LIMITED OFFICIAL USE 101 1 indicated that the SHU staff was aware that he 2 was leaving. So, they put the tags up, they 3 should remove the tags. And there would be no 4 reason to keep a tag on the door, indicating 5 that there is two inmates. One, when you are 6 aware that he is no longer going to be there. 7 MR. : But should 8 MS. : Yeah. 9 MR. : -- should those 10 lieutenants have conducted a round on basically 11 Epstein's cell? 12 MS. : I would -. You would conduct a 13 I would say yes. Because especially if you 14 have a highlighted inmate, or an inmate of 15 great concern. Or someone that you know you 16 need to check on. If you are not going to look 17 at anybody else's cell, you would definitely 18 look at, or check on, the inmates that are of 19 concern, to even say, hey, you okay? Or, you 20 know, just to talk with them, or physically see 21 them. So, I would say that you would - yeah - 22 that you would have looked in his cell to see 23 something, that something is going on. 24 MR. : Now, what about -- 25 MS. : And then -. EFTA00127305

LIMITED OFFICIAL USE 102 1 MR. if Epstein -. So, if 2 they are conducting their rounds when Epstein 3 is in attorney visits, should they still be 4 checking in on his cell itself, like, to make 5 sure everything is okay with his cellmate, or 6 anything like that? 7 MS. : Well, if he was, if he was 8 physically inside of his, he physically was not 9 inside the cell at the time, but the only way 10 for you to know, because why would the 11 lieutenant automatically know that he's in 12 attorney conference? So, you still would have 13 looked in his cell. 14 MR. : So, they - regardless, in 15 this specific, you know, Epstein is your 16 highest profile inmate at the time -- 17 MS. : Mm-hmm. 18 MR. : -- any time a lieutenant 19 basically goes into that SHU, they should 20 really check on him? And check on that cell? 21 MS. : I would say so. 22 MR. : Okay. But that is more 23 of a, you know, it sounds like it's not 24 necessarily a policy, but just, that's good 25 practice. Is that what you are saying? EFTA00127306

LIMITED OFFICIAL USE 103 1 MS. : Yeah. Yeah. That's what I'm 2 saying. And because it was known, as you and I 3 discussed, that he should have a cellmate. So, 4 there's certain things that you would be 5 checking for, you would be checking for his 6 welfare, and you would also be checking to make 7 sure that those recommendations were adhered to 8 because you want to make sure, with certainty, 9 if you are saying that you made the round, you 10 are annotating it in the book that you made the 11 round. And you would want to say that you 12 actually went around to them, and you checked 13 on these things. 14 MR. : But is there any kind of 15 BOP or MCC policy or directive that, you know, 16 they would have violated, if they didn't in 17 fact check on Epstein's cell? 18 MS. : I can't say that it would be a 19 I don't know about the lieutenant, that 20 they would say that, because they didn't look 21 in one cell or two cells. But I do know, if 22 you are indicating, and then, that's another 23 thing. If you are, when you come inside of the 24 Special Housing Unit, there is a logbook. If 25 you are annotating in the logbook that you are EFTA00127307

LIMITED OFFICIAL USE 104 1 visiting, or if you are indicating in the 2 logbook that you are doing a round, you -. So, 3 I'm going to backtrack what I said before. 4 MR. : Well, there is an actual 5 log sheet that they sign. So, the lieutenants 6 actually have to sign that they conducted their 7 round. 8 MS. : So then, that's why I'm going 9 to backtrack then. If you are saying that you 10 did rounds, that means that you should have 11 looked in all of the cells. 12 MR. : Okay. And so, for a 13 lieutenant, that - and that, so, this is where 14 we've been getting kind of different 15 information - some lieutenants are saying, 16 absolutely, you need to go down each range, 17 check on every cell door. Other lieutenants 18 are saying, no, no, no, no, we're just supposed 19 to check in with the staff member that are in 20 there, and make sure that they don't have any 21 problems. Our rounds are really conducted on 22 the staff members, not on the inmates. So, 23 that is where I am - and there is nothing that 24 I can find, specifically in policy, that really 25 specifies that information. EFTA00127308

LIMITED OFFICIAL USE 105 1 MS. : Yeah. So, I - and that's where 2 I was kind of weaving back and forth. A 3 lieutenants' purpose, let's just say in the 4 general housing, like, general, you know, GP. 5 You are making rounds on the unit, you're 6 checking on, generally, you're checking on the 7 unit itself. And you don't, you would not go 8 down, and checking every cell, because that's 9 general population. You don't anticipate being 10 in SHU. And you are making yourself available 11 in the event that the staff member needs 12 something. So, you are physically supposed to 13 go. But if it's the Special Housing Unit, and 14 then, also 10 South, which MCC also has. 15 MR. : Correct. 16 MS. : Your responsibility level, 17 because of the practices, or just you knowing, 18 inherently, what you should be doing, it's a 19 little different than the just making yourself 20 available to the staff. You are not just there 21 for the staff. You are also there for the 22 inmates because they can't come to you. You 23 have to go to them. 24 MR. : Okay. So -- 25 MS. : So -. EFTA00127309

LIMITED OFFICIAL USE 106 1 MR. : -- so, basically, I'm 2 understanding that general population, no, a 3 SHU - or a lieutenant wouldn't have to - with 4 their rounds - don't have to be with the 5 specific inmates, but in the SHU, because they 6 have limited movement, and they are only in 7 their cells, a lieutenant really should be 8 checking on each cell, during their rounds? 9 MS. : For - like you said - for good 10 correctional judgment, sound correctional 11 practices, you - yeah - you would. 12 MR. : But to your knowledge, 13 there is no requirement? It's just sound 14 judgment and sound practice? 15 MS. : Yeah. And because that, but 16 that's why I was going back, because I don't 17 think there is anything written that says when 18 a lieutenant makes his rounds, they should go 19 to every single cell. I know their requirement 20 is, like you said, for you to, for a lieutenant 21 to be present, and to, on every shift, as well 22 as if there is also, also different departments 23 that are required to make rounds. Weekly. And 24 with that in mind, you typically know that that 25 means that you are stopping at every door, and EFTA00127310

LIMITED OFFICIAL USE 107 1 you are talking to the inmates, because again, 2 your purpose in SHU is to provide information, 3 and again, it's not like they can come out to 4 you. So, you have to go to them. 5 MR. : So, just to wrap this 6 thing up, if a lieutenant is saying that they 7 did not conduct any rounds of cells, they just 8 stopped in and talked to staff members. Do you 9 believe that they did something wrong? 10 MS. : I would say that I don't think 11 that they acted responsibly. I don't want to 12 say it's wrong or right because, you know, then 13 that person could say this, it's not written, 14 but I would say that that's not a responsible 15 decision. 16 MR. : So, when they certify 17 their round sheets that they conducted a round, 18 what do you believe that they are certifying? 19 MS. : That they have visited SHU, and 20 that they visited the inmates. 21 MR. : Okay. So, you do believe 22 that certification that they are signing, that 23 they conducted a round in the SHU, is that they 24 actually did conduct a round with the inmates? 25 MS. : That is what I believe. EFTA00127311

LIMITED OFFICIAL USE 108 1 MR. : Okay. But that is more 2 of a belief and opinion versus a knowledge. 3 Correct? 4 MS. : Yes. 5 MR. : Okay. Great. We can 6 move on. Next thing we are going to talk 7 about, and I apologize this has taken a little 8 long, is the cameras. Do you know if the SHU 9 cameras were recording on August 9th and 10th 10 of 2019? 11 MS. : I know there was some -. And 12 again, this is information that has become 13 available after the fact. I know it has become 14 known after the fact that there was some 15 cameras that were not working. And that were 16 not recorded. But did I know the day of the 17 incident? No. I did not know on the day of 18 the incident. 19 MR. : Did you know why they 20 weren't recording? Do you know what happened 21 with the cameras? 22 MS. : I know that, I don't know why 23 they were not working on that day, but I know 24 that, following Epstein, that there have been 25 issues with MCC's cameras. The recorder, that EFTA00127312

LIMITED OFFICIAL USE 109 1 there was supposed to be a backup camera, and 2 that, when the primary camera failed to record, 3 that there was supposed to be another camera 4 that kind of acts, or kind of, you know, 5 interfaces, so that there is always some 6 recording going on. That has been going on, 7 and again, that was after the fact, but as far 8 as the day of, I don't know. 9 MR. : So, you don't know what 10 caused the cameras to stop recording? 11 MS. : No. I don't know. 12 MR. : Okay. And do you 13 remember the - so, on August 8th, which would 14 have been a Thursday - do you remember, if on 15 August 8th, if you and SIS Lieutenant 16 were attempting to review video footage, and 17 you learned that you were not able to rewind 18 the cameras, and review the footage that you 19 were looking for? 20 MS. : You said on August 8th? 21 MR. : Right. And to help 22 further jog your memory. So, the information 23 we received from Lieutenant was that the 24 two of you were attempting to review video 25 footage, you weren't able to, so you called the EFTA00127313

LIMITED OFFICIAL USE 110 1 comtech, Hughwon and asked him to 2 review the matter, and fix the issue. Does 3 that ring a bell to you? 4 MS. : If she's saying that that's 5 happened, and I know, Lieutenant and I 6 have had conversations, and about that, I would 7 say that that's - that if she is saying that 8 she and I had a conversation, I would say that 9 that probably did occur. 10 MR. : But you don't recall it? 11 MS. : I don't know if it was August 12 8th, or if it happened prior to. But I do 13 recall. I, again, I recall her and I trying to 14 look at something, but I don't recall the date 15 or the timeframe. 16 MR. : So, I guess, when you 17 arrived on the 10th, and learned that the 18 cameras weren't recording, which is, I'm 19 assuming, you would have learned on that day, 20 the 10th, that Epstein was found. Is that -- 21 MS. : Mm-hmm. 22 MR. : -- is that accurate? 23 MS. : No. No. That is not accurate. 24 MR. : Okay. When did you learn 25 that the cameras actually weren't, or didn't EFTA00127314

LIMITED OFFICIAL USE 1 record, or weren't recording? 2 MS. : I don't recall exactly when I 3 learned that -- 4 MR. : Oh, okay. 5 MS. : -- but mm-hmm. 6 MR. : Okay. So, when we spoke 7 with Lieutenant , she said, when she 8 found out on the 10th that the cameras weren't 9 recording, she went to and said, hey, 10 what happened? You were to supposed fix this. 11 So, I didn't know if you 12 MS. : Oh. 13 MR. : -- you would have, you 14 know, had a similar reaction, or a similar take 15 on the matter. 16 MS. : Mm-hmm. And she is saying that 17 it was the SHU cameras that were not recording? 18 That -- 19 MR. : Well, she -- 20 MS. (Indiscernible *01:45:44). 21 MR. : -- well, she just said 22 that she knows that there were problems with 23 the cameras. I would have to look back at her 24 transcript to find out exactly if we were 25 talking about the SHU, but she says that -- EFTA00127315

LIMITED OFFICIAL USE 1 MS. : Mm-hmm. 2 MR. : -- the two of you were 3 trying, were attempting to review video, and 4 you were unable to review it because there was, 5 you couldn't find the recording, or you 6 couldn't rewind. So, the, you know, the 7 determination was made between the two of you, 8 and I can actually, let me pull up the actual 9 specific part of what she, of what she said 10 here. To see if you think it's accurate. So, 11 it says, "I remember stepping into his office." 12 Oh, okay. 13 So, "I remember stepping into his office, 14 which was right next door to mine, and 15 notifying him that the camera was down, and I'm 16 trying to get back to look at footage, and I 17 can't. Actually, I had one of the associate 18 wardens with me, as well, who happens to be his 19 supervisor." "So," I said, "Who was that?" 20 "Associate Warden ." " was there?" 21 "Yes." "Okay." "It was me and her together, 22 looking at the camera." 23 "Okay. So, it wasn't ? It 24 was actually ?" "No. It was me and AW 25 • " "And that was with Captain ?" EFTA00127316

LIMITED OFFICIAL USE 113 1 "Yes." "Okay. So then, the two of them knew 2 that the cameras were down?" "Yes." "All 3 right. And do you know if they had any 4 conversation with about a need to get 5 them back up?" 6 She says, "I don't know if they had a 7 separate conversation, but when I called Mr. 8 over the radio, Ms. was still 9 standing there with me in the office, and she 10 was there with me when he came up to check, 11 because we thought it was something that maybe 12 he could just go in, and it allow us to go to 13 look at the camera, and look for what we were 14 looking for." So, does that ring a bell to you 15 at all? 16 MS. : Yeah. That does. Mm-hmm. 17 MR. : Does that sound accurate? 18 MS. : It does. Mm-hmm. 19 MR. : Okay. So, and this was 20 what she was saying, was on August 8th, that 21 she went in. So, do you know if, were you 22 there and present when was brought into 23 the office and told to fix the issue? 24 MS. : I don't recall. I don't recall 25 - hmm-mm - I don't recall having that EFTA00127317

LIMITED OFFICIAL USE 114 1 conversation. And then, and I could have had 2 that conversation, but I don't recall having a 3 conversation with 4 MR. : Okay. So, you don't 5 recall But you do recall 6 MS. : Mm-hmm. 7 MR. : -- this interaction -- 8 MS. : I remember -- 9 MR. : -- with both you, 10 Lieutenant , and -- 11 MS. : Yeah. 12 MR. : -- Captain 13 MS. : Mm-hmm. I do remember that. 14 And speaking of, I don't remember if it was, if 15 it was, because I'm trying to understand if it 16 was because you were saying we just couldn't 17 rewind, or if it was known that it was not, or 18 if it was that the cameras were not recording. 19 I'm hoping that you understand what I'm saying. 20 MR. : Yeah. So, the way that - 21 all right - the question was asked, so I said, 22 "Okay. So then, the two of them knew the 23 cameras were down?" She said, "Yes." And I 24 said, "Oh, all right. And do you know if they 25 had any conversations with about a need EFTA00127318

LIMITED OFFICIAL USE 115 1 to get them back up?" She said, "I don't know 2 if they had a separate conversation, but when I 3 called Mr. over to radio, Ms. was 4 still standing there with me in the office, and 5 she was there with me when he came up to check 6 because we thought it was something that may be 7 he could just go in and it allow us to go to 8 the camera, and look for what we were looking 9 for." 10 I then said, "And when he mentioned the 11 whole -". So then, we started talking about 12 overtime, and when he could fix it, I said, 13 "And when he mentioned the whole, I'll stay 14 overtime, was she there when - was there - 15 when he mentioned that he would stay to work 16 overtime?" And she said, "I can't remember." 17 MS. : Well, and I know that, if I had 18 a conversation with , or anybody, about 19 the cameras not recording, versus you not being 20 able to rewind on your, on the Nice Vision. 21 That that would have been something that would, 22 that I would have known that was important. 23 And I'm trying to differentiate because there 24 are there, and I have had the experience that I 25 have access to Nice. And I was not able to EFTA00127319

LIMITED OFFICIAL USE 116 1 actually rewind on one of the cameras. 2 But it's not because the camera was not 3 recording. It's because it was, the camera was 4 not programmed correctly or something. I don't 5 even know if I'm using the proper word. But 6 it's not that the camera was not recording. It 7 had something to do more with you're not being 8 able to pull it up and rewind it on the Nice 9 Vision application. But it's not the same as 10 it not being recorded. So, that's why I was 11 asking you, is she saying that we knew that it 12 was not recording? Because that's not my 13 knowledge, or my understanding, that the 14 cameras were not recording. 15 MR. : Okay. Yeah. No. Her 16 specific words were, "I remember stepping into 17 his office, which was right next door to mine, 18 and notifying him that the camera was down. 19 And I'm trying to go back and look at the 20 footage, and I can't. Actually, I had one of 21 the associate wardens with me 22 MS. : Yeah. 23 MR. : -- as well." 24 MS. : That - I wouldn't say that that 25 means that the camera is not recording. Hmm- EFTA00127320

LIMITED OFFICIAL USE 1 mm. 2 MR. : So -- 3 MS. : And that -. 4 MR. : -- so, saying the camera 5 was down, that would, what would you think that 6 that was saying? 7 MS. : And that's not -. When you say 8 that a camera is down, that's different than 9 the whole system not recording. That's not the 10 same thing. That might be that one particular 11 camera, and whatever area that she was talking 12 about, that I believe they had to be a fight, 13 or something happening for her and I to look at 14 a camera. That particular camera may, again, 15 something might have not been programmed 16 correctly, that we were not able to rewind. 17 But that is not the same thing as a whole 18 system not being operational. 19 MR. : Okay. 20 MS. : It's two totally different 21 things. 22 MR. : Okay. So, my question on 23 this really is -- 24 MS. : And it's still fine. 25 MR. : -- my question on this is EFTA00127321

LIMITED OFFICIAL USE 118 1 really is 2 MS. : Mm-hmm. 3 MR. : -- regarding 4 because it sounds like was told to fix 5 the issue, and that's really why I'm asking 6 this question. Do you know if was 7 instructed that you need to fix this issue? 8 MS. : You said in SHU? 9 MR. : Well, no. This is just 10 the cameras in general. 11 MS. (Indiscernible *01:52:06). 12 MR. : Well, we learned that the 13 cameras in SHU weren't recording. 14 MS. : Okay. 15 MR. : Through the 16 investigation. And to find -- 17 MS. : Mm-hmm. 18 MR. : -- and determining, well, 19 when was this first found out? This is 20 MS. : Okay. 21 MR. : -- you know, that there 22 was a problem with the cameras. You know, we 23 obviously had to talk to a lot of people, 24 including, you know, , and , and, 25 you know -- EFTA00127322

LIMITED OFFICIAL USE 119 1 MS. : Now, that, now, I would like to 2 ask you to, did ever say that he knew 3 that the whole camera system was not working, 4 and when he knew, and who he had a conversation 5 with? 6 MR. : No, no, no. 7 MS. : About it. 8 MR. : So, that -- 9 MS. : Oh. 10 MR. : -- so, the understanding 11 that I am of, is that - and again, I know at 12 least spoke with , and she 13 believed that you were with her when the 14 conversation took place. So, that is where I 15 was asking if you recall having a conversation 16 with and 17 MS. : I recall that, but not about 18 the camera system. The whole Nice system. And 19 all of the cameras in SHU not recording. 20 MR. : Yeah. Right. And I'm 21 not saying that that would have been the 22 conversation. I would think that the 23 conversation would more be along the lines of, 24 hey, we are trying to review this video. We 25 are not able to do it. Can you figure out EFTA00127323

LIMITED OFFICIAL USE 120 1 what's going on with the cameras? 2 MS. : If that, if we had a 3 conversation about that, then I could see, 4 logically, that, yeah, I would say, 5 hey, why we can't rewind? 6 MR. : Sure. 7 MS. : Can you fix a camera, X, Y, and 8 Z, or see why it's not focused, or something to 9 that effect. 10 MR. : Right. And so, my 11 question -- 12 MS. : Yeah. Yeah. 13 MR. is to you 14 MS. : Yeah. 15 MR. : -- do you remember what 16 the conversation entailed? 17 MS. : I can't remember the 18 conversation, but I know, if we were talking 19 about a particular image, or a particular 20 camera, and again, I'm not saying that it's not 21 recording, we are saying that we can't rewind, 22 that is what it would have been about. 23 why can't we rewind? Why can't we pull up 24 camera X, Y, and Z? But not about the whole 25 system. Especially if the whole system was not EFTA00127324

LIMITED OFFICIAL USE 121 1 in question. Or there was no talk about the 2 system not recording, or even SHU not 3 recording. There was never any conversation 4 about SHU, or anything. So, that's the 5 conversation would have been limited to that 6 particular camera, and why we can't rewind. 7 MR. : Absolutely. And then -- 8 MS. : And -. 9 MR. : -- that is kind of my 10 understanding -- 11 MS. : Yeah. 12 MR. : -- is what your part of 13 this conversation was, is we are having an 14 issue trying to record, can you figure it out? 15 And my question to isn't, like, you know, this 16 isn't an I gotcha type of question, even in the 17 slightest. It's just, if you can -- 18 MS. : Yeah. 19 MR. : -- recall what 20 conversation you had with 21 MS. : I can only recall about that, 22 like you said, about the interaction with 23 and I talking about why we were not able 24 to rewind to see what happened. Because we 25 were able to pull the image up. We were just EFTA00127325

LIMITED OFFICIAL USE 122 1 not able to rewind. So, that is what I'm 2 saying. There is, and it might sound like I'm 3 trying to be very specific and deliberate, 4 because I am, because there is a difference 5 with you accessing the Nice system, and I'm not 6 an electronic - an electrician - or, you know, 7 an electronics person, and I could physically 8 see it, I could see it, but I am not able to 9 rewind. That doesn't let me know that, oh, the 10 system is not recording. So, that would not 11 have ever been part of the conversation. The 12 conversation would have been limited to, why is 13 it that I am able to look at it, but I can't 14 rewind? 15 MR. : Sure. Now, do you know 16 anything about -- 17 MS. : So, figure that out. 18 MR. and do you know if, do 19 you know if Lieutenant created a memo, 20 and provided it to , regarding the camera 21 issue on the 8th? 22 MS. : No. Now, if she included me in 23 it, then I would say, oh, okay -- 24 MR. : But you -- 25 MS. : -- but I don't -- EFTA00127326

LIMITED OFFICIAL USE 123 1 MR. : -- yeah. And I don't 2 know that she would have included. She said 3 that she wrote a memo, based upon the issue 4 with the camera, and provided it to Captain 5 6 MS. : No. 7 MR. : But -- 8 MS. : Hmm-mm. 9 MR. : -- but when you -. But 10 you do remember when, you know, in her, like I 11 just read to you, she said that the 12 conversation with the problem with rewinding 13 actually was with you and , though? Do 14 you remember being present for that, you 15 know -? 16 MS. : Now, I don't know if was 17 present for that. But I do, I know, because of 18 you reciting about the conversation, I do know, 19 definitely, that was there, and if she 20 is saying that was there, it is -. 21 Gosh, I don't know see why she would say he was 22 or he wasn't. It didn't have great importance 23 to me, that conversation, because it wasn't -. 24 So, that is why I am not, I am not - I can't 25 recall this to say that, oh, this person was EFTA00127327

LIMITED OFFICIAL USE 124 1 there, that person was there, because it 2 wasn't, it wasn't, in my mind, highlighted that 3 the camera system was down. So -- 4 MR. : Okay. So, what we have 5 learned is that, that is when checked on 6 the system, and he realized that - and this, 7 there is nothing that we learned that, you 8 know, have any knowledge of this, so I will 9 just, you know, put that out front - is that 10 said he checked on the system, and he 11 realized that two of the drives were down, and 12 when two drives go down, it stops the system 13 from recording. So, half of the cameras in the 14 institution stopped, were not recording at the 15 time. And this was basically learned on August 16 8th and August 9th, when he was trying to fix 17 the system. Were you ever made aware of that 18 information? 19 MS. : No. I was not. 20 MR. : Okay. Is this the first 21 time you are even hearing of that information? 22 MS. : Absolutely. 23 MR. : And is there someone that 24 he should have told about that information, the 25 fact that -- EFTA00127328

LIMITED OFFICIAL USE 125 1 MS. : Yeah. 2 MR. : -- no, no, no, that half 3 the cameras in the institution are actually 4 down and not recording? I mean, there is 5 live feed, but there is no recording. 6 MS. : Yeah. So, he should have 7 definitely told his first line supervisor, who 8 would have known to then tell his supervisor, 9 and if I am the common denominator, because I 10 am, I was the AW, and I probably was 11 supervising facilities at the time, that 12 information, at some point, would have made it 13 to me. 14 MR. : All right. So, this is 15 another one of those everyone seemed to be out 16 on the 9th, at least. Mr. was the 17 facilities manager, and he was actually out 18 that entire week. So, he wasn't in the know 19 that the cameras were down. So, it was just 20 MS. : There is a, there is a -. 21 Okay. So, there is his -. So, first 22 line supervisor is not actually 23 was his second line supervisor. 24 MR. : Okay. 25 MS. : His first line supervisor was EFTA00127329

LIMITED OFFICIAL USE 126 1 another person. (Phonetic Sp. 2 *01:58:34). I don't know if was working 3 at the institution at the time, but , who 4 is the facility manager, is the second line 5 supervisor. 6 MR. : Would -- 7 MS. : So, I don't -. 8 MR. : -- would be, you 9 are talking about the general foreman? 10 MS. : Yeah. The general foreman. 11 MR. : If there was no one -- 12 MS. : Yeah. 13 MR. : -- filing the general 14 foreman at the time -- 15 MS. : No. 16 MR. : -- is our understanding. 17 MS. : So, there was not even an 18 acting in place? 19 MR. : Yeah. From out 20 of office response, to the people that acted in 21 his stead, where , and I think her 22 name was 23 MS. : Oh. Oh. 24 MR. : But -- 25 MS. : Acting in his place. EFTA00127330

LIMITED OFFICIAL USE 127 1 MR. : -- right. So, but there 2 wasn't an acting for the general foreman. From 3 our understanding is that there was just no one 4 in the general foreman role at the time, and 5 that's, unfortunately, on the 9th, there is a 6 lot of people that were out of the institution, 7 and a lot of people that were not there, that 8 would have -- 9 MS. : Then -- 10 MR. : -- potentially been in 11 the know in these situations. 12 MS. : -- then he could have 13 contacted, he should have contacted somebody. 14 I mean, if you are all - and I'm just going to 15 say line staff, but they are all peers, they 16 are all subordinates, and no one is a 17 supervisor. If there is something that, that' 18 a security issue, you would raise it to 19 someone, of a supervisory nature. And if your 20 supervisor is not there, you would raise that 21 to the next level, who was, in the absence of 22 your supervisor, your supervisor's supervisor. 23 MR. : And do you know, so, 24 according to , this is something that 25 happened quite regularly. EFTA00127331

LIMITED OFFICIAL USE 128 1 MS. : Mm-hmm. 2 MR. : That these things would 3 go down, he would have to rebuild the system, 4 and then the cameras would be down for, you 5 know, a period of 24 hours, while the system 6 rebuilt. Were you aware of that? 7 MS. : Hmm. No. I know, after the 8 fact, there have been issues that we were aware 9 of with the camera. But prior to, and again, 10 arrived at the institution in July 11 MR. : Sure. 12 MS. so, this is one-month in. 13 So, if there were historical issues with the 14 camera, I have no way of knowing what existed 15 because I was not present then. But at the 16 time that I was present, there is no mention of 17 those cameras being down. And again, because 18 of that incident, there was obviously 19 heightened attention to the cameras, and who 20 you should notify when you are aware that a 21 camera is down. But at the time, when I was, 22 you know, like I said, a recent arrival, there 23 was no mention or a discussion that I was aware 24 of about any issues with the camera. 25 MR. : Okay. So, leading up to EFTA00127332

LIMITED OFFICIAL USE 129 1 this issue, you didn't know that the cameras, 2 they are a big problem at the institution? 3 MS. : You said leading up, or 4 following the incident? 5 MR. : No. Leading up to the 6 incident. 7 MS. : You said, did I have any 8 knowledge of it? 9 MR. : Right. 10 MS. : Yes. Leading up to the 11 incident, there was no knowledge that there was 12 issues with the cameras recording. 13 MR. : Okay. And do you know if 14 - when you and Lieutenant were speaking 15 with - do you know if he was told to fix 16 the camera situation immediately? Or to just 17 look into it and figure out what's going on. 18 Do you recall? 19 MS. : I don't -. I don't want to -. 20 I don't want to -. I don't recall my exact 21 words to him. But again, if there was no 22 mention that the camera was not recording, 23 there is a difference when instruction, based 24 on knowledge that the cameras are not working, 25 versus knowledge that the camera that I can see EFTA00127333

LIMITED OFFICIAL USE 130 1 it, but I can't rewind it: 2 MR. : Sure. 3 MS. : And not -- 4 MR. : So, you 5 MS. : -- knowing -- 6 MR. : -- so, you knew that 7 there was an issue with the camera. You just 8 didn't know what the issue was. 9 MS. : I knew that we could not 10 rewind. Yes. 11 MR. : Okay. 12 MS. : Yes. 13 MR. : And do you remember if 14 you ever followed up, after that conversation, 15 with anyone, to say, hey, did that ever get 16 resolved? 17 MS. : I don't. I don't recall. 18 MR. : Okay. Is there a reason 19 why you should have, or did you believe someone 20 else was on top of it, and that was fixing it, 21 and looking into it? 22 MS. : I don't (Indiscernible 23 *02:02:48). I don't -. I actually, I don't 24 recall because, again, at the time, when we 25 were looking at the camera, you can see it. EFTA00127334

LIMITED OFFICIAL USE 131 1 So, there was, there was never any discussion, 2 or there was never even no information to say 3 that the camera was not working. There was 4 never any discussion about that. So, to follow 5 up on an issue that you don't know is present, 6 I would say that that's, if I didn't have a 7 further discussion about it, it's because of 8 that, that there was no discussion that the 9 camera was not recording. 10 MR. : Okay. So, from the 11 knowledge that you do have, that, you know, you 12 know, according to , she was saying she 13 knew that the cameras weren't recording, and 14 they were down. And then, saying that 15 he was going to fix them, and he clearly knew 16 the cameras weren't recording. What should 17 have happened? 18 MS. : Well, first, I want to clarify, 19 you are saying that said that she knew 20 the cameras were not recording. 21 MR. : She - yeah - her -. That 22 is what i read you before - that she said, her 23 words, "Notifying him that the camera was down, 24 and trying to go back and look at the footage, 25 and I can't." And then, later on -- EFTA00127335

LIMITED OFFICIAL USE 132 1 MS. : But that's not saying that -- 2 MR. : -- saying, you know, 3 saying -- 4 MS. : -- (Indiscernible *02:04:10). 5 MR. : -- so, okay -- 6 MS. : Yeah. 7 MR. : -- the two of them knew 8 the cameras were down. Yes. And then, she 9 said that she actually wrote a memo to the 10 captain, saying that, you know, the cameras 11 were down, and that was fixing the 12 issue. And then, when he came in on the 10th, 13 to find out the cameras still hadn't recorded, 14 she had a conversation with and said, 15 hey, you told me you were going to fix the 16 cameras. Why didn't you fix them? So, I'm not 17 saying that you have any part of this. What 18 I'm saying 19 MS. : Oh. 20 MR. : -- you, is -- 21 MS. : No. I know -- 22 MR. : -- being that Lieutenant 23 seems to have known that the cameras 24 were down, and definitely knew the 25 cameras were down, what should have happened? EFTA00127336

LIMITED OFFICIAL USE 133 1 MS. : Then someone should have 2 followed up to say were the cameras, if saying 3 down means not recording. 4 MR. : Right. And that's what 5 they -- 6 MS. : That's (Indiscernible 7 *02:04:57). 8 MR. : -- and that was clear. 9 went into, you know, great detail of, 10 the cameras, you could watch live, it's only 11 when you try to rewind, because they weren't 12 recording. And he said 13 MS. : That's -- 14 MR. : -- this is what happened 15 16 MS. (Indiscernible *02:05:11). 17 MR. : -- and he -- 18 MS. (Indiscernible *02:05:11). 19 MR. sorry. Go ahead. 20 MS. : I don't know if knew 21 that what, the explanation that you said, 22 provided, that, I have never had a 23 conversation to say that the reason why you 24 can't rewind is because the cameras are not 25 recording. I don't know. I can't say what EFTA00127337

LIMITED OFFICIAL USE 134 1 knew. If she understood that that's 2 what that meant. I know that I know that 3 that's -. I did not know that that's what that 4 meant. So, if never came back, and 5 said, oh, the cameras are not recording, that 6 is a difference with then just saying that, oh, 7 you could see the camera, you are thinking that 8 the camera is working. If you pull up a camera 9 on the Nice Vision (Phonetic Sp. *02:05:52), 10 and you could actually see the image and 11 everything, you are thinking that the camera is 12 recording. So, how else would -? Why else 13 would you think that it's not recording? 14 MR. : Well, that's why -- 15 MS. (Indiscernible *02:06:02) 16 MR. : -- that's why I'm trying 17 to explain to you -- 18 MS. (Indiscernible *02:06:04). 19 MR. : -- like, said that 20 she knew that they weren't. That's why she 21 wrote the memo to the captain, and that's why - 22 23 MS. : Yeah. 24 MR. : -- on the 10th, when she 25 found out that the cameras were still down, she EFTA00127338

LIMITED OFFICIAL USE 135 1 confronted and said, you were supposed 2 to fix this, why didn't you fix the cameras? 3 MS. : Hmm. 4 MR. : So, those two things is 5 what I'm trying to -. I've been trying to 6 explain to you -- 7 MS. : Oh. 8 MR. : -- is that she did know, 9 is because that is why she wrote the memo to 10 the captain, and that is why she confronted 11 on the 10th, saying why didn't you fix 12 this? 13 MS. : And my response then would be: 14 maybe she thought - and I'm not, I don't even 15 want to -. I don't know. Maybe -- 16 MR. : And she didn't point the 17 18 MS. : -- (Indiscernible *02:06:42). 19 MR. : -- she didn't point the 20 finger at you in the slightest. I'm not even 21 trying to insinuate that. 22 MS. : Mm-hmm. 23 MR. : I'm saying, because you 24 are the AW in charge of -- 25 MS. : Yeah. EFTA00127339

LIMITED OFFICIAL USE 136 1 MR. : -- you know, this 2 situation, what should have happened? And this 3 4 MS. : Mm-hmm. 5 MR. : -- and again, isn't 6 gotcha. I'm asking you -- 7 MS. : Mm-hmm. 8 MR. : -- as a genuine question. 9 Like, you're the boss. What should have they 10 done? 11 MS. : Yeah. Someone should have 12 specifically said the cameras are not 13 recording. And I'm not going to say it's 14 responsibility, but she reported it. 15 If she reported it to her supervisor, she did 16 what she was supposed to do. So, I'm going to 17 kind of -. Like you said, I'm going to try to 18 come back and be, like, really assess it. If 19 she reported it to her supervisor, that's her 20 responsibility. 21 That's what she did. But from there, it - 22 I wish had said to me, hey, I 23 received this memo from , saying that the 24 cameras are not working. And that I spoke with 25 , and the cameras are not working, they EFTA00127340

LIMITED OFFICIAL USE 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 are not I could have to recording. And have definitely do overtime, in 137 that is something that said, okay, f you the absence of your supervisor, I am authorizing you to do overtime, to then fix the cameras, and then, when something like that happens, obviously, you know you have to make security related decisions. Then you could have recalled all the inmates, so that if there is any incidents that happened, at least the inmates are confined to their cells. And then, you say, well, there is no cameras inside of the cells. But you make rounds. You have to make rounds in Special Housing anyway. You know? So, you wouldn't be able to capture what's happening inside of the cell itself. But you would have a general idea about, you know, with the cameras, what's going on. But there would have been decisions that would have been made, to ensure security. But there should have been notification, and clarification, and specificity about - specificity - about actually what was the issue. EFTA00127341

