LIMITED OFFICIAL USE 101 1 Special Housing Unit. So, I don't know if his 2 tag was removed. But you - by us talking - you 3 indicated that the SHU staff was aware that he 4 was leaving. So, they put the tags up, they 5 should remove the tags. And there would be no 6 reason to keep a tag on the door, indicating 7 that there is two inmates. One, when you are 8 aware that he is no longer going to be there. 9 MR. : But should -- 10 MS. : Yeah. 11 MR. : -- should those 12 lieutenants have conducted a round on basically 13 Epstein's cell? 14 MS. : I would -. You would conduct a 15 -. I would say yes. Because especially if you 16 have a highlighted inmate, or an inmate of 17 great concern. Or someone that you know you 18 need to check on. If you are not going to look 19 at anybody else's cell, you would definitely 20 look at, or check on, the inmates that are of 21 concern, to even say, hey, you okay? Or, you 22 know, just to talk with them, or physically see 23 them. So, I would say that you would - yeah - 24 that you would have looked in his cell to see 25 something, that something is going on. EFTA00110102

LIMITED OFFICIAL USE 102 1 MR. : Now, what about -- 2 MS. : And then -. 3 MR. : -- if Epstein -. So, if 4 they are conducting their rounds when Epstein 5 is in attorney visits, should they still be 6 checking in on his cell itself, like, to make 7 sure everything is okay with his cellmate, or 8 anything like that? 9 MS. : Well, if he was, if he was 10 physically inside of his, he physically was not 11 inside the cell at the time, but the only way 12 for you to know, because why would the 13 lieutenant automatically know that he's in 14 attorney conference? So, you still would have 15 looked in his cell. 16 MR. : So, they - regardless, in 17 this specific, you know, Epstein is your 18 highest profile inmate at the time 19 MS. : Mm-hmm. 20 MR. : -- any time a lieutenant 21 basically goes into that SHU, they should 22 really check on him? And check on that cell? 23 MS. : I would say so. 24 MR. : Okay. But that is more 25 of a, you know, it sounds like it's not EFTA00110103

LIMITED OFFICIAL USE 103 1 necessarily a policy, but just, that's good 2 practice. Is that what you are saying? 3 MS. : Yeah. Yeah. That's what I'm 4 saying. And because it was known, as you and I 5 discussed, that he should have a cellmate. So, 6 there's certain things that you would be 7 checking for, you would be checking for his 8 welfare, and you would also be checking to make 9 sure that those recommendations were adhered to 10 because you want to make sure, with certainty, 11 if you are saying that you made the round, you 12 are annotating it in the book that you made the 13 round. And you would want to say that you 14 actually went around to them, and you checked 15 on these things. 16 MR. : But is there any kind of 17 BOP or MCC policy or directive that, you know, 18 they would have violated, if they didn't in 19 fact check on Epstein's cell? 20 MS. : I can't say that it would be a 21 I don't know about the lieutenant, that 22 they would say that, because they didn't look 23 in one cell or two cells. But I do know, if 24 you are indicating, and then, that's another 25 thing. If you are, when you come inside of the EFTA00110104

LIMITED OFFICIAL USE 104 1 Special Housing Unit, there is a logbook. If 2 you are annotating in the logbook that you are 3 visiting, or if you are indicating in the 4 logbook that you are doing a round, you -. So, 5 I'm going to backtrack what I said before. 6 MR. : Well, there is an actual 7 log sheet that they sign. So, the lieutenants 8 actually have to sign that they conducted their 9 round. 10 MS. : So then, that's why I'm going 11 to backtrack then. If you are saying that you 12 did rounds, that means that you should have 13 looked in all of the cells. 14 MR. : Okay. And so, for a 15 lieutenant, that - and that, so, this is where 16 we've been getting kind of different 17 information - some lieutenants are saying, 18 absolutely, you need to go down each range, 19 check on every cell door. Other lieutenants 20 are saying, no, no, no, no, we're just supposed 21 to check in with the staff member that are in 22 there, and make sure that they don't have any 23 problems. Our rounds are really conducted on 24 the staff members, not on the inmates. So, 25 that is where I am - and there is nothing that EFTA00110105

LIMITED OFFICIAL USE 105 1 I can find, specifically in policy, that really 2 specifies that information. 3 MS. : Yeah. So, I - and that's where 4 I was kind of weaving back and forth. A 5 lieutenants' purpose, let's just say in the 6 general housing, like, general, you know, GP. 7 You are making rounds on the unit, you're 8 checking on, generally, you're checking on the 9 unit itself. And you don't, you would not go 10 down, and checking every cell, because that's 11 general population. You don't anticipate being 12 in SHU. And you are making yourself available 13 in the event that the staff member needs 14 something. So, you are physically supposed to 15 go. But if it's the Special Housing Unit, and 16 then, also 10 South, which MCC also has. 17 MR. : Correct. 18 MS. : Your responsibility level, 19 because of the practices, or just you knowing, 20 inherently, what you should be doing, it's a 21 little different than the just making yourself 22 available to the staff. You are not just there 23 for the staff. You are also there for the 24 inmates because they can't come to you. You 25 have to go to them. EFTA00110106

LIMITED OFFICIAL USE 106 1 MR. : Okay. So -- 2 MS. : So -. 3 MR. : -- so, basically, I'm 4 understanding that general population, no, a 5 SHU - or a lieutenant wouldn't have to - with 6 their rounds - don't have to be with the 7 specific inmates, but in the SHU, because they 8 have limited movement, and they are only in 9 their cells, a lieutenant really should be 10 checking on each cell, during their rounds? 11 MS. : For - like you said - for good 12 correctional judgment, sound correctional 13 practices, you - yeah - you would. 14 MR. : But to your knowledge, 15 there is no requirement. It's just sound 16 judgment and sound practice? 17 MS. : Yeah. And because that, but 18 that's why I was going back, because I don't 19 think there is anything written that says when 20 a lieutenant makes his rounds, they should go 21 to every single cell. I know their requirement 22 is, like you said, for you to, for a lieutenant 23 to be present, and to, on every shift, as well 24 as if there is also, also different departments 25 that are required to make rounds. Weekly. And EFTA00110107

LIMITED OFFICIAL USE 107 1 with that in mind, you typically know that that 2 means that you are stopping at every door, and 3 you are talking to the inmates, because again, 4 your purpose in SHU is to provide information, 5 and again, it's not like they can come out to 6 you. So, you have to go to them. 7 MR. : So, just to wrap this 8 thing up, if a lieutenant is saying that they 9 did not conduct any rounds of cells, they just 10 stopped in and talked to staff members. Do you 11 believe that they did something wrong? 12 MS. : I would say that I don't think 13 that they acted responsibly. I don't want to 14 say it's wrong or right because, you know, then 15 that person could say this, it's not written, 16 but I would say that that's not a responsible 17 decision. 18 MR. : So, when they certify 19 their round sheets that they conducted a round, 20 what do you believe that they are certifying? 21 MS. : That they have visited SHU, and 22 that they visited the inmates. 23 MR. : Okay. So, you do believe 24 that certification that they are signing, that 25 they conducted a round in the SHU, is that they EFTA00110108

LIMITED OFFICIAL USE 108 1 actually did conduct a round with the inmates? 2 MS. : That is what I believe. 3 MR. : Okay. But that is more 4 of a belief and opinion versus a knowledge. 5 Correct? 6 MS. : Yes. 7 MR. : Okay. Great. We can 8 move on. Next thing we are going to talk 9 about, and I apologize this has taken a little 10 long, is the cameras. Do you know if the SHU 11 cameras were recording on August 9th and 10th 12 of 2019? 13 MS. : I know there was some -. And 14 again, this is information that has become 15 available after the fact. I know it has become 16 known after the fact that there was some 17 cameras that were not working. And that were 18 not recorded. But did I know the day of the 19 incident? No. I did not know on the day of 20 the incident. 21 MR. : Did you know why they 22 weren't recording? Do you know what happened 23 with the cameras? 24 MS. : I know that, I don't know why 25 they were not working on that day, but I know EFTA00110109

LIMITED OFFICIAL USE 109 1 that, following Epstein, that there have been 2 issues with MCC's cameras. The recorder, that 3 there was supposed to be a backup camera, and 4 that, when the primary camera failed to record, 5 that there was supposed to be another camera 6 that kind of acts, or kind of, you know, 7 interfaces, so that there is always some 8 recording going on. That has been going on, 9 and again, that was after the fact, but as far 10 as the day of, I don't know. 11 MR. : So, you don't know what 12 caused the cameras to stop recording? 13 MS. : No. I don't know. 14 MR. : Okay. And do you 15 remember the - so, on August 8th, which would 16 have been a Thursday - do you remember, if on 17 August 8th, if you and SIS Lieutenant 18 were attempting to review video footage, and 19 you learned that you were not able to rewind 20 the cameras, and review the footage that you 21 were looking for? 22 MS. : You said on August 8th? 23 MR. : Right. And to help 24 further jog your memory. So, the information 25 we received from Lieutenant was that the EFTA00110110

LIMITED OFFICIAL USE 110 1 two of you were attempting to review video 2 footage, you weren't able to, so you called the 3 comtech, Hughwon Daniel, and asked him to 4 review the matter, and fix the issue. Does 5 that ring a bell to you? 6 MS. : If she's saying that that's 7 happened, and I know, Lieutenant and I 8 have had conversations, and about that, I would 9 say that that's - that if she is saying that 10 she and I had a conversation, I would say that 11 that probably did occur. 12 MR. : But you don't recall it? 13 MS. : I don't know if it was August 14 8th, or if it happened prior to. But I do 15 recall. I, again, I recall her and I trying to 16 look at something, but I don't recall the date 17 or the timeframe. 18 MR. : So, I guess, when you 19 arrived on the 10th, and learned that the 20 cameras weren't recording, which is, I'm 21 assuming, you would have learned on that day, 22 the 10th, that Epstein was found. Is that -- 23 MS. : Mm-hmm. 24 MR. : -- is that accurate? 25 MS. : No. No. That is not accurate. EFTA00110111

