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1
SWORN STATEMENT
OF
TOVA NOEL
OIG CASE #:
2019-010614
JUNE 21, 2021
EFTA00118226
2
APPEARANCES:
BY:
BY:
WITNESS:
TOVA NOEL
JASON FOY, ESQ.
EFTA00118227
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.
9 Department of Justice Office of the Inspector
10 General investigation. Today's date is June
11 22, 2021 and the time is 10:09 a.m. This
12 interview is being conducted at - what is the
13 location - 15 -?
14
MR. FOY:
15
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
23 DOJ OIG Special Agent -;
24 Correctional officer Tova Noel; Ms. Noel's
25 attorneys, Jason Foy, and Eric Sarraga of Foy &
EFTA00118228
4
1 Seplowitz, LLC; as well as union representative
2
of the Local 3149 with the BOP.
3 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
, M-A-T-U-L-I-W-I-C-Z.
9
MR.
: I am DOJ OIG Special Agent
10
D-A-N-I-I-L.
11
MS. NOEL: I'm Tova Noel, N-O-I-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.
, G-R-I-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
24 reporting false information. This is an
25 official DOJ OIG investigation and you are
EFTA00118229
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
14 provide information as part of an investigation
15 being conducted by the Office of the Inspector
16 General. This investigation is being conducted
17 pursuant to the Inspector General Act of 1978
18 as amended. This investigation pertains to
19 your alleged misconduct to include allegations
20 of false statements, job performance failure,
21 security failure, and reporting false
22 information. This is a voluntary interview.
23 Accordingly, you do not have to answer
24 questions. No disciplinary action will be
25 taken against you if you choose not to answer
EFTA00118230
6
1 questions. Any statement you furnish may be
2 used as evidence in any future criminal
3 proceeding or agency disciplinary proceedings
4 or both. And of course, there's the DPA
5 waiver. I understand the warnings and
6 assurances stated above and I am willing to
7 make a statement or answer questions. No
8 promises or threats have been made to me and no
9 pressure or coercion of any kind has been used
10 against me. You can take a look at this and
11 review it. If you agree, there's a section
12 there for your name and signature.
13
MR. FOY: So the only thing that this is
14 actually subject to is the deferred prosecution
15 agreement.
16
MR.
: Well so there's the
17 agreement that you had, so that's the part
18 where I'm talking about the specific part where
19 it says criminal.
20
MR. FOY: Mm-hmm.
21
MR.
: That's something I think
22 that was worked out with the U.S. Attorney's
23 Office --
24
MR. FOY: Right. Exactly.
25
MR.
: So -.
EFTA00118231
7
1
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
EFTA00118232
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. I'll 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:
24
25
MR.
: Thank you. What's your
EFTA00118233
9
1
2
3
4
date of birth?
MS. NOEL:
MR.
: And your last four of
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
MS. NOEL: Prior to working with the BOP I
EFTA00118234
10
1 worked at the Post Office.
2
MR.
: Okay. What did you do
3 there?
4
MS. NOEL: I was a mail handler.
5
MR.
: And for how long?
6
MS. NOEL: Uh, six months.
7
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
18 have any military service?
19
MS. NOEL: Yes.
20
MR.
: And what is that?
21
MS. NOEL: Military service?
22
MR.
:
Yeah. Can you tell me
23 what the service?
24
MS. NOEL: The Army.
25
MR.
: Army. And how long were
EFTA00118235
11
1 you in the Army?
2
MS. NOEL: Six years.
3
MR.
: From when until when?
4
MS. NOEL: 2008 to 2014.
5
MR.
: And what did you do with
6 the military?
7
MS. NOEL: I was a patient administrative
8 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.
EFTA00118236
12
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
EFTA00118237
13
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
EFTA00118238
14
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:
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?
EFTA00118239
15
1
MS. NOEL: Yes.
2
MR.
: Okay. Any other cell
3 phone numbers?
4
MS. NOEL: No.
5
MR.
6 email address?
7
MS. NOEL: Um,
8
MR.
Okay. And your current
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.
EFTA00118240
16
1
MR.
2
MS. NOEL: No.
3
MR.
By no other means?
: 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
EFTA00118241
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
EFTA00118242
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 annual 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.
: It's for OC's sprays?
25
MR.
: Oh, for OC spray.
EFTA00118243
19
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
EFTA00118244
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.
