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 EFTA00118328

104 1 lieutenant's office. 2 MS. NOEL: Yes. 3 MR. : Okay. And I believe you 4 answered this, but did you have any 5 communications with 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 EFTA00118329

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? EFTA00118344

120 1 MS. NOEL: Like the time? 2 MR. : Yep. 3 MS. NOEL: It had to have been about after 4 8:00 because that's the time he comes back from 5 attorney conference. 6 MR. : Okay. So around 8:00 7 p.m. - ish? 8 MS. NOEL: After. 9 MR. : After 8:00 p.m. - ish? 10 MS. NOEL: Mm-hmm. 11 MR. : Okay. Are you able to 12 look? Was assigned to the SHU when he 13 gave him his phone call? 14 MS. NOEL: No. 15 MR. : Where was he assigned? 16 That's fine. Do you know what - why 17 went to the SHU in the first place? 18 Was the escorting Epstein back from his 19 attorneys? 20 MS. NOEL: I'm not sure. 21 MR. : So you don't know the 22 reason why he actually entered the SHU? 23 MS. NOEL: No. I don't know. 24 MR. : And you -? Do you 25 remember if he walked into the SHU with Epstein EFTA00118345

121 1 and immediately placed him into the shower 2 area? Or do you think that he went and 3 retrieved Epstein from his cell? 4 MS. NOEL: No. He didn't retrieve him 5 from his cell. He came in and said that he was 6 going to give him a phone call. 7 MR. : So he was with him at the 8 time? 9 MS. NOEL: Yes. And he placed him in the 10 shower. 11 MR. : So do you recall then if 12 he walked in the SHU with Epstein? 13 MS. NOEL: I don't know if he walked in 14 with him. But after because you could come in 15 and he could have been -. There's a holding 16 cell there. That's why I'm saying I don't 17 know. And then he came in after with him. But 18 from that door to the shower, he walked in with 19 20 MR. : Okay. So Epstein wasn't 21 in his own cell? 22 MS. NOEL: No. 23 MR. : He could have potentially 24 been in a holding cell? 25 MS. NOEL: Yes. EFTA00118346

122 1 MR. : Alright. But you don't 2 know who brough Epstein -- 3 MS. NOEL: No because 4 MR. : -- back there? 5 MS. NOEL: somebody could have brought 6 him up and then - so I don't know. 7 MR. : Okay. Now in order to 8 get into the SHU though, either you, or 9 10 MS. NOEL: Had to open the -. 11 MR. : -- open the door. Do you 12 remember who opened the door on that day? 13 MS. NOEL: I don't know. 14 MR. : It was not you? 15 MS. NOEL: No. 16 MR. : Okay. And I'm sorry, you 17 may have said this and I do apologize. What 18 time did and work there until? 19 MS. NOEL: was 4:00 to 12:00 and 20 was 2:00 to 10:00. 21 MR. : Okay. And what was the 22 hierarchy with the three of you that were 23 present at that time? Is there someone that 24 was in charge as an officer in charge? Or how 25 does that work when you're working together EFTA00118347

123 1 with those two other individuals? 2 MS. NOEL: I don't know who was in charge. 3 We just kind of worked together that day. But 4 I don't know as far as who is the -. 5 MR. : Is everyone considered 6 equals? When you're working together? 7 MS. NOEL: Well I'm the newest person 8 there, so and - I don't know how 9 long they've been there, but -. 10 MR. : Does it - does then when 11 you work with someone else, is it based upon 12 how long they've been with the Bureau? 13 MS. NOEL: No. 14 MR. : So is there -. I know 15 you're saying you're the newest. So you might 16 ask them questions. But is there like when 17 there's three of you in there, is there someone 18 that's supposed to be in charge? Or are you 19 all equally -? 20 MS. NOEL: On the roster it'll say who is 21 supposed to be in charge. 22 MR. : Okay. So (Indiscernible 23 *01:28:25) -• 24 MS. NOEL: But that doesn't necessarily 25 that's not necessarily the case. EFTA00118348

124 1 MR. : On that roster on August 2 9th of those three people, who does it say 3 should have been in charge? 4 MR. : It's on the first page. 5 MR. : It's on the first page. 6 If you look all the way to the left, you'll see 7 SHU assignments. And then you can look - go 8 over to the right and see their names. I 9 believe. 10 MS. NOEL: I don't see . I'm looking 11 for . I don't see that. 12 MS. : Really quick, can I just show 13 her how she reads -- 14 MR. : Absolutely. 15 MS. : -- a roster? 16 MS. NOEL: Oh I see him here. 17 MS. : So - sorry. Most of what 18 they're asking you would be on page one and 19 page two, right? So these are your shifts. 20 These are the posts. And then these are the 21 people who worked that shift too. If morning 22 watch, 3:00, 6:00 to 2:00, 6:00 and 8:00 is day 23 watch. This is the p.m. 12:00 to 8:00, 2:00 to 24 10:00, and this is all your evening watch. 25 This is like a person with a day off, sick EFTA00118349

125 1 leave, so on and so forth. These things I 2 don't believe apply to their questions because 3 these are all the changes that took place on 4 the roster. 5 MR. : Most everything is going 6 to be on the first page. 7 MS. : Yeah, so this can be a little 8 bit confusing. 9 MS. NOEL: Okay. 10 MS. : And it probably doesn't apply 11 to the stuff that they're asking. 12 MS. NOEL: Okay. 13 MS. : So you would just focus on 14 MS. NOEL: These two pages. 15 MS. : Yeah. The shifts are up top. 16 MR. FOY: So how does she determine who's 17 the boss? Because that's the question. 18 MS. NOEL: Yeah. 19 MS. : So this - these positions will 20 tell you who is in that position for that 21 shift. Right? I don't want to answer the 22 question for you, but when you look at the SHU 23 24 MR. FOY: Can you show her where the 25 answer is on the paper? EFTA00118350

126 1 MS. : Here. SHU I. That's your 2 OIC. 3 MS. NOEL: Okay. 4 MS. : Straight across. SHU II. SHU 5 III is your 6:00 to 2:00, 2:00 to 10:00. And 6 SHU IV is straight across. Right? So for 7 example, SHU IV was vacant on evening watch. 8 And then this is showing that was SHU 9 number one for the evening watch shift. 10 MS. NOEL: And this one to what time? 11 MS. : Shift III is 6:00 to 2:00. 12 MS. NOEL: Oh, okay. 13 MS. : And then shift ten is 2:00 to 14 10:00. 15 MS. NOEL: Okay. 16 MR. : Thank you very much for 17 that assistance. 18 MS. : Mm-hmm. 19 MS. NOEL: So basically on this it would 20 have been 21 MR. : Okay. would 22 have been -? 23 MS. NOEL: In charge. Mm-hmm. 24 MR. : Okay. Because he was SHU 25 I? EFTA00118351

127 1 MS. NOEL: Yes. 2 MR. : And do you know what SHU 3 I means he was the officer in charge? 4 MS. NOEL: Yes. 5 MR. : What does SHU II and SHU 6 III represent? Are there different duty 7 responsibilities - duties and responsibilities 8 based upon if you're SHU I, SHU II, or SHU III? 9 MS. NOEL: I just know whoever the number 10 one is would be the person in charge. But as 11 far as two and three, I don't know the 12 difference in responsibility. 13 MR. : Now in the time that you 14 worked there, did that actually play into 15 anything? If someone was SHU I or SHU II or 16 SHU III? 17 MS. NOEL: No. 18 MR. : No? So -. 19 MS. NOEL: Because we're always short- 20 staffed. So. 21 MR. : Okay. So would that mean 22 that like if the person SHU I even though on 23 paper they're the officer in charge, they're 24 actually not providing orders or anything? 25 Everyone's equally -. EFTA00118352

128 1 MS. NOEL: Doing what we need to do. 2 MR. : Okay. So everybody 3 basically has the same job responsibility. 4 MS. NOEL: Yes. 5 MR. : Okay. So you don't look 6 to someone as the actual officer in charge. 7 MS. NOEL: I do because I don't know. So 8 - but not necessarily the officer in charge, 9 just whoever that I'm working with. 10 MR. : Okay. And what was your 11 -? I don't know, this may have just answered 12 that, but what was your role in the SHU on 13 August 9, 2019? What SHU number were you? 14 MS. NOEL: Number two. 15 MR. : Number two. Like again, 16 you don't believe that actually provided you 17 with a different responsibility that SHU I or 18 SHU III? 19 MS. NOEL: No. 20 MR. : No? Okay. And what 21 conversations did you have with the SHU staff 22 that you worked with on August 9th regarding 23 Epstein? 24 MS. NOEL: None. 25 MR. : So you said that the one EFTA00118353

129 1 was with 2 MS. NOEL: Yes. 3 MR. : Correct? With regard to 4 the phone call. 5 MS. NOEL: Yes. 6 MR. : Now try to put yourself 7 back then. 8 MS. NOEL: Mm-hmm. 9 MR. : Any other conversations 10 at that point with regard to Epstein? 11 MS. NOEL: Um.... No. 12 MR. : Any follow on to when he 13 said get the phone from Epstein? 14 MS. NOEL: No. When he said to get the 15 phone, I got the phone. And I spoke to 16 Epstein. 17 MR. : Okay. And what was it 18 that you spoke with Epstein about? 19 MS. NOEL: I was told that your time is up 20 and I have to take the phone. And he said 21 okay. 22 MR. : Okay. And did 23 say to then place him back in his cell? Or was 24 that understood? 25 MS. NOEL: No. That was understood. EFTA00118354

130 1 MR. : And is that what you did? 2 MS. NOEL: I didn't place him back in the 3 cell. I went to the bathroom upstairs on 10. 4 MR. : Okay. 5 MS. NOEL: And when I came back, he was 6 placed back in his cell. 7 MR. : Okay. So what did you 8 do? You went to the shower and just instructed 9 him through the door? 10 MS. NOEL: Yeah. 11 MR. : To hang up? 12 MS. NOEL: No. I told him that I was told 13 that his time was up and I have to take the 14 phone in. And he said okay. And then he 15 handed me the phone. It's like a slot. 16 MR. : Okay. And then you 17 walked away? 18 MS. NOEL: Yes. 19 MR. : And he just stayed there 20 and waited? 21 MS. NOEL: Yes. 22 MR. : And then who brought him 23 from the shower to his cell? 24 MS. NOEL: I don't know. well it had to 25 be and because it takes two EFTA00118355

131 1 people to move him. And I went to the 2 bathroom. 3 MR. : Okay. So you used the 4 restroom at the time that he was transported -? 5 MS. NOEL: Back to his cell. Yes. 6 MR. : Okay. And did you have 7 any conversation with the individuals after 8 they placed - before or after they placed him 9 into the cell? 10 MS. NOEL: No. 11 MR. : Did you instruct them, 12 hey I just took the phone from him, can you 13 place him back into the cell? 14 MS. NOEL: Yes. 15 MR. : Okay. So you did talk to 16 them about that. 17 MS. NOEL: Yes. I said I was going to the 18 bathroom and he has to go back to the cell. 19 MR. : Okay. That was the 20 extent of it? 21 MS. NOEL: That was the extent of it. 22 MR. : Alright. And again, we 23 briefly talked about him, but 24 MS. NOEL: Yes. 25 MR. : Now do you know if he EFTA00118356

132 1 worked that day? 2 MS. NOEL: In the morning. 3 MR. : And who replaced him? 4 MS. NOEL: 5 MR. -' 6 MS. NOEL: Because he worked 6:00 to 2:00 7 and comes in 2:00 to 10:00. 8 MR. : Okay. So when someone 9 gets replaced, do they typically give a 10 briefing? Like so would - and I apologize 11 about the name but - Would they - 12 would he typically be responsible to provide 13 with information so that he - you know 14 with regard to what happened on his assignment 15 so that he can utilize that for when he's not 16 replacing him? 17 MS. NOEL: I don't know. 18 MR. : Does that make any sense? 19 MS. NOEL: I mean I don't know if he's 20 typically required to, but I guess if there's 21 information to give, he would give it to him. 22 But I don't know if he has to. 23 MR. : Okay. And during your 24 time, was there any conversation with any 25 information that gave to ? Or EFTA00118357

133 1 passed along? 2 MS. NOEL: I wasn't -. 3 MR. : For the replacements? 4 MS. NOEL: I wasn't there at 2:00. I came 5 in at 4:00. But nothing was told to me. 6 MR. : So never informed 7 you or in your presence? 8 MS. NOEL: No. 9 MR. : Okay. So there was no 10 discussion for Epstein to be reassigned a 11 celimate? 12 MS. NOEL: No. 13 MR. : And again, you didn't 14 even know that his cellmate wasn't there? 15 MS. NOEL: Wasn't there. 16 MR. : Okay. And should have 17 you known that his cellmate wasn't there? 18 MS. NOEL: I don't know. 19 MR. : So when you're doing 20 rounds and conducting counts, wouldn't that be 21 when you would know if someone was with or 22 without a celimate? Because you said only one 23 other person there didn't have a celimate. 24 Correct? 25 MS. NOEL: But people move all the time. EFTA00118358

134 1 When you're in SHU, like let's say if you did 2 something and you're in trouble. So you're in 3 the SHU. You could be sent back to your 4 regular unit. So it wouldn't be odd like if I 5 was counting and the person wasn't there. It 6 would just be lesser the count. But it 7 wouldn't be odd if the physical person wasn't 8 there to me. Because people move back all the 9 time. 10 MR. : But wouldn't they have to 11 advise you if you knew that there was only one 12 person without - you know, one person that 13 doesn't have a cellmate. Wouldn't they have to 14 advise you? Hey, this person left, so this 15 persons' in there by himself. 16 MS. NOEL: I don't know. Because nobody 17 said anything to me. 18 MR. : So I'm not -. I'm just 19 saying in general now. So like if you're 20 conducting your rounds and your counts, in 21 order for you to know who you're supposed to be 22 counting and what -. During both rounds and 23 counts, you know, who are you supposed to be 24 checking on. Wouldn't you need to know if a 25 cellmate was removed and now there's only one EFTA00118359

135 1 inmate in the cell? 2 MS. NOEL: No. like if I'm counting and 3 the person is not there. Like say the count 4 was 66. And I counted 65, that's just what 5 I'll count. 6 MR. : And you wouldn't try to 7 like figure out where is the 66th? 8 MS. NOEL: No because whoever moved the 9 person would have I guess documented where they 10 moved them to. 11 MR. : So you wouldn't - it is 12 after you count at 65, then would you have to 13 just go try to find paperwork. Hey, is there 14 another guy that someone else moved? 15 MS. NOEL: No. 16 MR. : Okay. So how do you 17 reconcile the numbers? Rather than me saying 18 so many words, you tell me how -- 19 MS. NOEL: Okay. So let's say -. 20 MR. : -- do you know who's in 21 the SHU? 22 MS. NOEL: So let's say like if there was 23 66 people in there. And one person moved to 24 wherever. They would have already did that. 25 So it wouldn't be for me to do. When I count EFTA00118360

136 1 now because the person is not there, I'm going 2 to just count 65. But the number is not going 3 to be off because whoever moved the body 4 already moved them to like let's say back to 5 the unit or wherever. So I wouldn't be trying 6 to find or figure out where the person went. 7 I'm just counting. 8 MR. : Okay. So and you're 9 counting during the counts, right? Not during 10 the rounds? 11 MS. NOEL: Right. During the counts. 12 MR. : Rounds are every 30 13 minutes approximately? 14 MS. NOEL: Yeah. 15 MR. : So during those rounds, 16 are you supposed to be when you're conducting 17 the rounds, what is the intent of those rounds? 18 MS. NOEL: Whoever is in there to make 19 sure that they're okay. 20 MR. : So if you don't know who 21 is in there, how do you make sure that they're 22 there and okay? 23 MS. NOEL: Because they would have already 24 been -. If the person is not there, like they 25 would have already been moved in the system. EFTA00118361

137 1 So if I'm making a round, I'm not going be like 2 well oh this person is not in here. Because 3 people go to different places. They go back to 4 the unit. They go to court. They go to 5 different places. So again, it wouldn't be 6 odd if somebody is not there. I mean I could 7 ask the person that I'm working with. Like oh 8 hey, whatever happened to so-and-so, but. 9 MR. : Alright. So you're 10 saying that even though you knew only one 11 inmate didn't have a SHU and especially, it 12 sounds like you're working later. 13 MS. NOEL: Mm-hmm. 14 MR. : So everyone should pretty 15 much be back from wherever they went to. 16 Correct? 17 MS. NOEL: Correct. 18 MR. : So at that point, you 19 only know one person doesn't have a cellmate. 20 You're walking through and you see that someone 21 doesn't have a cellmate. You're not asking -- 22 MS. NOEL: But see I don't know -. 23 MR. : -- where is that person? 24 MS. NOEL: But see I don't know that the 25 person has to have a cellmate. So again, even EFTA00118362

138 1 though the one person doesn't have a cellmate, 2 it's not odd to me because I don't know that 3 they have to have a cellmate. What if the 4 person went back to the unit? I didn't know 5 where Reyes went to. 6 MR. : Okay. 7 MR. : Can I ask her something? 8 MR. : Yes, please. 9 MS. NOEL: Mm-hmm. 10 MR. : I just want to clarify. When 11 you come in, right. Let's say you come on re- 12 shift. Is there somewhere near the computer 13 that tells you how many inmates are supposed to 14 eb in the SHU? 15 MS. NOEL: On the roster. 16 MR. : On the roster? 17 MS. NOEL: Yes. 18 MR. : And now let's say - do you 19 review the roster when you come in? 20 MS. NOEL: No. 21 MR. : So how do you know? Let's 22 just say someone went missing. How do you 23 know? 24 MS. NOEL: I don't know. 25 MR. : But isn't that - when you EFTA00118363

139 1 come on shift, right. You're responsible. I'm 2 not saying this is the case. But you're 3 responsible to know how many inmates are in the 4 SHU at that time. Right? 5 MS. NOEL: When I come on shift, I just 6 come on and relive the person and just -. Like 7 when I come on at 4:00, it's time to feed. So 8 I'm doing trays and I'm feeding. I'm not 9 looking to see who's on the roster or -. You 10 would probably wait for count time to count and 11 then count to see how much people is in there. 12 But I'm not looking to see okay the roster says 13 75 and I'm counting to make sure there's 75 14 people. Only at count time. 15 MR. : So when you're doing your 16 rounds, all you're doing is the people that you 17 see, are they okay. If someone escaped, you 18 wouldn't know that until count time? 19 MS. NOEL: I wouldn't. No. 20 MR. : Okay. And that's 21 basically - that answers it. So she's saying 22 that she's not even worried about if someone is 23 not there. She's only worried about the people 24 that are there. Is that correct? 25 MS. NOEL: Yes. Yes. EFTA00118364