LIMITED OFFICIAL USE 111 1 MR. : Okay. When did you learn 2 that the cameras actually weren't, or didn't 3 record, or weren't recording? 4 MS. : I don't recall exactly when I 5 learned that -- 6 MR. : Oh, okay. 7 MS. but mm-hmm. 8 MR. : Okay. So, when we spoke 9 with Lieutenant , she said, when she 10 found out on the 10th that the cameras weren't 11 recording, she went to Daniel and said, hey, 12 what happened? You were to supposed fix this. 13 So, I didn't know if you 14 MS. : Oh. 15 MR. : -- you would have, you 16 know, had a similar reaction, or a similar take 17 on the matter. 18 MS. : Mm-hmm. And she is saying that 19 it was the SHU cameras that were not recording? 20 That -- 21 MR. : Well, she -- 22 MS. (Indiscernible *01:45:44). 23 MR. : -- well, she just said 24 that she knows that there were problems with 25 the cameras. I would have to look back at her EFTA00110112

LIMITED OFFICIAL USE 1 transcript to find out exactly if we were 2 talking about the SHU, but she says that -- 3 MS. : Mm-hmm. 4 MR. : -- the two of you were 5 trying, were attempting to review video, and 6 you were unable to review it because there was, 7 you couldn't find the recording, or you 8 couldn't rewind. So, the, you know, the 9 determination was made between the two of you, 10 and I can actually, let me pull up the actually 11 specific part of what she, of what she said 12 here. To see if you think it's accurate. So, 13 it says, "I remember stepping into his office." 14 Oh, okay. 15 So, "I remember stepping into his office, 16 which was right next door to mine, and 17 notifying him that the camera was down, and I'm 18 trying to get back to look at footage, and I 19 can't. Actually, I had one of the associate 20 wardens with me, as well, who happens to be his 21 supervisor." "So," I said, "Who was that?" 22 "Associate Warden ." " was there?" 23 "Yes." "Okay." "It was me and her together, 24 looking at the camera." 25 "Okay. So, it wasn't ? It EFTA00110113

LIMITED OFFICIAL USE 113 1 was actually ?" "No. It was me and AW 2 • " "And that was with Captain ?" 3 "Yes." "Okay. So then, the two of them knew 4 that the cameras were down?" "Yes." "All 5 right. And do you know if they had any 6 conversation with Daniel about a need to get 7 them back up?" 8 She says, "I don't know if they had a 9 separate conversation, but when I called Mr. 10 Daniel over to radio, Ms. was still 11 standing there with me in the office, and she 12 was there with me when he came up to check, 13 because we thought it was something that maybe 14 he could just go in, and it allow us to go to 15 look at the camera, and look for what we were 16 looking for." So, does that ring a bell to you 17 at all? 18 MS. : Yeah. That does. Mm-hmm. 19 MR. : Does that sound accurate? 20 MS. : It does. Mm-hmm. 21 MR. : Okay. So, and this was 22 what she was saying, was on August 8th, that 23 she went in. So, do you know if, were you 24 there and present when Daniel was brought into 25 the office and told to fix the issue? EFTA00110114

LIMITED OFFICIAL USE 114 1 MS. : I don't recall. I don't recall 2 - hmm-mm - I don't recall having that 3 conversation. And then, and I could have had 4 that conversation, but I don't recall having a 5 conversation with Daniel. 6 MR. : Okay. So, you don't 7 recall -. But you do recall 8 MS. : Mm-hmm. 9 MR. : -- this interaction 10 MS. : I remember -- 11 MR. : -- with both you, 12 Lieutenant , and -- 13 MS. : Yeah. 14 MR. : -- Captain 15 MS. : Mm-hmm. I do remember that. 16 And speaking of, I don't remember if it was, if 17 it was, because I'm trying to understand if it 18 was because you were saying we just couldn't 19 rewind, or if it was known that it was not, or 20 if it was that the cameras were not recording. 21 I'm hoping that you understand what I'm saying. 22 MR. : Yeah. So, the way that - 23 all right - the question was asked, so I said, 24 "Okay. So then, the two of them knew the 25 cameras were down?" She said, "Yes." And I EFTA00110115

LIMITED OFFICIAL USE 115 1 said, "Oh, all right. And do you know if they 2 had any conversations with Daniel about a need 3 to get them back up?" She said, "I don't know 4 if they had a separate conversation, but when I 5 called Mr. Daniel over to radio, Ms. was 6 still standing there with me in the office, and 7 she was there with me when he came up to check 8 because we thought it was something that may be 9 he could just go in and it allow us to go to 10 the camera, and look for what we were looking 11 for." 12 I then said, "And when he mentioned the 13 whole -". So then, we started talking about 14 overtime, and when he couldn't fix it, I said, 15 "And when he mentioned the whole, I'll stay 16 overtime, was she there when - was there - 17 when he mentioned that he would stay to work 18 overtime?" And she said, "I can't remember." 19 MS. : Well, and I know that, if I had 20 a conversation with Daniel, or anybody, about 21 the cameras not recording, versus you not being 22 able to rewind on your, on the Nice Vision. 23 That that would have been something that would, 24 that I would have known that was important. 25 And I'm trying to differentiate because there EFTA00110116

LIMITED OFFICIAL USE 116 1 are there, and I have had the experience that I 2 have access to Nice. And I was not able to 3 actually rewind on one of the cameras. 4 But it's not because the camera was not 5 recording. It's because it was, the camera was 6 not programmed correctly or something. I don't 7 even know if I'm using the proper word. But 8 it's not that the camera was not recording. It 9 had something to do more with you're not being 10 able to pull it up and rewind it on the Nice 11 Vision application. But it's not the same as 12 it not being recorded. So, that's why I was 13 asking you, is she saying that we knew that it 14 was not recording? Because that's not my 15 knowledge, or my understanding, that the 16 cameras were not recording. 17 MR. : Okay. Yeah. No. Her 18 specific words were, "I remember stepping into 19 his office, which was right next door to mine, 20 and notifying him that the camera was down. 21 And I'm trying to go back and look at the 22 footage, and I can't. Actually, I had one of 23 the associate wardens with me -- 24 MS. : Yeah. 25 MR. : -- as well." EFTA00110117

LIMITED OFFICIAL USE 117 1 MS. : That - I wouldn't say that that 2 means that the camera is not recording. Hmm- 3 mm. 4 MR. : So -- 5 MS. : And that -. 6 MR. : -- so, saying the camera 7 was down, that would, what would you think that 8 that was saying? 9 MS. : And that's not -. When you say 10 that a camera is down, that's different than 11 the whole system not recording. That's not the 12 same thing. That might be that one particular 13 camera, and whatever area that she was talking 14 about, that I believe they had to be a fight, 15 or something happening for her and I to look at 16 a camera. That particular camera may, again, 17 something might have not been programmed 18 correctly, that we were not able to rewind. 19 But that is not the same thing as a whole 20 system not being operational. 21 MR. : Okay. 22 MS. : It's two totally different 23 things. 24 MR. : Okay. So, my question on 25 this really is -- EFTA00110118

LIMITED OFFICIAL USE 118 1 MS. : And it's still fine. 2 MR. : -- my question on this is 3 really is 4 MS. : Mm-hmm. 5 MR. : -- regarding Daniel, 6 because it sounds like Daniel was told to fix 7 the issue, and that's really why I'm asking 8 this question. Do you know if Daniel was 9 instructed that you need to fix this issue? 10 MS. : You said in SHU? 11 MR. : Well, no. This is just 12 the cameras in general. 13 MS. (Indiscernible *01:52:06). 14 MR. : Well, we learned that the 15 cameras in SHU weren't recording. 16 MS. : Okay. 17 MR. : Through the 18 investigation. And to find 19 MS. : Mm-hmm. 20 MR. : -- and determining, well, 21 when was this first found out? This is 22 MS. : Okay. 23 MR. : -- you know, that there 24 was a problem with the cameras. You know, we 25 obviously had to talk to a lot of people, EFTA00110119

LIMITED OFFICIAL USE 119 1 including, you know, Daniel, and , a 2 you know -- 3 MS. : Now, that, now, I would like to 4 ask you to, did Daniel ever say that he knew 5 that the whole camera system was not working, 6 and when he knew, and who he had a conversation 7 with? 8 MR. : No, no, no. 9 MS. : About it. 10 MR. : So, that -- 11 MS. : Oh. 12 MR. : -- so, the understanding 13 that I am of is that - and again, I know at 14 least spoke with Daniel, and she 15 believed that you were with her when the 16 conversation took place. So, that is where I 17 was asking if you recall having a conversation 18 with and Daniel? 19 MS. : I recall that, but not about 20 the camera system. The whole Nice system. And 21 all of the cameras in SHU not recording. 22 MR. : Yeah. Right. And I'm 23 not saying that that would have been the 24 conversation. I would think that the 25 conversation would more be along the lines of, EFTA00110120

LIMITED OFFICIAL USE 120 1 hey, we are trying to review this video. We 2 are not able to do it. Can you figure out 3 what's going on with the cameras? 4 MS. : If that, if we had a 5 conversation about that, then I could see, 6 logically, that, yeah, I would say, Daniel, 7 hey, why we can't rewind? 8 MR. : Sure. 9 MS. : Can you fix a camera, X, Y, and 10 I, or see why it's not focused, or something to 11 that effect. 12 MR. : Right. And so, my 13 question -- 14 MS. : Yeah. Yeah. 15 MR. : -- is to you 16 MS. : Yeah. 17 MR. : -- do you remember what 18 the conversation entailed? 19 MS. : I can't remember the 20 conversation, but I know, if we were talking 21 about a particular image, or a particular 22 camera, and again, I'm not saying that it's not 23 recording, we are saying that we can't rewind, 24 that is what it would have been about. Daniel, 25 why can't we rewind? Why can't we pull up EFTA00110121

LIMITED OFFICIAL USE 121 1 camera X, Y, and I? But not about the whole 2 system. Especially if the whole system was not 3 in question. Or there was no talk about the 4 system not recording, or even SHU not 5 recording. There was never any conversation 6 about SHU, or anything. So, that's the 7 conversation would have been limited to that 8 particular camera, and why we can't rewind. 9 MR. : Absolutely. And then 10 MS. : And -. 11 MR. : -- that is kind of my 12 understanding -- 13 MS. : Yeah. 14 MR. is what your part of 15 this conversation was, is we are having an 16 issue trying to recording, can you figure it 17 out? And my question to isn't, like, you know, 18 this isn't an I gotcha type of question, even 19 in the slightest. It's just, if you can 20 MS. : Yeah. 21 MR. : -- recall what 22 conversation you had with Daniel. 23 MS. : I can only recall about that, 24 like you said, about the interaction with 25 and I talking about why we were not able EFTA00110122

LIMITED OFFICIAL USE 122 1 to rewind to see what happened. Because we 2 were able to pull the image up. We were just 3 not able to rewind. So, that is what I'm 4 saying. There is, and it might sound like I'm 5 trying to be very specific and deliberate, 6 because I am, because there is a difference 7 with you accessing the Nice system, and I'm not 8 an electronic - an electrician - or, you know, 9 an electronic person, and I could physically 10 see it, I could see it, but I am not able to 11 rewind. That doesn't let me know that, oh, the 12 system is not recording. So, that would not 13 have ever been part of the conversation. The 14 conversation would have been limited to, why is 15 it that I am able to look at it, but I can't 16 rewind? 17 MR. : Sure. Now, do you know 18 anything about 19 MS. : So, figure that out. 20 MR. : -- and do you know if, do 21 you know if Lieutenant created a memo, 22 and provided it to , regarding the camera 23 issue on the 8th? 24 MS. : No. Now, if she included me in 25 it, then I would say, oh, okay -- EFTA00110123

LIMITED OFFICIAL USE 123 1 MR. : But you -- 2 MS. : -- but I don't -- 3 MR. : -- yeah. And I don't 4 know that she would have included. She said 5 that she wrote a memo, based upon the issue 6 with the camera, and provided it to Captain 7 8 MS. : No. 9 MR. : But -- 10 MS. : Hmm-mm. 11 MR. : -- but when you -. But 12 you do remember when, you know, in her, like I 13 just read to you, she said that the 14 conversation with the problem with rewinding 15 actually was with you and , though? Do 16 you remember being present for that, you 17 know -? 18 MS. : Now, I don't know if was 19 present for that. But I do, I know, because of 20 you reciting about the conversation, I do know, 21 definitely, that was there, and if she 22 is saying that was there, it is 23 Gosh, I don't know see why she would say he was 24 or he wasn't. It didn't have great importance 25 to me, that conversation, because it wasn't -. EFTA00110124

LIMITED OFFICIAL USE 124 1 So, that is why I am not, I am not - I can't 2 recall this (Indiscernible *01:56:39), oh, this 3 person was there, that person was there, 4 because it wasn't, it wasn't, in my mind, 5 highlighted that the camera system was down. 6 So -- 7 MR. : Okay. So, what we have 8 learned is that, that is when Daniel checked on 9 the system, and he realized that - and this, 10 there is nothing that we learned that, you 11 know, have any knowledge of this, so I will 12 just, you know, put that out front - -s that 13 Daniel said he checked on the system, and he 14 realized that two of the drives were down, and 15 when two drives go down, it stops the system 16 from recording. So, half of the cameras in the 17 institution stopped, were not recording at the 18 time. And this was basically learned on August 19 8th and August 9th, when he was trying to fix 20 the system. Were you ever made aware of that 21 information? 22 MS. : No. I was not. 23 MR. : Okay. Is this the first 24 time you are even hearing of that information? 25 MS. : Absolutely. EFTA00110125

LIMITED OFFICIAL USE 125 1 MR. : And is there someone that 2 he should have told about that information, the 3 fact that -- 4 MS. : Yeah. 5 MR. : -- no, no, no, that half 6 the cameras in the institution are actually 7 down and not recording? I mean, there is 8 live feed, but there is no recording. 9 MS. : Yeah. So, he should have 10 definitely told his first line supervisor, who 11 would have known to then tell his supervisor, 12 and if I am the common denominator, because I 13 am, I was the AW, and I probably was 14 supervising facilities at the time, that 15 information, at some point, would have made it 16 to me. 17 MR. : All right. So, this is 18 another one of those everyone seemed to be out 19 on the 9th, at least. Mr. Nobile was the 20 facilities manager, and he was actually out 21 that entire week. So, he wasn't in the know 22 that the cameras were down. So, it was just 23 MS. : There is a, there is a -. 24 Okay. So, there is his -. So, Daniel's first 25 line supervisor is not actually Nobile. Nobile EFTA00110126

LIMITED OFFICIAL USE 126 1 was his second line supervisor. 2 MR. : Okay. 3 MS. : His first line supervisor was 4 another person. Linton (Phonetic Sp. 5 *01:58:34). I don't know if Linton was working 6 at the institution at the time, but Nobile, who 7 is the facility manager, is the second line 8 supervisor. 9 MR. : Would -- 10 MS. : So, I don't -. 11 MR. : -- would Linton be, you 12 are talking about the general foreman? 13 MS. : Yeah. The general foreman. 14 MR. : If there was no one -- 15 MS. : Yeah. 16 MR. : -- filing the general 17 foreman at the time -- 18 MS. : No. 19 MR. : -- is our understanding. 20 MS. : So, there was not even an 21 acting in place? 22 MR. : Yeah. From Nobile's out 23 of office response, to the people that acted in 24 his stead, where Ryan McNamara (Phonetic Sp. 25 *01:58:57), and I think her name was Geise EFTA00110127

LIMITED OFFICIAL USE 1 (Phonetic Sp. *01:59:02). 2 MS. : Oh. Oh. 3 MR. : But -- 4 MS. : Acting in his place. 5 MR. : -- right. So, but that 6 wasn't an acting for the general foreman. From 7 our understanding is that there was just no one 8 in the general foreman role at the time, and 9 that's, unfortunately, on the 9th, there is a 10 lot of people that were out of the institution, 11 and a lot of people that were not there, that 12 would have -- 13 MS. : Then -- 14 MR. : -- potentially been in 15 the know in these situations. 16 MS. : -- then he could have 17 contacted, he should have contacted somebody. 18 I mean, if you are all - and I'm just going to 19 say line staff, but they are all peers, they 20 are all subordinates, and no one is a 21 supervisor. If there is something that, that's 22 a security issue, you would raise it to 23 someone, of a supervisory nature. And if your 24 supervisor is not there, you would raise that 25 to the next level, who was, in the absence of EFTA00110128

LIMITED OFFICIAL USE 128 1 your supervisor, your supervisor's supervisor. 2 MR. : And do you know, so, 3 according to Daniel, this is something that 4 happened quite regularly. 5 MS. : Mm-hmm. 6 MR. : That these things would 7 go down, he would have to rebuild the system, 8 and then the cameras would be down for, you 9 know, a period of 24 hours, while the system 10 rebuilt. Were you aware of that? 11 MS. : Hmm. No. I know, after the 12 fact, there have been issues that we were aware 13 of with the camera. But prior to, and again, 14 arrived at the institution in July -- 15 MR. : Sure. 16 MS. so, this is one-month in. 17 So, if there were historical issues with the 18 camera, I have no way of knowing what existed 19 because I was not present then. But at the 20 time that I was present, there is no mention of 21 those cameras being down. And again, because 22 of that incident, there was obviously 23 heightened attention to the cameras, and who 24 you should notify when you are aware that a 25 camera is down. But at the time ,when I was, EFTA00110129

LIMITED OFFICIAL USE 129 1 you know, like I said, a recent arrival, there 2 was no mention or a discussion that I was aware 3 of about any issues with the camera. 4 MR. : Okay. So, leading up to 5 this issue, you didn't know that the cameras, 6 they are a big problem at the institution? 7 MS. : You said leading up, or 8 following the incident? 9 MR. : No. Leading up to the 10 incident. 11 MS. : You said, did I have any 12 knowledge of it? 13 MR. : Right. 14 MS. : Yes. Leading up to the 15 incident, there was no knowledge that there was 16 issues with the cameras recording. 17 MR. : Okay. And do you know if 18 - when you and Lieutenant were speaking 19 with Daniel - do you know if he was told to fix 20 the camera situation immediately? Or to just 21 look into it and figure out what's going on. 22 Do you recall? 23 MS. : I don't -. I don't want to -. 24 I don't want to -. I don't recall my exact 25 words to him. But again, if there was no EFTA00110130

LIMITED OFFICIAL USE 130 1 mention that the camera was not recording, 2 there is a difference when instruction, based 3 on knowledge that the cameras are not working, 4 versus knowledge that the camera that I can see 5 it, but I can't rewind it: 6 MR. : Sure. 7 MS. : And not -- 8 MR. : So, you 9 MS. : -- knowing -- 10 MR. : -- so, you knew that 11 there was an issue with the camera. You just 12 didn't know what the issue was. 13 MS. : I knew that we could not 14 rewind. Yes. 15 MR. : Okay. 16 MS. : Yes. 17 MR. : And do you remember if 18 you ever followed up, after that conversation, 19 with anyone, to say, hey, did that ever get 20 resolved? 21 MS. : I don't. I don't recall. 22 MR. : Okay. Is there a reason 23 why you should have, or did you believe someone 24 else was on top of it, and that was fixing it, 25 and looking into it? EFTA00110131

LIMITED OFFICIAL USE 1 MS. : I don't (Indiscernible 2 *02:02:48). I don't -. I actually, I don't 3 recall because, again, at the time, when we 4 were looking at the camera, you can see it. 5 So, there was, there was never any discussion, 6 or there was never even no information to say 7 that the camera was not working. There was 8 never any discussion about that. So, to follow 9 up on an issue that you don't know is present, 10 I would say that that's, if I didn't have a 11 further discussion about it, it's because of 12 that, that there was no discussion that the 13 camera was not recording. 14 MR. : Okay. So, from the 15 knowledge that you do have, that, you know, you 16 know, according to , she was saying she 17 knew that the cameras weren't recording, and 18 they were down. And then, Daniel saying that 19 he was going to fix them, and he clearly knew 20 the cameras weren't recording. What should 21 have happened? 22 MS. : Well, first, I want to clarify, 23 you are saying that said that she knew 24 the cameras were not recording. 25 MR. : She - yeah - her -. That EFTA00110132