EFTA00118245
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
EFTA00118246
22
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
MS. NOEL: 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
EFTA00118247
23
1 an injury, the lieutenant asked me to sign
2 because when they had program review, they need
3 to show that I received the training. But I
4 never did. She just asked me to sign. That's
5 why I wonder why.
6
MR.
: Who asked you to do that?
7
MS. NOEL:
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?
EFTA00118248
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. •
23 copy of it?
24
MR.
: Will you be able to give me a
: Yes. I think it says on
25 there that we will forward you a copy of that.
EFTA00118249
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?
EFTA00118250
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
EFTA00118251
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. We'll let that -
18 we'll do that this time, but if this continues
19 to happen, I'm going to have to give you a
20 different form that says you can stay here
21 voluntarily if you want, but we're going to ask
22 you not to interrupt the interview. And if you
23 do, then we're going to ask her if she wants to
24 continue with the interview without you.
25
MS.
: So but that form says
EFTA00118252
28
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
EFTA00118253
29
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
EFTA00118254
30
1 I would be informing her of anything.
2
MR.
: Okay. But so yes. To
3 answer your question, you can be here to
4 represent here if she's asking you for the
5 information. I don't want you stopping our
6 interview.
7
MS.
: 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 we'll have to
14 proceed from there. And then there's a
15 different form to provide you. So does that
16 make sense?
17
MS.
: 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.
EFTA00118255
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.
EFTA00118256
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 I'll 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.
EFTA00118257
33
1
MS.
: I appreciate it. Thank you.
2
MR.
: I am going to pause the
3 recording. It is currently 10:32 a.m.
4 [Whereupon, the above-entitled matter went off
5 the record and went back on the record.] Okay.
6 The recorder is back on. It is 10:38 a.m.
7 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. FOY: 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?
EFTA00118258
34
1 Alright. DO you know where we left off Lyeson?
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
EFTA00118259
35
1 into work and the lieutenant asked me to go see
2
. 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?
EFTA00118260
36
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
EFTA00118261
37
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
EFTA00118262
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
EFTA00118263
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 I
10 know that you said that you didn't - they
11 didn't provide you with the SHU training. Did
12 they provide you with the policies of the SHU?
13
MS. NOEL: No.
14
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
EFTA00118264
40
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
EFTA00118265
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:
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.
EFTA00118266
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 - if
11 you don't know something or you do know
12 something, that's great. You don't really want
13 to ask other people for the answers.
14
MS. 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.
EFTA00118267
43
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
EFTA00118268
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.
EFTA00118269
45
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 1, I don't do what SHU 1 is
25 supposed to do because I don't know how to do
EFTA00118270
46
1 it. I rely on the senior officer that I'm
2 working with.
3
MR.
: Okay. So you didn't
4 really know what your duties and
5 responsibilities were? Is that what you're
6 saying?
7
MS. 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
EFTA00118271
47
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
EFTA00118272
48
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 had CPR training
17 (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?
EFTA00118273
49
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.
EFTA00118274
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?
EFTA00118275
51
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
EFTA00118276
52
1 the hotlist is like um, how should I say, like
2 inmates that are like -. Inmates that are like
3 - mm.
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 -. I'll just read it for the record.
24 SHU hotlist identifies inmates with mental
25 health conditions who may become dangerous,
EFTA00118277
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
EFTA00118278
54
1
2
3
4
the
you?
front.
MS. NOEL: Mm-hmm.
MR.
:
Was that ever provided to
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.
EFTA00118279
55
1
MR.
: You never even heard the
2 term?
3
MS. NOEL: I thought that hotlist was like
4 inmates that were like, um.... 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?
EFTA00118280
56
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?
EFTA00118281
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, through 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.
EFTA00118282
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 I'll 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?
EFTA00118283
59
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?
EFTA00118284
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.?
EFTA00118285
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?
EFTA00118286
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 we'll 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
EFTA00118287
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
EFTA00118288
64
1 you had that interaction with the one
2 individual who told you that he was a high-
3 profile person, that he was in the news all the
4 time, there was never a discussed that we need
5 to pay close attention to him?
6
MS. NOEL: No.
7
MR.
: And
, 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?
EFTA00118289
65
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
EFTA00118290
66
1
2
3
4
in charge of the SHU?
MS. NOEL: No.
MR.
:
it Grill?
Do you know who - wasn't
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?
EFTA00118291
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
EFTA00118292
68
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?
EFTA00118293
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
EFTA00118294
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?
EFTA00118295
71
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's
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
EFTA00118296
72
1
2
3
4
or elsewhere?