140 1 MR. : Alright. 2 MS. : What - I've got a question. 3 MR. : Absolutely. 4 MS. : Would procedural clarification 5 help with the question? 6 MR. : Sure. We have all the 7 polices here. Would you like me to show her 8 the policies? I'm happy to do that. 9 MS. : Yeah. Or I could explain it. 10 MR. : I'll give her the 11 policies and just ask if she's familiar with 12 them. That's fine. So she knows what she 13 should have done. 14 MS. : I'll just say this to you. 15 The policy is very general for the entire 16 agency, not specific to MCC New York. 17 MR. : Okay. 18 MS. : So. 19 MR. : While he's looking, I just 20 want clarification. 21 MS. NOEL: Mm-hmm. 22 MR. : When you came in, if an 23 inmate was removed, would that roster have been 24 edited? 25 MS. NOEL: It should be. EFTA00118365

141 1 MR. : Do you recall if that roster 2 - was there a roster on your desk? 3 MS. NOEL: There's always a roster. But I 4 don't look at the roster. 5 MR. : But you don't recall if there 6 was anything - if there was a notification or 7 anything written down saying inmate Efren Reyes 8 was removed from the SHU? 9 MS. NOEL: No. 10 MR. : Is that something the 11 previous shift should have communicated to you? 12 MS. NOEL: They could have. 13 MR. : Alright. So I'm going to 14 read this out loud and then I'll provide it to 15 you. This is the Metropolitan Correctional 16 Center, New York, New York specific post 17 orders. This is specifically says SHU number 18 one. And I think that would be the officer in 19 charge as we just discussed. But I think that 20 they're, like you said, everyone's kind of 21 responsible for the same thing. But it 22 discusses right here, I'm going to go down to 23 the third paragraph on page 2 of 18. It says 24 report for duty by telephone with the 25 operations lieutenant and receive any EFTA00118366

142 1 additional information. Begin making 30 -. So 2 according to this, it says when you're report 3 to duty, you're supposed to talk to the 4 operations lieutenant and receive whatever 5 information you're supposed to on your shift. 6 It says, "Begin making 30-minute rounds 7 ensuring you document the findings into True 8 Scope (Phonetic Sp. *01:42:49). Staff will 9 observe all inmates in continued lockdown 10 status once in the first 30-minute period of 11 the hour. Example, 12:00 to 12:30 a.m. 12 Followed by another round in the second 30- 13 minute period of the same hour 12:30 to 1:00 14 a.m. This will ensure an inmate is observed at 15 least twice per hour. These rounds are to be 16 conducted on an irregular schedule and no more 17 than 40 minutes apart. All observations must 18 be documented. It should be clearly understood 19 that none of these activities are to take place 20 until the evening watch officer is relieved. 21 It should be noted that it is understood that 22 not all of the above will be accomplished by or 23 before the count." Then it talks about 24 official count time. The SHU number two 25 officer you said you were working, is that for EFTA00118367

143 1 both your shifts? Because this is specifically 2 talking about 12:00 a.m. What were you at 3 12:00 a.m. on August 10th? 4 MS. NOEL: I think I was number one. Yes. 5 MR. : Alright. So this 6 actually is pertaining to your shift during 7 12:00 a.m. to 8:00 a.m. So -. 8 MR. FOY: You mean according to what you 9 just read? 10 MR. : What I just read. This 11 says for -- 12 MR. FOY: Right. 13 MR. : -- the specific 14 (Indiscernible *01:43:58) so we're SHU number 15 one. So I guess what you were supposed to do 16 per post orders was when you get on board, 17 you're supposed to call the operations 18 lieutenant. And then you're supposed to say 19 hey, is there any information I need to know. 20 And then you're supposed to start making your 21 counts. And that would be like where you would 22 find out Epstein doesn't have a cellmate. Make 23 sure that when you're doing your rounds, you 24 know there's nobody in there. You know I would 25 think. Is that - was that your understanding EFTA00118368

144 1 at all? 2 MS. NOEL: No. I've never 3 MR. : Was that ever put into 4 practice? 5 MS. NOEL: No. Nobody ever calls the 6 lieutenant when they get on shift. 7 MR. : So no one ever talked to 8 them? 9 MS. NOEL: No. 10 MR. : Okay. Is there - I don't 11 know if I need to continue reading this because 12 we're going to take a lot of time with it if we 13 do. Just because I read it, if you want to 14 take a look. And just initial and date there. 15 And then we're just going to move on. 16 MS. NOEL: Mm-hmm. 17 MR. : Because that's - this is 18 taking up. 19 MR. FOY: Initial the top. 20 MR. : But the point on that 21 matter was that you knew you were supposed to 22 observe the people that were there. You 23 weren't too concerned about people that weren't 24 there. 25 MS. NOEL: Nothing. Correct. EFTA00118369

145 1 MR. : Is that a correct 2 understanding? 3 MS. NOEL: Yes. 4 MR. : Alright. On August 9th, 5 do you recall having any discussions with 6 regarding Epstein? 7 MS. NOEL: No. 8 MR. : And again, would 9 have been the one - did you say he was the one 10 who replaced -? 11 MS. NOEL: Relieved 12 MR. : Okay. So if 13 provided with information, did not 14 provide you with that information. 15 MS. NOEL: I don't know if 16 MR. : Yeah-yeah-yeah, I know. 17 I'm asking that 18 MS. NOEL: Oh, about didn't 19 MR. : If he did that, 20 certainly didn't provide it to you. 21 MS. NOEL: No. 22 MR. : Okay. And didn't 23 provide you with any special instructions 24 regarding Epstein? 25 MS. NOEL: No. EFTA00118370

146 1 MR. : No? Did you discuss the 2 need for Epstein to be reassigned a cellmate 3 with anyone on August 9th? 4 MS. NOEL: No. 5 MR. : No. When did 6 depart the SHU? On August 9th? 7 MS. NOEL: At 10:00. 8 MR. : 10:00 p.m.? Correct? 9 MS. NOEL: Correct. 10 MR. : You said unit manager 11 Nathan He actually wasn't in the SHU? 12 I mean he wasn't assigned to the SHU. I'm 13 sorry. 14 MS. NOEL: No. 15 MR. : He was just in there in 16 order to facilitate the start of this telephone 17 conversation? 18 MS. NOEL: Phone call. Yes. 19 MR. : And you don't know why he 20 was in there in the first place? 21 MS. NOEL: No. 22 MR. : So you don't know if he 23 brought Epstein in? 24 MS. NOEL: No. 25 MR. : He just - and you're not EFTA00118371

147 1 the one to allow them? 2 MS. NOEL: No. 3 MR. : Alright. So he didn't 4 actually have any responsibilities in the SHU? 5 MS. NOEL: No. 6 MR. : And aside from the 7 telephone conversation that you had with 8 , with specifically with regards to get 9 the phone away from him, his time is up. Any 10 other conversations? 11 MS. NOEL: With no. 12 MR. : No. About Epstein or 13 otherwise. 14 MS. NOEL: No. 15 MR. : No. Any conversations 16 with him in person? 17 MS. NOEL: Only when I took the phone from 18 him. 19 MR. : No-no, not Epstein. 20 21 MS. NOEL: Oh, no. 22 MR. : And that's what I was 23 asking about before. It's just to make sure 24 that we're clear. Any other conversations 25 aside from that one conversation on the phone EFTA00118372

148 1 where he said get the phone from Epstein his 2 time is up. 3 MS. NOEL: And when he came in, he said 4 I'm going to put him in the shower to use the 5 phone. 6 MR. : And that was the extent 7 of it? 8 MS. NOEL: That was the extent of it. 9 MR. : Okay. Nothing to do with 10 Epstein being housed with MCC or SHU? 11 MS. NOEL: No. 12 MR. : Or the need for a 13 cellmate? 14 MS. NOEL: No. 15 MR. : Do you know who 16 authorized to provide Epstein with that 17 telephone call? 18 MS. NOEL: I don't know. 19 MR. : No. Who plugged the 20 telephone line into the legal line in the 21 shower area? 22 MS. NOEL: 23 MR. -: did. And do you 24 know if he did that per ' direction? 25 MS. NOEL: No. EFTA00118373

149 1 MR. : You're not sure. And to 2 you, that was an authorized practice? 3 MS. NOEL: To use the phone in the shower? 4 Yeah. 5 MR. : What is that line in the 6 shower area for? 7 MS. NOEL: I don't know. 8 MR. : Is it -? Okay. Is there 9 usually a phone that's plugged in there? Or is 10 it just a -- 11 MS. NOEL: No. 12 MR. : -- line that's available? 13 MS. NOEL: The is there. 14 MR. : Just the . And you 15 know that to be a legal line like for 16 attorneys? 17 MS. NOEL: I don't know. 18 MR. : You don't know that 19 that's what that is - a legal line? 20 MS. NOEL: I don't know. 21 MR. : But what is just your 22 overall understanding briefly about policy for 23 inmates assigned to the SHU when they need to 24 make a phone call? How often do they get to do 25 it? How do they do it? EFTA00118374