LIMITED OFFICIAL USE 132 1 is what I read you before - that she said, her 2 words, "Notifying him that the camera was down, 3 and trying to go back and look at the footage, 4 and I can't." And then, later on 5 MS. : But that's not saying that 6 MR. : -- saying, you know, 7 saying -- 8 MS. : -- (Indiscernible *02:04:10). 9 MR. : -- so, okay -- 10 MS. : Yeah. 11 MR. : -- the two of them knew 12 the cameras were down. Yes. And then, she 13 said that she actually wrote a memo to the 14 captain, saying that, you know, the cameras 15 were down, and that Daniel was fixing the 16 issue. And then, when he came in on the 10th, 17 to find out the cameras still hadn't recorded, 18 she had a conversation with Daniel and said, 19 hey, you told me you were going to fix the 20 cameras. Why didn't you fix them? So, I'm not 21 saying that you have any part of this. What 22 I'm saying -- 23 MS. : Oh. 24 MR. : -- you, is -- 25 MS. : No. I know -- EFTA00110133

LIMITED OFFICIAL USE 133 1 MR. : -- being that Lieutenant 2 seems to have known that the cameras 3 were down, and Daniel definitely knew the 4 cameras were down, what should have happened? 5 MS. : Then no one should have 6 followed up to say were the cameras, if saying 7 down means not recording. 8 MR. : Right. And that's what 9 they -- 10 MS. : That's (Indiscernible 11 *02:04:57). 12 MR. : -- and that was clear. 13 Daniel went into, you know, great detail of, 14 the cameras, you could watch live, it's only 15 when you try to rewind, because they weren't 16 recording. And he said -- 17 MS. : That's -- 18 MR. : -- this is what happened 19 20 MS. : -- (Indiscernible *02:05:11). 21 MR. : -- and he -- 22 MS. (Indiscernible *02:05:11). 23 MR. sorry. Go ahead. 24 MS. : I don't know if knew 25 that what, the explanation that you said, EFTA00110134

LIMITED OFFICIAL USE 134 1 Daniel provided, that, I have never had a 2 conversation to say that the reason why you 3 can't rewind is because the cameras are not 4 recording. I don't know. I can't say what 5 knew. If she understood that that's 6 what that meant. I know that I know that 7 that's -. I did not know that that's what that 8 meant. So, if Daniel never came back, and 9 said, oh, the cameras are not recording, that 10 is a difference with then just saying that, oh, 11 you could see the camera, you are thinking that 12 the camera is working. If you pull up a camera 13 on the Nice Vision (Phonetic Sp. *02:05:52), 14 and you could actually see the image and 15 everything, you are thinking that the camera is 16 recording. So, how else would -? Why else 17 would you think that it's not recording? 18 MR. : Well, that's why -- 19 MS. (Indiscernible *02:06:02) 20 MR. : -- that's why I'm trying 21 to explain to you -- 22 MS. (Indiscernible *02:06:04). 23 MR. : -- like, said that 24 she knew that they weren't. That's why she 25 wrote the memo to the captain, and that's why - EFTA00110135

LIMITED OFFICIAL USE 135 1 2 MS. : Yeah. 3 MR. : -- on the 10th, when she 4 found out that the cameras were still down, she 5 confronted Daniel and said, you were supposed 6 to fix this, why didn't you fix the cameras? 7 MS. : Hmm. 8 MR. : So, those two things is 9 what I'm trying to I've been trying to 10 explain to you 11 MS. : Oh. 12 MR. : -- is that she did know, 13 is because that is why she wrote the memo to 14 the captain, and that is why she confronted 15 Daniel on the 10th, saying why didn't you fix 16 this? 17 MS. : And my response then would be: 18 maybe she thought - and I'm not, I don't even 19 want to -. I don't know. Maybe -- 20 MR. : And she didn't point the 21 22 MS. : -- (Indiscernible *02:06:42). 23 MR. : -- she didn't point the 24 finger at you in the slightest. I'm not even 25 trying to insinuate that. EFTA00110136

LIMITED OFFICIAL USE 136 1 MS. : Mm-hmm. 2 MR. : I'm saying, because you 3 are the AW in charge of -- 4 MS. : Yeah. 5 MR. : -- you know, this 6 situation, what should have happened? And this 7 8 MS. : Mm-hmm. 9 MR. : -- and again, isn't 10 gotcha. I'm asking you -- 11 MS. : Mm-hmm. 12 MR. : -- as a genuine question. 13 Like, you're the boss. What should have they 14 done? 15 MS. : Yeah. Someone should have 16 specifically said the cameras are not 17 recording. And I'm not going to say it's 18 responsibility, but she reported it. 19 If she reported it to her supervisor, she did 20 what she was supposed to do. So, I'm going to 21 kind of -. Like you said, I'm going to try to 22 come back and be, like, really assess it. If 23 she reported it to her supervisor, that's her 24 responsibility. 25 That's what she did. But from there, it - EFTA00110137

LIMITED OFFICIAL USE 137 1 . I wish had said to me, hey, I 2 received this memo from , saying that the 3 cameras are not working. And that I spoke with 4 Daniel, and the cameras are not working, they 5 are not recording. And that is something that 6 I could have definitely said, okay, Daniel, you 7 have to do overtime, in the absence of your 8 supervisor, I am authorizing you to do 9 overtime, to then fix the cameras, and then, 10 when something like that happens, obviously, 11 you know you have to make security related 12 decisions. 13 Then you could have recalled all the 14 inmates, so that if there is any incidents that 15 happened, at least the inmates are confined to 16 their cells. And then, you say, well, there is 17 no cameras inside of the cells. But you make 18 rounds. You have to make rounds in Special 19 Housing anyway. You know? So, you wouldn't be 20 able to capture what's happening inside of the 21 cell itself. But you would have a general idea 22 about, you know, with the cameras, what's going 23 on. 24 But there would have been decisions that 25 would have been made, to ensure security. But EFTA00110138

LIMITED OFFICIAL USE 138 1 there should have been notification, and 2 clarification, and specificity about - 3 specificity - about actually what was the 4 issue. 5 MR. : Okay. So, in your 6 opinion, though, it's should have 7 reported it to should have made 8 the appropriate - like, this is, I'm not saying 9 that this did or didn't happen. I'm just 10 saying, under, from what you know -- 11 MS. : Mm-hmm. 12 MR. should have 13 told should have made whatever 14 appropriate, you know 15 MS. : He should have told -- 16 MR. : -- taken whatever actions 17 needed to be taken. 18 MS. : -- he should have -. Yeah. 19 Then, if I was his supervisor, then he should 20 have told me. 21 MR. : Okay. And again, it 22 sounds like this is how - you already answered, 23 but to be clear - you knew there was a problem 24 with that one specific incident, trying to 25 rewind, but you had no idea what the problem EFTA00110139

LIMITED OFFICIAL USE 139 1 was. You just knew you weren't able to rewind. 2 MS. : And - yeah - if you simplify 3 it. Yeah. 4 MR. : Right. So, you didn't 5 know that the -- 6 MS. : Mm-hmm. 7 MR. : -- point being, you 8 didn't know the cameras were down. 9 MS. : Yeah. 10 MR. : You didn't know that they 11 were not recording. 12 MS. : Exactly. 13 MR. : Great. So, were you 14 aware that MCC cameras were scheduled to be 15 replaced? 16 MS. : Him. No. I didn't know that 17 they were scheduled to be replaced. I know 18 again - there is information that you -. I 19 don't know if they were scheduled to be 20 replaced. I know that they have been, they 21 were upgraded after. And then, I know there 22 was certain projects. But I don't -. I, 23 again, I don't know what I -. That, if they 24 were scheduled to be replaced at the time of 25 the incident. EFTA00110140

LIMITED OFFICIAL USE 140 1 MR. : So, I guess what I'm 2 saying is, do you know if they were, you had 3 new cameras on site at the MCC, and there was 4 currently a camera project underway, of 5 replacing the old cameras? Did you know that? 6 MS. : No. Not at the time. 7 MR. : Okay. 8 MS. : Not -. Not at the time. 9 MR. : So, based on the work 10 orders and email communications that we 11 received -- 12 MS. : Mm-hmm. 13 MR. : -- the MCC ordered new 14 cameras, DVRs, and other system parts, and had 15 them delivered to the MCC in approximately 16 October of 2018. 17 MS. : Mm-hmm. 18 MR. : These were the cameras 19 that were installed immediately after Epstein's 20 death in August of 2019. 21 MS. : Hmm. 22 MR. : Did you know that to be 23 accurate? 24 MS. : I know that there were cameras 25 that were installed after, and afterward, but EFTA00110141

LIMITED OFFICIAL USE 141 1 again, I don't know when those cameras arrived 2 because I didn't work there in 2018. 3 MR. : Sure. Sure. 4 MS. : No. 5 MR. : But I guess what I'm 6 saying, though, is -- 7 MS. : Oh. 8 MR. : -- did you know that 9 those cameras were on site, and they were, you 10 know -- 11 MS. : No. 12 MR. : -- you didn't even know 13 that? 14 MS. : No. There's a lot of things 15 that have, obviously that folks have knowledge 16 of after the fact because of the incident, and 17 there have been actions after, but there was 18 no, I was not knowledgeable about cameras being 19 on site, and about the installation prior to. 20 MR. : And just to be clear. 21 So, Nobile, you know, the facilities manager -- 22 MS. : Mm-hmm. 23 MR. : -- you know, Warden 24 N'Diaye, and, you know, Daniel, they have all 25 said, yup, this is accurate. So, the follow up EFTA00110142

LIMITED OFFICIAL USE 142 1 on that is, when should the new camera system, 2 that was already on site at the MCC, have been 3 installed? Do you have even a -? Or do you 4 just not have knowledge on that because you 5 weren't there at the time? 6 MS. : Yeah. So, I don't have 7 knowledge of that. 8 MR. : Okay. Do you know who 9 would have been ultimately responsible for 10 ensuring -? Because it sounds - and again, you 11 weren't there at the time, but there was a lot 12 of problems, the same problem happened time and 13 time again, at the MCC, where these cameras 14 would -. Two hard drives would crash, and then 15 take out the system. And then, Daniel would 16 have to go and rebuild the system, and it was, 17 like, a 24 hour process to rebuild it. 18 MS. : Mm-hmm. 19 MR. : Who should have made sure 20 that new camera system was installed? That was 21 on site. Who should have, like, said, like, 22 this is an urgent matter? And I am assuming it 23 was. Was that an urgent matter, if the cameras 24 are down? 25 MS. : Mm-hmm. Yeah. EFTA00110143

LIMITED OFFICIAL USE 143 1 MR. : And they are not 2 recording? I would think that that's a pretty 3 big deal. Correct? 4 MS. : Mm-hmm. Correct. 5 MR. : So, who should have made 6 sure that that new system was installed? That 7 had been on site, all the way back to October 8 2018. 9 MS. : It's multi-layered. And when 10 it's a multi -. This is multi-layered. Because 11 if you are saying that, who actually does the 12 work for the installation, or who the primary 13 person is the electronics technician. But 14 ultimately, they have a supervisor, and that 15 supervisor tracks the completion of projects. 16 The progress of projects. So, it's - that's 17 what I'm saying - it's multi-layered. That, 18 and if the cameras were present, I don't know 19 what would have happened to make them not be 20 installed. 21 MR. : And just for more -- 22 MS. (Indiscernible *02:13:50) 23 MR. : -- information, the 24 reason why they were on site, the reason why 25 you guys were able to get your cameras EFTA00110144

LIMITED OFFICIAL USE 144 1 immediately back up and running, with a whole 2 new system, was because they were already on 3 site. So, knowing that information, what is 4 your thought on the matter? Like, the fact, 5 now that you are hearing, and again, this is, 6 I'm looking at you as a subject matter expert. 7 I am not looking for any type -. 8 I'm not accusing you of anything. I'm 9 just looking at you as you are a boss there. 10 You are in charge of custody. So, I am just 11 kind of giving you this information, so you can 12 give me your professional feedback. So, the 13 fact that they were able to immediately install 14 this, have SigNet come in, who was the 15 contracted company, and install these new 16 cameras that had been on site since October of 17 2018 -- 18 MS. : Mm-hmm. 19 MR. : -- what is your opinion 20 on that? 21 MS. : Hmm. 22 MR. : Do you think that they 23 were, you know, the MCC, or, you know, really 24 dropped the ball with having this faulty camera 25 system, and actually having the parts that they EFTA00110145

LIMITED OFFICIAL USE 145 1 needed on site, to be able to be replaced? 2 MS. : I'm careful with saying about 3 this, who dropped the ball. I know if you know 4 that there is cameras present. And there is no 5 logical reason why the cameras can't be 6 installed. And if it is your department that 7 is responsible for installing the cameras, then 8 you should ultimately ensure that the cameras 9 are installed. And -. 10 MR. : Now, should - would it 11 fall on the facilities manager to make sure 12 that that's happening? 13 MS. : The Comtech works for the 14 facility manager. So, the facility manager is 15 responsible for the department that that staff 16 member works in. 17 MR. : So -- 18 MS. : You know? 19 MR. : -- according to Daniel, 20 he said that his job was basically to fix it. 21 His job, you know, fix things when they're 22 broken. And he had been screaming that there 23 was a problem with these camera systems for a 24 long time, and he's basically the reason why 25 they got the new cameras, but he said, you EFTA00110146

LIMITED OFFICIAL USE 146 1 know, it wasn't his job to get SigNet there, to 2 be able to actually get these installed. 3 You know, so, that is where, to me, 4 hearing that explanation, it sounds like oh, 5 well, it's really probably the facilities 6 manager that is, you know, supposed to manage 7 that task, and make sure that they get in 8 there. But I don't -. I want to make sure 9 that that would be an accurate, you know, 10 assessment, or if I'm off. 11 MS. : Now, would have I don't know 12 if, like you said, if it's the facility manager 13 that actually calls SigNet, or if it is the 14 Comtech that would call and coordinate SigNet's 15 visit. It's between the two. 16 MR. : So, you believe they 17 have, both have part responsible --- 18 MS. : Mm-hmm. 19 MR. : -- you know -- 20 MS. : Mm-hmm. 21 MR. : -- their part exposure to 22 this thing? 23 MS. : Yeah. 24 MR. : And anything -- 25 MS. : Yeah. EFTA00110147

LIMITED OFFICIAL USE 147 1 MR. anyone outside of the 2 facilities manager? I mean, did this go up to 3 the executive, you know, level, to the captain, 4 AWs, or warden? 5 MS. : If they were aware that the 6 cameras were there, and that the cameras should 7 have been installed. Now, and that's what I'm 8 saying, I don't know if, who knew that the 9 cameras were there. 10 MR. : Yeah. I mean, certainly, 11 the warden did. 12 MS. : Or that -- 13 MR. : But -. 14 MS. : -- that it shipped. Mm-hmm. 15 MR. : So, if the -- 16 MS. : Mm-hmm, 17 MR. : -- warden knew that, is 18 that something you think that he has exposure 19 to, then, as well? 20 MS. : Hmm. Oh my gosh. If - again, 21 without knowing who knew what, I don't, I don't 22 know who -. This is -. Yeah. 23 MR. : Sure. 24 MS. : No. 25 MR. : No. And that's fine. EFTA00110148

LIMITED OFFICIAL USE 148 1 And point being, though, you didn't know that 2 the cameras were even there. It sounds like 3 you are saying? 4 MS. : I would have no knowledge to 5 know about the cameras were there, because this 6 all happened prior to me. 7 MR. : Right. No. I'm just 8 saying -- 9 MS. (Indiscernible *02:17:39). 10 MR. : -- like, you know, you 11 were -- 12 MS. : Yeah. No. 13 MR. : -- you were -- 14 MS. : No. 15 MR. : -- you were, I know it 16 was only a month and a half, but you were 17 there, leading up to this point. I just didn't 18 know if that was a conversation that would be 19 happening within executive staff meetings, 20 that, hey, this is where we are on the camera 21 project. You know, and -- 22 MS. : Well, now -- 23 MR. : -- we'll be -. 24 MS. : -- conversations about the 25 camera project, and again, I'm going to EFTA00110149

LIMITED OFFICIAL USE 149 1 reiterate what I've kind of said before, 2 because of this incident, there have been 3 discussions about things that happened within 4 this incident, but that's after the fact. 5 MR. : And so, prior 6 MS. you're asking -- 7 MR. : -- prior to August 10th, 8 that you weren't involved in the conversations 9 at all with the camera project? 10 MS. : I do not recall anything 11 specifically about discussing about camera 12 project. 13 MR. : Great. 14 MS. : Now, if you can, if you can 15 show me something, or anything to that effect, 16 then I can say, okay, yes. 17 MR. : No, no, no, and again, 18 this is not an I gotcha interview. This is 19 just to ask -- 20 MS. : No. I know. 21 MR. : -- you know -. 22 MS. : I know. But I'm being 23 forthcoming, so that's why I'm trying to tell 24 you. In your investigation, I know you are 25 aware, you've had conversations with folks that EFTA00110150

LIMITED OFFICIAL USE 150 1 are giving you information, but this is 2 information after the fact. 3 MR. : Right. And then -- 4 MS. : So -. 5 MR. : -- and point being is you 6 don't recall anything prior to, about -- 7 MS. : No. 8 MR. : -- a camera project. You 9 are not -. You weren't aware that there was a 10 - at least at this moment in time - you don't 11 recall there ever being a camera project 12 leading up to the incident? 13 MS. : I do not recall. Hmm-mm. 14 MR. : Okay. 15 MS. : I did -. Yeah. I don't 16 recall. Mm-hmm. 17 MR. : Okay. So, now, we are 18 going to touch on cell assignments. Then we're 19 going to just try to fly through the rest, 20 because that was the primary things I wanted to 21 talk to you about, were the cameras and 22 MS. : Mm-hmm. 23 MR. : So, these are more just 24 to touch on some things. 25 MS. : Mm-hmm. EFTA00110151

LIMITED OFFICIAL USE 151 1 MR. : Now, are you aware that, 2 on August 9th and 10th, 2019, Epstein was not 3 in his assigned cell, as documented within the 4 BOP cell assignment history, and the BOP 5 database? 6 MS. : Can you say that one more time? 7 I'm sorry. 8 MR. : So, were you aware, are 9 you aware of anything with a cell discrepancy, 10 with Epstein, that he was, he was physically in 11 a cell that didn't correspond with the BOP 12 system? 13 MS. : Yes. And this information 14 after, after the fact. 15 MR. : And do you know why 16 Epstein wasn't in his assigned cell, according 17 to the BOP database? 18 MS. : Sheer error. 19 MR. : And do you know who made 20 that error? 21 MS. : Not - no - not specifically. 22 don't know who made the error. 23 MR. : So, what do you know 24 about it? 25 MS. : I know that there were keying EFTA00110152

LIMITED OFFICIAL USE 152 1 errors. And so, Sentry reflected one cell 2 assignment, but he was physically in another 3 cell. 4 MR. : And do you -? So, he was 5 in that cell from the time he, you know, 6 assigned to that cell in Sentry, from July 7 30th, all the way to August 10th. 8 MS. : Mm-hmm. 9 MR. : So, being that he was 10 there for, you know, ten or 11 days -- 11 MS. : Mm-hmm. 12 MR. : -- should that have been 13 caught in that period of time? 14 MS. : Yes. 15 MR. : And who should have 16 caught that? 17 MS. : The folks that are doing the 18 rounds. 19 MR. : So, is that, that falls 20 onto the SHU staff? 21 MS. : If - yeah - if it happened in 22 GP, it would have fallen on the person that is 23 actually doing the rounds in GP. So, yes. Mm- 24 hmm 25 MR. : Okay. And then, would EFTA00110153

LIMITED OFFICIAL USE lr 1 any lieutenants, whether it be the SHU 2 lieutenant, or the captain, or, you know, ops, 3 activities lieutenant, should any of them 4 caught this? 5 MS. : Well, they would have only know 6 that if they actually looked at a roster, and 7 physically walked with a roster, to know which 8 cell he was in. But I'm thinking about the 9 292s, whether or not it would have the cell on 10 it. I'm not sure if the 292 -. Do you know 11 what I'm talking about when I say 292? 12 MR. : Yeah. His file that is 13 kept in the housing unit. 14 MS. : Does it have this -? I'm not 15 even sure if it has the cell number on it. But 16 the long and short of it, you are making 17 rounds, you're pulling the inmate in and out of 18 his cell, you're keying, because -- 19 MR. : Now, are you talking 20 about bed book count, or are you talking about, 21 like, actual rounds? 22 MS. : No. You're making rounds. Not 23 a bed count. If you actually did it, if a bed 24 book was done, between those days, then whoever 25 did the bed book would most definitely know EFTA00110154

LIMITED OFFICIAL USE 154 1 that there was an error. Because you have to 2 have the roster with you. But without, if a -. 3 I don't know if a bed book was count during 4 that time. I know that the counts were done 5 after the fact. 6 MR. : And is there a -- 7 MS. : (Indiscernible *02:22:36). 8 MR. : -- requirement to do, 9 like, a bed book count, like once a week, or 10 any certain amount of days, or -? 11 MS. : There is no, there is no 12 requirement that says a bed book count has to 13 be done once a week. That was -. There was 14 some procedures put in place after the fact. 15 MR. : Okay. And is, and how do 16 we determine if a bed book count was in fact 17 conducted? 18 MS. : Without there being some 19 documentation, or to say, or, because I know 20 after the fact, like I said, when that was a 21 procedure put in place, it was indicated that 22 that should be documented in the log. 23 MR. : But that was an after the 24 fact thing? So, it wasn't -- 25 MS. : After. EFTA00110155

LIMITED OFFICIAL USE 155 1 MR. : -- being documented prior 2 to? 3 MS. : No. It wasn't. It wasn't done 4 prior to. Now, if you are making, TruScope, 5 the officers have a log that they do. Any 6 activity is part of whatever is going on in 7 your unit. That should have That could 8 have been logged. But is there a requirement 9 that said that you have to log that, that you 10 did the bed book count? You would be doing it, 11 you know, for documentation purposes. But a 12 lieutenant or a staff member can do a bed book 13 count, just to make sure that things are done 14 accurate. So, that's not -. It's not 15 something that was a requirement prior to. 16 MR. : Okay. So -- 17 MS. : Mm-hmm. 18 MR. : -- aside from the bed 19 book count, though, is there any other way, 20 though, and you said when they were conducting 21 rounds. I mean, when a staff member is 22 conducting rounds, are they supposed to be 23 walking around with the, you know, Sentry 24 report, or BOP roster, or whatever it is, the 25 housing roster that indicates what cell he is EFTA00110156

LIMITED OFFICIAL USE 156 1 assigned to in the system? 2 MS. : No. They don't have to have 3 the roster. However, once the inmate is 4 introduced into SHU, typically, the OIC does a 5 lot of the data entry. So, someone, even if 6 it's not the OIC, if someone in SHU, if someone 7 is doing the data entry, they are the ones that 8 is physically recording where the inmates is. 9 No one else would know where that inmate was 10 assigned unless they actually go in the system 11 and do the Sentry assignment. So -- 12 MR. : Okay. 13 MS. : -- the person that is saying, 14 okay, if I am saying put inmate X, Y, and I in 15 cell ten, I have to change him from wherever he 16 was before, and make sure that I update, I 17 update it. And not only that, there is a 18 physical board in SHU that you have the cards. 19 You have name tags or whatever. And it shows 20 where everyone is. 21 MR. : And does it say where 22 they are based upon them writing it down from 23 knowing that they are in there, or is that 24 showing where they are based upon what the BOP 25 system says? EFTA00110157

LIMITED OFFICIAL USE lr 1 MS. : From knowing where - from 2 knowing where they are. 3 MR. : Okay. 4 MS. : So, the system, and everything 5 should be the same. So, if I'm changing, if 6 I'm changing an inmate's Sentry assignment, 7 then I know I - I automatically know there is 8 not just one thing I have to do, there is a 9 couple of things I have to do. 10 MR. : Mm-hmm. 11 MS. : I have to physically move the 12 body from one place to another. 13 MR. : Okay. 14 MS. : I have to put the card, you 15 know, the card off of one door, put it on the 16 new door, and I know I have to update Sentry 17 because Sentry should be accurate. I 18 physically have to do a PP - I can't remember - 19 34, and then update the Sentry assignment. And 20 then, I should physically update the board, so, 21 the door and the board would have cards on 22 them, or, you know -- 23 MR. : And this is where, so, _ 24 know what happened. I know what happened when 25 this all happened on the 30th. On the - I know EFTA00110158

LIMITED OFFICIAL USE 158 1 what happened, how it was done, where the 2 discrepancy came in place. So, I guess my 3 question, though, is: between - and so, I know 4 that the person who dropped, you know, 5 basically dropped the ball by not making the 6 correct entry on the 30th, but the fact that 7 from the 30th all the way to the 10th -- 8 MS. : Mm-hmm. 9 MR. : -- this, you know, 10 discrepancy continued, my question to you is, 11 is there any point, aside from when he was 12 physically placed in the wrong cell, and the 13 key entry wasn't, you know, updated, or not in 14 the wrong cell, but they key entry wasn't 15 updated. Was there any way that that would 16 have been caught in those approximately ten 17 days? After that initial mistake happened. 18 So, like, an audit of the system -- 19 MR. : Yeah. 20 MS. : -- or, like, hey, let's, you 21 know, aside from a bed book count, how do we 22 know that these inmates are actually in the 23 cells that they are supposed to be assigned, 24 you know, or they are in the cells that they 25 are assigned in, in the system? Is there a EFTA00110159

LIMITED OFFICIAL USE 159 1 checks and balance to that? Are they -? Is 2 there -? Is the staff supposed to be checking 3 those sheets, or is it -? Is there an audit 4 that is done by the lieutenant or the OIC? 5 MS. : I wouldn't say that there is an 6 audit done, but you -. That's (Indiscernible 7 *02:27:56). That's the 30 (Indiscernible 8 *02:27:58), ten. That -. There is not a 9 specific audit that is done on a daily basis. 10 There is not an audit that is done besides, 11 like I said, you making rounds 12 MR. : Mm-hmm. 13 MS. : -- and you -. Yeah. I can't 14 think of a specific, like you said, a procedure 15 in place that you would check, where you would 16 audit on a daily basis, besides if you were 17 actually required to do a bed book count. 18 Which, she was not required to do a bed book 19 count daily. 20 MR. : Right. And at the time, 21 they weren't required to do them at all? 22 MS. : There was no procedure - and 23 when you say they were not required - there is 24 times when -- 25 MR. : I mean, based upon a time EFTA00110160

LIMITED OFFICIAL USE 160 1 period. 2 MS. : -- yeah. 3 MR. : versus, like, a, you 4 know, an incorrect count. 5 MS. : Yeah. Not that I am - not that 6 I am aware of. 7 MR. : Okay. Now, just to touch 8 on cell searches. On August 9th and 10th, 9 2019, do you know how often the SHU staff were 10 supposed to conduct cell searches? 11 MS. : Oh, you are supposed to do cell 12 searches daily. 13 MR. : Okay. And is it, like, 14 supposed to be at least five per shift -- 15 MS. : Mm-hmm. 16 MR. : -- aside from the 17 morning? 18 MS. : It's five. 19 MR. : Five. 20 MS. : Yeah. Yeah. And then, you 21 annotate it in, I believe it's TruScope, so 22 that you are ensuring, and that kind of, it 23 tracks, so that there is a, so that you can 24 ensure that all of the cells have been done. 25 MR. : Okay. So, is it EFTA00110161

LIMITED OFFICIAL USE 161 1 acceptable that only one cell was entered as 2 being searched in TruScope, on August 9th, 3 2019? 4 MS. : No. You should do at least 5 five. 6 MR. : Now, do you believe that 7 if only one was entered, does that mean only 8 one was actually conducted? 9 MS. : Hmm. I wouldn't say that. But 10 because I don't -. Hmm. That would be -. I 11 would question why one was only entered. But 12 you should do five. And you should recall, 13 record all five. 14 MR. : Now, being, you know, day 15 and night watch -- 16 MS. : Mm-hmm. 17 MR. : -- are required to do 18 five, who is responsible for, one) conducting 19 them; and two) entering them into TruScope? Is 20 it the OIC that is ultimately responsible to 21 make sure that they are done, and then enter 22 them, or is it, there is no rhyme or reason to 23 who is actually responsible? Everybody is -- 24 MS. : I wouldn't -- 25 MR. : -- responsible. EFTA00110162

LIMITED OFFICIAL USE 162 1 MS. : -- no. I wouldn't say who, 2 because the folks that actually do the, that do 3 the rounds, they are physically, you know, 4 doing the manual labor. And typically, the SHU 5 OIC, because there is not, like, five computers 6 up in SHU. There may be one or two computers 7 in SHU. And typically, the OIC is the one that 8 is logged in. And that person is doing all the 9 administrative work. So, they would ensure 10 that, okay, rounds are done. And if there were 11 bar taps, or like you said, if there were cell 12 searches done, that information is then 13 communicated from one officer to the OIC, and 14 then that person goes in and records that it's 15 done. 16 MR. : Okay. Do you know 17 anything about Epstein placing a telephone call 18 on August 9th, 2019, from the SHU? 19 MS. : You said from August 9th? 20 MR. : August 9th, 2019. Do you 21 know anything about Epstein placing -- 22 MS. : I -- 23 MR. : -- a telephone call from 24 25 MS. : -- again -- EFTA00110163

LIMITED OFFICIAL USE 1, 1 MR. : -- the SHU? 2 MS. : I know, I know information 3 after the fact. Just like everybody else. But 4 the day that it happened, no, I wasn't aware of 5 the phone call the day that it happened. I 6 know information after the fact. 7 MR. : Okay. And what did you 8 learn after the fact? And just briefly. 9 MS. : Mm-hmm. That there was a staff 10 member that allowed him to place a phone call. 11 MR. : Did you learn that it was 12 a phone call on an unrecorded line? 13 MS. : Mm-hmm. 14 MR. : Is that a yes? 15 MS. : Yes. That is a yes. 16 MR. : Okay. And then, do you - 17 is that standard practice, to allow inmates to 18 make personal calls, as had been done, from an 19 unrecorded line? 20 MS. : No. That is not standard 21 practice, and the phone call should be on the 22 ITS - the Inmate Telephone System - line. 23 MR. : Now, if he didn't have 24 his pack and PIN set up -- 25 MS. : Oh, yeah. EFTA00110164

LIMITED OFFICIAL USE 164 1 MR. : -- or PIN and pack, or 2 however, which way you say it, what, what could 3 have or should have happened, if you wanted to 4 allow someone to take a - make a telephone 5 call? 6 MS. : They don't make a phone call. 7 MR. : They just don't make one? 8 MS. : They don't make one. There is 9 allowances for, like, the (Indiscernible 10 *02:32:44) phone calls. That would be done by 11 the Chaplin, but that, too, is on a recorded 12 line. And that is in the Chaplin area. The 13 other thing is a legal phone call, and that 14 would be on an unmonitored line. But that 15 would only be for legal purposes. 16 MR. : Now, is it true, though, 17 if it was allowed to be done on a legal line, 18 if it was authorized by, you know, the captain 19 or whomever, or the case manager, unit manager, 20 should it be put on speaker phone, and 21 monitored by a staff member? 22 MS. : Policy says - I don't know - 23 but policy says that the inmates should make 24 phone calls, and it should be through the ITS 25 system. EFTA00110165

LIMITED OFFICIAL USE 165 1 MR. : And do you -- 2 MS. : But you -- 3 MR. : -- is that -? 4 MS. : -- but there is social calls 5 and legal calls. 6 MR. : Phone calls and legal 7 calls -. 8 MS. : Oh, no. I said there is social 9 calls and there is legal calls. 10 MR. : Okay. 11 MS. : And the only phone call that 12 should be on an unmonitored line would be the 13 legal call. 14 MR. : Okay. So, you don't, you 15 don't believe there is any circumstance where, 16 if it is not a legal call, that a social call 17 should be made? 18 MS. : I know policy, what I know of 19 policy, it indicates social calls, which should 20 be via ITS. 21 MR. : And do you know if there 22 was any kind of recorded line in the SHU, that 23 could have been utilized if an inmate did not 24 have a pack and PIN? 25 MS. : No. EFTA00110166

LIMITED OFFICIAL USE 166 1 MR. : No. 2 MS. : Hmm-mm. 3 MR. : There was no line. There 4 was no such line. Just a legal line? 5 MS. : No. I'm saying, there is an 6 ITS system in SHU. 7 MR. : No, no, no. What I'm 8 saying is 9 MS. (Indiscernible *02:34:31). 10 MR. : -- if someone doesn't 11 have a pack and PIN, to be able to record it, 12 do you know if there was another type of a 13 line, like you said, I think you said the 14 Chaplin has a line that people can use, that 15 for bereavement purposes, but it's still 16 recorded. 17 MS. : Mm-hmm. 18 MR. : Is there a line that is 19 still recorded, that a staff member can provide 20 to an inmate that doesn't have the ability to 21 make a call from his pack and PIN? 22 MS. : No. 23 MR. : Or -? 24 MS. : No. 25 MR. : And is that no, there is EFTA00110167

LIMITED OFFICIAL USE 1 no line, or no, you are not aware? 2 MS. : No, there is no line that you 3 can make a phone call from, that is recorded, 4 that is not hooked up to the ITS. 5 MR. : Okay. And when you say 6 7 MS. : -- (Indiscernible *02:35:09). 8 MR. : -- the ITS, what does 9 that mean? 10 MS. : Inmate Telephone System. 11 MR. : And is that -- 12 MS. : Yeah. 13 MR. : -- with reference to the 14 pack and PIN that they receive to be able to 15 put money on their cards and use -- 16 MS. : Mm-hmm. 17 MR. : -- or -? Yes? 18 MS. : Yeah. 19 MR. : Okay. 20 MS. : Yeah. That is a yes. 21 MR. : Okay. And what is your 22 understanding of what occurred in Epstein's 23 cell on August 9th or 10th, 2019? 24 MS. : Well, what I am aware of, 25 again, after the fact, is that he committed EFTA00110168

LIMITED OFFICIAL USE 168 1 suicide. 2 MR. : Okay. So, you believe 3 that Epstein took his own life? 4 MS. : Yes. He was the only one in 5 the cell. 6 MR. : And do you have any 7 information, with regard to anyone else taking 8 Epstein's life? 9 MS. : No. 10 MR. : Had you heard anything 11 about Epstein's cell door being left open the 12 night of August 9th, 2019, or 10th, or the 13 morning of August 10th -- 14 MS. : No. 15 MR. : -- 2019? 16 MS. : This is the first If that 17 happened, this would be the first time that I 18 have, of me even hearing that. I have never 19 heard that. 20 MR. : And have you heard of any 21 other cell mates in the SHU, in the SHU, with 22 their doors being left open the night of August 23 9th, 2019, or the morning of August 10th -- 24 MS. : No. 25 MR. : -- 2019? EFTA00110169

LIMITED OFFICIAL USE 169 1 MS. : No. I have never heard that. 2 MR. : No? And do you know if - 3 4 MS. : Never heard that. 5 MR. : -- do you know any 6 information, with regard to anyone harming 7 Epstein on August 9th or 10th, 2019? 8 MS. : No. 9 MR. : Okay. Do you know 10 anything about Epstein changing his will just 11 prior to his death? 12 MS. : Again, that's just in the news, 13 but no, I don't have any knowledge of that. 14 MR. : So, only from what you've 15 heard in the news? 16 MS. : Yeah. I don't have any 17 knowledge of that. We don't -. The BOP has 18 nothing to do with inmates' wills. 19 MR. : Okay. So, and we're just 20 going to now wrap up. It's just specific to 21 the timeline. There was an after action report 22 that was created by the BOP. So, this is 23 specifically where I am getting this 24 information, but -- 25 MS. : Mm-hmm. EFTA00110170

LIMITED OFFICIAL USE 170 1 MR. : I'm just going to ask 2 you just a couple more questions, then we will 3 be done. 4 MS. : Okay. 5 MR. : It says, "6:33 a.m., on 6 August 10th, 2019, a body alarm is activated in 7 the Special Housing Unit. SHU staff reported 8 inmate Epstein was unresponsive in cell," and 9 it says the cell, but it says Sentry does not 10 reflect this accurately. "Staff entered the 11 cell and attempted to wake inmate Epstein. 12 Control center announced a medical emergency, 13 and CPR was initiated." So, the information 14 that we have is that 6:33, Thomas told Noel, 15 call in the emergency, and Thomas went straight 16 into the cell. Did Thomas act appropriately by 17 going straight into the cell, or should he have 18 waited for someone to arrive? 19 MS. : No. There is Well, it 20 depends if you feel like you - that is an 21 emergency, and it is a life or death situation. 22 I don't know if he had the -. He could have 23 gone into -. He could have gone into the cell. 24 MR. : Okay. So, policy doesn't 25 dictate that you are supposed to wait for other EFTA00110171

LIMITED OFFICIAL USE 1 people to arrive, so that if it was a 2 MS. : Yeah. 3 MR. : -- a ruse, that someone 4 could have overpowered him, and then taken -? 5 MS. : There is no When you say 6 policy, policy does state that you have to be 7 safe, and that you should wait for another 8 staff to arrive. Policy does say that. If 9 Thomas felt that he had enough staff on hand, 10 don't know if he felt that, but policy does say 11 to ensure. And especially if you have more 12 than one inmate in a cell. So, with, I guess 13 Thomas realized there was only one inmate in 14 the cell, and if he saw the inmate hanging, he 15 would probably want to act immediately. But 16 policy protects you either way. If you feel 17 that you have enough, because - and that's your 18 - that's what I said - that's your discernment. 19 If you feel that you have enough people on, you 20 know, available, maybe he felt that way. 21 MR. : Okay. And then, it says, 22 "At 7:36 a.m., inmate Epstein pronounced dead 23 by the emergency room physician." Do you know 24 of anything about -? Do you know if Epstein 25 ever shown signs of life, prior to leaving the EFTA00110172

LIMITED OFFICIAL USE 172 1 MCC, or specifically from 6:33 a.m. to 7:36 2 a.m., do you know if he showed any kind of 3 signs of movement or life? 4 MS. : No. I don't. I arrived after. 5 And I have never heard of anything to the 6 contrary that he exhibited life. 7 MR. : Okay. And here is 8 another thing that was written in there, in the 9 BOP, and again, this is the BOP after-action 10 report. It says, "SHU has multiple cells 11 equipped with video recording capability. 12 Inmate Epstein was not housed in one of these 13 cells, and there appears to be no set guidance 14 on when to utilize these cells." So 15 specifically, I am assuming he is, they are 16 either talking about 10 South or possibly G- 17 tier. I'm not sure. I can't remember if G- 18 tier has cameras or not. But 10 South 19 certainly does. 20 MS. : Mm-hmm. 21 MR. : Do you believe that 22 Epstein should have been placed in one of those 23 cells that were, that had cameras in them? 24 MS. : I'm not going to say that. I'm 25 not going to say that he should have been EFTA00110173

LIMITED OFFICIAL USE 173 1 placed in a cell with a camera. He was an -. 2 He is an inmate, just like another inmate. So, 3 I can't, I can't say that, that he should have 4 definitely been placed in a cell. There 5 obviously was a reason that they felt that he 6 was safe, since he didn't say that he was going 7 to -. I don't -. Yeah. I can't say that he 8 should have definitely been placed in a cell 9 with a camera. 10 MR. : Okay. 11 MS. : Because those cells are for the 12 SAMs inmates. Those inmates that can't, you 13 know, their communication has to be monitored. 14 So, that is a different vetting process. 15 MR. : Okay. 16 MS. : Mm-hmm. 17 MR. : And do you These are 18 going to be the last, like, three or four 19 questions. Oh. What do you believe allowed 20 Epstein to be able to - if he took his own life 21 - what do you believe allowed Epstein to take 22 his own life? 23 MS. : Well, there were, I think his, 24 if that's what he wanted to do, without - 25 because the -. Now, we do know that staff EFTA00110174

LIMITED OFFICIAL USE 174 1 members have to make rounds. They're going 2 to, every, I don't know, 30 minutes, a regular 3 round. But he could have done it right before, 4 or right after the round. So, it doesn't mean 5 that he still - at the end - still wouldn't 6 have happened. So, I can't say for certain 7 that, we still would not have had the same 8 outcome. 9 So, I can't -. I know there was some 10 things that staff did not do that they were 11 supposed to do. Had they still made their 12 rounds, there is a possibility that a death 13 could have still have occurred, because there 14 are instances where staff make their rounds, 15 and inmates still are able to successfully 16 complete suicide, unfortunately. So, in this 17 instance, staff - we all, again, know - staff 18 did not do what they were, you know, supposed 19 to do by policy, but I can't say with certainty 20 that he still would not have been able to 21 successfully complete suicide. 22 MR. : So, it sounds like rounds 23 would have helped. What about having a 24 cellmate? Do you think that would have helped? 25 MS. : Yes. A cellmate would have EFTA00110175

