like exact
23
amount.
24
MS. NOEL: When I came back from the
25
injury, my assignment was the SHU. So from
EFTA00117796
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. NOEL: Yes.
7
MR.
: -- in 2019?
8
MS. NOEL: Yes.
9
MR.
: Okay. Thank you. So
10
know that you said that you didn't - they
11
didn't provide you with the SHU training. Did
12
they provide you with the policies of the SHU?
13
MS. NOEL: No.
14
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 you provided -?
19
MS. NOEL: That's the employee code of
20
conduct.
21
MR.
: Okay.
22
MS. NOEL: 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
EFTA00117797
1
SHU?
2
MS. NOEL: In the SHU there is post
3
orders.
4
MR.
: Oh, okay. So in the SHU
5
there's the post orders.
6
MS. NOEL: Yes.
7
MR.
: And were you provided a
8
copy of that to review?
9
MS. NOEL: Yes.
10
MR.
: And had you reviewed
11
that?
12
MS. NOEL: Yes.
13
MR.
: Okay. And when did you
14
review that?
15
MS. NOEL: When I came back.
16
MR.
:
So sometime in that June
17
18
MS. NOEL: So in June.
19
MR.
: -- or July timeframe?
20
MS. NOEL: Yes.
21
MR.
: Okay. So aside from hose
22
post orders, did you receive any other SHU
23
training?
24
MS. NOEL: No.
25
MR.
:
No. And who was
EFTA00117798
41
1
responsible for making sure that you actually
2
did receive SHU training?
3
MS. NOEL: I don't know.
4
MR.
:
You don't know was that a
5
lieutenant issue --
6
MS. NOEL: I assumed -.
7
MR.
: -- or your first line
8
supervisor?
9
MS. NOEL: 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. NOEL: Lieutenant
15
MR. -:
.
Do you know his
16
first name?
17
MS. NOEL:
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. NOEL: 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 question to her.
25
MS. NOEL: Okay.
EFTA00117799
42
1
MR.
: But if you need to like,
2
yeah, that's fine.
3
MS. NOEL: Mm-hmm. Yeah.
4
MR.
: And if you don't know,
5
that's totally acceptable.
6
MS. NOEL: Yeah because I don't know.
7
MR.
: Okay. No-no, that's a
8
totally acceptable answer.
9
MS. NOEL: Mm-hmm.
10
MR.
:
So yeah, if you know -
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. NOEL: Right.
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. NOEL: 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. NOEL: No.
EFTA00117800
1
MR.
:
No. Okay. Did you
2
receive training on how to conduct rounds?
3
MS. NOEL: Yes.
4
MR.
: And when was that?
5
MS. NOEL: In IF.
6
MR.
: In IF?
7
MS. NOEL: Mm-hmm.
8
MR.
: Okay. And what did it
9
teach you about conducting rounds?
10
MS. NOEL: 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 you confirm the numbers of counting.
14
MR.
: Okay.
15
MS. NOEL: 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. NOEL: I don't recall.
22
MR.
:
You don't recall.
23
MS. NOEL: Mm-hmm.
24
MR.
: Okay. What was your
25
understanding if an inmate was placed, you
EFTA00117801
44
1
know, is suicidal or placed on suicide watch?
2
What was your understanding of how you should
3
treat those inmates?
4
MS. NOEL: If an inmate is placed on
5
suicide watch, I don't deal with them. They go
6
downstairs to suicide watch and they're being
7
watched by other inmates.
8
MR.
: Mm-hmm.
9
MS. NOEL: But and then when they're
10
cleared, they come back to the unit.
11
MR.
: And are you trained - are
12
you supposed to handle them differently when
13
they come back to the unit?
14
MS. NOEL: Uh, no.
15
MR.
: You're not?
16
MS. NOEL: You're not.
17
MR.
: You're not supposed to
18
handle them differently?
19
MS. NOEL: No.
20
MR.
: Not at all?
21
MS. NOEL: Because they're cleared to come
22
back.
23
MR.
: Okay.
24
MS. NOEL: So once you're cleared, you're
25
back to normal.
EFTA00117802
1
MR.
: Okay. And were you
2
assigned to the SHU on August 9th and 10th of
3
2019?
4
MS. NOEL: Yes.
5
MR.
: Do you recall what time
6
you began working on the SHU on August 9th?
7
MS. NOEL: 4:00 to midnight.
8
MR.
: Four to midnight. And
9
then on August 10th? It was?
10
MS. NOEL: Midnight to eight in the
11
morning.
12
MR.
: Okay. You said, again,
13
that was your quarterly bidded post.
14
MS. NOEL: Yes.
15
MR.
: Quarterly assignment.
16
And what were your overall duties and
17
responsibilities when you were assigned to the
18
SHU?
19
MS. NOEL: It varies because I'm new and
20
because I don't know how to run the SHU. I
21
just always rely on the senior person that I'm
22
working with. So even if the roster reflects
23
that I'm the senior officer, because sometimes
24
I'm assigned SHU I, I don't do what SHU I is
25
supposed to do because I don't know how to do
EFTA00117803
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. NOEL: 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 every other day. Count, that's it.
13
MR.
: So rounds and counts are
14
a part of that though?
15
MS. NOEL: 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. NOEL: Mm-hmm.
24
MR.
: And ask you things like
25
who told you that and houses that, you know who
EFTA00117804
1
should have provided you with the proper
2
training and information on how it was
3
technically supposed to be done.
4
MS. NOEL: Mm-hmm.
5
MR.
: And were there any
6
requirements - special requirements - for
7
inmates who are assigned to the SHU?
8
MS. NOEL: I don't know.
9
MR.
: That's fine. Do inmates
10
in the SHU have cellmates?
11
MS. NOEL: Yes.
12
MR.
: Okay. And are they
13
required to have cellmates?
14
MS. NOEL: I don't know.
15
MR.
:
You're not sure?
16
MS. NOEL: Hm-mm.
17
MR.
:
Are there any inmates
18
that don't have cellmates?
19
MS. NOEL: Yes.
20
MR.
: And do you know why they
21
wouldn't have cellmates?
22
MS. NOEL: I don't know.
23
MR.
:
Did you ever - were you
24
ever told it's because another inmate could
25
harm that inmate? Or there were certain
EFTA00117805
1
classifications of an inmate? They never
2
discussed that with you?
3
MS. NOEL: No.
4
MR.
: No? Okay. Did you ever
5
see training on medical emergencies? With
6
inmates?
7
MS. NOEL: 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 you how you would respond?
16
MS. NOEL: Yes. We also need bare
17
training. (Phonetic Sp. *00:35:08)
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. NOEL: That was in IF.
25
MR.
: IF as well?
EFTA00117806
1
MS. NOEL: Mm-hmm.
2
MR.
: Okay. So who is or was
3
Inmate Jeffrey Epstein? Reg number 76318-054?
4
MS. NOEL: Who was he?
5
MR.
:
Who was he? Was he an
6
inmate assigned to the MCC?
7
MS. NOEL: Yes.
8
MR.
:
Was he assigned to the
9
SHU?
10
MS. NOEL: 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. NOEL: 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. NOEL: As in I knew his name but
20
didn't know like what he was there for and who
21
he actually was.
22
MR.
:
So and when you say the
23
other coworker told you, who told you?
24
MS. NOEL:
25
MR. -:
EFTA00117807
50
1
MS. NOEL: Uh-huh.
2
MR.
: And what is
first
3
name?
4
MS. NOEL:
5
MR.
6
MS. NOEL: Mm-hmm.
7
MR.
: And what did he inform
8
you?
9
MS. NOEL: 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. NOEL: Mm. No.
18
MR.
:
Was it obviously it was
19
then prior to August 9th?
20
MS. NOEL: Yes.
21
MR.
: Okay. But you were
22
working in the SHU together?
23
MS. NOEL: Yes.
24
MR.
: Okay. Was Epstein in the
25
SHU when you had that conversation?
EFTA00117808
1
MS. NOEL: Never.
2
MR.
:
No. Was he with his
3
attorneys?
4
MS. NOEL: Mm-hmm.
5
MR.
: Okay. Do you remember
6
anything else about that conversation when he
7
told you about him?
8
MS. NOEL: No. That was it.
9
MR.
:
Did he tell you why he
10
was in?
11
MS. NOEL: No.
12
MR.
:
No? Just that he was
13
famous and in the SHU?
14
MS. NOEL: Mm-hmm.
15
MR.
: Okay. Why was - do you
16
know why Epstein was assigned to the SHU?
17
MS. NOEL: No.
18
MR.
:
Did anyone ever tell you
19
it was because he was a risk for suicide or
20
safety concerns?
21
MS. NOEL: No.
22
MR.
:
No? We're going to get
23
into this a little later, but do you know what
24
the hotlist is?
25
MS. NOEL: Um.... Are those -? I think
EFTA00117809
52
1
the hotlist is like um, how should I say, like
2
inmates that are like -. Inmates that are like
3
4
MR.
: I'm just going to show
5
you this and ask you if you ever received this
6
training either.
7
MS. NOEL: Mm-hmm.
8
MR.
: Or if you've ever seen
9
it. This will spell out exactly what the
10
hotlist is.
11
MS. NOEL: Mm-hmm.
12
MR.
: So this is the MCC New
13
York special housing unit. Slides.
14
(Indiscernible *00:38:01)
15
MR.
: Oh sorry.
16
MR.
: This one is special
17
housing unit management suicide prevention.
18
MS. NOEL: Mm-hmm.
19
MR.
: So can you just have -
20
there's two different tabs here which --
21
MS. NOEL: Mm-hmm.
22
MR.
: -- the first one is going
23
to say
just read it for the record.
24
SHU hotlist identifies inmates with mental
25
health conditions who may become dangerous,
EFTA00117810
53
1
self-destructive, or suicidal when placed into
2
the SHU.
3
MS. NOEL: Hm.
4
MR.
: And that - did you know
5
that?
6
MS. NOEL: No.
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. NOEL: No. I actually thought that
11
the hotlist was something else. Like that was
12
on the computer. No. 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. NOEL: 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 through that. Just basically the
24
MR.
: The two tabs.
25
MR.
: -- two tabs as well as
EFTA00117811
1
the front.
2
MS. NOEL: Mm-hmm.
3
MR.
:
Was that ever provided to
4
you? Did you ever see this?
5
MS. NOEL: Hm-mm. No.
6
MR.
:
No. Okay.
7
MR. FOY: Do you want her to initial?
8
MR.
:
If you could. Yeah.
9
Just so that we can -. You can do it on the
10
top page. No-no. Sorry. The front page.
11
MR.
: ON the front page.
12
MR. FOY: Just the first page.
13
MS. NOEL: Oh.
14
MR.
: And do you know who would
15
have been required to provide you that --
16
MS. NOEL: No.
17
MR.
: -- information? No? And
18
no one discussed that with you?
19
MS. NOEL: No.
20
MR.
:
Did anyone ever discuss
21
the hotlist with you?
22
MS. NOEL: No.
23
MR.
:
Had you ever heard of the
24
term hotlist?
25
MS. NOEL: No.
EFTA00117812
55
1
MR.
: You never even heard the
2
term?
3
MS. NOEL: I thought that hotlist was like
4
inmates that were like,
Like the
5
inmates that were up on 10 South. Like those
6
high inmates. Like El Chapo and those type of
7
inmates.
8
MR.
: Sure.
9
MS. NOEL: That's what I though hotlist
10
was.
11
MR.
: Okay. And because you
12
brought up 10 South, what's 10 South?
13
MS. NOEL: The level above the SHU.
14
MR.
: And is that a specialized
15
unit that are even more secure than the SHU?
16
MS. NOEL: Yes.
17
MR.
: And can you just explain
18
to me a little bit about who goes there? What
19
the cell makeup is? Are there cameras in each
20
individual cell?
21
MS. NOEL: I don't know.
22
MR.
: Oh, you don't know?
23
MS. NOEL: Hm-mm.
24
MR.
: Okay. Are inmates that
25
are in those cells only one inmate per cell?
EFTA00117813
1
MS. NOEL: I think so.
2
MR.
: And are they monitored
3
24/7?
4
MS. NOEL: Yes.
5
MR.
: Okay. But you don't know
6
how they're monitored?
7
MS. NOEL: No.
8
MR.
: Okay. But they're for
9
like a terrorist, high-profile, drugs -.
10
MS. NOEL: Yes.
11
MR.
:
You know?
12
MS. NOEL: Mm-hmm.
13
MR.
: Okay. And that's one
14
floor above where the SHU is?
15
MS. NOEL: Yes.
16
MR.
: Is it kind of in the
17
general location of the SHU though?
18
MS. NOEL: It's upstairs.
19
MR.
: Can you get to it through
20
the SHU?
21
MS. NOEL: Yes.
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?
EFTA00117814
57
1
MS. NOEL: I mean when you come into the
2
SHU, you go up the stairs and it's right there.
3
MR.
: Okay. Can you get to it
4
by other means?
5
MS. NOEL: No.
6
MR.
: So you have to go thought
7
the SHU --
8
MS. NOEL: Go through the SHU.
9
MR.
: -- to get --
10
MS. NOEL: Mm-hmm.
11
MR.
into it? Okay. And
12
how many correctional officers are placed in
13
the 10 South?
14
MS. NOEL: Um, one.
15
MR.
: One?
16
MS. NOEL: Mm-hmm.
17
MR.
: And there's no way in or
18
out other than through the SHU?
19
MS. NOEL: Mm-hmm. Thought the SHU.
20
MR.
: Okay. So when they come
21
in and out, do the officers that are working in
22
the SHU - you know where you are working - are
23
you the ones that have to allow them to get in
24
and out of the SHU?
25
MS. NOEL: Yes.
EFTA00117815
58
1
MR.
: Okay. Do you recall who
2
was working on 10 South on August 9th or 10th?
3
MS. NOEL:
4
MR.
?
5
MS. NOEL: Mm-hmm.
6
MR.
: Okay. Was that August
7
9th or 10th or both?
8
MS. NOEL: I don't know about the 9th but
9
the 10th.
10
MR.
: That's fine. And some of
11
this stuff
probably at some point give you
12
a list of the people so you can refer to like
13
the roster so you don't have to
14
MS. NOEL: Okay.
15
MR.
: You know you can recall
16
that way if you remember that those people were
17
in (Indiscernible *00:41:35).
18
MS. NOEL: Okay.
19
MR.
: But you did say Epstein
20
was assigned to the SHU on August 9th and
21
August 10th, 2019?
22
MS. NOEL: Yes.
23
MR.
: Okay. And he was
24
assigned to the SHU on the days leading up to
25
August 9, 2019?
EFTA00117816
1
MS. NOEL: Yes.
2
MR.
: Okay. Do you know
3
approximately how long Epstein was assigned to
4
the SHU?
5
MS. NOEL: 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. NOEL: When I came back and I was
10
working there?
11
MR.
: Correct.
12
MS. NOEL: Yes.
13
MR.
: Okay.
14
MS. NOEL: Mm-hmm.
15
MR.
: Yes? Okay. So does July
16
and August sound about right? That he was in
17
the SHU?
18
MS. NOEL: 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?
EFTA00117817
60
1
MS. NOEL: 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. NOEL: Yes.
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. NOEL: 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. NOEL: No because I usually do it on
16
the front end.
17
MR.
: Okay.
18
MS. NOEL: 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. NOEL: Yes.
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.?
EFTA00117818
61
1
MS. NOEL: Mm-hmm.
2
MR.
:
Would he eat when he was
3
in the SHU?
4
MS. NOEL: He gets common fare. That's
5
all I know. I don't know if he eats it. But
6
he gets common fare.
7
MR.
:
Would that be something
8
you supplied after 8:00 p.m.?
9
MS. NOEL: When he comes back. Yes.
10
MR.
: Okay. What time is
11
typically feeding time? In the evening?
12
MS. NOEL: Um...after 4:00?
13
MR.
: And so because he was
14
away, does he get -? Would he get an
15
individual tray that was saved for him or
16
provided when he returned?
17
MS. NOEL: Yes.
18
MR.
: Okay. And would you
19
provide that try to him?
20
MS. NOEL: Not necessarily me just
21
whomever.
22
MR.
:
Did you ever?
23
MS. NOEL: Yes.
24
MR.
: Okay. Did you provide
25
that to him on August 9th?
EFTA00117819
62
1
MS. NOEL: Yes.
2
MR.
: You were the one who did?
3
MS. NOEL: Mm-hmm.
4
MR.
: Okay. Did you ever have
5
any communications with Epstein during his stay
6
at the MCC?
7
MS. NOEL: No.
8
MR.
: Never any conversations
9
at all?
10
MS. NOEL: No.
11
MR.
: Okay. Did you even
12
verbal say hello - hello back? Anything like
13
that?
14
MS. NOEL: 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
get into that
22
but was that phone call on August 9, 2019?
23
MS. NOEL: Yes.
24
MR.
: Okay. But when you would
25
provide food or anytime he would come back
EFTA00117820
63
1
after 8:00 p.m. - even when he was coming in or
2
out, you wouldn't even say hello?
3
MS. NOEL: 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. NOEL: It was regular.
10
MR.
: Regular?
11
MS. NOEL: Mm-hmm.
12
MR.
:
Did he seem upset?
13
MS. NOEL: Uh, no.
14
MR.
:
No? Abnormal? Anything
15
out of the ordinary?
16
MS. NOEL: No.
17
MR.
:
No. What were your
18
instructions with regard to Epstein being
19
assigned to the SHU?
20
MS. NOEL: 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. NOEL: No.
25
MR.
: Alright. So even when
EFTA00117821
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. NOEL: No.
7
MR.
: And Lieutenant
, you
8
said was the lieutenant in the SHU, he never
9
told you to pay special attention to Epstein?
10
MS. NOEL: No.
11
MR.
: Okay. Was Epstein
12
assigned any cellmates when he was assigned to
13
the SHU?
14
MS. NOEL: Yes.
15
MR.
: And do you know when he
16
was assigned to the SHU was he always assigned
17
a cellmate?
18
MS. NOEL: Um, I just know he had two
19
cellmates.
20
MR.
: Okay. Two different
21
ones?
22
MS. NOEL: Yes.
23
MR.
: Alright. Did anyone ever
24
speak with you about Epstein needing a cellmate
25
when he was in the SHU?
EFTA00117822
1
MS. NOEL: No.
2
MR.
: No? Who was the officer
3
in charge or the OIC in the SHU?
4
MS. NOEL: Me.
5
MR.
: Um, are you talking about
6
at 12:00 a.m.?
7
MS. NOEL: Yes. On (Indiscernible
8
*00:46:06) -.
9
MR.
: In general, was there
10
like one officer in charge that has like is
11
considered the OIC in the SHU?
12
MS. NOEL: That's what I'm telling you.
13
On paper, it says me. But I don't know how to
14
run the SHU. So I rely on the senior officer.
15
Well on the roster, it says that I was the OIC.
16
MR.
: And -.
17
MS. NOEL: But -.
18
MR.
: I think I'm just not
19
asking the question correctly. I'm not talking
20
about like from 12:00 a.m. to 8:00 a.m. on
21
August 10th. I mean in general. Like in July
22
and August when you were in the SHU, was there
23
one person that was considered the officer in
24
charge? Like how there's one lieutenant of the
25
SHU which was
? Was there also an officer
EFTA00117823
1
in charge of the SHU?
2
MS. NOEL: No.
3
MR.
:
Do you know who - wasn't
4
it
5
MR.
6
MR.
:
Do you know who
7
is?
8
MS. NOEL: Yes.
9
MR.
:
Would he be considered
10
the officer in charge?
11
MS. NOEL: See I don't know. Because on
12
the roster, it can be a different person.
13
MR.
: Okay. Did
have
14
like a desk or a computer area that he always
15
sat in when he was there?
16
MS. NOEL: No.
17
MR.
:
Specifically?
18
MS. NOEL: It's the one that we all sit
19
at.
20
MR.
: But he didn't have one
21
specific location that he would sit at? Like -
22
23
MS. NOEL: No.
24
MR.
:
No, he would sit
25
wherever?
EFTA00117824
67
1
MS. NOEL: 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. NOEL: It was two desks. One this way
6
and one this way.
7
MR.
:
So kind of like an L type
8
of formation?
9
MS. NOEL: Yes. And computers, about
10
three.
11
MR.
: About three computers?
12
MS. NOEL: 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. NOEL: Um, yes.
17
MR.
: Okay. So it's just - it
18
rotates. You can sit at each one?
19
MS. NOEL: 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. NOEL: No.
25
MR.
: Alright. And then
EFTA00117825
1
Am I pronouncing that right?
2
MR.
:
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. NOEL: No.
10
MR.
:
No? What about - do you
11
recall ever seeing a sign posted on Epstein's
12
door?
13
MS. NOEL: No.
14
MR.
:
Saying that he was
15
required to have a cellmate?
16
MS. NOEL: No.
17
MR.
:
No? Okay. Who was
18
Inmate Nicholas Tartaglione, T-A-R-T-A-G-L-I-O-
19
N-I?
20
MS. NOEL: Uh, his first um cellmate that
21
he had.
22
MR.
: Epstein's first cellmate?
23
MS. NOEL: Mm-hmm.
24
MR.
:
Was that his cellmate in
25
July of 2019?
EFTA00117826
69
1
MS. NOEL: I'm not sure about the month,
2
but that was his first cellmate.
3
MR.
: Okay. Do you recall if
4
Tartaglione was already in the SHU or was he
5
brought in specifically to be Epstein's
6
cellmate?
7
MS. NOEL: I don't know that.
8
MR.
: You don't know that?
9
MS. NOEL: No.
10
MR.
: Okay. Are you aware of
11
any issues that took place between Epstein and
12
Tartaglione when they were cellmates?
13
MS. NOEL: 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. NOEL: 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. NOEL: No.
22
MR.
: Are you aware if
23
Tartaglione was his inmate at the time?
24
MS. NOEL: Yes.
25
MR.
: And you said you didn't
EFTA00117827
70
1
have any involvement in that matter though?
2
MS. NOEL: I wasn't at work. Hm-mm.
3
MR.
: Do you know if
4
Tartaglione was removed as Epstein's cellmate?
5
At that point?
6
MS. NOEL: After that he had another
7
cellmate: Reyes.
8
MR.
: And do you know why they
9
changed?
10
MS. NOEL: 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. NOEL: No.
15
MR.
: No. Had you ever heard
16
that Tartaglione attempted to harm Epstein?
17
MS. NOEL: No.
18
MR.
: You didn't even hear that
19
rumor?
20
MS. NOEL: No.
21
MR.
: Okay.
Do you know what
22
was used in the incident when Epstein attempted
23
to - allegedly attempted to take his life?
24
MS. NOEL: No.
25
MR.
: No?
EFTA00117828
1
MS. NOEL: Hm-mm.
2
MR.
:
Do you know if it was
3
like linens or a shirt or any kind of -?
4
MS. NOEL: I don't know.
5
MR.
:
No?
6
MS. NOEL: No.
7
MR.
:
No one discussed that
8
with you?
9
MS. NOEL: No.
10
MR.
: And you didn't ask
11
anybody about it?
12
MS. NOEL: No.
13
MR.
:
Do you know if Epstein
14
was placed on suicide watch or psychological
15
observation?
16
MS. NOEL: I think he was placed after
17
that. But I don't know which one.
18
MR.
: Okay. Is it usually that
19
someone will go on suicide watch for about 24
20
hours? Then after that they would go on what'
21
called psychological observation.
22
MS. NOEL: I'm not sure.
23
MR.
:
You're not sure?
24
MS. NOEL: Hm-mm.
25
MR.
:
Is that done in the SHU
EFTA00117829
1
or elsewhere?
2
MS. NOEL: It's done downstairs.
3
MR.
: And when you say
4
downstairs, what - do you know where?
5
MS. NOEL: Where the suicide watch is or
6
Unit 2.
7
MR.
: Okay. So second floor?
8
MS. NOEL: Mm-hmm.
9
MR.
: And do you know who makes
10
the determination to be able to place someone
11
on suicide watch or psychological observation?
12
MS. NOEL: No.
13
MR.
: No? Okay. Does it sound
14
right that he was placed on suicide watch on or
15
around July 23, 2019? And returned to the SHU
16
on or around July 30, 2019?
17
MS. NOEL: Yes.
18
MR.
: That sounds about right?
19
MS. NOEL: Mm-hmm.
20
MR.
: And at that time, was
21
Epstein assigned another cellmate?
22
MS. NOEL: Yes.
23
MR.
: Who - which cellmate?
24
MS. NOEL: Reyes.
25
MR.
: Reyes?
EFTA00117830
1
MS. NOEL: Mm-hmm.
2
MR.
: On or around July 30th.
3
And who was Inmate Reyes - Efren Reyes?
4
MS. NOEL: His cellmate.
5
MR.
: Do you know anything
6
about him?
7
MS. NOEL: No.
8
MR.
: Okay. But you do know he
9
was his cellmate from that point until about
10
August 9, 2019?
11
MS. NOEL: Yes.
12
MR.
: Okay. And do you know if
13
Inmate Reyes was already in the SHU? Or was he
14
brought in specifically to be Epstein's
15
cellmate?
16
MS. NOEL: I don't know.
17
MR.
: You don't know if he was
18
already in there?
19
MS. NOEL: No.
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
them or do you just kind of -?
24
MS. NOEL: No.
25
MR.
: No? so you don't -. Did
EFTA00117831
74
1
you ever know why people were specifically in
2
the SHU?
3
MS. NOEL: No.
4
MR.
:
No. Do you know why
5
Inmate Reyes was removed from the MCC on August
6
9, 2019?
7
MS. NOEL: No.
8
MR.
:
So even at this point do
9
you know why he was removed?
10
MS. NOEL: 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. NOEL: Oh, no.
15
MR.
:
You don't even know that
16
he was removed?
17
MS. NOEL: 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 today -.
21
MS. NOEL: But for now, I don't know the
22
reason why he was removed.
23
MR.
: Okay.
24
MS. NOEL: No.
25
MR.
: But you do know that he
EFTA00117832
1
was removed?
2
MS. NOEL: Yes.
3
MR.
: And did you know that he
4
was removed on August 9, 2019?
5
MS. NOEL: No.
6
MR.
: So even on August 9th you
7
didn't know that he was removed?
8
MS. NOEL: 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. NOEL: 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. NOEL: No.
20
MR.
: Okay. And do you know if
21
anybody was aware that Reyes was departing the
22
MCC or SHU prior to August 9, 2019?
23
MS. NOEL: I don't know.
24
MR.
: You don't even know that
25
- you know at this point- if anyone was aware?
EFTA00117833
1
MS. NOEL: No.
2
MR.
:
No. Do you know if it
3
was anticipated or not an anticipated move?
4
MS. NOEL: 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
Reyes was removed?
10
MS. NOEL: Never.
11
MR.
:
Never?
12
MS. NOEL: Never.
13
MR.
: Okay. And are you pretty
14
confident about that?
15
MS. NOEL: Yes.
16
MR.
: Okay. Are you aware if
17
Epstein should have been reassigned a cellmate
18
after Inmate Reyes was removed on August 9,
19
2019?
20
MS. NOEL: No.
21
MR.
: So you're not aware:
22
MS. NOEL: No.
23
MR.
:
If he should have been?
24
MS. NOEL: No.
25
MR.
:
So your understanding was
EFTA00117834
77
1
he had cellmates. You just didn't know if one
2
of them was removed that he should be
3
reassigned one?
4
MS. NOEL: Exactly. Mm-hmm.
5
MR.
: Okay. Do you know who
6
was responsible for assigning Epstein a new
7
cellmate?
8
MS. NOEL: I don't know.
9
MR.
: No. Could SHU staff have
10
assigned Epstein a new cellmate? Would you
11
have the authority being - working in the SHU
12
if you knew someone was supposed to have a
13
cellmate? Do you have the authority to place
14
another inmate with that person?
15
MS. NOEL: See I don't know. Because I'm
16
that new.
17
MR.
: Okay.
18
MS. NOEL: So like I said, I rely on the
19
senior person a lot. So I don't know. like
20
that would be a question I would ask them. So
21
I don't know.
22
MR.
: When you were - during
23
your time in the SHU, which you said I guess
24
was from you know late June through August 9th
25
or 10th. Did you ever see that happen before?
EFTA00117835
78
1
SHU staff assign inmates with other inmates?
2
MS. NOEL: When an inmate comes, they
3
place them with another inmate.
4
MR.
: And would they do that
5
based upon their own responsibilities and
6
duties or would someone tell them to do that?
7
MS. NOEL: See I don't know.
8
MR.
: You don't even know?
9
MS. NOEL: Hm-mm.
10
MR.
: Okay. So you saw people
11
be assigned with other ones, but you don't know
12
how --
13
MS. NOEL: No.
14
MR.
: -- that was determined?
15
MS. NOEL: Yeah.
16
MR.
: Okay. So you don't even
17
know if you could have assigned Epstein a new
18
cellmate?
19
MR.
: I don't know.
20
MR.
: Do you know if SHU staff
21
should have assigned? You know like
Or I
22
guess you just answered that. So you said you
23
know. And again, on August 9th, no one
24
notified you that Reyes was gone from the SHU?
25
MS. NOEL: No.
EFTA00117836
79
1
MR.
: And you were working in
2
the SHU.
3
MS. NOEL: Nope.
4
MR.
: Do they typically tell
5
you when an inmate in the SHU is - has left and
6
is not coming back?
7
MS. NOEL: 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. NOEL: 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. NOEL: No.
21
MR.
: Do you have any dealings
22
with them at all?
23
MS. NOEL: No.
24
MR.
: Does the name Chief
25
ring a bell?
EFTA00117837
1
MS. NOEL: No.
2
MR.
:
No? How about staff
3
psychologist
4
MS. NOEL: Mm-hmm. I know her.
5
MR.
: Okay. Who is she?
6
MS. NOEL: She's one of the psychologists.
7
MR.
: Okay. And did you heave
8
dealings with her?
9
MS. NOEL: I had dealings with her after.
10
MR.
:
You after August 10th?
11
MS. NOEL: Like on August 10th she came to
12
the unit.
13
MR.
: Okay. Prior to August
14
10th did you have any dealings with her?
15
MS. NOEL: No not really.
16
MR.
:
No. What about a
17
18
MS. NOEL: Yes I know her.
19
MR.
: And who is she?
20
MS. NOEL: A psychologist.
21
MR.
:
Did you have any dealings
22
with her?
23
MS. NOEL: No.
24
MR.
:
So only with
25
EFTA00117838
1
MS. NOEL: Yes but she came after the
2
incident.
3
MR.
: But what was your dealing
4
with her after the incident?
5
MS. NOEL: 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. NOEL: No.
10
MR.
: No? So it was specific
11
to you?
12
MS. NOEL: Yes.
13
MR.
: Okay. Are you aware was
14
Epstein meeting with staff psychologists during
15
his stay at the MCC?
16
MS. NOEL: No.
17
MR.
: No. Would have he met
18
with them I guess during suicide watch and
19
psychological obviously?
20
MS. NOEL: Yes.
21
MR.
: Okay. So that. Did you
22
know that he did meet with them then?
23
MS. NOEL: I don't know if he did, but I'm
24
going to assume he did.
25
MR.
: Okay. But you do know
EFTA00117839
1
that he was placed on suicide watch?
2
MS. NOEL: 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. NOEL: No.
8
MR.
: Or that he was - needed
9
to have a cellmate at all times.
10
MS. NOEL: No.
11
MR.
: Or that you needed to
12
watch him?
13
MS. NOEL: No.
14
MR.
: Do you know who placed
15
him on suicide watch?
16
MS. NOEL: 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
EFTA00117840
1
correctional officer training at FLETC. Did
2
they discuss suicide?
3
MS. NOEL: 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 attempting to harm himself.
15
MS. NOEL: No.
16
MR.
: We should place him with
17
another cellmate.
18
MS. NOEL: No.
19
MR.
: That we should watch him.
20
MS. NOEL: No.
21
MR.
: Or make sure that he
22
hasn't harmed himself.
23
MS. NOEL: No.
24
MR.
: Or pay special close
25
attention to that individual.
EFTA00117841
1
MS. NOEL: No.
2
MR.
: You said suicide watch
3
though, that is on the second floor?
4
MS. NOEL: 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. NOEL: No.
10
MR.
: Do you know the
11
difference between suicide watch and
12
psychological observation?
13
MS. NOEL: No.
14
MR.
: No? Are they both done
15
in - on the second floor?
16
MS. NOEL: Yes.
17
MR.
: Okay. But you don't even
18
know what that is?
19
MS. NOEL: No.
20
MR.
: Did you know that Epstein
21
was also on psychological observation?
22
MS. NOEL: No.
23
MR.
: No? Just suicide watch?
24
MS. NOEL: Mm-hmm.
25
MR.
: And to you it's one and
EFTA00117842
1
the same thing?
2
MS. NOEL: Yes.
3
MR.
: Okay.
4
MS. NOEL: Mm-hmm.
5
MR.
: And I did ask about
6
suicide watch, but do you know who placed
7
Epstein on psychological observation?
8
MS. NOEL: No.
9
MR.
:
No? And you don't know -
10
. Are inmates that come from psychological
11
observation required to have a cellmate?
12
MS. NOEL: No.
13
MR.
:
You don't know?
14
MS. NOEL: I don't know.
15
MR.
:
So were you aware of any
16
inmates that are in the SHU that were on
17
suicide watch - came from suicide watch and
18
psychological observation?
19
MS. NOEL: No.
20
MR.
: And again, that hotlist.
21
Did you say that you do remember there being
22
one?
23
MS. NOEL: No.
24
MR.
:
In the SHU?
25
MS. NOEL: No.
EFTA00117843
1
MR.
: So you don't even
2
remember there being a hotlist in the SHU?
3
MS. NOEL: No.
4
MR.
: Would you like look
5
around at the boards and look at the walls and
6
see different things?
7
MS. NOEL: There is no list.
8
MR.
: No? There's no like --
9
MS. NOEL: No.
10
MR.
: -- where the post orders
11
are - where are they kept as -.
12
MS. NOEL: It's on the desk.
13
MR.
: Was there also on the
14
desk something called the hotlist?
15
MS. NOEL: 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. NOEL: There's a roster.
20
MR.
: A roster like of all the
21
inmates in the SHU? Total?
22
MS. NOEL: 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 -
EFTA00117844
1
seeing like one list where there's special
2
people assigned to that list called the
3
hotlist?
4
MS. NOEL: No.
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. NOEL: Yes.
9
MR.
: Did any staff
10
psychologist visit the SHU?
11
MS. NOEL: Yes.
12
MR.
: Did they ever visit
13
Epstein in the SHU?
14
MS. NOEL: No.
15
MR.
: No? What time typically
16
would they come to the SHU when they would
17
visit?
18
MS. NOEL: Um like after -. When I worked
19
the 8:00 to 4:00. I don't know. Sometime in
20
the day like maybe 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. NOEL: Because he wasn't there.
25
MR.
: Do you know if they ever
EFTA00117845
88
1
visited him when he was with his attorneys?
2
MS. NOEL: 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. NOEL: 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. NOEL: 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 20, 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
EFTA00117846
1
assigned?
2
MS. NOEL: No.
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. NOEL: No.
8
MR.
: Do you know why other
9
employees would have received this and you
10
wouldn't have?
11
MS. NOEL: 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. NOEL: That's the lieutenant.
22
MR.
: Do you recognize
23
Lieutenant
on there?
24
MS. NOEL: Yes. But this is not sent
25
This is not the workers.
EFTA00117847
90
1
MR.
:
None of those people were
2
assigned to the SHU? Towards the bottom of
3
that?
4
MS. NOEL: No.
5
MR.
:
No? Okay. So just the
6
only person that you see on that is Lieutenant
7
8
MS. NOEL: Lieutenant
9
MR.
: And he never discussed
10
that matter with you?
11
MS. NOEL: No.
12
MR.
: If you don't mind, could
13
you initial and date it?
14
MS. NOEL: I initialed.
15
MR.
: And date.
16
MS. NOEL: Ten....
17
MR.
: The 22nd. 6/22/21.
18
MR.
: Agent
just has a
19
couple questions on that.
20
MR.
:
Here.
21
MR.
:
During your time in the SHU -
22
23
MS. NOEL: Mm-hmm.
24
MR.
:
Did any new inmates come in
25
during your shift?
EFTA00117848
1
MS. NOEL: On that specific day or in
2
general?
3
MR.
:
Yeah. From June to August.
4
When you worked in the SHU. Did the SHU
5
receive any new inmates?
6
MS. NOEL: Yeah.
7
MR.
:
When they came in, how did
8
you assign the inmates?
9
MS. NOEL: I didn't. The senior officer
10
did.
11
MR.
: Senior officer. Did you see
12
them assign inmates? Assign a cell to them.
13
MS. NOEL: Like they put them in a cell?
14
Yes.
15
MR.
:
Were they ever put by
16
themselves?
17
MS. NOEL: I don't remember.
18
MR.
:
Do you recall any inmates
19
being placed by themselves in the SHU?
20
MS. NOEL: I think there was one inmate by
21
himself.
22
MR.
: Any reason why he was placed
23
by himself?
24
MS. NOEL: I don't know.
25
MR.
:
So of all the inmates,
EFTA00117849
1
there was only one that was by themselves?
2
MS. NOEL: I think it was an inmate by
3
himself on G tier.
4
MR.
: Now you mentioned that day
5
were you on August 9th you were notified that
6
Efren Reyes 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. NOEL: No.
11
MR.
: How would you find out if the
12
inmate was supposed to eb in the SHU or not?
13
MS. NOEL: How would I find out if an
14
inmate is supposed -?
15
MR.
: Let's say the morning
16
started.
17
MS. NOEL: 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. NOEL: When I count and he's not
24
there.
25
MR.
: You wouldn't be notified any
EFTA00117850
1
other way?
2
MS. NOEL: 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. NOEL: No.
8
MR.
: -- when he was there?
9
No? Who was the MCC warden in July and August
10
of 2019?
11
MS. NOEL:
12
MR.
: Is that
13
MS. NOEL: 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. NOEL: None.
19
MR.
: None. And he never
20
provided you special instructions with regard
21
to Epstein?
22
MS. NOEL: No.
23
MR.
: Did the warden ever tell
24
you that Epstein was required to have a
25
cellmate?
EFTA00117851
94
1
MS. NOEL: No.
2
MR.
:
Did the warden ever visit
3
the SHU during Epstein's stay at the MCC?
4
MS. NOEL: I don't know. Not on my shift.
5
MR.
:
Not during your shift?
6
MS. NOEL: No.
7
MR.
:
No? Okay. Do you know
8
if the warden ever met with Epstein during his
9
stay?
10
MS. NOEL: I don't know.
11
MR.
:
Who were the MCC
12
associate wardens in August of 2019?
13
MS. NOEL: Um, associate warden was
14
15
MR. -:
16
MS. NOEL: Yes.
17
MR.
: Anyone else? That you're
18
aware of?
19
MS. NOEL: No.
20
MR.
: Okay. And what
21
communications did you have with
22
or the other AW with regard to
23
Epstein being housed withing the MCC or the MCC
24
SHU?
25
MS. NOEL: None.
EFTA00117852
95
1
MR.
:
None? Would you have
2
communications with any of the AWs?
3
MS. NOEL: No.
4
MR.
:
No? So did you not even
5
ever speak with them?
6
MS. NOEL: Not in the SHU.
7
MR.
:
Not in the SHU. When
8
would you speak with them?
9
MS. NOEL: On the regular housing unit
10
when they made rounds.
11
MR.
:
So in July and August did
12
you ever speak with them that you recall?
13
MS. NOEL: No.
14
MR.
:
No. So not since you
15
were assigned to the SHU at the end of June.
16
MS. NOEL: Mm-hmm.
17
MR.
: Okay. What about the
18
warden? Is that the same thing?
19
MS. NOEL: Mm-hmm.
20
MR.
:
No communications?
21
MR. FOY: Don't know.
22
MS. NOEL: No.
23
MR.
:
No?
24
MR. FOY: Don't answer if you don't know.
25
MS. NOEL: Okay.
EFTA00117853
96
1
MR. FOY: Okay?
2
MR.
:
Do you know if any of the
3
AWs ever visited the SHU during Epstein's stay?
4
MS. NOEL: I don't know.
5
MR.
:
You don't know. Not
6
during your watch though?
7
MS. NOEL: No.
8
MR.
: Okay. Do you know if any
9
of the AWs ever met with Epstein during his
10
stay at the MCC?
11
MS. NOEL: I don't know.
12
MR.
:
You don't know. But not
13
when you were in the SHU?
14
MS. NOEL: Not on my shift.
15
MR.
: Who was the MCC captain
16
in July and August of 2019?
17
MS. NOEL: Captain
18
MR.
:
Is that
19
MS. NOEL: Yes.
20
MR.
: Okay. And what
21
communications did you have with Captain
22
with regard to Epstein being housed within the
23
MCC or the MCC SHU?
24
MS. NOEL: None.
25
MR.
:
None? And did he ever
EFTA00117854
1
provide you with special instructions with
2
regards to Epstein?
3
MS. NOEL: No.
4
MR.
: Captain
5
MS. NOEL: No.
6
MR.
: Did the captain ever tell
7
you that Epstein was required to have a
8
celimate?
9
MS. NOEL: No.
10
MR.
: In the SHU? No? Did the
11
captain ever visit the SHU during Epstein stay
12
at the MCC?
13
MS. NOEL: 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. NOEL: 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
EFTA00117855
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. NOEL: I don't recall.
9
MR.
: You don't recall.
10
MS. NOEL: No.
11
MR.
: Okay. So he wasn't
12
there. So if he's not there, who has oversight
13
over the SHU?
14
MS. NOEL: I don't know.
15
MR.
: Do you - would it be the
16
operations lieutenant or the activities
17
lieutenant?
18
MS. NOEL: 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. NOEL: No.
23
MR.
: Would anybody if
24
Lieutenant
wasn't there check in with you?
25
MS. NOEL: I mean the other lieutenant
EFTA00117856
1
would make a round.
2
MR.
:
What other lieutenant
3
would that be?
4
MS. NOEL: Whoever was on. You mean that
5
day?
6
MR.
:
Yes. On August 9th and
7
August 10th. I'm wondering who had
8
responsibility of the SHU? If Lieutenant
9
wasn't there. He was the SHU lieutenant.
10
MS. NOEL: In the daytime, it was a
11
regular officer acting.
12
MR.
: Okay.
13
MS. NOEL: From the when I was on at 4:00
14
to 12:00.
15
MR.
: Okay.
16
MS. NOEL: And then from midnight it was
17
Lieutenant
MR.
: Okay. So would that
19
other person that you're referring to. Do you
20
know who that was?
21
MS. NOEL: The acting? That was acting?
22
MR.
: Acting.
23
MS. NOEL:
24
MR.
:
SOS
25
MS. NOEL: Say that again.
EFTA00117857
100
1
MR.
: Was it SOS
2
Senior Officer Specialist
3
MS. NOEL: Yes.
4
MR.
: Is that
5
MS. NOEL: (Indiscernible *01:11:25)
6
MR.
: I might be saying that
7
name wrong.
8
MS. NOEL: I'm not sure of her first name,
9
but -.
10
MR.
: That's fine. Okay. So
11
those are the two that you remember:
and
13
MS. NOEL: Was Acting in the day. Yes.
14
MR.
: Okay. What about by
15
looking at that. Would the - do you see where
16
it says
17
MS. NOEL: Yes.
18
MR.
: Would that person have
19
oversight over the SHU from - does it say that
20
that person was the operations lieutenant?
21
MS. NOEL: That's what it says here but
22
didn't see Lieutenant
23
MR.
: And do you know as being
24
the operations lieutenant would they be
25
responsible for overseeing the SHU? If
EFTA00117858
101
1
MS. NOEL: I don't know.
2
MR.
:
You don't even know that?
3
Okay. So you don't know if after -. Is it
4
true that after
replaced him
5
as the operations lieutenant?
6
MS. NOEL: According to this, yes.
7
MR.
: Okay. And you're not
8
aware that that person would have oversight
9
over the SHU?
10
MS. NOEL: I don't know.
11
MR.
:
You don't know. No one
12
ever talked to you about
isn't there. Who
13
should you go to if there are any problems or
14
who would check in with you?
15
MS. NOEL: No. I would call downstairs to
16
the lieutenant's office.
17
MR.
: And would you just talk
18
to whoever answered?
19
MS. NOEL: Yes.
20
MR.
:
And who would sit in the
21
lieutenant's office?
22
MS. NOEL: The lieutenants.
23
MR.
: All of them?
24
MS. NOEL: Yes.
25
MR.
:
So it wouldn't be like
EFTA00117859
102
1
the operations lieutenant and the activities
2
lieutenant?
3
MS. NOEL: No. All the lieutenants.
4
MR.
: Okay. They all just sit
5
in there together?
6
MS. NOEL: Mm-hmm.
7
MR.
:
Not one of them
8
specifically answers the phone though? Just -?
9
MS. NOEL: No. Anybody.
10
MR.
: Okay. Do you remember -?
11
Again, Lieutenant
was reportedly off on
12
August 9th and August 10th.
13
MS. NOEL: Mm-hmm.
14
MR.
:
Do you recall ever seeing
15
him on August 9th or August 10th?
16
MS. NOEL: Hm-mm.
17
MR.
:
Where would Lieutenant
18
sit? When he was at the MCC?
19
MS. NOEL: Upstairs.
20
MR.
:
When you say upstairs,
21
upstairs where?
22
MS. NOEL: There's an office right next to
23
10 South upstairs there.
24
MR.
:
Within the SHU?
25
MS. NOEL: Yes.
EFTA00117860
1
MR.
: Okay. So he was
2
physically in the SHU?
3
MS. NOEL: Yes.
4
MR.
: Alright. So when he
5
wasn't there, would any other lieutenant come
6
visit the SHU?
7
MS. NOEL: 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. NOEL: I don't know.
14
MR.
: You don't know. you just
15
knew that they were a lieutenant.
16
MS. NOEL: 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. NOEL: No. Just call the lieutenant's
24
office.
25
MR.
: Just call the
EFTA00117861
104
1
lieutenant's office.
2
MS. NOEL: Yes.
3
MR.
: Okay. And I believe you
4
answered this, but did you have any
5
communications with Lieutenant
regarding
6
Epstein at all?
7
MS. NOEL: No.
8
MR.
: So he never provided you
9
any special instructions with Epstein?
10
MS. NOEL: No.
11
MR.
: And you never -
12
Lieutenant
never told you Epstein was
13
required to have a cellmate in the SHU?
14
MS. NOEL: No.
15
MR.
: Do you know who
16
Operations Lieutenant Carlos
was from
17
August 9th? Do you know that individual?
18
MS. NOEL: Yes.
19
MR.
: But as the operations
20
lieutenant, you don't know that he was
21
responsible for overseeing the SHU on August 9,
22
2019?
23
MS. NOEL: I don't know.
24
MR.
: Did you have any
25
communications with Lieutenant
regarding
EFTA00117862
105
1
Epstein being housed at the MCC or in the SHU?
2
MS. NOEL: No.
3
MR.
: He never did - did
4
Lieutenant
ever provide you with special
5
instructions with regard to Epstein?
6
MS. NOEL: No.
7
MR.
: Did Lieutenant
ever
8
tell you that Epstein was required to have a
9
cellmate while he was assigned to the SHU?
10
MS. NOEL: No. I'm going to ask you these
11
questions with a couple people. So I just want
12
you to like really think about those people and
13
they're going to be repetitive.
14
MR.
: Okay.
15
MR.
: Because I know you can
16
just simply say I didn't have any
17
communications. But I want you to really think
18
about that individual and any communications
19
you had with that person with regard to Epstein
20
and the SHU and your assignments. Okay?
21
MS. NOEL: Okay.
22
MR.
: Who is Lieutenant David
23
Medina?
24
MS. NOEL: A lieutenant.
25
MR.
: A lieutenant. By looking
EFTA00117863
106
1
at that roster, was he on it on August 9th?
2
MS. NOEL: No.
3
MR.
: No. Do you know if he
4
was physically present at -? Do you recall if
5
he was physically present on August 9th?
6
MS. NOEL: I don't recall.
7
MR.
: He was reportedly on sick
8
leave. I just want to make sure that he wasn't
9
there.
10
MS. NOEL: Okay.
11
MR.
: So you don't recall
12
having any communications with him?
13
MS. NOEL: No.
14
MR.
: Alright. And did
15
Lieutenant Medina ever provide you with special
16
instructions with regard to Epstein?
17
MS. NOEL: No.
18
MR.
: No. Did Lieutenant
19
Medina ever tell you that Epstein was required
20
to have a cellmate while he was assigned to the
21
SHU?
22
MS. NOEL: No.
23
MR.
: And then this is who you
24
were just referring to. Who was senior officer
25
specialist
EFTA00117864
1
MS. NOEL: An officer.
2
MR.
: And on August 9th, was
3
she the acting lieutenant responsible for
4
overseeing the SHU?
5
MS. NOEL: I don't know if she was
6
responsible for overseeing the SHU, but I know
7
she was the acting lieutenant. I don't know
8
for the whole building.
9
MR.
: But you said she --
10
MS. NOEL: But she -.
11
MR.
: -- conducted a round?
12
MS. NOEL: She did.
13
MR.
: Okay. So if she
14
conducted a round, would that lead you to
15
believe that she was probably -? Hey,
16
Lieutenant
isn't there, she's conducting
17
the round here, she's probably got oversight
18
over the SHU?
19
MS. NOEL: I don't know. It could be
20
another lieutenant also. I don't know.
21
MR.
: Okay. Did she visit the
22
SHU on August 9, 2019?
23
MS. NOEL: Yeah, she did.
24
MR.
: And what time was she on
25
duty on August 9th? By looking at that roster.
EFTA00117865
108
1
Can you tell?
2
MS. NOEL: It says 8:00 to 4:00.
3
MR.
: I think it would just be
4
on that first page.
5
MR.
: Is that August 10th or 9th?
6
MS. NOEL: This is 9th.
7
MR.
: It just says 8:00 to
8
4:00?
9
MS. NOEL: Yes.
10
MR.
: Can you check on the
11
lieutenants column up top?
12
MS. NOEL: (Indiscernible *01:17:34)
13
MR.
: Is there a name?
14
MR.
:
It should be under
15
activities lieutenant.
16
MS. NOEL: 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. NOEL: No.
24
MR.
:
No? And did she provide
25
you with any special instructions with regard
EFTA00117866
109
1
to Epstein?
2
MS. NOEL: No.
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. NOEL: 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. NOEL:
and
14
MR.
:
Just
and
15
When you arrived to the SHU was anybody else
16
there? Do you recall replacing?
17
MS. NOEL: I don't remember who I
18
relieved.
19
MR.
:
Do you know a
20
? (Phonetic Sp. *01:18:40)
21
MR.
22
MS. NOEL:
23
MR. -•
24
MS. NOEL: Yes.
25
MR.
: Alright. And
EFTA00117867
110
1
2
MS. NOEL: Yes.
3
MR.
: Were either of them in
4
the SHU on August 9, 2019?
5
MS. NOEL:
6
MR.
7
MS. NOEL: Mm-hmm.
8
MR.
: But while you were there,
9
not
10
MS. NOEL: I don't remember. But I
11
remember
because he spoke to me.
12
MR.
: Okay. So
13
and
are the people that you
14
remember that were in the SHU?
15
MS. NOEL: Yes.
16
MR.
: Okay. And you said that
17
you remember
speaking with you?
18
MS. NOEL: Yes.
19
MR.
: About what?
20
MS. NOEL: 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. NOEL: So because he -.
EFTA00117868
1
MR.
: Just walk me through.
2
This one is one of those ones I'll ask you to
3
explain a little more. Can you just from eh
4
start of the conversation to what you did with
5
Epstein to the finish.
6
MS. NOEL: Okay. So Epstein stays in
7
attorney conference all day. So I guess when
8
it's time to use the phone, he's not present.
9
So when he came upstairs,
gave him the
10
phone in the shower to use the phone. And then
11
left. He called on the phone. I
12
happened to answer and he said, "Hey can you
13
take the phone from Epstein? Because the time
14
is up." So -.
15
MR.
: So when he gave him the
16
phone he left and no one else was present with
17
Epstein when he was on the phone?
18
MS. NOEL: No. Nobody was there.
19
MR.
: Do you know that to be a
20
legitimate practice?
21
MS. NOEL: I mean it's in the SHU, so
22
yeah.
23
MR.
: So is no one supposed to
24
be - because is the SHU a recorded line?
25
MS. NOEL: I don't know.
EFTA00117869
112
1
MR.
:
So do you know if someone
2
is calling from a non-recorded line, are you
3
supposed to take notes of that call?
4
MS. NOEL: I don't know.
5
MR.
:
Do you know if you're
6
supposed to log the telephone call in any kind
7
of a logbook?
8
MS. NOEL: No.
9
MR.
: Okay. So your
10
understanding is
gave him - plugged in
11
the line, gave him the phone, and then left?
12
MS. NOEL: Yes.
13
MR.
:
No one was there to
14
monitor?
15
MR.
: Okay. So he -.
16
MS. NOEL: We were in the SHU, but nobody
17
was monitoring him.
18
MR.
:
How far away from you was
19
he when he was making this call?
20
MS. NOEL: He was on G tier. And like
21
that's far from the desk.
22
MR.
: Approximately - do you
23
know how to like -?
24
MS. NOEL: I don't know.
25
MR.
: Is it like from here to
EFTA00117870
113
1
like that fire extinguisher over there? Or is
2
it further?
3
MS. NOEL: No. Maybe from the wall by the
4
EC to over there.
5
MR.
: Okay. So approximately
6
25 feet?
7
MS. NOEL: Mm-hmm.
8
MR.
: Could you hear his
9
conversation from there?
10
MS. NOEL: No.
11
MR.
: And were you asked to
12
listen to his conversation?
13
MS. NOEL: No.
14
MR.
: Prior to placing the
15
call, did
speak to you at all?
16
MS. NOEL: No.
17
MR.
: So just after he placed
18
the call, he called you and what did he say?
19
MS. NOEL: 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 phone?
23
MS. NOEL: No.
24
MR.
: Were you watching him
25
while he was on that phone?
EFTA00117871
1_
1
MS. NOEL: No.
2
MR.
: Was it abnormal for an
3
inmate to be out by himself on the phone in the
4
SHU?
5
MS. NOEL: No.
6
MR.
: So they can just freely -
7
that's not an abnormal circumstance?
8
MS. NOEL: 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. NOEL: 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. NOEL: Yes.
20
MR.
: -- in the cell? So he
21
was in the shower area. Was he by himself?
22
MS. NOEL: Yes.
23
MR.
: Were showers running?
24
MS. NOEL: No.
25
MR.
: He was just - he placed
EFTA00117872
115
1
the call in the shower, cell c