MS. NOEL:
MR.
downstairs, what
It's done downstairs.
: And when you say
- 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?
EFTA00118297
73
1
MS. NOEL: Mm-hmm.
2
MR.
: On or around July 30th.
3 And who was Inmate Reyes - Efrain 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
EFTA00118298
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
EFTA00118299
75
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?
EFTA00118300
76
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
EFTA00118301
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?
EFTA00118302
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 celimate?
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.
EFTA00118303
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
25
ring a bell?
EFTA00118304
80
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
EFTA00118305
81
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
EFTA00118306
82
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
EFTA00118307
83
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.
EFTA00118308
84
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
EFTA00118309
85
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.
EFTA00118310
86
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 board.
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 -
EFTA00118311
87
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
EFTA00118312
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 30, 2019.
21 It says inmate Epstein is being taken off
22 psychological observation and needs to be
23 housed with an appropriate cellmate. Did
24 anyone ever forward this information to you?
25 Being that you worked in the SHU where he was
EFTA00118313
89
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
on there?
24
MS. NOEL: Yes. But this is not sent
25 This is not the workers.
EFTA00118314
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:
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?
EFTA00118315
91
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,
EFTA00118316
92
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 be 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
EFTA00118317
93
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?
EFTA00118318
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 within the MCC or the MCC
24 SHU?
25
MS. NOEL: None.
EFTA00118319
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.
EFTA00118320
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:
18
MR.
:
Is that
19
MS. NOEL: Yes.
20
MR.
: Okay. And what
21 communications did you have with
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
EFTA00118321
97
1 provide you with special instructions with
2 regards to Epstein?
3
MS. NOEL: No.
4
MR. -•
5
MS. NOEL: No.
6
MR.
: Did the captain ever tell
7 you that Epstein was required to have a
8 cellmate?
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
EFTA00118322
98
1
2
3
4
10th? I'm giving you the MCC New York daily
assignment roster. So there's August 9th and
August 10th. So who were the MCC supervisors
on duty with responsibility for overseeing the
5 SHU on August 9th and 10th? Do you recall if
6
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
wasn't there check in with you?
25
MS. NOEL: I mean the other lieutenant
EFTA00118323
99
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
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
18
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.
EFTA00118324
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:
12
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 I
22 didn't see
23
MR.
: And do you know as being
24 the operations lieutenant would they be
25 responsible fox overseeing the SW? If -?
EFTA00118325
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
EFTA00118326
102
1
2
3
4
the operations lieutenant and the activities
lieutenant?
MS. NOEL: No. All the lieutenants.
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,
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.
EFTA00118327
103
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
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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
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
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
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
regarding
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105
1 Epstein being housed at the MCC or in the SHU?
2
MS. NOEL: No.
3
MR.
: He never did - did
4
ever provide you with special
5 instructions with regard to Epstein?
6
MS. NOEL: No.
7
MR.
: Did
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
MS. NOEL: 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
23
24
MS. NOEL: A lieutenant.
25
MR.
: A lieutenant. By looking
EFTA00118330
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
ever provide you with special
16 instructions with regard to Epstein?
17
MS. NOEL: No.
18
MR.
: No. Did Lieutenant
19
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
EFTA00118331
107
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
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.
EFTA00118332
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
EFTA00118333
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
21
MR. _:
22
MS. NOEL:
23
MR. -'
24
MS. NOEL: Yes.
25
MR.
: Alright. And
EFTA00118334
110
1
2
3
4
MS. NOEL: Yes.
MR.
Were either of them in
the SHU on August 9, 2019?
5
MS. NOEL:
6
MR. -•
7
MS. NOEL: Mm-hmm.
8
9
MR.
not
: But while you were there,
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 -.
EFTA00118335
111
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.
EFTA00118336
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
EFTA00118337
113
1 like that fire extinguisher over there? Or is
2 it further?
3
MS. NOEL: No. Maybe from the wall by the
4 AC 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?
EFTA00118338
114
1
2
3
4
MS. NOEL: No.
MR.
: Was it abnormal for an
inmate to be out by himself on the phone in the
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
14
shower because the
the
didn't work.
- where his cell is,
So he was placed in the
15 shower to use the phone there. But the shower
16 is like a cell.
17
18
MR.
closed --
: Okay. So was the door
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
EFTA00118339
115
1 the call in the shower, cell closed behind him,
2 it was approximately 25 feet from you but you
3 didn't hear anything?
4
MS. NOEL: No.
5
MR.