LIMITED OFFICIAL USE 175 1 been able to alert a staff member, that is, if 2 they were alert and oriented themselves. 3 MR. : Yeah. I would think, 4 though, if a cellmate was in there, and they 5 saw someone hanging themselves, you know, 6 obviously, there would be no requirement, I 7 guess, for them to do it, but that would 8 certainly indicate to that person that they 9 probably, there was an issue. Right? 10 MS. : Yeah. But when you say that, 11 when you say that, it depends on, see, if the 12 manner in which he committed suicide, he did it 13 because he was in there by himself. Yes. 14 MR. : Right. 15 MS. : But there is instances where 16 you have cellmates, if you are on, you could 17 have - an inmate could have tied a ligature 18 around his neck, if he was in his bed, and just 19 hung himself that way. So, again, there are 20 things that were not done on line with policy, 21 but I can't say for certain because we have, we 22 do have successful suicides, where staff do 23 follow procedure and follow policy. 24 MR. : But in this case, I 25 guess, you know, you know, correct me if I'm EFTA00110176

LIMITED OFFICIAL USE 176 1 wrong, but I would think that the two most 2 glaring things were the fact that he was 3 required to have a cellmate, and he didn't; and 4 that, also, staff were not conducting rounds as 5 they were required. Would you agree with that 6 assessment? 7 MS. : Yeah. We know that those 8 things did not happen. 9 MR. : And do you believe 10 anything else, you know, basically, if we are 11 looking at what all, you know, what could have 12 helped prevent this from happening in the 13 future? If we are looking at it as, you know, 14 like, well, what can we do better next time? 15 Aside from making sure, you know, cellmates 16 that are required to have cellmates have them, 17 and then, aside from making sure that staff are 18 actually conducting their rounds and counts, is 19 there anything else that should have been done? 20 MS. : Just -- 21 MR. : It sounds like you didn't 22 agree with putting him in a cell with a camera. 23 So, I'm just wondering if there is anything 24 else that -- 25 MS. : No. I'm not saying necessarily EFTA00110177

LIMITED OFFICIAL USE 177 1 I agree or disagree. I'm saying that there is 2 inmates that are in cells without cameras, and 3 they don't necessarily commit suicide. So, 4 what was the difference? Why did Epstein have 5 to be in a cell with a camera? So, I'm saying, 6 we don't -. That's not part of our policy, 7 that cameras have to be present. So, that is 8 not the That does -. That in and of itself 9 doesn't determine or make a difference whether 10 someone commits suicide or doesn't. 11 MR. : Sure. 12 MS. : Like, that's not a requirement. 13 MR. : So, I guess the - and I 14 probably got you off on track, on the camera 15 thing - I'm just saying, is there anything else 16 we are missing here, aside from, you know, what 17 we just discussed, as far as reasons that 18 allowed for Epstein to be able to take his 19 life? 20 MS. : No. 21 MR. : No. 22 MS. : I don't know. 23 MR. : Okay. What do you 24 believe the failures of the BOP - if you 25 believe there are any - that allowed for EFTA00110178

LIMITED OFFICIAL USE 178 1 Epstein to die? 2 MS. : I don't believe that the BOP is 3 responsible for him committing suicide. I 4 believe that, as you investigate, that there 5 are things that - no, none with the policy, but 6 I don't believe that that contributed to the 7 suicide itself. Because, like I said, I know 8 we are looking at it after, like, Monday 9 morning quarterbacking, but there are, there 10 are some instances where there is a successful 11 suicide, where does not follow protocol from 12 top to bottom. And it happens, unfortunately. 13 And in this instance, they didn't do everything 14 that they were supposed to do, or they didn't 15 do a lot, but I don't believe that it 16 contributed to him committing suicide. I 17 don't. I don't really believe that. 18 MR. : So, you don't believe - 19 and we didn't get into staff members sleeping 20 but you don't believe that a staff member not 21 conducting rounds, a staff member sleeping on 22 the job, a staff members not, you know, making 23 proper notifications and getting a new cellmate 24 into them, you don't believe that that is 25 contributed to him taking his own life? EFTA00110179

LIMITED OFFICIAL USE 179 1 MS. : I'm -- 2 MR. : The ability to do that? 3 MS. : hmm. Because when you are 4 saying staff members sleeping, yeah, if, even 5 if a staff member is awake, and that I'm saying 6 that because I'm aware of a successful suicide, 7 staff members can make their rounds every 30 8 minutes. And when they go by, unfortunately, 9 if someone actually is intent on committing 10 suicide, they can wait for you to make your 11 round, and they know that you don't have to 12 come back until another 30 minutes. 13 MR. : Sure. And I didn't say 14 that staff members -- 15 MS. (Indiscernible *02:47:32). 16 MR. -: -- caused him to die. 17 What I said is, helped contribute, and allowed 18 for him -- 19 MS. : Yeah. 20 MR. : -- to take his life. So, 21 what I'm saying is, like, the job -- 22 MS. : Okay. 23 MR. : -- performance that 24 wasn't done, and that's why this investigation 25 pertains to security failure and job EFTA00110180

LIMITED OFFICIAL USE 180 1 performance failure, because it seems to me 2 that there was a lot of job performance failure 3 here, at the very least, in the sense that 4 people weren't doing their jobs. 5 MS. : Mm-hmm. 6 MR. : And that, that helped 7 cause, you know, and again, I think you 8 mentioned it, if a person wants to kill 9 themselves, they're probably going to be able 10 to find a way. But there is also things that, 11 when an inmate is in our custody, it is our job 12 to try to do everything we can to keep them 13 alive, and prevent that from happening. 14 MS. : Mm-hmm. 15 MR. : So, my question to you 16 is, you don't believe that, by though, you 17 know, them not doing those things, that that 18 helped contribute? 19 MS. : And I know this might sound - 20 but you sound bewildered by my response, but 1 21 believe that it contributed to some failures, 22 but I don't really believe that the failure 23 equals the contribution of the suicide. I 24 really don't believe that. 25 MR. : Okay. Yeah. I don't EFTA00110181

LIMITED OFFICIAL USE 181 1 know that I look at it as a contribution. I'm 2 just saying, the failures that allowed for him 3 to be able to take his own life. And so, 4 again, I'm not saying that they helped assist 5 him with taking his life, but by not doing -- 6 MS. : Mm-hmm. 7 MR. their job, that, you 8 know, provided him ample opportunity to do so. 9 Would you agree with that? 10 MS. : Again, I'm going to - my thing 11 is going to be the same. 12 MR. : Okay. No. You're just 13 the first person I've talked to that said that. 14 MS. : Yeah. 15 MR. : Okay. That's totally 16 fine. Okay. Well, is there anything else that 17 I missed, or that you would like to add to 18 this? 19 MS. : Hmm-mm. No. 20 MR. : And are you still 21 there? Is there any follow up questions that 22 you have, before we end this thing? 23 MR. : No follow up questions. 24 MR. : All right. Great. Well, 25 you have my information. My cell phone. My EFTA00110182

LIMITED OFFICIAL USE 182 1 email. 2 MS. : Mm-hmm. 3 MR. : If there is anything you 4 need, please feel free to contact me. But 5 otherwise, I would very much greatly appreciate 6 if you get me that stuff we talked about, 7 specific with regard to the documents that you 8 9 MS. : Okay. 10 MR. : -- that you kept on file, 11 and I think you took - there was something else 12 that we discussed. What was the other thing? 13 Was it -? 14 MS. : You said it was about the bad 15 (Indiscernible *02:49:59). I made some notes 16 about the bad count. And then, about the court 17 document. 18 MR. : Perfect. Yeah. So, 19 there would be those specific things. But 20 again, anything -? I think you said you made 21 records of things that you produced, that would 22 be very much appreciated, as well. 23 MS. : Yeah. 24 MR. : It is 1:24 p.m. on 25 December 2nd, 2021. This is Senior Special EFTA00110183

LIMITED OFFICIAL USE 183 1 Agent and I am going to turn 2 off this recorder. 3 MS. : Okay. 4 (Whereupon, the above-entitled matter went 5 off the record and back on the record). 6 MR. : This is Senior Special 7 Agent It is currently 1:26 8 p.m., 12/02/2021. Prior to hanging up the 9 call, Associate Warden asked if I could 10 turn back on the recorder so she could make a 11 clarifying statement. So, Ms. , go ahead. 12 I'll just remind you, you are under oath, and 13 this is a voluntary interview. 14 MS. : I wanted to clarify whether I 15 filled that, some of the things helped, I guess 16 helped to, or contributed to, Epstein's ability 17 to commit suicide. While I understand that 18 this is something that no one wanted, there 19 were things that were not done, that were in 20 line with policy. That were required to be 21 done, and had those things been done, maybe we 22 would not be questioning the liability aspect. 23 But I just want to ensure that it's understood 24 that I have - I believe that that's should 25 follow policy, to ensure with certainty that no EFTA00110184

LIMITED OFFICIAL USE 184 1 inmate is able to hurt themselves, or that no 2 other inmate is able to hurt them. 3 So, with that knowledge, again, I really 4 hope that staff would have done everything 5 within their power to follow policy, so that 6 there would be no question as to what should or 7 should not have been done. And with 8 acknowledgement that there were not things done 9 that should have been done, as it relates to 10 following policy. 11 MR. : All right. Thank you 12 very much. Is there anything else you wanted 13 to add before I turn off the recorder and we 14 end this interview? 15 MS. : No. I think that's it. I just 16 wanted to add that as a sentiment, that I 17 understand that this is a serious matter, and 18 that it required care and attention, and that 19 it requires me to clarify what I believe 20 actually, you know, the staff did or did not 21 do. 22 MR. : Perfect. Thank you so 23 much. Again, if there is anything you need 24 from me, you have my email, and I will greatly 25 look forward to the information you can provide EFTA00110185

LIMITED OFFICIAL USE 185 1 following this interview. It is 1:28 p.m., 2 12/02/2021. This is Senior Special Agent 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 recorder. and I am turning off the EFTA00110186

LIMITED OFFICIAL USE 186 1 CERTIFICATE 2 I hereby certify that the foregoing pages 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 represent an accurate transcript of the electronic sound recording of the proceedings before the Department of Justice, Office of the Inspector General in the matter of: Interview of /St Brianna Rose Burton, Transcriber EFTA00110187