150 1 MS. NOEL: Um. When they had them the 2 phone in the cell and they use that PIN - the 3 number - to make the phone call. How often, I 4 don't know. Because that's usually done before 5 I come in. But I know showers are every other 6 day. I don't know if phones is every other day 7 also. 8 MR. : Okay. So you're not 9 sure? 10 MS. NOEL: I'm not sure. 11 MR. : You said you didn't hear 12 any part of that telephone conversation? 13 MS. NOEL: No. 14 MR. : Did you see any part of 15 that telephone conversation? 16 MS. NOEL: Only when I went to go get it 17 from him. 18 MR. : But while he was on it? 19 MS. NOEL: No. 20 MR. : Discussing? 21 MS. NOEL: No. 22 MR. : And no one observed him? 23 MS. NOEL: No. 24 MR. : So no one watched him or 25 listened? EFTA00118375

151 1 MS. NOEL: No. 2 MR. : And no one informed you 3 to watch or listen? 4 MS. NOEL: No. 5 MR. : And previous instances 6 when people have used that line, were other - 7 were people watching and listening to those 8 people? 9 MS. NOEL: No. 10 MR. : And around what time was 11 Epstein brought back to his cell did you say? 12 MS. NOEL: Maybe about after 9:00. 13 MR. : So he did the telephone 14 call sometime before 9:00 and around after 9:00 15 is when he was put back into his cell? 16 MS. NOEL: Probably because I was in the 17 bathroom. 18 MR. : And you went to the 19 bathroom you think around 9:00? 20 MS. NOEL: I'm not sure. 21 MR. : Sure. 22 MS. NOEL: But around. 23 MR. : I'm not asking for 24 specifics. 25 MS. NOEL: Yeah. Like around. EFTA00118376

152 1 MR. : Around 9:00 p.m. 2 MS. NOEL: Mm-hmm. 3 MR. : Okay. And you said 4 you're not the person who brought him. Someone 5 else did. After someone else brought him to 6 his cell, did you have any more conversations 7 with Epstein? 8 MS. NOEL: Yes. 9 MR. : Okay. What - when was 10 that and where? 11 MS. NOEL: Not a conversation when I 12 counted. 13 MR. : When did you count? 14 MS. NOEL: At 10:00. 15 MR. : At 10:00 p.m. you 16 counted? 17 MS. NOEL: Yes. 18 MR. : So you actually went 19 through each tier and counted? 20 MS. NOEL: Yes. 21 MR. : And did you go into the 22 tier? Or did you just go up to the door? 23 MS. NOEL: I went into the tier. 24 MR. : Okay. So you didn't head 25 around at 10:00 p.m. you didn't stop at the EFTA00118377

153 1 door and just look in? You actually went 2 through? 3 MS. NOEL: Yeah, I went through. 4 MR. : And looked through and 5 counted each person? 6 MS. NOEL: Yes because he was on the 7 floor. And I knocked. And he put his hand up. 8 MR. : Okay. So that wasn't 9 just from the outer door of the tier. 10 MS. NOEL: No. 11 MR. : That was actually -. 12 MS. NOEL: No, that was in there. 13 MR. : Okay. And you said you 14 don't know who brought him back to the cell. 15 MS. NOEL: No I was in the bathroom. 16 MR. : Okay. And when - around 17 10:00 p.m. you looked in and you said he was on 18 the floor and he put his hand up? 19 MS. NOEL: Yeah. He sleeps on the floor. 20 The mattress - he puts the mattress on the 21 floor. 22 MR. : Okay. So you never 23 actually see his bunk. He would sleep on the 24 floor. 25 MS. NOEL: The floor yeah. EFTA00118378

154 1 MR. : Take the mattress off the 2 bunk? 3 MS. NOEL: And put it on the floor. 4 MR. : Sleep there. Is that 5 typical? 6 MS. NOEL: For him. 7 MR. : For him? Which other 8 inmates do that? 9 MS. NOEL: Not in the SHU, but sometimes 10 they do that. 11 MR. : And is there anything up 12 with policy that prohibits people from doing 13 that? 14 MS. NOEL: Not that I know of. 15 MR. : No. So it wasn't 16 anything of concern? 17 MS. NOEL: No. 18 MR. : Okay. But he - did you - 19 did he verbalize anything or just put his hand 20 up? 21 MS. NOEL: He put his hand up. 22 MR. : Just like, I'm accounted 23 for? 24 MS. NOEL: Right. 25 MR. : Okay. And is that after EFTA00118379

155 1 you said you knocked? 2 MS. NOEL: Yes. 3 MR. : And did you communicate 4 with him at all? 5 MS. NOEL: Mm.... 6 MR. : You okay? 7 MS. NOEL: No. 8 MR. : No. So it was just a 9 knock and hand up. 10 MS. NOEL: Yes. 11 MR. : No communication. 12 MS. NOEL: None. 13 MR. : Just visualization. 14 MS. NOEL: Yeah. 15 MR. : And notice anything 16 different about him at that time? 17 MS. NOEL: No. 18 MR. : No. You said that was 19 around 10:00 p.m.? 20 MS. NOEL: I think he asked for the CPAP 21 machine to be plugged in because he had a CPAP 22 machine. 23 MR. : What's a CPAP machine? 24 MS. NOEL: When people have sleep apnea, I 25 guess they use that machine. EFTA00118380

156 1 MR. : Okay. 2 MS. NOEL: So the cord has to be ran from 3 outside of his room all the way down to be 4 plugged in. 5 MR. : It's for sleep apnea? 6 MS. NOEL: I don't know what else it's 7 for. But that's what I know people use it for. 8 MR. : And did you get it for 9 him? 10 MS. NOEL: It's in his room. It's just 11 for it to be plugged in. 12 MR. : Oh. And did you plug it 13 in for him? 14 MS. NOEL: Yes. 15 MR. : Okay. So you did have 16 some communication with him then? 17 MS. NOEL: Well he asked and I just 18 nodded. And I plugged it in. 19 MR. : So okay. So when I ask 20 you these things, I just really want you to be 21 clear with like -- 22 MS. NOEL: Mm-hmm. 23 MR. if there's 24 communications just really think about like 25 what communications you actually had. EFTA00118381

157 1 MS. NOEL: Mm-hmm. 2 MR. : So just tell me about 3 specifically what you can remember. Because 4 again, if this is the last time you saw him. 5 Just try to recall -- 6 MS. NOEL: Remember it. 7 MR. -- what it is he said. 8 MS. NOEL: I remember he put his hand up. 9 And he asked about the CPAP machine to be 10 plugged in. That's it. 11 MR. : Do you remember his 12 words? Like -- 13 MS. NOEL: NO. 14 MR. : -- did he say, "CPAP 15 machine." Or, "Can you plug this in for me?" 16 MS. NOEL: I don't remember how he said 17 it, but basically he asked for it to be plugged 18 in. But I don't remember exactly what he said 19 or how he said it. 20 MR. : Alright. So at that 21 point you went and plugged it in? 22 MS. NOEL: Yes. 23 MR. : Alright. And that's like 24 a cord that runs like under his cell door or 25 something? EFTA00118382

158 1 MS. NOEL: Yes. 2 MR. : Okay. And then any 3 conversations afterwards? 4 MS. NOEL: No. 5 MR. : No. Alright. Can you 6 just briefly explain the process of people 7 entering and exiting the SHU? 8 MS. NOEL: There's double doors. 9 MR. : Okay. 10 MS. NOEL: And we open the doors to let 11 the person in. 12 MR. : So is there somebody that 13 they have to go through an outer door first to 14 get to your door? 15 MS. NOEL: Yeah. There's two doors. And 16 so they come in the first door, then the second 17 door, and then you're in the SHU. 18 MR. : How do they get into the 19 first door? 20 MS. NOEL: We open the door. 21 MR. : Not the control center? 22 MS. NOEL: No. 23 MR. : So you're able to - from 24 the first door before they get to your door, 25 you open both doors? EFTA00118383

159 1 MS. NOEL: Yes. 2 MR. : Okay. So the control 3 center, they don't call for it first and the 4 control center pops the first door? And then 5 you have keys for the second door? 6 MS. NOEL: No. 7 MR. : Alright. Okay. So I'm 8 going to stop talking. You tell me exactly how 9 they do it. Somebody knock or they call or 10 buzz or what? 11 MS. NOEL: Somebody knocks. Or sometimes 12 they use the radio. And then we go to the door 13 and open the door. 14 MR. : So do you have a - from 15 your desk is there a buzz to -? 16 MS. NOEL: No. You've got to open it with 17 a key. 18 MR. : The initial outer door? 19 MS. NOEL: Both doors. 20 MR. : So you go, you open the 21 inner door to you and then go to the 22 MS. NOEL: Door. 23 MR. : -- outer door -- 24 MS. NOEL: Yes. 25 MR. : -- and do the second? EFTA00118384

160 1 MS. NOEL: Yes. 2 MR. : And you have control over 3 both doors? 4 MS. NOEL: Yes. 5 MR. : Alright. Does the 6 operations center also have control over that 7 outer door? 8 MS. NOEL: I don't know. I don't think 9 for SHU they do. I don't know. 10 MR. : Alright. Anytime people 11 enter and exit, you've always - 12 MS. NOEL: The person on the inside yes. 13 MR. : For both doors. 14 MS. NOEL: Yes. 15 MR. : Alright. And that's the 16 same as when they leave? 17 MS. NOEL: Yes. 18 MR. : So after they leave that 19 second outer door -- 20 MS. NOEL: Mm-hmm. 21 MR. : -- you go, you lock that 22 manually -- 23 MS. NOEL: Mm-hmm. 24 MR. : -- and then lock the 25 other one? EFTA00118385

161 1 MS. NOEL: Yeah. 2 MR. : Manually? Both manually 3 from the SHU? 4 MS. NOEL: If that one I think - the outer 5 one like once you pull it in it locks. 6 MR. : Okay. Which one is that? 7 MS. NOEL: The outer door. 8 MR. : The outer door. And who 9 entered and exited the SHU on August 9, 2019 10 between let's say for the first shift: 9:00 11 p.m. and 12:00 p.m. So if you have to open up 12 two doors, I'm assuming that's kind of a 13 process and there aren't many of you in there. 14 MS. NOEL: 15 MR. -• 16 MS. NOEL: No you said on the first shift? 17 MR. : First shift. From 9:00 18 p.m. to 12:00 a.m. - 12:00 a.m. sorry. 19 MS. NOEL: From - I don't know. 20 MR. : So it would be the people 21 that were in there. Correct? Would that be 22 and 23 MS. NOEL: . And me. 24 MR. : And you. Anyone else? 25 MS. NOEL: I'm trying to remember because EFTA00118386

162 1 you said between 9:00 p.m. and 12:00 a.m. I 2 3 don't remember exactly when made her rounds, but -. 4 MR. : Okay. would have 5 showed up at one time or another though? 6 MS. NOEL: Yes. 7 MR. : Do you remember that 8 conversation when she showed up? 9 MS. NOEL: No. 10 11 MR. anything? : Did she talk to you about 12 MS. NOEL: No. 13 MR. : Did you specifically 14 speak to her at all? 15 MS. NOEL: I mean I said hey. 16 MR. : Just hey. 17 MR. : What's up. 18 MR. : Okay. And who allowed 19 to enter and exit? 20 MS. NOEL: I don't remember that. 21 MR. : Alright. Do you know who 22 23 - when and them to leave? left, who allowed 24 MS. NOEL: Mm. I don't remember that. 25 MR. : You don't remember that. EFTA00118387

163 1 MS. NOEL: No. 2 MR. : Alright. And who was 3 present with you in the SHU after midnight? 4 From approximately 6:30, 6:33 a.m. on August 5 10, 2019? 6 MS. NOEL: Me and 7 MR. : Anyone else? 8 MS. NOEL: No. 9 MR. : Visitors? 10 MS. NOEL: 11 MR. : At around what time did 12 she visit? 13 MS. NOEL: I don't remember the time. 14 MR. : Does around 4:00 a.m. 15 sound right? 16 MS. NOEL: I don't remember the time. To 17 be honest. 18 MR. : Okay. Was there another 19 officer that you remember around like 5:30 a.m. 20 visiting? 21 MS. NOEL: No. The officer upstairs - he 22 left to go get food and come back. 23 MR. : So would that be 10 24 South? 25 MS. NOEL: Yes. EFTA00118388

164 1 MR. : Alright. And then when 2 he leaves 10 South to come to the SHU, do you 3 also have to allow him access into the SHU? Or 4 is he able to get into the SHU by himself? 5 MS. NOEL: Coming down from 10 South? 6 MR. : Mm-hmm. 7 MS. NOEL: relieved him. And then 8 he came down and went. 9 MR. -: relieved the 10 person on 10 South? 11 MS. NOEL: Yes. 12 MR. : So wasn't assigned 13 to the SHU? He was assigned to 10 South. 14 MS. NOEL: He was assigned to the SHU. 15 MR. : So can you just explain 16 what you mean by relieved? You mean he relived 17 him temporarily while he got food? 18 MS. NOEL: He called and said that the 19 lieutenant said that he could go get his food. 20 So can one of us relieve him to go get his 21 food. So went, relieved him, and he 22 came down and he went out to get his food. 23 MR. : Okay. So you were the 24 only person in the SHU at that point? 25 MS. NOEL: Downstairs I guess. EFTA00118389

165 1 MR. : And 2 MS. NOEL: As far as the time, I don't 3 know. 4 MR. : Okay. So are they the 5 only two people that were in the SHU between -? 6 MR. FOY: Do you want the context of when 7 that request from to get coverage to get 8 food? Because there's a context there. 9 MR. : Sure. I mean. 10 MR. FOY: Alright. So I want you to talk 11 about what you were doing before when he asked 12 you. Right. 13 MS. NOEL: Okay. 14 MR. FOY: You remember what you were 15 doing, right? 16 MS. NOEL: I remember what I was doing but 17 I 18 MR. FOY: This is a three event, there's a 19 five event, and then -. 20 MS. NOEL: Oh! Like I counted with 21 upstairs at that time. And when I came back 22 downstairs, he called and he said that the 23 lieutenant said to relive him to get food. I 24 didn't believe him, so I called the 25 lieutenant's office. And I said, did you say EFTA00118390

166 1 for me to relive to get food? But 2 another lieutenant came on, so he said well I 3 don't know if the lieutenant before said that. 4 So I said okay and I hung the phone up. And 5 said I'll go relieve him so he could go 6 get his food. 7 MR. : Okay. And I do 8 apologize. You counted with him? 9 MS. NOEL: Yes. 10 MR. : And you're talking about 11 the individual in 10 South. 12 MS. NOEL: Yes. 13 MR. : And then you came back to 14 the SHU and then relieved him? 15 MS. NOEL: Yes. 16 MR. : Um. 17 MS. NOEL: But I don't remember if it was 18 at the 3:00 or the 5:00. I don't remember 19 which one. 20 MR. : Alright. And I do 21 apologize. I just want to make sure I have 22 this clear. So when you went up at either 3:00 23 or 5:00, and I'm assuming it was 5:00, you 24 helped him count. And at that point he's 25 when he said he wanted to go get food? EFTA00118391

167 1 MS. NOEL: When I came back downstairs he 2 called. 3 MR. : Oh so not while you were 4 doing the count. 5 MS. NOEL: No. 6 MR. : So you left. 7 MS. NOEL: Came back downstairs. 8 MR. : He called and said I just 9 spoke to the lieutenant? 10 MS. NOEL: He said the lieutenant said for 11 when you had to relieve me to get food. 12 MR. : And then you said you 13 verified that? 14 MS. NOEL: I called. 15 MR. : The lieutenant? 16 MS. NOEL: Yes. 17 MR. : Was this both 18 both times? Was that who it was? 19 MS. NOEL: No. When I called, 20 answered and he said he didn't know. 21 MR. : SO it was Lieutenant 22 . So this would have been at like 5:30 23 then probably? 24 MS. NOEL: Probably. 25 MR. : Okay. If you look at the EFTA00118392

168 1 schedule, can you tell me what time came 2 on? 3 MS. NOEL: On here it says 8:00 to 4:00. 4 MR. : Are you looking at 8/10 - 5 August 10th? 6 MS. NOEL: Yes. But it was before that. 7 It was (Indiscernible *02:00:18). 8 MR. : Oh, sorry. So there's a 9 little caveat there. So the officers' times 10 are two hours before, do he would have started 11 at 6:00. But I believe he actually - his would 12 be 6:00 to 2:00 as opposed to 8:00 to 4:00 like 13 the roster. So it's confusing. Um, they 14 allowed the lieutenants to come in two hours 15 earlier and end their shift two earlier. 16 MS. NOEL: Hm. 17 MR. : But I do believe he 18 arrived at 5:30. So this would have been 19 probably you said - you said there were two 20 different lieutenants you spoke to. So I'm 21 assuming one - 22 MS. NOEL: No I spoke to Lieutenant 23 asking did he say for me to relive to 24 get the food. So he said he doesn't know. 25 Maybe Lieutenant told him. But I EFTA00118393

169 1 didn't speak to her. 2 MR. : Sure. And what I'm - I 3 think that he started around 5:30. So he 4 probably called around like 5:28, spoke with 5 lieutenant - and then you probably called 6 shortly after 5:30. Does that sound like 7 potentially could have happened? 8 MS. NOEL: Could have. Yes. 9 MR. : Okay. So does around 10 that 5:30 timeframe right before you know you 11 were going to feed the inmates. Does that 12 sound about right? 13 MS. NOEL: Right. 14 MR. : Okay. So the 5:00 a.m. 15 count. That (Indiscernible *02:01:18)? 16 MS. NOEL: Right. 17 MR. : Okay. So he is - and I'm 18 sorry, who was in the 10 South? 19 MS. NOEL: 20 MR. : It was and then who 21 else visited the SHU where Epstein was housed 22 between 12:00 a.m. and 6:30? 23 MS. NOEL: Lieutenant • 24 MR. : Are they the only two 25 people that visited the SHU aside from you and EFTA00118394

170 1 2 MS. NOEL: Yes. 3 MR. : Okay. No one else? 4 MS. NOEL: No. 5 MR. : Okay. When you were in 6 the SHU with was there a hierarchy 7 then? 8 MS. NOEL: On the paper it says that I was 9 the number one. 10 MR. : And would that be - I 11 know you said a lot of time it's because you're 12 new, you would ask other people for guidance. 13 Is that because that was your quarterly post? 14 MS. NOEL: Yes. The post. 15 MR. : And was in there 16 as an overtime post? 17 MS. NOEL: Yes. 18 MR. : Not his regular 19 assignment? 20 MS. NOEL: Correct. 21 MR. : Okay. So on paper, you 22 were in charge. But in practice, you're both 23 the same. 24 MS. NOEL: In practice, I ask because I 25 don't know. So even if I'm in charge, I don't EFTA00118395

171 1 know everything because I'm new. So I ask the 2 senior officer. 3 MR. : Okay. Do you remember 4 any conversations you had with that 5 night? 6 MS. NOEL: As far as -? 7 MR. : Just were you conversing? 8 While you were there? Just the two of you? 9 MS. NOEL: I'm not -. 10 MR. : I'm not asking for what 11 conversations at this point. I'm just saying 12 were you talking to one another? 13 MS. NOEL: No not really. 14 MR. : You guys didn't really 15 communicate or talk? 16 MS. NOEL: No. 17 MR. : Okay. Do you remember 18 any conversations with regard to Epstein at 19 all? 20 MS. NOEL: No. 21 MR. : No. Alright. So it's 22 just you two, you said and 23 . The only four people from that - those 24 periods when you started your shift at 12:00 25 a.m. to 6:30? EFTA00118396

172 1 MS. NOEL: Correct. 2 MR. : What was the purpose of 3 visit? 4 MS. NOEL: To conduct a round. 5 MR. : Okay. And what is she 6 required to do during a round? 7 MS. NOEL: I don't know. 8 MR. : Are you aware if she was 9 supposed to conduct a count with you during her 10 round? Or -? 11 MS. NOEL: She's not supposed to conduct 12 the count. But I don't know how she's supposed 13 to conduct her rounds. 14 MR. : So do you understand if 15 her round is at a round of her staff members? 16 Or is it also she's supposed to do anything 17 with inmates when she does rounds? 18 MS. NOEL: I don't know. 19 MR. : You don't know. And do 20 you remember when she entered and exited the 21 SHU who let her in and out? 22 MS. NOEL: I did. 23 MR. : Both times? Both in and 24 out? 25 MS. NOEL: Yes. EFTA00118397

173 1 MR. : Okay. And then what 2 about when departed the SHU? Who let him 3 in and out? 4 MS. NOEL: That I don't remember. 5 MR. : Would it be -? 6 MS. NOEL: But it probably would have been 7 me. 8 MR. : -- you since 9 relived him 10 MS. NOEL: Right. Went upstairs. 11 MR. : -- Correct? 12 MS. NOEL: Yes. 13 MR. : I would think went 14 up there, then you probably would have 15 MS. NOEL: Let them out. Mm-hmm. 16 MR. : Okay. And both with 17 and you verified that that 18 those doors were shut and sealed? 19 MS. NOEL: Yes. 20 MR. : And no one else got in 21 and out between those times? 22 MS. NOEL: No. 23 MR. : And were they - those two 24 individuals authorized visitors - and 25 authorized visits - within the SHU? EFTA00118398

174 1 MS. NOEL: Who Lieutenant 2 MR. : Was their presence in the 3 SHU authorized? 4 MS. NOEL: Yes. 5 MR. : Was it justified. And 6 did you see them the entire time that they were 7 actually in the SHU? 8 MS. NOEL: Yes. 9 MR. : Was there anything out of 10 the ordinary? 11 MS. NOEL: No. 12 MR. : No. Any - either of them 13 have any conversations about Epstein? 14 MS. NOEL: No. 15 MR. : And you say 16 was the operations lieutenant on August 10th? 17 MS. NOEL: Yes. 18 MR. : Did you have any 19 conversations with her on the phone? 20 MS. NOEL: No. 21 MR. : That you recall? No. 22 What about like when you guys would call in 23 counts? 24 MS. NOEL: I don't remember who took the 25 count, but when 1 got called control to give EFTA00118399

175 1 the count, I don't remember if it was her that 2 took the count. But. 3 MR. : Okay. So you don't 4 recall any other conversations with 5 aside from when she visited at 4:00 to 6 check in? 7 MS. NOEL: Correct. 8 MR. : And she never provided 9 any special instructions? 10 MS. NOEL: No. 11 MR. : About anything during 12 that shift? 13 MS. NOEL: No. 14 MR. : She never told - 15 never told you that Epstein was 16 required to have a cellmate? 17 MS. NOEL: No. 18 MR. : Didn't ask about Reyes or 19 anything? 20 MS. NOEL: No. 21 MR. : Or about a new cellmate 22 being place in? 23 MS. NOEL: No. 24 MR. : Alright. And we just 25 briefly mentioned that who was Lieutenant EFTA00118400

176 1 2 MS. NOEL: The lieutenant that came on in 3 the morning. 4 MR. : Okay. And he started - 5 we believe around 5:30 based upon what we just 6 talked about. 7 MS. NOEL: Correct. 8 MR. : Okay, 5:30 a.m. on August 9 10th. And during that conversation, you said 10 that you called Lieutenant . What all was 11 spoken about during that call? 12 MS. NOEL: If I should relive to get 13 food. If that's what he said. 14 MR. : Any discussion about 15 inmates? 16 MS. NOEL: No. 17 MR. : Any discussion about 18 Epstein? 19 MS. NOEL: No. 20 MR. : No. He didn't' provide 21 any special instructions or ask about anything 22 about your shift? 23 MS. NOEL: No. 24 MR. : About him coming on? 25 MS. NOEL: No. EFTA00118401

177 1 2 3 4 MR. : No. Do you remember if the control center, R&D, or anyone else called the SHU on August 9th or 10th during your two shifts? About Epstein's cellmate leaving? 5 MS. NOEL: I don't know. If they did, 6 they didn't speak to me. 7 MR. : You didn't speak with 8 anybody? 9 MS. NOEL: No. 10 MR. : R&D or anyone else?› 11 MS. NOEL: No. 12 MR. : If an inmate is removed 13 from the SHU and is released from the MCC, how 14 does the SHU find out? 15 MS. NOEL: I don't know. 16 MR. : You don't know? 17 MS. NOEL: No. 18 MR. : Has that ever happened to 19 you before? 20 MS. NOEL: Where an inmate had gone? No. 21 MR. : When an inmate goes to 22 court or something and then is released? 23 MS. NOEL: But I don't -. If that 24 happens, like I'll give the phone to the senior 25 officer because I don't know. But that never EFTA00118402

178 1 happened where like an inmate was released when 2 I'm there. 3 MR. : So from 4:00 p.m. on 4 August 9th, you don't recall that call coming 5 in 6 MS. NOEL: NO. 7 MR. : -- or a discussion 8 happening -- 9 MS. NOEL: Not to me. 10 MR. : -- about Reyes not coming 11 back? 12 MS. NOEL: Not to me. No. 13 MR. : And you didn't have a 14 conversation with anybody at all? 15 MS. NOEL: Nope. 16 MR. : And you don't know if 17 control or R&D or anybody spoke with anyone 18 else? 19 MS. NOEL: I don't know. 20 MR. : Even if they didn't 21 discuss the details of it. You didn't overhear 22 that conversation? 23 MS. NOEL: No. 24 MR. : So what is your 25 understanding? If Reyes is released on August EFTA00118403

179 1 9th from the SHU. Epstein is required to have 2 a cellmate. What should have happened? 3 MS. NOEL: I don't know what should have 4 happened because when I came in at 4:00, the 5 cell was empty. So I don't know what should 6 have happened. Epstein came back and went to 7 his cell. I don't know where Reyes is or if 8 he's coming back. So I don't know what should 9 have happened. 10 MR. : Okay. So if an inmate is 11 required to have a cellmate, such as Epstein, 12 when the cellmate -. Sorry, I don't know if I 13 just misspoke. If Epstein was required to have 14 a cellmate, as Epstein was, after his cellmate 15 departs, which was Reyes, do you know if 16 there's a - how long it should take for him to 17 get replaced? 18 MS. NOEL: Oh. I don't know. 19 MR. : You don't know that? 20 MS. NOEL: No. 21 MR. : Do you know who the 22 decision-makers would be on that? 23 MS. NOEL: I don't know. 24 MR. : Do you know if you were 25 authorized to assign Epstein a cellmate? EFTA00118404

180 1 MS. NOEL: I don't know. 2 MR. : Again, no conversations 3 at all with -? 4 MS. NOEL: None. 5 MR. : He's gone. No? Um and 6 you don't remember him being removed from the 7 roster list so when you're doing your rounds 8 and your counts. 9 MS. NOEL: No. 10 MR. : You know how many are 11 supposed to be counting. 12 MS. NOEL: No. 13 MR. : Alright. We're just 14 going to talk a little bit about counts and 15 rounds. According to you, what is a cell count 16 and you have it in front of you if you need to 17 refer to the policy. But what is your 18 understanding of a cell count? Or sorry, an 19 inmate count. 20 MS. NOEL: You count every inmate to make 21 sure that they're alive. 22 MR. : To make sure that they're 23 alive? And accounted for? 24 MS. NOEL: Yes. 25 MR. : Alright. And can you EFTA00118405

181 1 just explain the process? 2 MS. NOEL: The first officer goes down and 3 counts. And then the second officer goes down 4 and counts. And we confirm the numbers. 5 MR. : Okay. And prior to 6 confirming the numbers, do you tell the other 7 officer how many you counted? 8 MS. NOEL: No. 9 MR. : Alright. So you get your 10 number, then another officer goes down, gets 11 their number. 12 MS. NOEL: And when they come back. 13 MR. : And is that tier by tier 14 or do you -? 15 MS. NOEL: Yes. Tier by tier. 16 MR. : Tier by tier. Just one 17 person stands outside while the other person -- 18 MS. NOEL: Yes. 19 MR. : -- goes down range and 20 counts the inmates? 21 MS. NOEL: Yes. 22 MR. : So do you have to like 23 see the person moving, see - what do you need 24 to do when you're doing that count? 25 MS. NOEL: You need to see the prisoner EFTA00118406

182 1 move. 2 MR. : Do you have to like talk 3 to them? Make sure they're responsive or 4 anything? 5 MS. NOEL: Or you could see them 6 breathing. 7 MR. : Just as long as you see 8 some life. Okay. So what are the requirements 9 in the SHU on how often is a count conducted 10 for counts? 11 MS. NOEL: Counts is at 4:00. I mean it's 12 been a long time. I really don't remember. 13 But I think 4:00, 10:00, 12:00, 3:00, and 5:00. 14 MR. : Okay. So 4:00 p.m., 15 10:00 p.m., 12:00 a.m., 3:00 a.m., and 5:00 16 a.m.? 17 MS. NOEL: Yes. 18 MR. : And is that every day or 19 is it Monday through Friday? Do you know? 20 MS. NOEL: Every day. 21 MR. : Every day. And you're 22 just making sure they're alive. You don't 23 actually have to speak with them? 24 MS. NOEL: No you don't. 25 MR. : Okay. And what's the EFTA00118407

183 1 difference? What's a round? 2 MS. NOEL: I mean the round you're walking 3 down the tier basically checking to see if 4 they're okay. But you're not counting. You're 5 just checking to make sure. 6 MR. : So you're doing the same 7 thing you're just not counting -- 8 MS. NOEL: Counting. 9 MR. : -- the inmates? Alright. 10 So you're making sure that they're okay and 11 they're alive. But you're not just -- 12 MS. NOEL: Counting. 13 MR. : -- actually making sure 14 they're 15 MS. NOEL: Yeah like you don't need a 16 number. 17 MR. : But one CO goes down, 18 checks, and then does the other one? Or does 19 there only need to be one? 20 MS. NOEL: Well it's one. 21 MR. : So both don't need to 22 actually do that? 23 MS. NOEL: No. 24 MR. : Alright. So just one CO 25 goes down. Does the other CO have to remain at EFTA00118408

184 1 the door to make sure that CO is okay? 2 MS. NOEL: Yes. 3 MR. : Okay. So is that the 4 difference then? 5 MS. NOEL: Between the counts and the 6 rounds. Yes. 7 MR. : Only one CO is required 8 and that's per your understanding of policy. 9 MS. NOEL: Yes. 10 MR. : Okay. And during a 11 round, do you have to speak with the inmates? 12 MS. NOEL: You don't have to. 13 MR. : No? But on both 14 instances both COs have to be present. You're 15 just saying with rounds, only one CO actually 16 needs to go down. 17 MS. NOEL: Go down range. Yeah. 18 MR. : You said the purpose is 19 to make sure they're okay and they're alive? 20 MS. NOEL: Yes. 21 MR. : And are they - are the 22 counts and the rounds both documented? 23 MS. NOEL: Yes. 24 MR. : And do you have to sign 25 documents when you conduct counts and rounds? EFTA00118409

185 1 MS. NOEL: Yes. 2 MR. : Okay. Now if you and 3 another officer like on the case of when you 4 work 12:00 a.m. to 8:00 a.m. If you and 5 another officer are the only ones assigned to 6 the SHU, are you both just as responsible for 7 documenting the round sheets and the count 8 slips? So if you're the one documenting all 9 the rounds for the 30-minute rounds, is your 10 documentation - does that also carry weight for 11 the other person that's with you? Are you 12 signing for both of you? 13 MS. NOEL: I don't think so because it's 14 just my signature. 15 MR. : So you would take 16 responsibility for the cell count rather than 17 saying that you're both responsible? Or the 18 round -? 19 MS. NOEL: Well the rounds and the counts 20 have to be done with two people. 21 MR. : But -. 22 MS. NOEL: But on the -. 23 MR. : Let me just show you so 24 you know what I'm talking about. I'm just 25 going to show you for August 9th and 10th the EFTA00118410

186 1 cell counts and the rounds so that there's no 2 misunderstanding. So this first one is going 3 to be the 8/9/2019 for the 30-minute check 4 sheet. And the other one is going to be 5 8/10/2019. Can you just let me know if you see 6 your handwriting and initials on these two 7 documents? 8 MS. NOEL: Yes. 9 MR. : Okay. Do you see it on 10 both? 11 MS. NOEL: Yes. 12 MR. : Okay. And I guess we'll 13 first discuss August 9th. Where do you see it 14 and from what time to what time? 15 MS. NOEL: From 4:00 to 11:30. 16 MR. : And are you ever one of 17 them? 18 MS. NOEL: Yes. 19 MR. : Okay. So every 30 20 minutes, you have your initials. And you wrote 21 those. That's actually your initials on that 22 one? 23 MS. NOEL: Yes. 24 MR. : And what about on August 25 10, 2019? EFTA00118411

187 1 MS. NOEL: Yes. 2 MR. : Okay. So what I'm asking 3 here is by you placing those initials is that 4 now fall on you? Or if you're only two people 5 in there like on August 10th -- 6 MS. NOEL: Mm-hmm. 7 MR. : -- are you basically 8 signing for both people? Or do you think 9 you're only signing for yourself there avowing 10 that the round was conducted. 11 MS. NOEL: I don't know. 12 MR. : Okay. 13 MS. NOEL: I guess because like you're 14 trying to say if the rounds have to be 15 conducted with two people, when I sign it would 16 be -. I don't know. 17 MR. : Okay. But you did sign 18 and certify that they were conducted? 19 MS. NOEL: Yes. 20 MR. : Okay. And what do you do 21 with the rounds - the sheets - how are they 22 maintained? 23 MS. NOEL: Well I usually fill it out like 24 prior in hopes to conduct the round. Like when 25 I work in the SHU, I've never actually done the EFTA00118412

188 1 round every 30 minutes. Like when you go down 2 to give out toilet paper, that's counted as a 3 round. To pick up trays, it's counted as a 4 round. To give out food, that's counted as a 5 round. But and then you fill it out either 6 after or before. You're not sitting like every 7 30 minutes like filling it out. 8 MR. : Okay. And you're - you 9 said you do it a lot of times prior to actually 10 conducting the round? 11 MS. NOEL: Yes. 12 MR. : Alright. And with 13 rounds, do you call anybody with that 14 information? 15 MS. NOEL: No. 16 MR. : What's done with the 17 sheet? Is it at the end of the shift something 18 done with it? Are they logged into the BOP 19 database at all? What happens with those 20 sheets? 21 MS. NOEL: I don't know. Because it's 22 left on the table. I don't know what they do 23 with them. 24 MR. : So as far as you know, 25 you just fill it out and you leave it there? EFTA00118413

189 1 MS. NOEL: Yes. 2 MR. : Okay. You don't ever 3 provide it to anyone. 4 MS. NOEL: No. 5 MR. : And you don't ever go 6 into any BOP database and enter those rounds. 7 MS. NOEL: No. 8 MR. : Do you know if someone 9 else does? 10 MS. NOEL: I don't know. 11 MR. : You don't know. Okay. 12 What about with counts? Do you call people 13 after you do the counts? 14 MS. NOEL: Yes. Control. 15 MR. : You call control? 16 MS. NOEL: Yes. 17 MR. : And do you recall on 18 August 9th or August 10th you called - did you 19 call anyone with those numbers? 20 MS. NOEL: Yes. 21 MR. : Okay. And do you 22 remember which counts you called? 23 MS. NOEL: I don't remember which. 24 MR. : You know you did some of 25 them you just don't remember specifically which EFTA00118414

190 1 ones? 2 MS. NOEL: Which ones. 3 MR. : Okay. And do you 4 remember speaking with lieutenants when you're 5 there or with regular officers assigned to the 6 control center? 7 MS. NOEL: I don't remember who I spoke 8 to. 9 MR. : You don't remember. Well 10 with the count slips, you said you just leave 11 those round slips on the table. When you're 12 done - when you do the count slips, what do you 13 do with those slips? 14 MS. NOEL: We did the same thing. We 15 filled them out before. 16 MR. : Before you actually 17 conduct the count before you filled them out. 18 MS. NOEL: Yes. 19 MR. : So before actually even 20 getting the number, you fill out the number? 21 MS. NOEL: Because we know the number. 22 MR. : Okay. So do you then 23 call somebody with the number? 24 MS. NOEL: Yes. 25 MR. : Who do you call? EFTA00118415

191 1 2 3 4 MS. NOEL: Control. MR. : Control? Okay. And you provide them the number that you wrote on that document? 5 MS. NOEL: Yes. 6 MR. : Sorry, we did this. My 7 question was supposed to be what do you do with 8 the physical pieces of paper? 9 MS. NOEL: Stick it in the door and then 10 internal takes it. 11 12 MR. in -- : So no one actually comes 13 MS. NOEL: No. 14 MR. : -- to the SHU? You stick 15 it in what door? 16 MS. NOEL: The outer door. 17 MR. : So you open up the 18 interior - the inner door and then you go to 19 the outer door and you -- 20 MS. NOEL: Stick it in there. 21 MR. : -- there's like a special 22 slot for it? 23 24 MS. the door. NOEL: Not a slot. It's just between 25 MR. : Okay. Internal never EFTA00118416

192 1 comes in though? 2 MS. NOEL: They didn't that day. I don't 3 know if they ever come in, but they didn't 4 (Indiscernible *02:17:51). 5 MR. : Okay. On August 9, 2019, 6 you said you filled all that out. What rounds 7 did you conduct during your shift on August 9, 8 2019? 9 MS. NOEL: That's hard for me to tell 10 because I didn't conduct it every 30 minutes. 11 It was give out food, pick up the trays, give 12 out toilet paper, go down. So those were the 13 rounds that I conducted. Bu it don't. 14 MR. : So you were counting a 15 round as just doing something with an inmate? 16 MS. NOEL: Yes because I actually 17 physically walked. 18 MR. : Every tier all six? 19 MS. NOEL: Yes. 20 MR. : Is there six tiers in the 21 SHU? 22 MS. NOEL: Yes. 23 MR. : Okay. 24 MR. : Two floors - two levels. 25 MS. NOEL: Yes. Yes. EFTA00118417

193 1 2 3 4 MR. : So when you do these rounds, when you would go down range and handle an inmate or give something to an inmate, you would then also do all six? 5 MS. NOEL: Yes. 6 MR. : Alright. So about how 7 often -. Let's ask it a different way. About 8 how many of those didn't you do on August 9th? 9 MS. NOEL: I don't know. I can't give a 10 number of how much I didn't do. But. 11 MR. : Are some of those that 12 were documented, were they not done? 13 MS. NOEL: Yes. 14 MR. : Alright. So you didn't 15 do some of them. You just don't know which -- 16 MS. NOEL: Ones. 17 MR. : -- ones? 18 MS. NOEL: Right. 19 MR. : Alright. And -. Okay. 20 MR. FOY: Let me just say to help clarify. 21 MR. : Absolutely. 22 MR. FOY: The times that you wrote down. 23 MS. NOEL: Okay. 24 MR. FOY: Right? 25 MS. NOEL: Mm-hmm. EFTA00118418

194 1 MR. FOY: When did you write the times 2 down? 3 MS. NOEL: Before. 4 MR. FOY: Alright. So when you did a 5 round to take toilet paper, did you change the 6 time to reflect that particular round? Did you 7 do anything with the paperwork to change -- 8 MS. NOEL: No. 9 MR. FOY: -- the actual time? 10 MS. NOEL: No. 11 MR. : And why did you do that? 12 Is it because of the requirement? 13 MS. NOEL: Why did I fill -? 14 MR. : Why did you fill these 15 ahead of time? Were you just trying to stay on 16 top of what the actual requirement was to 17 conduct a 30-minute round was? 18 MS. NOEL: I mean I don't know why I did 19 it. I just always did it that way. 20 MR. : Did someone train you to 21 do it that way? 22 MS. NOEL: I mean I've seen it done that 23 way before - after. And three's people that 24 actually do it as they do it. It's been done 25 all three different ways. EFTA00118419

195 1 MR. : Some do it before, some 2 do it during, some do it after? 3 MS. NOEL: Yes. 4 MR. : And just this instance 5 you did it all before? 6 MS. NOEL: Yes. 7 MR. : Alright. And some - at 8 least some of them. Would you say the majority 9 were not done or were done? 10 MS. NOEL: On the 9th? Majority was done. 11 MR. : You believe the majority. 12 Now I know we're doing estimates because you 13 don't know exactly. You think like 51% or do 14 you think -? 15 MS. NOEL: I don't know. 16 MR. : You don't know. 17 MS. NOEL: No. 18 MR. : Alright. But again, for 19 the ones that you did do, you're not just going 20 down one tier. 21 MS. NOEL: No 22 MR. : You're going down all six 23 tiers? 24 MS. NOEL: I'm doing all. 25 MR. : You are? EFTA00118420

196 1 MS. NOEL: Yes. 2 MR. : And that's - this is the 3 under-oath thing. We've got to make sure 4 because the video is and all that kind of 5 stuff. 6 MS. NOEL: Yes. 7 MR. : That's your 8 understanding? 9 MS. NOEL: Yes. 10 MR. : Alright. That you're 11 actually checking every door. 12 MS. NOEL: Yes. 13 MR. : And when you go give that 14 one-person toilet paper or whatever, you're 15 actually looking at all the different doors? 16 MR. FOY: Can we take a break real quick? 17 Because I need to take a break. 18 MR. : Absolutely. 19 MR. FOY: (Indiscernible *02:20:53) 20 MR. : Yeah-yeah. Absolutely. 21 Alright. So it is currently 12:35 p.m. We are 22 going to take a quick break. [Whereupon, the 23 above-entitled matter went off the record and 24 went back on the record.] The recorder is back 25 on. This is Senior Special Agent EFTA00118421

197 1 . It is 12:49 p.m. Ms. Noel, I 2 remind you this is a voluntary interview and 3 you are under oath. 4 MS. NOEL: Mm-hmm. 5 MR. : Alright. Is there 6 anything that we wanted to revise before we 7 continue? 8 MR. FOY: Yeah. I want her to go back. 9 This was from earlier about the double door. 10 How they operate. 11 MR. : Okay. 12 MR. FOY: I think there were some 13 unintentional inaccuracies on that. 14 MR. : Sure. 15 MR. FOY: That we clarified. So let's 16 start with that first. 17 MS. NOEL: The outer door control pops the 18 outer door. I control the inner door. So the 19 outer door can only be opened by control. 20 MR. : Okay. So we were talking 21 about like popping the -. It was just your 22 memory was foggy? 23 MS. NOEL: I don't remember a lot of 24 stuff. But yeah. The outer door, you have to 25 call control to pop the 27 door. And we EFTA00118422

198 1 control the inner door. 2 MR. : Okay. And then just 3 while we're going back. It's something I was 4 probably going to follow-up on later. But 5 there's been a ton of questions of like you 6 don't know. 7 MS. NOEL: Yes. 8 MR. : I just want to remind you 9 - you did go to the Federal Law Enforcement 10 Training Center -- 11 MS. NOEL: Yes. 12 MR. : -- where you were trained 13 as a correctional officer. And you also 14 received this IF training which I think you 15 said was like a two-week in-house training. 16 MS. NOEL: Yes. 17 MR. : Is that what that was? 18 As well as you received the annual training. 19 And all this stuff that we're talking about 20 isn't like the real detailed stuff. This is 21 like you know conducting counts and rounds. 22 And the essential duties as a correctional 23 officer. So I'm assuming you -. Is it safe to 24 assume that you received this training you know 25 during those trainings? I know you didn't go EFTA00118423

199 1 to the SHU trainings. But not too far from 2 when this happened, you were only on for a 3 little over a year. And you conducted all 4 three of those trainings. Correct? 5 MS. NOEL: I was only on for a little 6 under a year. The training that I received in 7 Georgia is specific to camps and not 8 necessarily high rises. And the in-house 9 training, the roster reflects all these 10 trainings but we didn't' actually receive all 11 the training because sometimes there was nobody 12 to train us. 13 MR. : Okay. 14 MS. NOEL: So when I say I don't know, I 15 don't know. 16 MR. : Yeah, no. It's just 17 almost every question. I feel like we've gone 18 through 18 pages so far and so many of them are 19 20 MS. NOEL: Because I really -. 21 MR. : -- like I don't know. 22 So. 23 MS. NOEL: I really don't know. 24 MR. : Alright. It's just 25 because you know people are going to say like EFTA00118424

200 1 well you went to all these trainings. You 2 should know at least some of this stuff. So I 3 just wanted to try to get you to like think 4 back on your training. 5 MS. NOEL: Mm-hmm. 6 MR. : And your duties and your 7 responsibilities when I'm asking these 8 questions just so you can really like think. 9 Do I really now know or is that you know, did I 10 know that these things should be done. Does 11 that make sense? 12 MS. NOEL: Correct. 13 MR. : And then um -. 14 MR. : Can I say -? 15 MR. : Yes, please. 16 MR. : Just to clarify. I know you 17 might not have received some of the official 18 trainings. Some of this stuff you might learn 19 along the way. 20 MS. NOEL: Mm-hmm. 21 MR. : From your daily duties. 22 MS. NOEL: Right. 23 MR. : Like it's repetitive. Some 24 of the stuff that you do. So you might have 25 known this based on the fact that you've done EFTA00118425