: And he didn't - and
6
didn't instruct you?
7
MS. NOEL: No.
8
MR.
: Did you ever experience
9 that prior to that instance? Where an inmate
10 would do that in the SHU?
11
MS. NOEL: Yeah. If they have to use the
12 phone and where there cell is, it's not
13 working. They place them in there because they
14 have to plug it close to where they can have
15 access to the phone.
16
MR.
: Okay. So in their cells
17 do they have cell lines that they can typically
18 call from?
19
MS. NOEL: No.
20
MR.
: Are the inmates provided
21 anything to be able to make calls?
22
MS. NOEL: No.
23
MR.
: Some kind of a card pass
24 or number or like something to be able to -?
25
MS. NOEL: Oh, like a pack and - yeah.
EFTA00118340
116
1
MR.
: Okay. Can you explain
2 what that is?
3
MS. NOEL: I mean I don't know too much
4 about it. I just know that they have a PIN
5 that they use to use the phone.
6
MR.
: Okay. Do you know if
7 Epstein had that PIN to use the phone?
8
MS. NOEL: I don't know.
9
MR.
: But specifically with
10 regard to the shower, having an inmate call
11 from the shower, have you ever experienced that
12 before?
13
MS. NOEL: Yes.
14
MR.
: When was the last time
15 you had experienced that prior to August 9th?
16
MS. NOEL: If the
is not working.
17 The
that's closest to their door. If it's
18 not working, then it's being plugged at the
19 bottom where the shower is. So you place them
20 in the shower just so they can reach the phone.
21
MR.
: And do you know if that
22 was an authorized practice?
23
MS. NOEL: I don't know.
24
MR.
: Okay. And did you ever
25 place anybody in the shower to do that?
EFTA00118341
117
1
MS. NOEL: No.
2
MR.
: No?
3
MS. NOEL: No.
4
MR.
: Who typically does that?
5
MS. NOEL: The officers.
6
MR.
: Okay. But not you,
7 right?
8
MS. NOEL: No.
9
MR.
: Would you ever allow
10 inmates to place calls?
11
MS. NOEL: When -.
12
MR.
: You personally.
13
MS. NOEL: When I come on, they have
14 already like got their phone calls.
15
MR.
: Oh, okay. So it's not
16 typically one of your responsibilities?
17
MS. NOEL: No.
18
MR.
: What was unique about
19 this situation with Epstein?
20
MS. NOEL: Well I guess because he's
21 always downstairs, so they made an exception
22 for him to make a call.
23
MR.
: Okay. Do we need to take
24 a break?
25
MR. FOY: DO you need to use the bathroom
EFTA00118342
118
1
2
3
4
or anything?
MS. NOEL: No.
MR. FOY: We can continue.
MR.
Great. Alright. So what
5 were
instructions. You said that
6 he's - his time is up. So what's - how much
7 time is he allotted?
8
MS. NOEL: I don't know.
9
MR.
:
Do you know how long he
10 was in that shower?
11
MS. NOEL: Mm.... I don't know.
12
MR.
:
You don't know. Was it
13 like 5 minutes, 10 minutes -?
14
MS. NOEL: It wasn't 5 minutes. He was in
15 there for maybe 20 minutes.
16
MR.
: 20 minutes? Okay. And
17 where was
18
MS. NOEL: He was gone.
19
MR.
:
Like left the SHU
20 altogether?
21
MS. NOEL: Mm-hmm.
22
MR.
: So he placed him in there
23 --
24
MS. NOEL: Sorry.
25
MR.
: -- left the SHU, and then
EFTA00118343
119
1 where did he call you from in order to say get
2 the phone from him?
3
MS. NOEL: A phone in the building. I
4 don't know where because it doesn't say where.
5 Like the phone rang and I answered. And he
6 just told me to take the phone from Epstein.
7 His time is up.
8
MR.
: Is that weird to you at
9 all? That he again, he gave someone a phone,
10 put them in the shower and then left?
11
MS. NOEL: No.
12
MR.
: That's not weird?
13
MS. NOEL: No.
14
MR.
: Okay. But without
15 providing anybody -. Did you know if he -
16
- provided anybody instructions prior
17 to him departing the SHU?
18
MS. NOEL: I don't know.
19
MR.
20
MS. NOEL: No.
21
MR.
You don't know.
: Who else was in the SHU
22 with you at that time?
23
MS. NOEL:
and
24
MR.
: And did you recall when
25 around that took place?
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120
1
MS. NOEL: