101 1 2 3 4 Right. When did you go to the SHU? MS. : Like I said earlier, I think it was MR. : Can you do me a favor? Can 5 you sign it and date it just like before? 6 MR. : Initial and date on the 7 top. 8 MR. : Initial. 9 MS. : Which one? 10 MR. : All of them. 11 MR. : Oh. Since I showed you. 12 MS. : Okay. 13 MR. : I'll take that. When did you 14 -? Did you make a round into the SHU on August 15 10th? 16 MS. : Yes. 17 MR. : What time? 18 MS. : I don't remember what 19 time. It was like halfway between my shift 20 later on in the morning. 21 MR. : Did you speak to -? 22 MS. : Probably about 4:-- 23 something. Between 4:00 and 5:00 I guess. 24 MR. : Do you recall who the COs 25 were on duty? EFTA00114284

102 1 MS. : Yes. Thomas and 2 Noel. 3 MR. : Okay. Did you speak to them? 4 MS. : Yes. 5 MR. : Okay. And everything was 6 good? Did they say have any complaints or 7 anything like that? 8 MS. : No. They were fine. 9 MR. : Do you recall your 10 conversation at all? 11 MS. : I don't recall my 12 conversation with them, but I spoke to them for 13 a minute because I stopped there. I went up to 14 10 South and I made my rounds up there. And I 15 came back and I spoke with them again before I 16 left. 17 MR. : So you spoke with them 18 twice? 19 MS. : Yeah. I spoke with 20 them initially. And I told them you know when 21 I get back out -. I'm going to run up to 10 22 South and make my rounds and sign my books and 23 stuff up there. And then I'll get back with 24 you guys. I'll come back on my way down. 25 Because I needed to sign their round sheets. EFTA00114285

103 1 MR. : Okay. 2 MR. : Now you mentioned that you 3 don't know - you never heard of the requirement 4 for Epstein needing a cellmate. Right? 5 MS. : Right. 6 MR. : So you didn't know. 7 According to what you said before, you didn't 8 even know the COs knew that requirement. 9 MS. : If I didn't know, I 10 know they didn't know. And according to that 11 because I don't even see Where is that 12 email? Because I want to see who did they 13 actually send that to. If it says on the email 14 who they sent that to. 15 MR. : It looks like they sent 16 it up to all the officers, lieutenants and. 17 MS. : This says suicide 18 watch/psych observation update. 19 MR. : So on or around July 20 30th, Epstein came off of the suicide 21 observation and was placed back into the SHU. 22 And this was supposed to be the email saying 23 that he was required to have a cellmate while 24 he was in the SHU. 25 MS. : Yeah, but this isn't EFTA00114286

104 1 MYM all. 2 MR. : Right. So you said you 3 think it should have gone to all staff. 4 MS. : Yeah-yeah. 5 MR. : So I guess what I'm 6 MS. : This is only 7 addressed to suicide - whoever is in that 8 group. It looks like a group that they made 9 up. Because I never heard of that group 10 before. Suicide watch/psych -. 11 MR. 12 them? 13 MR. 14 MS. You never got the email from : Sure. So -. : Slash psych 15 observation update. I guess that's a group. 16 MR. : So these are the -. So 17 the one - pages one through three. These are 18 the people that they I guess placed in that -- 19 MS. : That they placed in 20 that group. 21 MR. -: group. And it looks 22 like it's all the lieutenants and the officers 23 in the institution as opposed to the COs 24 themselves. 25 MS. : You mean specific EFTA00114287

105 1 officers? Specific staff? Because I can 2 assure you that's not all of them. 3 MR. : That's not all of them. 4 Yeah. So I don't know how they actually chose 5 it. But you said you know you were on it but 6 you don't recall receiving it. 7 MS. 8 receiving that. 9 MR. : I do not recall : Now do you know -? I 10 don't know how it works here. I mean are you 11 in front of your computer? Do you read your 12 emails? How is that? 13 MS. : During that time, I 14 will be honest with you. I didn't have time to 15 read any emails because in addition to not 16 having a lot of staff, we had a bunch of 17 incidents that were going on during that time 18 as well. 19 MR. : Okay. 20 MS. : A bunch of body 21 alarms and stuff like that that was going on. 22 And because of the fact that we were so short- 23 handed, you didn't have time to read emails and 24 stuff at the time. You just had too much to do 25 with the time in your shift. It was just way EFTA00114288

106 1 too much. 2 MR. : Sure. 3 MS. : It was way too much. 4 MR. : So although this was sent 5 to you, you don't think you probably even 6 clicked on it? 7 MS. : I got a lot of emails 8 during that time that I can assure you I didn't 9 read. 10 MR. : Sure. Alright. So you 11 were unaware. How does it work -? Just can 12 you walk me through specifically on you know if 13 Reyes the cellie. Did you know that Epstein 14 had a ceilmate? 15 MS. : I didn't know Epstein 16 had a ceilmate. 17 MR. : So you didn't even know 18 he had a cellmate at all? 19 MS. : I didn't know if he 20 had a cellmate or not. 21 MR. : Okay. 22 MS. : When all of this 23 happened, it of course later came out that he 24 had a cellmate and the inmate was removed. But 25 as far as me having personal knowledge of EFTA00114289

107 1 whether or not he had a cellmate, I didn't know 2 if he had a cellmate or not. I assumed he had 3 a cellmate. 4 MR. : Now being that you know 5 they sent this email. You said who should have 6 advised you at least at some point, hey he 7 needs a cellmate. Where was the communication 8 breakdown there? 9 MS. : It wasn't just me. 10 It should have been everybody. 11 MR. : Sure. So what my question 12 is though, who is responsible for that? 13 MS. : The - you would think 14 that psychology would have called us or 15 somebody should have been making sure. 16 MR. : Okay. So let's go 17 through that. From psychology, who should 18 who dropped the ball here? 19 MS. : Well I'm not going to 20 say anybody dropped the ball because it's all 21 about responsibilities to -. 22 MR. : But somebody - psychology 23 I guess made the note. So is it the person 24 that's on the email, this 25 (Phonetic Sp. *01:39:47) Should have she gone EFTA00114290

108 1 around and aside from sending this email should 2 have she spoken to people or had a meeting? 3 What should have happened? 4 MS. : I mean if that's what 5 she -. I just feel as though they that - to 6 communicate Like I said originally. My 7 whole thing was Epstein should have been placed 8 on 10 South to begin with because he was that 9 type of inmate that checked all the boxes for - 10 - 11 MR. : Sure. 12 MS. : -- someone that 13 should have been placed on 10 South. 14 MR. : And that's going to be 15 one of my follow-up questions is what the 16 difference between the SHU and 10 South. But 17 specifically to this, like what should have 18 psychology done differently? 19 MS. : I would have made 20 sure - I just would have -. I just would have 21 made sure that everybody -. I never even would 22 have sent Epstein back to -. I would have 23 never even put him back in that position again. 24 MR. : So if he had -. 25 MS. : If he had a cellmate EFTA00114291

109 1 because even saying that he had a cellmate. 2 Even telling somebody that he should have had a 3 cellmate. Still wouldn't have prevented him 4 from trying to harm himself. We had just went 5 through that. 6 MR. : Sure. 7 MS. : We - that was a 8 scenario when they got him. That got to the 9 memo being done. 10 MR. : Okay. So -. 11 MS. : You know? He had a 12 cellmate then. 13 MR. : The other lieutenants 14 though in this case, they knew that he was 15 required to have a cellmate. Correct? 16 According to -- 17 MR. : Yes. 18 MR. : -- there? So it sounds - 19 From reviewing the other interviews, it 20 looks like you were the one that didn't know. 21 everyone else knew. Do you know why that would 22 have been? Who should have made sure you knew 23 that he needed a cellmate? 24 MS. : I would think whoever 25 knew that he needed an inmate. EFTA00114292

110 1 MR. : So that's what I'm 2 saying. Everyone else know. So like all the 3 other lieutenants and the captain. They all 4 said that they were aware that he was required 5 to have a cellmate. So the question So I 6 don't know if they got the information from the 7 email, if there was an all-hands. Who should 8 have made sure that you knew that he had a 9 cellmate? 10 MS. : Okay. So if they 11 knew that. If everybody is saying that they 12 knew he should have had a cellmate, then why 13 didn't he have one? 14 MR. : That's the -. 15 MS. : How did we get to 16 that? 17 MR. : That's the reason why 18 we're talking with you. That is the big issue 19 of why didn't he have one? Who? Where was the 20 communication breakdown? 21 MS. : I don't know. 22 MR. : So should have the 23 captain told you that? Should have the person 24 who relieved you that day? Should have that 25 person told you? Hey just so you know, Epstein EFTA00114293

111 1 doesn't have a cellmate. 2 MS. : It would have been 3 nice to have when I got relieved for someone to 4 have said yeah, by the way, we got this email 5 saying that we were notified the Epstein now 6 requires to have a cellmate. Yeah. That would 7 have been real helpful. 8 MR. : So looking at the Friday, 9 August 9th. Was it -? It looks like 10 Was that the person who relieved you? As the 11 ops lieutenant? It looks like he was the ops 12 lieutenant. 13 MS. : You relieved him. 14 MS. : Yeah. I would have 15 16 MR. : No. She relieved him. 17 It was August 9th. 18 MS. : Yeah. That would 19 have been who I would have relieved. 20 MR. : Or he would have relieved 21 you. Correct? Because that's August 9th. You 22 started August 10th at 12:00 a.m. So let's see 23 how it shows here. 24 MS. : I would have relieved 25 because was evening watch. EFTA00114294

112 1 MR. : But this was August 9th. 2 And you started August 10th, 12:00 a.m. 3 MS. : Right. So that would 4 have bene evening watch of -. 5 MR. : You would have relieved 6 him. Correct. 7 MS. : Right. I would have 8 relieved him. 9 MR. : And so should have he 10 told you? 11 MS. : I would - I mean -. 12 MR. : How would then -? Or 13 should have -? would have been gone. 14 So I'm assuming he would have been the one? 15 MS. : Let me tell you 16 something. In the real world in a real 17 institution that was running in the manner in 18 which it should. 19 MR. : Sure. 20 MS. : Sure. That would 21 have 22 MR. : And you're not saying -- 23 MS. occurred. 24 MR. that he did anything 25 wrong. EFTA00114295

113 1 MS. : And I'm not -. 2 MR. : Let's get this place up 3 to running as best as possible. 4 MS. : No. Let me -. 5 MR. : Where should have this 6 communication occurred? 7 MS. : Let's make something 8 clear right now. 9 MR. : Yeah. 10 MS. : I'm not here to cover 11 for anybody. 12 MR. : Yeah-yeah-yeah. 13 MS. : I'm not here to make 14 excuses for anybody or any of that. 15 MR. : Right. 16 MS. : What I'm trying to 17 get over to you is that at that particular time 18 when - even before 19 MR. : Mm-hmm. 20 MS. : Um....this incident 21 happened with Epstein. Even before the 22 suicide. We were so busy with a number of 23 different things. 24 MR. : Sure. 25 MS. : We were here when we EFTA00114296

114 1 were finding shanks every - an unusual amount 2 of shanks, cell phones, drugs. Inmates were 3 going out of their mind on drugs and all this 4 other stuff. We had inmates fighting, inmates 5 getting stabbed, inmates getting slashed. 6 There were -. In addition to everything else 7 that we had to take care of. We were doing 8 uses of forces. We didn't' have adequate staff 9 to even do a use of force or even to respond to 10 a body alarm a lot of times. There were 11 incidents where we as lieutenants were the only 12 people here and had to do things. So -. 13 MR. : So there's just 14 overwhelming You guys were just completely 15 overwhelmed. In the weeds. 16 MS. : We -. At that time, 17 there was just so much going on. 18 MR. : Right. 19 MS. : You would be hell- 20 bent to stay abreast of every little thing that 21 was going on. You just -. When your relief 22 came, you know, you was like let me get some 23 fresh air. 24 MR. : Just let me -. In this 25 circumstance. We're going to try to reign it EFTA00114297

115 1 in specifically to -. 2 MS. : If everything was 3 going fine -- 4 MR. : So how -. 5 MS. : -- and on a good day. 6 Yes. 7 MR. : Say he was - Reyes - 8 Epstein's inmate was released you know sometime 9 between 8:00 and 2:00. So I'm assuming the way 10 it should have worked is the CO should have 11 notified a lieutenant. The lieutenant maybe 12 should have notified the ops lieutenant. The 13 ops lieutenant should have notified the 14 captain. Is that the way it should have worked 15 in a perfect world? 16 MS. : It depends on who is 17 here. 18 MR. : But should -. So -- 19 MS. : I'm saying that's -- 20 MR. that's why we're 21 looking at the 9th. 22 MS. : -- what I would have 23 done. 24 MR. : Right. 25 MS. : I can't tell you what EFTA00114298

116 1 somebody -- 2 MR. : Because - but would that 3 -- 4 MS. : -- else would have 5 done. 6 MR. : -- be standard operating 7 procedure? That's the way it works? 8 MS. : That's not standing. 9 That's just what I would have done. 10 MR. : Okay. 11 MS. : Just to make sure 12 that -. 13 MR. : So let's say -. 14 MS. : Just to answer the 15 questions that I would have had regarding that. 16 MR. : So -. 17 MS. : I can't explain -. I 18 can't tell you what somebody else would have 19 done. 20 MR. : So let's say -- 21 MS. : Or should have done. 22 MR. for instance. 23 He was on the looks like 8:00 to 2:00 p.m. 24 Let's say he knew that Reyes was gone and 25 Epstein was required to have a cellmate. What EFTA00114299

117 1 should have he done? Should have he notified 2 and should have he notified 3 MS. used to -. If 4 he wasn't at that time, used to be the 5 SHU lieutenant. So probably would have 6 told them put somebody else in the cell with 7 him. 8 MR. : Okay. 9 MS. : You know? 10 MR. : So you think he would 11 have just taken immediate action? 12 MS. : I think he probably 13 would have said just put somebody in the cell 14 with him and call and say hey this dude 15 don't have a cellie. I took care of it or 16 whatever. 17 MR. : Now what about if -- 18 MS. : Or maybe he -. 19 MR. the executive staff 20 wants to have a hand in picking and choosing 21 who it is that Epstein is assigned to because 22 of his high-profile status? Should have 23 still done that temporarily? Or should have 24 just notified 25 MS. : That is - that wasn't EFTA00114300

118 1 written in stone. 2 MR. : Okay. 3 MS. : That is something 4 that I would have done. 5 MR. : You would have done what? 6 MS. : I would - that's 7 something that I would have done. 8 MR. : Was that temporarily? 9 MS. : I'm not saying that 10 that's across the board that every operations 11 lieutenant that was here that day and was that 12 found themselves in that position. I'm not 13 going to say that's what -. There's no 14 standard procedure for that situation because 15 that's out of the ordinary. First of all, if 16 we're going to go by what should have been 17 done, Epstein should have been on 10 South. 18 That's what should have been done. 19 MR. : Okay. 20 MS. : Period. 21 MR. : And what -? 22 MS. : Now everything when - 23 . 24 MR. : So you keep on going back 25 to 10 South. EFTA00114301

119 1 MS. : Right because -- 2 MR. : What the difference 3 between -- 4 MS. : -- that's how -- 5 MR. 10 South -? 6 MS. : -- important it is. 7 MR. : So what's the difference 8 between 10 South and the SHU? 9 MS. : The difference 10 between SHU is that SHU is for general 11 population inmates. 12 MR. : Okay. 13 MS. : You know. You're not 14 guaranteed to have a cellie there. You know. 15 So you may have a cellie and you may not. 16 Epstein was a high-profile inmate. All high- 17 profile inmates they usually assign to 10 18 South. Epstein had just -. Even before he 19 committed suicide. Everybody knew and that's 20 not just here. That's people in the region. 21 You know all the way up to Donald Trump knew 22 Epstein was here. You know. And when you look 23 at Donald Trump all the way down the line, you 24 know, to the regional director, the 25 correctional services administrator. All those EFTA00114302

120 1 people should have been involved in where 2 Epstein was placed when he got here. Now that 3 you know because they failed to do their job, 4 you know, and place him on 9 South where he 5 never should have been to begin with. 6 MR. : Nine South or 10? Oh 7 they put him in 9 South. 8 MS. : 9 South. 9 MR. : Okay. 10 MS. : They placed him in 11 regular old SHU. 12 MR. : Okay. 13 MS. : For inmates that 14 faced disciplinary action. Inmates that are 15 being separated from other inmates in 16 protective custody. Those to - things of that 17 nature. 18 MR. : So -. 19 MS. : If he -. 20 MR. : In 10 South, do inmates 21 all have cellmates in 10 South? 22 MS. : Inmates on 10 South 23 don't have cellmates. But. 24 MR. : Okay. 25 MS. : What they do have up EFTA00114303

121 1 there -. And I'm telling you he should have 2 been put up there from day one. Most 3 especially after he attempted suicide. So if 4 you didn't place him up there from day one. 5 When he attempted suicide with a cellmate. 6 Okay? Let's not forget that because when he 7 attempted suicide, he had a cellmate. 8 MR. : Yeah but isn't the reason 9 why he didn't - wasn't successful partly 10 because of the cellmate? My understanding was 11 because once you're - once you commit suicide, 12 you want another person to try to prevent it 13 from actually a suicide being successful. So 14 if they want someone in there to basically 15 watch him, wouldn't they want him in the SHU 16 versus 10 South? 17 MS. : You're not guaranteed 18 that -. 19 MR. : You're not guaranteed but 20 I think that the purpose of him being required 21 a cellmate was that they want someone in there. 22 And that's why they wanted him vetted. Because 23 the purpose was so that someone could be 24 watching him partly. If he's trying to hang 25 himself, there's obviously going to be another EFTA00114304

122 1 celimate in there saying what are you going? 2 MS. : First of all, an 3 inmate don't owe you nothing. 4 MR. : Sure. 5 MS. : Another inmate don't 6 owe you anything. And another inmate by policy 7 is not to be supervising another inmate. So by 8 you saying - because I don't even agree with 9 inmate companions. 10 MR. : Okay. 11 MS. : I've known a lot of 12 inmate companions who would antagonize the 13 person on watch just so they hang their damn 14 selves. Okay? 15 MR. : Okay. 16 MS. : So for you to sit 17 here and put somebody who you know is as high- 18 profile and as important as everybody made 19 Epstein out to be at that time, you relied on a 20 random inmate to keep him safe. I mean, that's 21 You're fooling yourself. 22 MR. : Okay. 23 MS. : You're fooling 24 yourself. 25 MR. : Okay. So just for your EFTA00114305

123 1 own personal opinion was that he should have 2 been on 10 South and he shouldn't have had an 3 inmate at all. He should have just had closer 4 eyes on by staff members? 5 MS. : That's not my 6 personal opinion. That's my professional 7 opinion. 8 MR. : Right. 9 MS. : Because I've worked 10 in this environment -- 11 MR. : Sure. 12 MS. : -- long enough to 13 know -- 14 MR. : Okay. 15 MS. : -- that if somebody 16 said important to you 17 MR. : Where psychology -. 18 MS. : -- and you wanted to 19 keep them safe, and for the type of inmate that 20 he was, that was the best environment for him. 21 They have cameras up there in every cell. And 22 they have a staff member 23 MR. : There's cameras in the 24 cell themselves? 25 MS. : There's cameras in EFTA00114306

124 1 each individual cell. And there is - the 2 officers have monitors right by their desk. 3 MR. : Okay. 4 MS. : So. 5 MR. : So if they would have had 6 eyes on at all times. 7 MS. : They would have had 8 eyes on him at all times. 9 MR. : Awesome. Okay. So 10 alright. I just wanted to get 11 MS. : And I mean -. 12 MR. : I really wanted to find 13 out though, in this specific circumstance, who 14 should have told you? That's the main 15 question. 16 MS. : I mean a lot of 17 people. 18 MR. : Who should have informed 19 you. 20 MS. : A lot of people could 21 have told me. 22 MR. : Right. 23 MS. : A lot of people could 24 have told me. 25 MR. : And you didn't have any EFTA00114307

125 1 conversations with anyone about that 2 requirement? Because again, it seems like 3 everybody else knew. You didn't. So I'm just 4 trying to figure out where that communication 5 breakdown 6 MS. : I don't know where it 7 8 MR. : - occurred. 9 MS. : -- occurred. 10 MR. : Okay. 11 MS. : To be honest with 12 you. 13 MR. : Okay. Would have it been 14 the captain is responsible for that? Or is it 15 in this instance, since you said you didn't 16 know at all, should have called 17 told you? 18 MS. : I don't -. Look. 19 Look. I'm not going to sit here and tell you 20 what somebody could have, should have, would 21 have done. Because like I said, there was a 22 lot of things going on at this institution. If 23 we're going to say "shoulda-woulda-coulda," 24 then we should have had adequate staffing. 25 MR. : Yep. EFTA00114308

126 1 MS. : We shouldn't have had 2 staff here that were dead on their feet. 3 MR. : Sure. 4 MS. : You know. Trying to 5 watch an inmate. And when all those 6 circumstances that was going on, there was a 7 lot of things that we should have been doing 8 that wasn't done. So it's not just about what 9 happened to Epstein. It's about everything 10 else surrounding his death that occurred that 11 didn't happen. 12 MR. : That's one point. 13 MS. : That should have been 14 occurring that didn't happen. 15 MR. : Okay. Now let's - I'm going 16 to take it out. Let's say you're on shift. 17 Inmate attempted to commit suicide. You know 18 there's an issue with the inmate. You're 19 leaving the shift. Do you have a conversation 20 with the person you're relieving - I mean 21 whoever's relieving you? Do you have a 22 conversation with that person and advise them 23 what happened during your shift? 24 MS. : Yes. I would -. 25 MR. : Why? Why would you do it? EFTA00114309

127 1 Just to reason -. 2 MS. : Because look. Let me 3 explain something to you. 4 MR. : No-no-no. I just need an 5 explanation. 6 MS. : No-no-no. I'm going 7 to give you an explanation. But I'm going to 8 give you the explanation that best suits the 9 question that you're 10 MR. : Okay. 11 MS. : -- asking me. When 12 we do these pass downs, everybody is different. 13 Some people tell you verbatim everything that 14 happened. Some people don't. That's just the 15 nature of the beast. You know. I could sit 16 here all day and say somebody should have told 17 me something. Or you know if they had the 18 information. But when you've got so many 19 things on your mind and you've dealt with so 20 many things during the course of the day, you 21 know, people don't want to continue to stand 22 there and do it. People forget. I mean they 23 could have been standing there talking to me 24 for five minutes with all the things that go on 25 during the course of the day. You know. EFTA00114310

128 1 That's not just here. That's every place I've 2 been when it comes to pass down. Some people 3 will tell you a bunch of stuff depending on 4 when it happened during the course of the day 5 and whatever else came behind it or came before 6 it. People they 7 MR. : No, I understand that. No- 8 no. I just 9 MS. : -- don't always 10 remember. 11 MR. : I get that. But let's just 12 say as Agent already mentioned. If 13 there was instructions form the captain down 14 and the lieutenant. Let's say Lieutenant 15 was aware of the instructions and was clear 16 instructions that Epstein had to have a 17 cellmate. And he knew that the cellmate was 18 removed. What was -. Let's just say in a 19 perfect world. What was his role? When he 20 left the shift. What should he have done? 21 MS. would have -. 22 MR. : No-no-no. It's not "would 23 have." What should he have done? 24 MS. : They would have 25 already had -. If you're telling me that this EFTA00114311

129 1 inmate left at what time? 2 MR. : Well he left the cell at 3 8:30 and by 1:30 he was gone from the 4 institution. 5 MS. : Okay. So by the time 6 I got here at 10:00 at night, he should have 7 already had. That should have already been 8 taken care of. 9 MR. : Okay. And that's what 10 we're asking. Who should have taken care of 11 it? 12 MS. : The first person to 13 have known that he didn't have a cellie. 14 MR. : So if was that 15 person, should have he what should have he 16 done? doesn't work for the BOP anymore. 17 So we're just asking what should have happened? 18 MS. : It doesn't matter 19 even if he was still 20 MR. : I know. I just -. 21 MS. : -- working for the 22 Bureau. I mean. If someone knew for a fact 23 that he was supposed to have had a cellie. And 24 they received some type of information or they 25 came aware of the fact that he didn't. And EFTA00114312

130 1 that inmate was never coming back. Depending 2 on that, they should have questioned to see 3 what was the circumstances surrounding that. 4 When they determine what the circumstances were 5 based upon the fact that if he was coming back 6 or whether or not he wasn't coming back, then 7 they should have made arrangements for him to 8 get another cellie. 9 MR. : Okay. I'm done. Can I see 10 the roster one more time? 11 MR. : Yeah. And then let's 12 stay specific to your instance so we don't have 13 to ask you like what should have they done? So 14 as far as yours. If you - and again you 15 weren't. But if you were aware that he was 16 required to have a cellmate. Was there any 17 action that you should have or could have taken 18 between the hours that you were working? 19 MS. : If I -. 20 MR. : Could cell mates have 21 been reassigned at that time of night? 22 MS. : Morning watch is not 23 the time to be moving inmates around because it 24 presents too much of a safety issue. 25 MR. : Sure. EFTA00114313

131 1 MS. : And being that if we 2 don't have adequate staffing, then -. Morning 3 watch, period. You're not even supposed to be 4 opening doors on morning watch. 5 MR. : So that's my question. 6 If had told you, which obviously he 7 didn't. Correct? 8 MS. : Correct. 9 MR. : If he had, could have you 10 even taken action? 11 MS. : I would have 12 contacted -. Like I said. I would have called 13 or psychology or somebody. 14 MR. : So even at that time of 15 night? 16 MS. : Even at that - yes. 17 Even at that time of the night. 18 MR. : Okay. 19 MS. : To figure out what's 20 going on with I mean I can't justify just 21 leaving him up there without a cellie if he's 22 supposed to have one. How am I going to 23 justify that? And that's not even something 24 that I would even risk. 25 MR. : What about the COs? If EFTA00114314

132 1 the COs knew - so Noel and Thomas - that he was 2 required to have a cellmate. Should have they 3 notified you? 4 MS. : They should have 5 notified me. If they knew that he was supposed 6 to have a cellie and he didn't, yes. And they 7 would have. 8 MR. : And in this -? 9 MS. : If they had known 10 that they would have. 11 MR. : In this instance they 12 never notified you though. Correct? 13 MS. : No. 14 MR. : So they didn't tell you 15 and during this 4:00 a.m. it sounds like you 16 talked to them twice. They never told you that 17 Epstein didn't' have a cellmate? 18 MS. : No. 19 MR. : Did they discuss Epstein 20 with you at all? 21 MS. : No. 22 MR. : Okay. And did they - 23 when they called control or any communications 24 you had over the telephone - did they ever 25 discuss Epstein? EFTA00114315

133 1 MS. : No. 2 MR. : Or the cellmate? 3 MS. : No. 4 MR. : Okay. 5 MS. : No. 6 MR. : So these are the 7 questions. We just want more like yes-no like 8 this. And I don't mean to rush you, but we 9 have a bunch of other interviews we have to 10 conduct. So if we can keep to those like yes- 11 no type of things would be so appreciated on 12 our end. 13 MS. : Well I can assure you 14 that everything is not going to be a flat yes 15 or no answer. 16 MR. : Absolutely. I 100% get 17 that. 18 MS. : Because nothing in 19 this business is 20 MR. : Right. 21 MS. : -- flat yes or no. 22 It's all off the cuff. So. 23 MR. : Absolutely. And that's 24 what we're just saying. Like if knew 25 what should have he done. It sounds like what EFTA00114316

134 1 you're saying is he should have notified the 2 captain and he should have made sure a cellmate 3 was put in there. If knew, same thing. 4 He should have notified the captain, he should 5 have put someone there. If you knew, you 6 should have notified the caption, you should 7 have put someone there. That's just the kind 8 of what the ops lieutenant does. Would it be 9 basically the ops lieutenant if it came up to 10 that person? They notify the captain. They 11 make sure it's done. Is that a fair 12 assessment? 13 MS. : Yeah. That's a fair 14 assessment. And you're just notifying - and 15 the only reason why we're letting the captain 16 know is to let him know. Hey, you know you 17 guys we keep telling you this guy should be on 18 10 South, but you keep him on SHU. And we keep 19 running into these close - really, really, 20 close calls. 21 MR. : So the staff -. 22 MS. : So that's one reason 23 why -- 24 MR. : Is the staff ever -? 25 MS. : -- you notify them. EFTA00114317

135 1 MR. : Did you ever have any 2 discussions about him needing to be 10 South 3 with anyone prior to -? 4 MS. : Everybody was telling 5 them that he needed to be on 10 South. 6 Everybody knew that. 7 MR. : Alright. So prior to him 8 even dying, you know, prior to August 10th. It 9 was the captain and above were notified, hey we 10 need to get him on 10 South? 11 MS. : Let me tell you 12 something. If we as lieutenants are 13 responsible for knowing everything that we're 14 supposed to know. and we're running this 15 institution off the cuff, we don't know what's 16 going to happen here at any given time of the 17 day or night. If we're required to know that, 18 you think that these cats in the region and in 19 the central office and at the executive staff 20 level don't know the same thing that or more 21 than we know? 22 MR. : So I guess the question 23 is have you ever had any conversation - did you 24 ever have any conversations with the caption 25 yourself at that time? EFTA00114318

136 1 MS. : We've mentioned to 2 them several times that Epstein should be on 10 3 South. 4 MR. : So who did you have 5 conversations with regarding that? 6 MS. : We've - I've never 7 had a conversation with anybody. But during 8 these times, when this stuff was happening, I 9 used to always say you guys need to put Epstein 10 on 10 South. Epstein needs to be on 10 South. 11 MR. : So my question is when 12 you say, "you guys," who were you saying that 13 to? 14 MS. . I would tell 15 16 MR. : So you specifically told 17 18 MS. : I would tell 19 that -. 20 MR. : Do you remember what his 21 responses were? 22 MS. : No. I don't remember 23 what his -. Apparently, it was nothing. He 24 never got moved. 25 MR. : Right. And that's what I EFTA00114319

137 1 just meant. Did you say like did he 2 acknowledge at least that information that was 3 provided to him? Hey, he should be on 10 4 South? 5 MS. : I don't know if he 6 did or not. 7 MR. : Bu you do recall actually 8 telling him that? 9 MS. : We all used to say 10 that Epstein needs to be 10 South. 11 MR. : Did you do it with a 12 group of other lieutenants when you say, "we 13 all used to?" 14 MS. : No. 15 MR. : But you yourself. Do you 16 recall at least on one occasion or more that 17 you told that? 18 MS. : Yeah. I mentioned to 19 that Epstein should be on 10 South. 20 Yes. 21 MR. : Prior to August 10th? 22 MS. : I don't know what the 23 date was. 24 MR. : I just mean prior to him 25 dying you told him this? EFTA00114320

138 1 MS. : Yes. Prior to him 2 dying. And after he died. I mean. 3 MR. : Okay. Sorry, I'll hand 4 it back over to you. I apologize for 5 hijacking. 6 MR. : Do you have anything else on 7 that topic? Because I'm going to jump through 8 that. 9 MR. : No. The main things, 10 again, are these about the email. Why it 11 wasn't received. The cellmate requirements 12 which she said that she didn't. who was 13 responsible for telling her that? What action 14 should have been taken. What did she know -? 15 MR. : That's (Indiscernible 16 *02:01:29) 17 MR. : Sure. 18 MR. : So I'm just going to jump to 19 a different topic. 20 MR. : And you mentioned how 21 cameras are so important in 10 South. So now 22 we're going to talk about the cameras that were 23 actually in the SHU. 24 MS. : Mm-hmm. 25 MR. : So basic question. Who had EFTA00114321

139 1 access to see what was happening on the 2 cameras? 3 MS. : What cameras? 4 MR. : The cameras inside the MCC. 5 As a lieutenant did you ever utilize the 6 cameras for your job? 7 MS. : I mean what cameras 8 are you talking about? Because we don't - 9 those of us who have access to cameras don't 10 have access to the same cameras or -. 11 MR. : You want to know about 12 the SHU cameras. 13 MR. : Yeah. It's about the SHU 14 cameras. 15 MR. : Who has access to the SHU 16 cameras? 17 MS. : Control. The control 18 center has access to the SHU cameras. We have 19 access to the SHU cameras. And as far as I 20 know, that's it. 21 MR. : When you say "we," is 22 that the lieutenant's office? 23 MS. : The lieutenant's 24 office. 25 MR. : Do you normally utilize the EFTA00114322

140 1 cameras for your job at all? For you daily 2 routine. Do you ever use it? 3 MS. : If we're looking for 4 - say we're looking for somebody say internal. 5 MR. : Okay. 6 MS. : We may glance at the 7 camera to see if we see them or something like 8 that. But we're not sitting there. We don't 9 even have time to do that. And even if we did, 10 we wouldn't be doing it. We're not sitting up 11 there the whole time during our shift and just 12 looking at the cameras to see what's going on. 13 MR. : No. That's not what I mean. 14 I just want to know. At that time - around 15 that time period, did you know that there were 16 cameras inside the MCC that were not working> 17 MS. : I don't believe I 18 did. 19 MR. : So it -. 20 MR. : Specific to the SHU. 21 MS. : Oh. No. 22 MR. : Did you know the cameras 23 -- 24 MS. : No. 25 MR. : -- in the SHU were -- EFTA00114323

141 1 MS. : No-no-no. 2 MR. not working? 3 MS. : No-no-no. I wasn't 4 aware. 5 MR. : So even though you were 6 the lieutenant at that night did you not know 7 ? 8 MS. : The only cameras that 9 I would know that I would be aware of if 10 they're working or not would be the cameras 11 that I have access to which I can look on the 12 TV monitor and see that they're actively not 13 working at the time. Or one of the other staff 14 members who have access to cameras would call 15 and tell me or say something to me about that 16 camera not working. 17 MR. : And did you know on 18 August 10th during your shift or I guess late 19 August 9th, early August 10th, that any cameras 20 in the SHU were not working? 21 MS. : No. I wasn't aware of 22 that. 23 MR. : As far as you remember, 24 were the live portion of the cameras working in 25 there? The ones that you were able to monitor EFTA00114324

142 1 in real-time. 2 MS. : The camera that we 3 had access to from the lieutenant's office at 4 the time was working. 5 MR. : Would that show you both 6 the staff members as well as the range? 7 MS. : That camera only - 8 that camera was really -. The visibility on it 9 was bad. It has always been bad. 10 MR. : So was it only one camera 11 that you could access from your office of the 12 SHU? 13 MS. : There was only one 14 camera that's up there on that monitor. 15 MR. : Okay. And what does that 16 camera show? 17 MS. : I think it shows like 18 the common area. 19 MR. : Okay. So it doesn't even 20 -- 21 MS. : The SHU. 22 MR. show the range? 23 MS. : The ranges and stuff 24 like that? No. 25 MR. : But are there cameras on EFTA00114325

143 1 the range? 2 MS. : Yes. There's cameras 3 on the range. 4 MR. : So who has access to 5 monitor that? 6 MS. : I mean whoever has it 7 up on their computer 8 MR. : Okay. So you could 9 toggle through what you want to look at. 10 MS. : We can't toggle 11 through -- 12 MR. : Okay. 13 MS. : -- on our cameras in 14 the lieutenant's office. No. 15 MR. : Okay. 16 MS. : And I don't 17 MR. : So in the lieutenant's 18 office, it's just -. Would control center? 19 Would they be the ones that would be having 20 eyes on the range? 21 MS. : Nobody is sitting 22 around watching the range. 23 MR. : Sure. 24 MS. : The only people who 25 would be watching the cameras is the officers EFTA00114326

144 1 that's assigned to 10 South. 2 MR. : Okay. 3 MS. : Because they have the 4 monitors right there at their desks. 5 MR. : 10 South or 9 South? 6 MS. : 10 South. 7 MR. : So 10 South watches the 8 SHU as well? 9 MS. : No. Ten South 10 watches the inmates assigned to 10 South. 11 MR. : Oh. Sorry. But specific 12 -. We're talking specifically to the SHU. So 13 if, for instance, the range -. 14 MS. : No. You asked me who 15 would be watching SHU. Who would have access 16 to those cameras? And I'm telling you the only 17 person who would be watching any cameras and 18 who is required to watch them would be the 19 officers that are assigned to 10 South. 20 Outside of that -- 21 MR. : But my question is -- 22 MS. : -- nobody is watching 23 any camera. 24 MR. : -- so no one is watching 25 it. But who -- EFTA00114327

145 1 MS. : As far as I know. 2 MR. -- would have had access 3 to it I guess is what we're saying. Who - if 4 someone wanted to look at the range within the 5 special housing unit, who would have access to 6 that camera? 7 MS. : I don't know if 8 control has access to that. 9 MR. : Okay. But your point is 10 no one's watching that. So if it's down, who 11 would know and how? 12 MS. : I would think the 13 people who are responsible for the cameras 14 would know. 15 MR. : And who is responsible 16 for the cameras? 17 MS. : The um, the 18 communication guys. 19 MR. : Do you know who -? 20 MS. : And that would be if 21 they -. I don't even know if they look at 22 every camera every day to make sure that -- 23 MR. : Sure. 24 MS. : -- they operative 25 because usually, staff reports that camera EFTA00114328

146 1 stuff when they notice it. 2 MR. : Well how - so would 3 people in the SHU know that their cameras were 4 down? 5 MS. : I don't know if they 6 would know that. I have no way of knowing 7 that. 8 MR. : You just said if staff 9 reported it. So that's the question would be 10 like if the range camera in the SHU was down, 11 who would know? Who would they notify? Who 12 was responsible? Do you follow? So how would 13 they know that the range camera was down? 14 MS. : I have no idea how 15 they would know. 16 MR. : You don't know? 17 MS. : Unless they have 18 access to it and they know - they can see it on 19 a monitor or something like that and see that 20 it's not working. I don't know outside of that 21 how they would know. 22 MR. 23 MS. 24 I don't know. 25 MR. : DO you know -? : Unless they was told. : Does the SHU have access EFTA00114329

147 1 to that? 2 MS. : Not that I'm aware 3 of. 4 MR. : Okay. So but you think 5 the communications would be the ones that would 6 know. Who in communications would be 7 responsible for getting it taken care of 8 fixing the cameras? 9 MS. 10 it? 11 MR. 12 MS. 13 communications. 14 MR. : If they knew about Right. : The guys that work in : All of them collectively? 15 Or is there one person? 16 MS. 17 don't work in communications. 18 19 MR. MS. I - look. Look. I : Sure. So I don't know if 20 one would know, another one would know, or if 21 they both would know at the same time. I don't 22 know. I can't tell you how another department 23 operates 24 MR. 25 named Mr. or how they conduct their business. : Okay. Was there someone (Phonetic Sp. *02:07:26) EFTA00114330

148 1 MS. : Mr. worked 2 down there. Yes. 3 MR. : Would he be potentially 4 the one responsible for fixing it? 5 MS. : I'm not going to say 6 he would be responsible for fixing it. But if 7 he was notified of it, he would have done it. 8 MR. : What was his -? 9 MR. : Okay. 10 MS. : I mean if that was 11 his job. If that's what people in this 12 institution wanted. 13 MR. : Okay. And what -? 14 MS. : Look. Let me make 15 this clear to you. I don't know what the 16 communications instructions were regarding 17 MR. : And we're not asking you 18 those questions. I'm sorry. We're not asking 19 you -. We're not looking at you to solve all 20 the problems. We just need to know like as far 21 as like if a camera goes down, who fixes it? 22 MS. : If a staff member had 23 access to a camera and that camera went out, we 24 would call the communications department to 25 have them take a look at that camera and to EFTA00114331

149 1 repair it or replace it, to fix it or whatever 2 needed to be done. 3 MR. : And roughly - 4 MS. : And that depends on 5 who answered the phone. That would be whoever 6 was working down there at the time, depending 7 on which one answered the phone. That's who we 8 would relay that information to. We weren't 9 picky about talking to a specific person. It 10 would be like if they work in that area, then 11 they should be capable of doing whatever it is 12 that we need to do to restore the cameras. Or 13 whatever manner they need to go about getting 14 it done. 15 MR. : How quickly usually does 16 that get resolved? If a camera goes down, do 17 they really get it back up and running pretty 18 quickly? Or does it take days? 19 MS. : If they're here and 20 they can replace it, they replace it on the 21 spot. 22 MR. : ON the spot? 23 MS. : Right. 24 MR. : Would it be abnormal for 25 it to take So if someone reported it on a EFTA00114332

150 1 Thursday, would it be abnormal for them to wait 2 until Monday to fix it? 3 MS. : I don't -. I can't 4 say that because I don't know what the 5 circumstances would be concerning why they're 6 waiting until Monday to do it. 7 MR. : Okay. 8 MR. : During your time as a 9 lieutenant during that time period, did you 10 ever see any cameras down for any extended 11 period of time? 12 MS. : Not that I can recall 13 right at this very moment. 14 MR. : And Mr. . What was 15 his position? Do you remember? 16 MS. : He's the 17 communications officer. I think that's his 18 title. 19 MR. : Do you know his first 20 name? 21 MS. : No. 22 MR. : I'm going to jump. 23 MR. : Yeah. Please. 24 MR. : Do you recall when you came 25 that evening August 9th. That evening when you EFTA00114333

151 1 came on the shift. Do you recall hearing about 2 Epstein making a phone call? 3 MR. : Jesus. This 4 (Indiscernible *02:09:51). 5 MR. : Do you recall that? 6 MS. : No. 7 MR. : Okay. Is it normal practice 8 -? I'm just going to -. Is it normal practice 9 -? Let's say an inmate had to make a phone 10 call. And the inmate doesn't have that line, 11 you know the PIN set up for them, is it normal 12 for an officer to use the legal line to allow 13 the inmate to make a phone call? 14 MS. : Not that I'm aware 15 of. 16 MR. : Okay. Have you ever heard of 17 anyone using the legal line other for anything 18 unauthorized? 19 MS. : No. 20 MR. : Okay. Did you interact or 21 see Epstein on August 9th? Interact with or 22 see Epstein on August 9th? 23 MS. : No. 24 MR. : Okay. 25 MR. : So neither August 9th nor EFTA00114334

152 1 August 10th? 2 MS. : No. 3 MR. : Did you ever have any 4 interactions with Epstein? 5 MS. : Yes, I've had 6 interaction. When he committed the suicide 7 when he attempted suicide. I interacted with 8 him then. 9 MR. : What about after that 10 date? 11 MS. : After that day, no. 12 MR. : Did you even see him 13 after that day? 14 MS. : No. 15 MR. : No? What about the cells 16 in the SHU? Can you see through them or are 17 they like open up a slide in order to see in? 18 MS. : No. You can see 19 through it. 20 MR. : You can see through them? 21 MS. : Mm-hmm. 22 MR. : From the SHU desk, can 23 you see? 24 MS. : No. No. No. No. 25 MR. : So if Epstein's desk I EFTA00114335

153 1 think that's what we're showing you before was 2 the SHU layout. I think it was 15 feet - the 3 closest cell to where the people are sitting in 4 the SHU. They cannot see -. 5 MS. : I don't care where 6 you are inside a housing unit. You cannot see 7 from any - unless you're standing there in that 8 window, you can't see inside somebody's 9 MR. : And is the window open 10 the whole time? 11 MS. : I mean you may be 12 able to see if their light is on or something 13 like that. Whatever that window - whatever you 14 can see from that vantage point, you may be 15 able to see like the corner of something or 16 whatever. But no. 17 MR. : Is the window open the 18 whole time? Or do you have to open it and 19 close it? 20 MS. : The window is open 21 all the time. 22 MR. : And about how big is that 23 window? 24 MS. : I don't know how big 25 it is. EFTA00114336

154 1 MR. : Is it like 12 inches by 2 12 inches? 3 MS. : I don't know how big 4 it is. 5 MR. : Okay. But you've been in 6 the SHU though? 7 MS. : Yes I've been in the 8 SHU. But I don't have to measure the window to 9 tell you how big it is. 10 MR. : But I mean the difference 11 between like you know a three-foot by two-feet 12 or is it like -? 13 MS. : I'm not going to 14 I'm not even going to speculate on the 15 measurements. I mean. 16 MR. : Is it -? 17 MS. : I don't know how big. 18 I don't know the measurements of the window. 19 MR. : So we've never been in 20 there. So we're just asking because we've 21 never put eyes on - in the SHU. So is it a 22 large thing that you can - where you have to 23 kind of like get up close to it or -? 24 MS. : No. It's a little 25 narrow. It's a small window. It's not a big, EFTA00114337

155 1 huge window where -. 2 MR. : So would it be like as 3 big as this? 4 MS. : No. It wouldn't be 5 that big. 6 MR. : So smaller than basically 7 12X12? Roughly 16X12? 8 MS. : Sir, go up there and 9 look at the window. Because I don't 10 MR. : Okay. 11 MS. : -- know the 12 measurements of the window. 13 MR. : Okay. So for the record, 14 I'm holding up a piece of paper that's roughly 15 16 inches by 12 inches. And it is being said 16 that it is smaller than that. 17 MR. : SHU inmates. What are they 18 allowed to have in their cell? What kind of 19 items are they allowed to have inside3 their 20 cell? If you're placed in the SHU. 21 MR. : It depends on what your 22 status is in the SHU. I mean you have inmates 23 that are in there on AD status. You have 24 inmates that -- 25 MR. : What's AD? EFTA00114338

156 1 MS. : -- are on DS. 2 Administrative Detention. You have inmates 3 that they're on disciplinary segregation. You 4 have inmates up there that are up there for 5 protective custody. You have inmates up there 6 for various reasons. So there is different 7 items that each depending on their status they 8 are allowed to have. 9 MR. : So there's no set SHU policy 10 on what inmate is allowed to have and not have 11 in the cell? 12 MS. : I don't know what 13 their polices - what their policy is. If they 14 have a set policy here, in general, I've never 15 seen a set policy for this institution in 16 particular about what the inmates can have or 17 what they couldn't have if they're in SHU. 18 MR. : Okay so no -. 19 MS. : But I'm sure there 20 has to be something. 21 MR. : So what kind of holding was 22 Epstein under? What would he fall under? 23 MS. : I don't know what. 24 To be honest with you, I don't know what 25 because he wasn't up there for disciplinary EFTA00114339

157 1 action. He wasn't up there pending 2 disciplinary action. So I'm going to - and I 3 don't want to say he was up there for 4 protective custody. Because like I said 5 previously, and I'll continue to say that, for 6 someone in his position, he never should have 7 been up on SHU. 8 MR. : Now someone in the SHU. Are 9 they allowed to have the same types of items as 10 a normal person in a regular cell? Or they 11 have only a limited amount of items? 12 MS. : Um, Epstein, to be 13 honest with you, there's no telling what they 14 didn't allow Epstein to have in his cell. 15 MR. : Why do you say it like that? 16 MS. : I say it like that 17 because I know that he was always trying to get 18 things that he wasn't supposed to have. And to 19 be honest with you, I don't know if they 20 approved them or not. 21 MR. : What was he trying to get? 22 MS. : He was - when he was 23 in attorney conference he was trying to get his 24 meals delivered - his hot trays and stuff like 25 that. Regular inmate trays delivered to EFTA00114340

158 1 attorney conference. Things of that nature. 2 So -. 3 MR. : Did he get special 4 privileges? 5 MS. : I don't know if he 6 did or not because I worked nights. So I 7 didn't' have a lot of interactions with Epstein 8 or any other inmates during the daytime because 9 I wasn't here. 10 MR. : Was Epstein allowed to have 11 pill bottles in his cell? 12 MS. : I don't know if he 13 was or not. 14 MR. : Are inmates allowed to have 15 pill bottles in the cell? 16 MS. : If medical says that 17 they can have them, yes. 18 MR. : Okay. How many changes or 19 clothing or linens are inmates allowed to have 20 in the SHU? 21 MS. : I don't know what 22 their policy is up there on SHU. My previous 23 institution, they in SHU they don't have any 24 exchange of clothing up in SHU. When they get 25 their shower, their rec and shower, they're EFTA00114341

159 1 given a new set of clothing at that time. But 2 they don't maintain any additional clothing in 3 the special housing unit outside of that. I 4 don't know what they do here. But that's how 5 it was always done at my previous institution. 6 MR. : So inmates shouldn't have two 7 or three different pairs of -? 8 MS. : Like I said, I don't 9 know what their policy is or was in SHU at that 10 time because things change here. Because 11 things around here change on a moment-to-moment 12 basis. 13 MR. : How was Epstein with 14 direction with other inmates? Did he have any 15 issues with any inmates? 16 MS. : I don't know what his 17 interaction was with other inmates. 18 MR. : When was the last time you 19 interacted with Epstein? 20 MS. : I just told you. 21 When he attempted suicide. 22 MR. : Okay. Do you know why 23 Epstein was in prison? 24 MS. : Uh, because of some 25 allegation that he was having - engaging in EFTA00114342

160 1 sexual acts with underage females. 2 MR. : So the next set of questions 3 is just general questions we have to ask. Did 4 you have any specific feelings regarding why he 5 was in prison? 6 MS. : No. 7 MR. : Okay. Did you speak about 8 Epstein with other inmates? 9 MS. : No. 10 MR. : What time did you leave shift 11 hat day? I know 12 MS. : It was right after 13 5:00. 14 MR. : After 5:00? 15 MS. : Yes. 16 MR. : And when did you hear about 17 the incident? 18 MS. : I think it was - I 19 was working late that day because I had some - 20 I was still finishing up my work. And I don't 21 know probably 7:00 sometime after 7:00 I guess. 22 MR. : You left after 7:00? Or you 23 heard after 7:00? 24 MS. : I think it was after 25 7:00. I wasn't really looking at the clock. I EFTA00114343

161 1 was here working. I had went downstairs to 2 finish some work that I had that I didn't get 3 to finish during my shift. And at some point 4 in time, that's when I heard that um that they 5 had had a medical emergency up in SHU. 6 MR. : But were you here on the 7 premises? 8 MS. : Yes. I was still 9 here. 10 MR. : Did you respond up there at 11 all? 12 MS. : I called up there to 13 make sure everybody was okay. And they - when 14 I asked who was up there they was telling me 15 that they didn't have but one or two staff 16 members up there. So yes. I went up there to 17 see if they needed some help because I knew 18 feeding and all that stuff still needed to be 19 done. 20 MR. : So when you went up to the 21 SHU after the incident, was Epstein still in 22 the SHU or was he removed already? 23 MS. : No. He wasn't there. 24 MR. : He wasn't there. Did you get 25 to see the inside of the cell? EFTA00114344

162 1 MS. : No. No. Nope. 2 MR. : Did you have any 3 communications with Michael Thomas or Toby Noel 4 after this incident? 5 MS. : Noel was still there. 6 I asked her if she was okay. And she said, you 7 know not really. And I went to help them feed 8 and shortly after that, when I came back up out 9 the range after feeding the tier, she was gone. 10 They had pulled her off her post. 11 MR. : Okay. After that day, did 12 you have any communications with them? 13 MS. : No. 14 MR. : Okay. 15 MR. : When inmates come off of 16 suicide watch and are in or assigned to the 17 SHU, so suicide watch to the SHU. Are they 18 assigned a cellmate? 19 MS. : One more time. 20 MR. : So when inmates come off 21 of suicide watch or psych observation and 22 they're on psych observation due to suicide 23 watch, are they assigned If they are then 24 assigned to the SHU, are they assigned a 25 cellmate? EFTA00114345

163 1 MS. : No. 2 MR. : No? When you said that 3 you were working nights, were you working 4 nights all in August 2019? 5 MS. : I don't. If that was 6 my quarterly post, more than likely I was. But 7 offhand I can't remember. 8 MR. : Do you remember if you 9 would have been working days as well? I'm just 10 trying to rectify -. 11 MS. : I mean I would have 12 to look at my schedule. 13 MR. : Sure. 14 MS. : I don't know if I was 15 working both or if I was strictly assigned to 16 that one. I'm not sure. 17 MR. : Okay. 18 MR. : I just had a follow-up on 19 that. 20 MR. : So you said. Sorry, go 21 ahead. 22 MR. : Did you work overtime during 23 that time? 24 MS. : What do you mean? 25 MR. : You mentioned everyone's EFTA00114346

164 1 working overtime during that time. Right? 2 Everyone's mandated and everything. 3 MS. : I'm sure at some 4 point in time. I don't' know if it was around 5 that time, but yeah. If a lieutenant then 6 called in sick, yeah. We was required to stay 7 and work that shift. 8 MR. : Would that be -? So that 9 would be the day watch? 10 MS. : It could have been 11 either or. Well depending on what shift you're 12 working. 13 MR. : So you said you were 14 involved with responding to the July 23rd 15 incident where Epstein originally tried to 16 commit suicide? 17 MS. : Yes. 18 MR. : Now is it your 19 understanding that he tried to commit suicide? 20 MS. : As far as I know. 21 MR. : Did you hear anything 22 about his cellmate attempting to kill him? 23 MS. : There was some 24 reference that I guess he had mentioned at that 25 time that his cellmate had done that to him. EFTA00114347

165 1 But when I went back and spoke to him he never 2 mentioned that to me. He never said. 3 MR. 4 questioned Epstein? 5 MS. When you say you actually : Yes. 6 MR. : And what did he say to 7 you? 8 MS. : He didn't say 9 anything. He really didn't say anything about 10 the incident. He said that he had gotten up to 11 get some water and the next thing he knew -. I 12 think that was what he said. He had gotten up. 13 I would have to look at my memo. I think he 14 said he had gotten up to get some water or 15 something like that. And the next thing he 16 knew we were there. 17 MR. : Okay. And what number 18 were you in responding? 19 MS. : I don't know what - 20 if I was first if we went because usually when 21 we respond to an emergency, we -. Even if I 22 get on the elevator first, the elevator may 23 stop and pick up somebody else along the way. 24 But I think it was me and I don't know. I 25 don't' remember. EFTA00114348

166 1 MR. : When you did respond, 2 what did you see? 3 MS. : Um. 4 MR. : When you got to the cell? 5 MS. : He was lying on the 6 floor. He appeared to eb unresponsive. But 7 when we walked up to him, we would see his 8 chest rising. And he was kind of clammy. 9 MR. : Did he have anything 10 around his neck? 11 MS. : No. He didn't have 12 anything around his neck. 13 MR. : Okay. 14 MS. : And there were 15 different times when he would open one eye and 16 kind of you know like he was trying to see what 17 we were doing. And then he would close his 18 eyes. But he would never respond to us. He 19 just wanted to maintain that mode like he was 20 unconscious or something like that. I guess. 21 I don't' know what was going through his mind. 22 MR. : Do you know if someone 23 removed something that was around his neck? 24 MS. : I don't know if 25 someone. I don't' know. EFTA00114349

167 1 MR. : Okay. Point being, like 2 if he's claiming someone tried to kill him, but 3 also at the same time is saying that he's 4 trying to commit suicide. He didn't' have 5 anything around his neck. Is there any reason 6 for you to believe that his cellmate was 7 actually trying to kill him? 8 MS. : No. I mean I had no 9 proof that his cellmate tried to do anything to 10 him. And I'm trying to remember what the 11 officer said. I don't' even remember offhand 12 what the officers were telling me. I don't 13 know if they saw him with something around his 14 neck or what they observed. But I can't 15 remember. I would have to refer back to my 16 notes. Because that was a long time ago. 17 MR. : Sure. So if counts are 18 not conducted. And I'm assuming -. Are counts 19 more important than rounds? Or are they both 20 just as equally as important? 21 MS. I mean they're both 22 important. They are both independently 23 important. 24 MR. : Okay. So let's go first 25 with counts. If counts are not conducted, who EFTA00114350

168 1 is -. So if counts are signed off on. You're 2 given a count slip. If those counts actually 3 weren't conducted. So if let's say for 4 instance that during your shift, the 12:00 5 a.m., the 3:00 a.m., and the 5:00 a.m. If they 6 were not conducted - those counts- who is 7 responsible for that? For them being signed 8 and certified? Who - so I'm assuming the 9 people? Noel and Thomas are the ones assigned 10 to that shift. And they are the ones who 11 certify that those counts were conducted and 12 then provided to you. Are they the only ones 13 that are responsible for providing false 14 information? 15 MS. : Providing false 16 information? 17 MR. : Correct. So if they're 18 saying they conducted counts but they didn't. 19 So they were providing you with something 20 saying either 72 or 73, but those counts were 21 not conducted. 22 MS. : How would I know if 23 they weren't conducted? 24 MR. : Right. That's what I'm 25 asking. So are they the only ones that are EFTA00114351

169 1 responsible for falsifying that? 2 MS. : Who else would know 3 whether or not they did them or not? I mean -- 4 MR. : That's what I'm asking. 5 MS. no one else would 6 have any way of knowing. 7 MR. : So it doesn't' go above 8 them. If they are the ones that are saying it, 9 there's no other people that can like verify 10 that it actually was conducted. 11 MS. : How would they verify 12 it? 13 MR. : That's my question to 14 you. 15 MS. : And that's what I'm 16 saying to you. If they're the ones that are 17 There is no reason whatsoever for us to ever 18 believe that someone is not conducting their 19 counts or doing what they're supposed to be 20 doing. You know. We're not out there with 21 them. I mean we have no way of knowing what 22 As far as I know, no one has any way of knowing 23 what I'm doing when I'm here. 24 MR. : Sure. 25 MS. : You know so you have EFTA00114352

170 1 to have confident in and you have to know your 2 staff. That's what it comes down to. You have 3 to walking and talking. It's not just about 4 the inmates. It's not just about you know what 5 we did with Epstein. IT's about every inmate 6 that was being housed at MCC at the time. 7 Every inmate had the potential to hang 8 themselves or kill themselves or do whatever. 9 It wasn't just about Epstein. We're 10 responsible for every inmate in this 11 institution. 12 MR. : Sure. 13 MS. : And I have - if I 14 have absolutely no reason to believe that a 15 staff member in this building or doubt unless 16 they reveal something to me that would make me 17 doubt what they said is true. 18 MR. : So -. 19 MS. : Other than that I 20 have no reason to believe that a staff member 21 isn't doing what they're supposed to be doing. 22 MR. : So if you were told that 23 the 12:00 a.m., 3:00 a.m. and 5:00 a.m. counts 24 were not conducted on August 10th, does that 25 surprise you? EFTA00114353

171 1 MS. : Yes, that would 2 surprise me. 3 MR. : It does surprise you? 4 MS. : Yes. 5 MR. : Okay. Do you have any 6 reasons to believe that either r Thomas or Noel 7 did not conduct counts in the past? 8 MS. : No. 9 MR. : No? 10 MS. : I have no reason to 11 believe. I don't even believe that they didn't 12 do it that night to be honest with you. But 13 no, I have no reason to believe that they 14 didn't -=. 15 MR. : Have you heard that they 16 made any statements to any other staff members 17 about not conducting rounds or counts? 18 MS. : No. No. 19 MR. : So you never heard those 20 either? 21 MS. : No. 22 MR. : Okay. And you don't know 23 of them ever not conducting rounds or counts 24 other than -? 25 MS. : I don't know of them EFTA00114354

172 1 or any other staff members not conducting 2 counts or rounds or anything like that. 3 MR. : Okay. And you didn't -? 4 On August 10th, did you speak to them at all 5 about hey did you guys really do these counts? 6 MS. : No. 7 MR. : Okay. 8 MS. : No. 9 MR. : What about with the 10 rounds? So would you be surprised to find out 11 that they didn't' do rounds on August 10th 12 during your shift? 13 MS. : Yes. I would be 14 surprised to find out 15 MR. : Okay. 16 MS. : -- that they didn't' 17 do rounds. Yes. 18 MR. : So if it were found out 19 that they didn't do any rounds. That to you is 20 shocking? You would be like wait what? 21 MS. : Yes. I would be 22 surprised that they didn't do 23 MR. : Okay. Do you have any 24 follow-ups on those specific questions? 25 Specifically with falsification of rounds and EFTA00114355

173 1 counts? Who has to sign off on the counts and 2 rounds? 3 MR. : What do you mean? 4 MR. : So is it solely the COs 5 that are in the SHU? Or does someone else have 6 to verify on the counts that they were 7 conducted? 8 MS. : I mean you can't 9 verify that they're conducted. You can verify 10 that the -. 11 MR. : That they provided you 12 that information. 13 MS. : Right. That they 14 turned in the count slip. 15 MR. : Right. 16 MS. : But you can't verify 17 anything else. 18 MR. : So there's no procedure 19 in place for a lieutenant to make sure that COs 20 are actually performing the duties that they 21 say they're doing? 22 MS. : Do you know how many 23 people who have -? Supervisors would have to 24 be in -? That would mean that a supervisor 25 would have to be on every unit during every EFTA00114356

174 1 count. 2 MR. : Well I'm talking 3 specifically about the SHU. 4 MS. : And watching the 5 count. 6 MR. : I'm speaking specifically 7 to the SHU. So in the special housing unit, 8 there's no verification process. If the COs 9 are saying they did it, you just take their 10 word. There's no way to verify it. 11 MS. : SHU is no different, 12 sir. Before this incident with Epstein, SHU 13 was no different than any other unit in this 14 building. It's not about whether or not solely 15 whether or not SHU is doing it. It's about 16 whether -- 17 MR. : So you're saying -- 18 MS. : -- everybody on every 19 unit -- 20 MR. : -- prior to this incident 21 -- 22 MS. : -- is doing it. 23 MR. -- is there something 24 that has been implemented since then? To 25 ensure that counts and rounds are being EFTA00114357

175 1 conducted? 2 MS. : No. 3 MR. : So it's still the same. 4 It's all up to the COs. If they're certifying 5 that they did it, the lieutenants are taking 6 their word for it. 7 MS. : That's correct. 8 MR. : Okay. 9 MS. : That's correct. As 10 far as I know. Yes. 11 MR. : On August 10th during 12 your shift from August 9th 10:00 p.m. to 6:00 13 a.m. the following day. What was the chain of 14 command? Was it Noel or Thomas or was there a 15 hierarchy? Was one in charge of the other? 16 Was one subordinate or were they both equal? 17 MS. : What do you mean? 18 You mean inside the SHU? 19 MR. : Correct. So does one 20 give the other orders or do they work tougher? 21 Is there a hierarchy in there? 22 MS. : Well they should be 23 working together. 24 MR. : Okay. But there's no 25 like person that's in charge of the other? EFTA00114358

176 1 MS. : No. 2 MR. : So if -? 3 MS. : No. 4 MR. : And how was it determined 5 with counts and rounds? Is there someone that 6 takes lead on it? Or is it? 7 MS. : No. 8 MR. : No? 9 MS. : I mean we all have 10 the same responsibilities. 11 MR. : Okay. Back over to you. 12 MR. : Just for in terms of policy- 13 wise. If a count is wrong. Right, there's an 14 issue with the count. What does the policy 15 state? What should happen? 16 MS. : What type of issue? 17 MR. : Let's say the COs in the SHU 18 did a count. And the count comes to the 19 control center and it's wrong. They identify 20 if the fact that it's wrong. What's the next 21 step? 22 MR. : What do you mean? It's wrong 23 how? 24 MR. : The count is off. The number 25 is wrong. Let's say it said 72 -. EFTA00114359

177 1 MS. : You mean the count 2 slip? The count slip comes to control -? 3 MR. : Yes. 4 MS. : And the count slip is 5 wrong? 6 MR. : Yes. 7 MS. : Then if control is 8 aware of that, and especially if control is 9 taking the count. Then control will call them 10 back and tell them I need a new count slip 11 because this one is not right. And usually the 12 only time that that would happen would be like 13 in the incidents where we may have moved a 14 staff member during that time. And we need to 15 go back and update that count slip that we were 16 originally getting. Or like in this case with 17 the inmate being in R&D. We needed to go back 18 and get another count slip that reflected the 19 new count which was 72. Once we put the inmate 20 in R&D. 21 MR. : Okay. On that same topic, if 22 the count was wrong, and you told them that 23 they needed to go back and do another count. 24 MS. : Not that the count 25 was wrong. That the count slip was wrong. The EFTA00114360

178 1 number that was reflected on the count slip was 2 wrong. 3 MR. : Did you see them do the 4 count? 5 MS. : No. 6 MR. : So the number they reported 7 was wrong. The count should have been -. 8 MS. : They said that they 9 had -. They said that they had their count was 10 73 but that they had there was an inmate that 11 was in R&D. So that was the problem. They 12 never did a count slip saying - they never said 13 my count is 73 and left it at that. They were 14 clear to say that the count is - SHU has 73 but 15 there is an inmate that is down on the third 16 floor in R&D. Or something to that effect. 17 They notified me that there was an inmate that 18 was off their housing unit. 19 MR. : So you're saying the count 20 wasn't wrong. 21 MS. : What was on the count 22 slip was wrong. 23 MR. : The count slip was wrong 24 but she said that they explained it when they 25 delivered it. EFTA00114361

179 1 MR. : But you just stated a little 2 bit before that the count wasn't wrong, the 3 count slip was wrong. 4 MS. : The count slip was 5 wrong. 6 MR. : Why did you ask them to go 7 back and do the count? 8 MS. : Because I needed to 9 find out what was going on with this dude in 10 R&D so that, you know, if they in fact -. If 11 we made changes to whatever the status was to 12 this guy in R&D. If he was in fact going to be 13 there overnight or whatever the case may be, 14 then we needed to get him off of their count. 15 So while I was verifying that, I said, you know 16 what just go back and do it again just to make 17 sure. While I'm looking into this thing with 18 this dude. I didn't say that to them. I'm 19 thinking to myself. I'll have them go back and 20 do another count while I check on this inmate 21 that was -. 22 MR. : There's a possibility the 23 count was wrong then. 24 MS. : What do you mean? 25 MR. : You said go back and verify EFTA00114362

180 1 if the guy was still there or not there. 2 MS. : I didn't say go back 3 and verify if the guy was still there. I said 4 while I verify what's going on with this guy in 5 R&D to see if he's still in R&D. That's what 6 I'm talking about. I wanted to verify if he 7 was still in R&D. And if he was if he was 8 going to be staying there. Because I wasn't 9 aware that there was an inmate in R&D. So from 10 my own, and I wasn't verbalizing this. I was 11 saying this to myself. 12 MR. : But the point being is you 13 got a count that was a 73 and you said do it 14 again. Correct? 15 MS. : The count slip that 16 was 73 was broke down because they had put the 17 count slip out. 18 MR. : Right. And you -- 19 MS. : So - 20 MR. : -- asked them to do the 21 count again though. Because you got a count - 22 and this is where I just want to make sure that 23 we're all on the same page here. So you did 24 though take action. You got a count slip that 25 seemed to be inaccurate and questioned it. You EFTA00114363

181 1 said can you do the count again. 2 MS. : I hadn't even gotten 3 the count slip then. 4 MR. : Oh, okay. 5 MS. : Like I said, when 6 they called in the count, they said the count 7 like the count in the book or wherever they was 8 reading it from say 73 but there is an inmate 9 in R&D. 10 MR. : So that's how they called 11 the count in? There's 73, but there's one 12 inmate in R&D. And you said, can you do the 13 count again? 14 MS. : They wasn't even 15 really calling in the count. They was 16 questioning. You know they were basically 17 informing me that we've got 73 -. Because they 18 weren't even sure what they should do or how 19 they should go about it. 20 MR. : Okay. 21 MS. : You know. They just 22 wanted it to be known that there was an inmate 23 off their housing unit that was somewhere else. 24 He wasn't physically on the housing unit. And 25 that was the whole question as to how do they EFTA00114364

182 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 want us to do - how are we supposed to count this guy? What's the deal with that? So I'm saying, you know, let me - I need to figure this out. know that So I need Because I wasn't - I didn't even there was a guy in R&D at the time. to verify that there is a guy in R&D and what's the status of this dude in R&D, why he's there. All these questions I have to ask before I can even tell them anything about it. MR. : So at what point would have they filled out the count slip? After you did the verification? Would have they then created the count slip? MS. : They would have created a new count slip. MR. : Okay. So -. MS. : And that count slip apparently was never picked up because -- MR. : Never picked up and not recorded. MR. THIELHORN: -- because the one that you all was able to get a copy of was the 73 and not the one that reflected the in count which would have been 72. MR. : And do you know that EFTA00114365

183 1 there was a count slip that was created? 2 MS. : I have no reason to 3 believe that there wasn't. 4 MR. : But do you have a reason 5 to believe that there was? Did you ever see 6 one? 7 MS. : If I had saw it, it 8 would have been during the time that I would 9 have taken the count and I would have attached 10 it to the rest of the count slips and went on 11 about my business. 12 MR. : So at the same time we're 13 saying to you there's no reason to believe that 14 there wasn't. there's also then no reason to 15 believe that there was. 16 MS. : I - let me tell you - 17 . 18 MR. : The point being is that 19 you don't know. You don't know if there was a 20 count slip. 21 MS. : If -. Let me tell 22 you something. Based upon the fact that I've 23 worked with these guys for a certain period of 24 time and I know what they're capable of doing. 25 I can for the most part tell you what somebody EFTA00114366

184 1 would do and what they wouldn't do. I have 2 never had a problem with a staff member not 3 correcting their count slip or not sending me 4 another - a corrected count slip. 5 MR. : Now we're only asking you 6 because I have personally not seen it. So I'm 7 asking you if there's another one, do we need 8 to go try to find this. Or do you not know. 9 MS. : You're not going to 10 find it. I mean it's two years after. 11 MR. : Right. 12 MS. : Where are you going 13 to find it at? If it wasn't picked up - I mean 14 the fact that they could have put it out there 15 and no one picked it up. 16 MR. : Here's a question. If they 17 did do one, right, it's expected that they 18 should have for that one. Right. A new one. 19 Yes or no? Because of the error, it was 20 expected that they would have filled out a new 21 one with the correct number. 22 MS. : I'm sure that they 23 feel that they filled out another one and 24 probably put it out in and it was an oversight 25 on somebody's part and they didn't pick it up. EFTA00114367

185 1 MR. : Yeah but here's the thing. 2 You don't know if - yes or no. Did you see it 3 for that? Yes or no. 4 MS. : No. I didn't' see 5 it. 6 MR. : No-no. We're going that 7 would it possibly have been picked up at the 8 3:00 a.m. count? 9 MS. : I don't know when it 10 could have been picked up, sir. 11 MR. : Is it in the same place? Or 12 is it a different place it's kept? 13 MS. : Depending. I mean 14 they could have put it in the same place. They 15 could have put it in a different place. I 16 don't know. 17 MR. : Okay. That's it. We just 18 want to know. 19 MR. : I can't tell you something 20 that I didn't see. If I didn't see it, I can't 21 22 MR. : And that's what -- 23 MS. : -- tell you where 24 they put it or who picked it up or what 25 happened to it. EFTA00114368

186 1 MR. : And that's what we're 2 getting at. The point being is that you're not 3 sure. So we just don't want to - because you 4 said you have no reason to believe that they 5 didn't. That indicates that they did. And we 6 just want to make sure that you're correct. 7 You've never seen it. You're actually not sure 8 if they did or not. 9 MS. : Okay. 10 MR. : Is that correct though? 11 MS. : No. I never saw the 12 count slip. 13 MR. : Okay. Perfect. I mean 14 it's not like a "gotcha," we just want to make 15 sure 16 MR. : Yeah. 17 MR. : -- that you dint - there 18 isn't a count slip out there that we need to 19 try to go find. 20 MS. : Let me tell you 21 something. It's -. If-if-if. I can't - if I 22 can make something right that's wrong or need 23 correcting, then that's what I'm here for. I'm 24 not here to like I said, and I'll say this a 25 thousand times. I'm not here to cover for EFTA00114369

187 1 nobody. I'm not here to provide false answers 2 for something that somebody had done, but at 3 the same time, you all are throwing these 4 questions at me about what somebody would have 5 done. I don't know what's in somebody's mind 6 - 7 MR. : Ma'am, we're absolutely 8 not asking 9 MS. : -- with the stuff -- 10 MR. : -- those questions. 11 We're asking you 12 MS. : -- that's taken 13 place. 14 MR. : We're saying did you see 15 it. So that's what we're trying to get you to 16 answer more like yes, no, I don't know on that 17 front. So we're trying to keep it consolidated 18 and ask you direct questions. What did you 19 know? Did you know if they did another count 20 slip? 21 MS. : Well what I also know 22 is there's no reason for them to not have done 23 it. I've never had a reason or a circumstance 24 where somebody didn't do a corrected count 25 slip. I mean it's - there's really nothing to EFTA00114370

188 1 it. 2 MR. : And this is only because 3 of the way you're answering this. Should have 4 you ensured that they did a new count slip? 5 MS. : I had no reason to. 6 MR. : But was it your 7 responsibility to ensure that they created a 8 new count slip? 9 MS. : It was my 10 responsibility to tell them. Well they knew to 11 create it. If the count was different, they 12 knew to create a new count slip. I'm not 13 required to wait around for that count slip to 14 manifest itself in SHU when I have a thousand 15 other duties to do. 16 MR. : Okay. 17 MS. : I leave that you 18 know. 19 MR. : So it's your requirement 20 to do a new count but it's not your requirement 21 to follow up to obtain a new count slip. 22 MS. : Because what 23 generally happens is that the internal officers 24 would go pick that count slip up and bring it 25 down to the control center. And they would EFTA00114371

189 1 attach it to that count. 2 MR. : And would have it then 3 been Noel or Thomas' responsibility to contact 4 internal to tell them to come get it? Or would 5 it have been your responsibility to tell 6 internal to? 7 MS. : Sometimes I would 8 tell them. Sometimes SHU would tell them. It 9 just depends -- 10 MR. : Okay. 11 MS. : -- on the 12 circumstance. 13 MR. : In this circumstance do 14 you know who would have been responsible for 15 that? 16 MS. : I mean we all could 17 have done it. 18 MR. : Okay. 19 MS. : We all could have 20 done it. 21 MR. : So when you say depending 22 on circumstance in this -. 23 MS. : Well that was just 24 something I said. But any of us could have 25 done it. If control - if I see that control EFTA00114372

190 1 MR. : So let's get at it this 2 way. Did you contact internal? 3 MS. : Let me tell you 4 something. If internal comes to the control 5 center, and I walk over there to drop off count 6 slips that they've already collected. And I 7 walk over there and I see them there. And I'll 8 say hey, can you go grab the new one from 9 9 South. That would be an example of a 10 circumstance. 11 MR. : Okay. So in this 12 circumstance, did you contact internal and tell 13 them to get the new slip? 14 MS. : I didn't contact -- 15 MR. : Okay. 16 MS. : -- to tell them. 17 MR. : And are you aware if 18 Thomas and Noel contacted internal to come 19 collect a new slip? 20 MS. : They may have. And I 21 may have 22 MR. : But you're not aware? 23 MS. : And control may have 24 announced it over the intercom. I can't 25 remember from -- EFTA00114373

191 1 MR. : Sure. 2 MS. : -- this year to that 3 one. 4 MR. : You're not aware. Great. 5 MS. : You know if that 6 actually occurred. 7 MR. : Now you mentioned that an 8 all-staff email should have been put out that 9 Epstein had a requirement. Who should have put 10 that out? 11 MS. : The person - the -. 12 MR. : Is that psychology? The 13 warden? The captain? The AW? 14 MS. : I mean they all 15 should have been doing it. 16 MR. : Okay. 17 MS. : To be honest with 18 you, they all should have known that he should 19 have been up on 10 South. 20 MR. : Okay. 21 MS. : But. 22 MR. : Has an all-staff email 23 ever gone out before saying that this person is 24 on suicide watch. He's required to have an 25 email. I mean a ceilmate. EFTA00114374

192 1 MS. : Here? 2 MR. : Yes. 3 MS. : I've never seen that. 4 I've never seen that done here. But we didn't 5 have -. I'm trying to remember a time when 6 prior to Epstein that I had even seen an email 7 period about an inmate needing an inmate in the 8 cell to be housed with another inmate. To be 9 honest with you. 10 MR. : Okay. Now speaking to 11 that though, you know, we showed you the email 12 that was sent to you that you said you don't 13 recall ever receiving it. Do you have a lot of 14 emails that have gone unread? 15 MS. : I'm sure I do. 16 MR. : Okay. So yeah. You 17 didn't receive this but there's also a lot of 18 emails that you didn't receive 19 MS. : There's a lot of 20 emails that I receive 21 MR. : -- and you probably 22 haven't -- 23 MS. : -- and have time to 24 read at that time because of everything that 25 was going on during our shift and in this EFTA00114375

193 1 building. 2 MR. : And is that just a 3 constant issue of just trying to keep up with 4 emails as well as do your job? 5 MS. : That was a constant 6 issue. Yes. Because there was so much going 7 on in this building at the time. So much 8 chaos. That you didn't have time to read. 9 MR. : Okay. 10 MS. : You didn't have time 11 to read a lot of the emails that you'd gotten. 12 But most importantly, if when you're talking 13 about information that's that important, you 14 know. Whoever is sending out the information. 15 Whoever got the information should always be 16 trying to make sure that everybody knows that 17 this is important. We have to make sure that 18 he had a cellie because like I said, the 19 officers are the main ones who come in contact. 20 MR. : And that goes back to our 21 original question. 22 MS. : With the inmates. 23 MR. : If the chain of command 24 went up toe during that time and that he 25 knew that he was required to have a cellmate EFTA00114376

194 1 and didn't. what should have he done? 2 MS. 3 MR. 4 lieutenant at the time, so put yourself into 5 the place of : If what? : If you were the ops If you knew 6 was required to have a cellmate, 7 current cellmate was removed, he that Epstein and his should have - 8 and what you said was, I believe, he should 9 have notified the captain and ensure that a 10 cellmate was put in place. 11 MS. 12 have done. 13 14 MR. MS. : That's what I would : Correct. : I said was the 15 SHU lieutenant at one point. So he probably 16 would have assigned another inmate to the cell. 17 It just depends on you as a supervisor. 18 MR. : Sure. 19 MS. : There is nothing 20 written in stone concerning how you're going to 21 - indicating how you're going to handle that 22 situation because -. 23 MR. : And if the inmate that 24 was removed - Reyes - was done at the end of 25 his shift, should have he then passed that EFTA00114377

195 1 information on to the next operations 2 lieutenant to be able to handle the situation? 3 MS. : That's if he knew 4 about it. But chances are, he probably would 5 have had it 6 MR. : No, let's -- 7 MS. : -- done before he 8 left. 9 MR. : Okay. 10 MS. : I can't -. 11 MR. : So you think that 12 MS. : Look. I can't answer 13 for him. 14 MR. : Sure. 15 MS. : I don't know what he 16 should have done or what he would have done or 17 what -- 18 MR. : If it was -. 19 MS. : -- he could have 20 done. 21 MR. : -- as an ops lieutenant. 22 Do you think even if it happened at the end of 23 a shift, he should have handled it? 24 MS. : I'm not saying what 25 he should have done. EFTA00114378

196 1 MR. : Okay. 2 MS. : I'm saying Look. 3 What he should have done and what he could have 4 done and what he would have done is on him. 5 MR. : Sure. 6 MS. : We don't have - there 7 is no instruction or no instructional manual 8 that tells us every little thing that we're 9 supposed to be doing 10 MR. : Right. 11 MS. : -- for every scenario 12 because it'll never happen. 13 MR. : Okay. 14 MS. : You'll never have an 15 exact scenario for everything that happens. 16 You just have to use your common sense and good 17 judgment regarding it. 18 MR. : So going back to what you 19 said about your hours aren't specific to what 20 the duty agent roster says. You said you would 21 work -. Although the roster says 12:00 a.m. to 22 8:00 a.m., you were actually 10:00 p.m. to 6:00 23 a.m. What would have have been on August 24 9th. Looking at the duty roster. What times 25 would he have actually - have worked according EFTA00114379

197 1 to that? 2 MS. : I'm thinking he would 3 have worked -. he would have came in around 4 6:00 and worked until 2:00. 5 MR. : Okay. So he would have 6 been 6:00 a.m. to 2:00 p.m.? 7 MS. : Yes. 8 MR. : And then would 9 have been 2:00 p.m. to 10:00 p.m.? 10 MS. : That's correct. 11 MR. : Okay. If he didn't 12 If didn't tell that, would have 13 it then been the ultimate responsibility for 14 the COs to again report it up the chain of 15 command? Or because they reported it 16 previously, would that have covered them with 17 hey we got it up to the ops lieutenant. That 18 person's supposed to take care of it. Do you 19 follow what I'm saying? So for people working 20 in the SHU. They had already reported it up. 21 It got to . At that point, is everybody 22 in the SHU covered? They reported it. Or 23 should each subsequent shift has also reported 24 hey he's supposed to have an inmate - he's 25 supposed to have a cellmate in here. He EFTA00114380

198 1 doesn't. 2 MS. : That's if they knew. 3 There is no reason for me to believe that those 4 guys that was there on SHU that if they knew 5 that, whether or not before they left, I'm sure 6 they would have questioned that again as to 7 what you want me to do about this particular 8 situation. 9 MR. : Okay. So should have 10 each So then let's say if Thomas and Noel 11 did know. And they knew he was without a 12 cellmate. Should have they then told you? 13 When you did your rounds? Like when they're 14 calling control. And you're stopping by at 15 4:00 a.m. Would have it been their 16 responsibility to say hey, just so you know, 17 he's required to have a cellmate and he 18 doesn't. 19 MS. : I'm not going to say 20 that that's what they should have done because 21 there's no rules and regulations regarding 22 that. But they - I would have - if it was me, 23 I would have mentioned it. 24 MR. : Okay. So even if they 25 know, somebody told them just make sure. He's EFTA00114381

199 1 required to have a SHU at that point, they're 2 not actually required to notify someone. 3 MS. : If what? If somebody 4 tells -? 5 MR. : So you're saying that 6 there's no rules and - 7 MS. : If who tells them 8 that? 9 MR. : So if they are told. And 10 I'm not saying you did. 11 MS. : You're saying -. Okay 12 so now you're saying if they knew that he was 13 supposed to have a cellie. 14 MR. : Correct. 15 MS. : Yeah. If they knew 16 the was supposed to have a cellie. 17 MR. : If they knew -. Yeah. 18 So if they then because it was during their 19 shift. They should have at some point informed 20 you hey he's supposed to have a cellmate and he 21 doesn't. And they didn't do that. Correct? 22 MS. : That's correct. 23 MR. : Okay. Fair enough. 24 That's it. You done? 25 MR. : (Indiscernible *02:48:29) EFTA00114382

200 1 MR. : What? 2 MR. : Do you know of any - 3 currently, do you know of any policy violations 4 that's happening at the MCC? 5 MS. : As far as what? 6 MR. : For August 9th and 10th 7 or are you talking about -- 8 MR. : No-no-no. Just in general. 9 MR. : -- just in general? 10 MR. : In general. In general, do 11 you know of any policy violations or any kind 12 of violations happened here at the MCC? 13 MS. : What I do know is 14 that there are people here who abuse their 15 power. They blame everybody for everything and 16 they expect everybody to members of 17 correctional services and to take on the 18 responsibilities of other departments when it's 19 clearly not their responsibility. You have a 20 lot of people that come here that really are 21 not versed on what it is they're supposed to be 22 doing - their responsibilities. So they pawn 23 that off on other people. But there's a -. 24 There's no clear and defined form of policy and 25 procedure here. There's no consistency that EFTA00114383