LIMITED OFFICIAL USE 138 1 MR. : Okay. So, in your 2 opinion, though, it's, should have 3 reported it to should have made 4 the appropriate - like, this is, I'm not saying 5 that this did or didn't happen. I'm just 6 saying, under, from what you know -- 7 MS. : Mm-hmm. 8 MR. should have 9 told should have made whatever 10 appropriate, you know 11 MS. : He should have told -- 12 MR. : -- taken whatever actions 13 needed to be taken. 14 MS. : -- he should have -. Yeah. 15 Then, if I was his supervisor, then he should 16 have told me. 17 MR. : Okay. And again, it 18 sounds like this is how - you already answered, 19 but to be clear - you knew there was a problem 20 with that one specific incident, trying to 21 rewind, but you had no idea what the problem 22 was. You just knew you weren't able to rewind. 23 MS. : And - yeah - if you simplify 24 it. Yeah. 25 MR. : Right. So, you didn't EFTA00127342

LIMITED OFFICIAL USE 139 1 know that the -- 2 MS. : Mm-hmm. 3 MR. : -- point being, you 4 didn't know the cameras were down. 5 MS. : Yeah. 6 MR. : You didn't know that they 7 were not recording. 8 MS. : Exactly. 9 MR. : Great. So, were you 10 aware that MCC cameras were scheduled to be 11 replaced? 12 MS. : Hmm. No. I didn't know that 13 they were scheduled to be replaced. I know - 14 again - there is information that you -. I 15 don't know if they were scheduled to be 16 replaced. I know that they have been, they 17 were upgraded after. And then, I know there 18 was certain projects. But I don't -. I, 19 again, I don't know what I -. That, if they 20 were scheduled to be replaced at the time of 21 the incident. 22 MR. : So, I guess what I'm 23 saying is, do you know if they were, you had 24 new cameras on site at the MCC, and there was 25 currently a camera project underway, of EFTA00127343

LIMITED OFFICIAL USE 140 1 replacing the old cameras? Did you know that? 2 MS. : No. Not at the time. 3 MR. : Okay. 4 MS. : Not -. Not at the time. 5 MR. : So, based on the work 6 orders and email communications that we 7 received -- 8 MS. : Mm-hmm. 9 MR. : -- the MCC ordered new 10 cameras, DVRs, and other system parts, and had 11 them delivered to the MCC in approximately 12 October of 2018. 13 MS. : Mm-hmm. 14 MR. : These were the cameras 15 that were installed immediately after Epstein's 16 death in August of 2019. 17 MS. : Hmm. 18 MR. : Did you know that to be 19 accurate? 20 MS. : I know that there were cameras 21 that were installed after, and afterward, but 22 again, I don't know when those cameras arrived 23 because I didn't work there in 2018. 24 MR. : Sure. Sure. 25 MS. : No. EFTA00127344

LIMITED OFFICIAL USE 1 MR. : But I guess what I'm 2 saying, though, is -- 3 MS. : Oh. 4 MR. : -- did you know that 5 those cameras were on site, and they were, you 6 know -- 7 MS. : No. 8 MR. : -- you didn't even know 9 that? 10 MS. : No. There's a lot of things 11 that have, obviously that folks have knowledge 12 of after the fact because of the incident, and 13 there have been actions after, but there was 14 no, I was not knowledgeable about cameras being 15 on site, and about the installation prior to. 16 MR. : And just to be clear. 17 So, , you know, the facilities manager -- 18 MS. : Mm-hmm. 19 MR. : -- you know, Warden 20 , and, you know, , they have all 21 said, yup, this is accurate. So, the follow up 22 on that is, when should the new camera system, 23 that was already on site at the MCC, have been 24 installed? Do you have even a -? Or do you 25 just not have knowledge on that because you EFTA00127345

LIMITED OFFICIAL USE 142 1 weren't there at the time? 2 MS. : Yeah. So, I don't have 3 knowledge of that. 4 MR. : Okay. Do you know who 5 would have been ultimately responsible for 6 ensuring -? Because it sounds - and again, you 7 weren't there at the time, but there was a lot 8 of problems, the same problem happened time and 9 time again, at the MCC, where these cameras 10 would -. Two hard drives would crash, and then 11 take out the system. And then, would 12 have to go and rebuild the system, and it was, 13 like, a 24 hour process to rebuild it. 14 MS. : Mm-hmm. 15 MR. : Who should have made sure 16 that new camera system was installed? That was 17 on site. Who should have, like, said, like, 18 this is an urgent matter? And I am assuming it 19 was. Was that an urgent matter, if the cameras 20 are down? 21 MS. : Mm-hmm. Yeah. 22 MR. : And they are not 23 recording? I would think that that's a pretty 24 big deal. Correct? 25 MS. : Mm-hmm. Correct. EFTA00127346

LIMITED OFFICIAL USE 143 1 MR. : So, who should have made 2 sure that that new system was installed? That 3 had been on site, all the way back to October 4 2018. 5 MS. : It's multi-layered. And when 6 it's a multi -. This is multi-layered. Because 7 if you are saying that, who actually does the 8 work for the installation, or who the primary 9 person is the electronics technician. But 10 ultimately, they have a supervisor, and that 11 supervisor tracks the completion of projects. 12 The progress of projects. So, it's - that's 13 what I'm saying - it's multi-layered. That, 14 and if the cameras were present, I don't know 15 what would have happened to make them not be 16 installed. 17 MR. : And just for more -- 18 MS. (Indiscernible *02:13:50) 19 MR. : -- information, the 20 reason why they were on site, the reason why 21 you guys were able to get your cameras 22 immediately back up and running, with a whole 23 new system, was because they were already on 24 site. So, knowing that information, what is 25 your thought on the matter? Like, the fact, EFTA00127347

LIMITED OFFICIAL USE 144 1 now that you are hearing, and again, this is, 2 I'm looking at you as a subject matter expert. 3 I am not looking for any type -. 4 I'm not accusing you of anything. I'm 5 just looking at you as you are a boss there. 6 You are in charge of custody. So, I am just 7 kind of giving you this information, so you can 8 give me your professional feedback. So, the 9 fact that they were able to immediately install 10 this, have SigNet come in, who was the 11 contracted company, and install these new 12 cameras that had been on site since October of 13 2018 -- 14 MS. : Mm-hmm. 15 MR. : -- what is your opinion 16 on that? 17 MS. : Hmm. 18 MR. : Do you think that they 19 were, you know, the MCC, or, you know, really 20 dropped the ball with having this faulty camera 21 system, and actually having the parts that they 22 needed on site, to be able to be replaced? 23 MS. : I'm careful with saying about 24 this, who dropped the ball. I know if you know 25 that there is cameras present. And there is no EFTA00127348

LIMITED OFFICIAL USE 145 1 logical reason why the cameras can't be 2 installed. And if it is your department that 3 is responsible for installing the cameras, then 4 you should ultimately ensure that the cameras 5 are installed. And -. 6 MR. : Now, should - would it 7 fall on the facilities manager to make sure 8 that that's happening? 9 MS. : The Comtech works for the 10 facility manager. So, the facility manager is 11 responsible for the department that that staff 12 member works in. 13 MR. : So -- 14 MS. : You know? 15 MR. : -- according to 16 he said that his job was basically to fix it. 17 His job, you know, fix things when they're 18 broken. And he had been screaming that there 19 was a problem with these camera systems for a 20 long time, and he's basically the reason why 21 they got the new cameras, but he said, you 22 know, it wasn't his job to get SigNet there, to 23 be able to actually get these installed. 24 You know, so, that is where, to me, 25 hearing that explanation, it sounds like oh, EFTA00127349

LIMITED OFFICIAL USE 146 1 well, it's really probably the facilities 2 manager that is, you know, supposed to manage 3 that task, and make sure that they get in 4 there. But I don't -. I want to make sure 5 that that would be an accurate, you know, 6 assessment, or if I'm off. 7 MS. : Now, would have -. I don't know 8 if, like you said, if it's the facility manager 9 that actually calls SigNet, or if it is the 10 Comtech that would call and coordinate SigNet's 11 visit. It's between the two. 12 MR. : So, you believe they 13 have, both have part responsible --- 14 MS. : Mm-hmm. 15 MR. : -- you know -- 16 MS. : Mm-hmm. 17 MR. : -- their part exposure to 18 this thing? 19 MS. : Yeah. 20 MR. : And anything -- 21 MS. : Yeah. 22 MR. anyone outside of the 23 facilities manager? I mean, did this go up to 24 the executive, you know, level, to the captain, 25 AWs, or warden? EFTA00127350

LIMITED OFFICIAL USE 147 1 MS. : If they were aware that the 2 cameras were there, and that the cameras should 3 have been installed. Now, and that's what I'm 4 saying, I don't know if, who knew that the 5 cameras were there. 6 MR. : Yeah. I mean, certainly, 7 the warden did. 8 MS. : Or that -- 9 MR. : But -. 10 MS. : -- that it shipped. Mm-hmm. 11 MR. : So, if the -- 12 MS. : Mm-hmm, 13 MR. : -- warden knew that, is 14 that something you think that he has exposure 15 to, then, as well? 16 MS. : Hmm. Oh my gosh. If - again, 17 without knowing who knew what, I don't, I don't 18 know who -. This is -. Yeah. 19 MR. : Sure. 20 MS. : No. 21 MR. : No. And that's fine. 22 And point being, though, you didn't know that 23 the cameras were even there. It sounds like 24 you are saying? 25 MS. : I would have no knowledge to EFTA00127351

LIMITED OFFICIAL USE 148 1 know about the cameras were there, because this 2 all happened prior to me. 3 MR. : Right. No. I'm just 4 saying -- 5 MS. (Indiscernible *02:17:39). 6 MR. : -- like, you know, you 7 were -- 8 MS. : Yeah. No. 9 MR. : -- you were -- 10 MS. : No. 11 MR. : -- you were, I know it 12 was only a month and a half, but you were 13 there, leading up to this point. I just didn't 14 know if that was a conversation that would be 15 happening within executive staff meetings, 16 that, hey, this is where we are on the camera 17 project. You know, and -- 18 MS. : Well, now -- 19 MR. : -- we'll be -. 20 MS. conversations about the 21 camera project, and again, I'm going to 22 reiterate what I've kind of said before, 23 because of this incident, there have been 24 discussions about things that happened within 25 this incident, but that's after the fact. EFTA00127352

LIMITED OFFICIAL USE 149 1 MR. : And so, prior 2 MS. you're asking -- 3 MR. : -- prior to August 10th, 4 that you weren't involved in the conversations 5 at all with the camera project? 6 MS. : I do not recall anything 7 specifically about discussing about camera 8 project. 9 MR. : Great. 10 MS. : Now, if you can, if you can 11 show me something, or anything to that effect, 12 then I can say, okay, yes. 13 MR. : No, no, no, and again, 14 this is not an I gotcha interview. This is 15 just to ask -- 16 MS. : No. I know. 17 MR. : -- you know -. 18 MS. : I know. But I'm being 19 forthcoming, so that's why I'm trying to tell 20 you. In your investigation, I know you are 21 aware, you've had conversations with folks that 22 are giving you information, but this is 23 information after the fact. 24 MR. : Right. And then -- 25 MS. : So -. EFTA00127353

LIMITED OFFICIAL USE 150 1 MR. : -- and point being is you 2 don't recall anything prior to, about -- 3 MS. : No. 4 MR. : -- a camera project. You 5 are not -. You weren't aware that there was a 6 - at least at this moment in time - you don't 7 recall there ever being a camera project 8 leading up to the incident? 9 MS. : I do not recall. Hmm-mm. 10 MR. : Okay. 11 MS. : I did -. Yeah. I don't 12 recall. Mm-hmm. 13 MR. : Okay. So, now, we are 14 going to touch on cell assignments. Then we're 15 going to just try to fly through the rest, 16 because that was the primary things I wanted to 17 talk to you about, were the cameras and Reyes. 18 MS. : Mm-hmm. 19 MR. : So, these are more just 20 to touch on some things. 21 MS. : Mm-hmm. 22 MR. : Now, are you aware that, 23 on August 9th and 10th, 2019, Epstein was not 24 in his assigned cell, as documented within the 25 BOP cell assignment history, and the BOP EFTA00127354

LIMITED OFFICIAL USE 151 1 database? 2 MS. : Can you say that one more time? 3 I'm sorry. 4 MR. : So, were you aware, are 5 you aware of anything with a cell discrepancy, 6 with Epstein, that he was, he was physically in 7 a cell that didn't correspond with the BOP 8 system? 9 MS. : Yes. And this information 10 after, after the fact. 11 MR. : And do you know why 12 Epstein wasn't in his assigned cell, according 13 to the BOP database? 14 MS. : Sheer error. 15 MR. : And do you know who made 16 that error? 17 MS. : Not - no - not specifically. I 18 don't know who made the error. 19 MR. : So, what do you know 20 about it? 21 MS. : I know that there were keying 22 errors. And so, Sentry reflected one cell 23 assignment, but he was physically in another 24 cell. 25 MR. : And do you -? So, he was EFTA00127355

LIMITED OFFICIAL USE 152 1 in that cell from the time he, you know, 2 assigned to that cell in Sentry, from July 3 30th, all the way to August 10th. 4 MS. : Mm-hmm. 5 MR. : So, being that he was 6 there for, you know, ten or 11 days -- 7 MS. : Mm-hmm. 8 MR. : -- should that have been 9 caught in that period of time? 10 MS. : Yes. 11 MR. : And who should have 12 caught that? 13 MS. : The folks that are doing the 14 rounds. 15 MR. : So, is that, that falls 16 onto the SHU staff? 17 MS. : If - yeah - if it happened in 18 GP, it would have fallen on the person that is 19 actually doing the rounds in GP. So, yes. Mm- 20 hmm 21 MR. : Okay. And then, would 22 any lieutenants, whether it be the SHU 23 lieutenant, or the captain, or, you know, ops, 24 activities lieutenant, should any of them 25 caught this? EFTA00127356

LIMITED OFFICIAL USE 153 1 MS. : Well, they would have only 2 known that if they actually looked at a roster, 3 and physically walked with a roster, to know 4 which cell he was in. But I'm thinking about 5 the 292s, whether or not it would have the cell 6 on it. I'm not sure if the 292 -. Do you know 7 what I'm talking about when I say 292? 8 MR. : Yeah. His file that is 9 kept in the housing unit. 10 MS. : Does it have this -? I'm not 11 even sure if it has the cell number on it. But 12 the long and short of it, you are making 13 rounds, you're pulling the inmate in and out of 14 his cell, you're keying, because 15 MR. : Now, are you talking 16 about bed book count, or are you talking about, 17 like, actual rounds? 18 MS. : No. You're making rounds. Not 19 a bed count. If you actually did it, if a bed 20 book was done, between those days, then whoever 21 did the bed book would most definitely know 22 that there was an error. Because you have to 23 have the roster with you. But without, if a 24 I don't know if a bed book count was during 25 that time. I know that the counts were done EFTA00127357

LIMITED OFFICIAL USE 154 1 after the fact. 2 MR. : And is there a -- 3 MS. : (Indiscernible *02:22:36). 4 MR. -- requirement to do, 5 like, a bed book count, like once a week, or 6 any certain amount of days, or -? 7 MS. : There is no, there is no 8 requirement that says a bed book count has to 9 be done once a week. That was -. There was 10 some procedures put in place after the fact. 11 MR. : Okay. And is, and how do 12 we determine if a bed book count was in fact 13 conducted? 14 MS. : Without there being some 15 documentation, or to say, or, because I know 16 after the fact, like I said, when that was a 17 procedure put in place, it was indicated that 18 that should be documented in the log. 19 MR. : But that was an after the 20 fact thing? So, it wasn't 21 MS. : After. 22 MR. : -- being documented prior 23 to? 24 MS. : No. It wasn't. It wasn't done 25 prior to. Now, if you are making, TruScope, EFTA00127358

LIMITED OFFICIAL USE 155 1 the officers have a log that they do. Any 2 activity is part of whatever is going on in 3 your unit. That should have That could 4 have been logged. But is there a requirement 5 that said that you have to log that, that you 6 did the bed book count? You would be doing it, 7 you know, for documentation purposes. But a 8 lieutenant or a staff member can do a bed book 9 count, just to make sure that things are done 10 accurate. So, that's not -. It's not 11 something that was a requirement prior to. 12 MR. : Okay. So -- 13 MS. : Mm-hmm. 14 MR. : -- aside from the bed 15 book count, though, is there any other way, 16 though, and you said when they were conducting 17 rounds. I mean, when a staff member is 18 conducting rounds, are they supposed to be 19 walking around with the, you know, Sentry 20 report, or BOP roster, or whatever it is, the 21 housing roster that indicates what cell he is 22 assigned to in the system? 23 MS. : No. They don't have to have 24 the roster. However, once the inmate is 25 introduced into SHU, typically, the OIC does a EFTA00127359

LIMITED OFFICIAL USE 156 1 lot of the data entry. So, someone, even if 2 it's not the OIC, if someone in SHU, if someone 3 is doing the data entry, they are the ones that 4 is physically recording where the inmates is. 5 No one else would know where that inmate was 6 assigned unless they actually go in the system 7 and do the Sentry assignment. So -- 8 MR. : Okay. 9 MS. : -- the person that is saying, 10 okay, if I am saying put inmate X, Y, and Z in 11 cell ten, I have to change him from wherever he 12 was before, and make sure that I update, I 13 update it. And not only that, there is a 14 physical board in SHU that you have the cards. 15 You have name tags or whatever. And it shows 16 where everyone is. 17 MR. : And does it say where 18 they are based upon them writing it down from 19 knowing that they are in there, or is that 20 showing where they are based upon what the BOP 21 system says? 22 MS. : From knowing where - from 23 knowing where they are. 24 MR. : Okay. 25 MS. : So, the system, and everything EFTA00127360

LIMITED OFFICIAL USE 157 1 should be the same. So, if I'm changing, if 2 I'm changing an inmate's Sentry assignment, 3 then I know I - I automatically know there is 4 not just one thing I have to do, there is a 5 couple of things I have to do. 6 MR. : Mm-hmm. 7 MS. : I have to physically move the 8 body from one place to another. 9 MR. : Okay. 10 MS. : I have to put the card, you 11 know, the card off of one door, put it on the 12 new door, and I know I have to update Sentry 13 because Sentry should be accurate. I 14 physically have to do a PP - I can't remember - 15 34, and then update the Sentry assignment. And 16 then, I should physically update the board, so, 17 the door and the board would have cards on 18 them, or, you know -- 19 MR. : And this is where, so, _ 20 know what happened. I know what happened when 21 this all happened on the 30th. On the - I know 22 what happened, how it was done, where the 23 discrepancy came in place. So, I guess my 24 question, though, is: between - and so, I know 25 that the person who dropped, you know, EFTA00127361

LIMITED OFFICIAL USE 158 1 basically dropped the ball by not making the 2 correct entry on the 30th, but the fact that 3 from the 30th all the way to the 10th -- 4 MS. : Mm-hmm. 5 MR. : -- this, you know, 6 discrepancy continued, my question to you is, 7 is there any point, aside from when he was 8 physically placed in the wrong cell, and the 9 key entry wasn't, you know, updated, or not in 10 the wrong cell, but they key entry wasn't 11 updated. Was there any way that that would 12 have been caught in those approximately ten 13 days? After that initial mistake happened. 14 So, like, an audit of the system -- 15 MR. : Yeah. 16 MS. : -- or, like, hey, let's, 17 you know, aside from a bed book count, how do 18 we know that these inmates are actually in the 19 cells that they are supposed to be assigned, 20 you know, or they are in the cells that they 21 are assigned in, in the system? Is there a 22 checks and balance to that? Are they -? Is 23 there -? Is the staff supposed to be checking 24 those sheets, or is it -? Is there an audit 25 that is done by the lieutenant or the OIC? EFTA00127362

LIMITED OFFICIAL USE 159 1 MS. : I wouldn't say that there is an 2 audit done, but you -. That's (Indiscernible 3 *02:27:56). That's 7/30 to 8/10. That -. 4 There is not a specific audit that is done on a 5 daily basis. There is not an audit that is 6 done besides, like I said, you making rounds -- 7 MR. : Mm-hmm. 8 MS. and you -. Yeah. I can't 9 think of a specific, like you said, a procedure 10 in place that you would check, where you would 11 audit on a daily basis, besides if you were 12 actually required to do a bed book count. 13 Which, she was not required to do a bed book 14 count daily. 15 MR. : Right. And at the time, 16 they weren't required to do them at all? 17 MS. : There was no procedure - and 18 when you say they were not required - there i.- 19 times when -- 20 MR. : I mean, based upon a time 21 period. 22 MS. : -- yeah. 23 MR. : versus, like, a, you 24 know, an incorrect count. 25 MS. : Yeah. Not that I am - not that EFTA00127363

LIMITED OFFICIAL USE 160 1 I am aware of. 2 MR. : Okay. Now, just to touch 3 on cell searches. On August 9th and 10th, 4 2019, do you know how often the SHU staff were 5 supposed to conduct cell searches? 6 MS. : Oh, you are supposed to do cell 7 searches daily. 8 MR. : Okay. And is it, like, 9 supposed to be at least five per shift -- 10 MS. : Mm-hmm. 11 MR. : -- aside from the 12 morning? 13 MS. : It's five. 14 MR. : Five. 15 MS. : Yeah. Yeah. And then, you 16 annotate it in, I believe it's TruScope, so 17 that you are ensuring, and that kind of, it 18 tracks, so that there is a, so that you can 19 ensure that all of the cells have been done. 20 MR. : Okay. So, is it 21 acceptable that only one cell was entered as 22 being searched in TruScope, on August 9th, 23 2019? 24 MS. : No. You should do at least 25 five. EFTA00127364

LIMITED OFFICIAL USE 161 1 MR. : Now, do you believe that 2 if only one was entered, does that mean only 3 one was actually conducted? 4 MS. : Hmm. I wouldn't say that. But 5 because I don't -. Hmm. That would be -. I 6 would question why one was only entered. But 7 you should do five. And you should recall, 8 record all five. 9 MR. : Now, being, you know, day 10 and night watch -- 11 MS. : Mm-hmm. 12 MR. : -- are required to do 13 five, who is responsible for, one) conducting 14 them; and two) entering them into TruScope? Is 15 it the OIC that is ultimately responsible to 16 make sure that they are done, and then enter 17 them, or is it, there is no rhyme or reason to 18 who is actually responsible? Everybody is -- 19 MS. : I wouldn't -- 20 MR. : -- responsible. 21 MS. no. I wouldn't say who, 22 because the folks that actually do the, that do 23 the rounds, they are physically, you know, 24 doing the manual labor. And typically, the SHU 25 OIC, because there is not, like, five computers EFTA00127365

LIMITED OFFICIAL USE 162 1 up in SHU. There may be one or two computers 2 in SHU. And typically, the OIC is the one that 3 is logged in. And that person is doing all the 4 administrative work. So, they would ensure 5 that, okay, rounds are done. And if there were 6 bar taps, or like you said, if there were cell 7 searches done, that information is then 8 communicated from one officer to the OIC, and 9 then that person goes in and records that it's 10 done. 11 MR. : Okay. Do you know 12 anything about Epstein placing a telephone call 13 on August 9th, 2019, from the SHU? 14 MS. : You said from August 9th? 15 MR. : August 9th, 2019. Do you 16 know anything about Epstein placing -- 17 MS. : I -- 18 MR. : -- a telephone call from 19 20 MS. : -- again -- 21 MR. : -- the SHU? 22 MS. : I know, I know information 23 after the fact. Just like everybody else. But 24 the day that it happened, no, I wasn't aware of 25 the phone call the day that it happened. I EFTA00127366

LIMITED OFFICIAL USE 1, 1 know information after the fact. 2 MR. : Okay. And what did you 3 learn after the fact? And just briefly. 4 MS. : Mm-hmm. That there was a staff 5 member that allowed him to place a phone call. 6 MR. : Did you learn that it was 7 a phone call on an unrecorded line? 8 MS. : Mm-hmm. 9 MR. : Is that a yes? 10 MS. : Yes. That is a yes. 11 MR. : Okay. And then, do you 12 is that standard practice, to allow inmates to 13 make personal calls, as had been done, from an 14 unrecorded line? 15 MS. : No. That is not standard 16 practice, and the phone call should be on the 17 ITS - the Inmate Telephone System - line. 18 MR. : Now, if he didn't have 19 his pack and PIN set up -- 20 MS. : Oh, yeah. 21 MR. : -- or PIN and pack, or 22 however, which way you say it, what, what could 23 have or should have happened, if you wanted to 24 allow someone to take a - make a telephone 25 call? EFTA00127367

LIMITED OFFICIAL USE 164 1 MS. : They don't make a phone call. 2 MR. : They just don't make one? 3 MS. : They don't make one. There is 4 allowances for, like, bereavement phone calls. 5 That would be done by the Chaplain, but that, 6 too, is on a recorded line. And that is in the 7 Chaplain area. The other thing is a legal 8 phone call, and that would be on an unmonitored 9 line. But that would only be for legal 10 purposes. 11 MR. : Now, is it true, though, 12 if it was allowed to be done on a legal line, 13 if it was authorized by, you know, the captain 14 or whomever, or the case manager, unit manager, 15 should it be put on speaker phone, and 16 monitored by a staff member? 17 MS. : Policy says - I don't know - 18 but policy says that the inmates should make 19 phone calls, and it should be through the ITS 20 system. 21 MR. : And do you -- 22 MS. : But you -- 23 MR. : -- is that -? 24 MS. : -- but there is social calls 25 and legal calls. EFTA00127368

LIMITED OFFICIAL USE 165 1 MR. : Phone calls and legal 2 calls -. 3 MS. : Oh, no. I said there is social 4 calls and there is legal calls. 5 MR. : Okay. 6 MS. : And the only phone call that 7 should be on an unmonitored line would be the 8 legal call. 9 MR. : Okay. So, you don't, you 10 don't believe there is any circumstance where, 11 if it is not a legal call, that a social call 12 should be made? 13 MS. : I know policy, what I know of 14 policy, it indicates social calls, which should 15 be via ITS. 16 MR. : And do you know if there 17 was any kind of recorded line in the SHU, that 18 could have been utilized if an inmate did not 19 have a pack and PIN? 20 MS. : No. 21 MR. : No. 22 MS. : Hmm-mm. 23 MR. : There was no line. There 24 was no such line. Just a legal line? 25 MS. : No. I'm saying, there is an EFTA00127369

LIMITED OFFICIAL USE 166 1 ITS system in SHU. 2 MR. : No, no, no. What I'm 3 saying is 4 MS. (Indiscernible *02:34:31). 5 MR. : -- if someone doesn't 6 have a pack and PIN, to be able to record it, 7 do you know if there was another type of a 8 line, like you said, I think you said the 9 Chaplain has a line that people can use, that 10 for bereavement purposes, but it's still 11 recorded. 12 MS. : Mm-hmm. 13 MR. : Is there a line that is 14 still recorded, that a staff member can provide 15 to an inmate that doesn't have the ability to 16 make a call from his pack and PIN? 17 MS. : No. 18 MR. : Or -? 19 MS. : No. 20 MR. : And is that no, there is 21 no line, or no, you are not aware? 22 MS. : No, there is no line that you 23 can make a phone call from, that is recorded, 24 that is not hooked up to the ITS. 25 MR. : Okay. And when you say EFTA00127370

LIMITED OFFICIAL USE li 1 2 MS. : -- (Indiscernible *02:35:09). 3 MR. -- the ITS, what does 4 that mean? 5 MS. : Inmate Telephone System. 6 MR. : And is that -- 7 MS. : Yeah. 8 MR. : -- with reference to the 9 pack and PIN that they receive to be able to 10 put money on their cards and use 11 MS. : Mm-hmm. 12 MR. : -- or -? Yes? 13 MS. : Yeah. 14 MR. : Okay. 15 MS. : Yeah. That is a yes. 16 MR. : Okay. And what is your 17 understanding of what occurred in Epstein's 18 cell on August 9th or 10th, 2019? 19 MS. : Well, what I am aware of, 20 again, after the fact, is that he committed 21 suicide. 22 MR. : Okay. So, you believe 23 that Epstein took his own life? 24 MS. : Yes. He was the only one in 25 the cell. EFTA00127371

LIMITED OFFICIAL USE 168 1 MR. : And do you have any 2 information, with regard to anyone else taking 3 Epstein's life? 4 MS. : No. 5 MR. : Had you heard anything 6 about Epstein's cell door being left open the 7 night of August 9th, 2019, or 10th, or the 8 morning of August 10th -- 9 MS. : No. 10 MR. : -- 2019? 11 MS. : This is the first -. If that 12 happened, this would be the first time that I 13 have, of me even hearing that. I have never 14 heard that. 15 MR. : And have you heard of any 16 other cell mates in the SHU, in the SHU, with 17 their doors being left open the night of August 18 9th, 2019, or the morning of August 10th 19 MS. : No. 20 MR. : -- 2019? 21 MS. : No. I have never heard that. 22 MR. : No? And do you know if - 23 24 MS. : Never heard that. 25 MR. : -- do you know any EFTA00127372

LIMITED OFFICIAL USE 169 1 information, with regard to anyone harming 2 Epstein on August 9th or 10th, 2019? 3 MS. : No. 4 MR. : Okay. Do you know 5 anything about Epstein changing his will just 6 prior to his death? 7 MS. : Again, that's just in the news, 8 but no, I don't have any knowledge of that. 9 MR. : So, only from what you've 10 heard in the news? 11 MS. : Yeah. I don't have any 12 knowledge of that. We don't -. The BOP has 13 nothing to do with inmates' wills. 14 MR. : Okay. So, and we're just 15 going to now wrap up. It's just specific to 16 the timeline. There was an after action report 17 that was created by the BOP. So, this is 18 specifically where I am getting this 19 information, but -- 20 MS. : Mm-hmm. 21 MR. : I'm just going to ask 22 you just a couple more questions, then we will 23 be done. 24 MS. : Okay. 25 MR. : It says, "6:33 a.m., on EFTA00127373

LIMITED OFFICIAL USE 170 1 August 10th, 2019, a body alarm is activated in 2 the Special Housing Unit. SHU staff reported 3 inmate Epstein was unresponsive in cell," and 4 it says the cell, but it says Sentry does not 5 reflect this accurately. "Staff entered the 6 cell and attempted to wake inmate Epstein. 7 Control center announced a medical emergency, 8 and CPR was initiated." So, the information 9 that we have is that at 6:33, told 10 call in the emergency, and went straight 11 into the cell. Did act appropriately by 12 going straight into the cell, or should he have 13 waited for someone to arrive? 14 MS. : No. There is -. Well, it 15 depends if you feel like you - that is an 16 emergency, and it is a life or death situation. 17 I don't know if he had the -. He could have 18 gone into -. He could have gone into the cell. 19 MR. : Okay. So, policy doesn't 20 dictate that you are supposed to wait for other 21 people to arrive, so that if it was a 22 MS. : Yeah. 23 MR. : -- a ruse, that someone 24 could have overpowered him, and then taken -? 25 MS. : There is no -. When you say EFTA00127374

LIMITED OFFICIAL USE 171 1 policy, policy does state that you have to be 2 safe, and that you should wait for another 3 staff to arrive. Policy does say that. If 4 felt that he had enough staff on hand, I 5 don't know if he felt that, but policy does say 6 to ensure. And especially if you have more 7 than one inmate in a cell. So, with, I guess 8 realized there was only one inmate in 9 the cell, and if he saw the inmate hanging, he 10 would probably want to act immediately. But 11 policy protects you either way. If you feel 12 that you have enough, because - and that's your 13 - that's what I said - that's your discernment. 14 If you feel that you have enough people on, you 15 know, available, maybe he felt that way. 16 MR. : Okay. And then, it says, 17 "At 7:36 a.m., inmate Epstein pronounced dead 18 by the emergency room physician." Do you know 19 of anything about -? Do you know if Epstein 20 ever showed signs of life, prior to leaving the 21 MCC, or specifically from 6:33 a.m. to 7:36 22 a.m., do you know if he showed any kind of 23 signs of movement or life? 24 MS. : No. I don't. I arrived after. 25 And I have never heard of anything to the EFTA00127375

LIMITED OFFICIAL USE 1 contrary that he exhibited life. 2 MR. : Okay. And here is 3 another thing that was written in there, in the 4 BOP, and again, this is the BOP after-action 5 report. It says, "SHU has multiple cells 6 equipped with video recording capability. 7 Inmate Epstein was not housed in one of these 8 cells, and there appears to be no set guidance 9 on when to utilize these cells." So 10 specifically, I am assuming he is, they are 11 either talking about 10 South or possibly G- 12 tier. I'm not sure. I can't remember if G- 13 tier has cameras or not. But 10 South 14 certainly does. 15 MS. : Mm-hmm. 16 MR. : Do you believe that 17 Epstein should have been placed in one of those 18 cells that were, that had cameras in them? 19 MS. : I'm not going to say that. I'm 20 not going to say that he should have been 21 placed in a cell with a camera. He was an -. 22 He is an inmate, just like another inmate. So, 23 I can't, I can't say that, that he should have 24 definitely been placed in a cell. There 25 obviously was a reason that they felt that he EFTA00127376

LIMITED OFFICIAL USE 173 1 was safe, since he didn't say that he was going 2 to -. I don't -. Yeah. I can't say that he 3 should have definitely been placed in a cell 4 with a camera. 5 MR. : Okay. 6 MS. : Because those cells are for the 7 SAMs inmates. Those inmates that can't, you 8 know, their communication has to be monitored. 9 So, that is a different vetting process. 10 MR. : Okay. 11 MS. : Mm-hmm. 12 MR. : And do you -. These are 13 going to be the last, like, three or four 14 questions. Oh. What do you believe allowed 15 Epstein to be able to - if he took his own life 16 - what do you believe allowed Epstein to take 17 his own life? 18 MS. : Well, there were, I think his, 19 if that's what he wanted to do, without - 20 because the -. Now, we do know that staff 21 members have to make rounds. They're going 22 to, every, I don't know, 30 minutes, a regular 23 round. But he could have done it right before, 24 or right after the round. So, it doesn't mean 25 that he still - at the end - still wouldn't EFTA00127377

LIMITED OFFICIAL USE 174 1 have happened. So, I can't say for certain 2 that, we still would not have had the same 3 outcome. 4 So, I can't -. I know there was some 5 things that staff did not do that they were 6 supposed to do. Had they still made their 7 rounds, there is a possibility that a death 8 could have still have occurred, because there 9 are instances where staff make their rounds, 10 and inmates still are able to successfully 11 complete suicide, unfortunately. So, in this 12 instance, staff - we all, again, know - staff 13 did not do what they were, you know, supposed 14 to do by policy, but I can't say with certainty 15 that he still would not have been able to 16 successfully complete suicide. 17 MR. : So, it sounds like rounds 18 would have helped. What about having a 19 cellmate? Do you think that would have helped? 20 MS. : Yes. A cellmate would have 21 been able to alert a staff member, that is, if 22 they were alert and oriented themselves. 23 MR. : Yeah. I would think, 24 though, if a cellmate was in there, and they 25 saw someone hanging themselves, you know, EFTA00127378

LIMITED OFFICIAL USE 1- 1 obviously, there would be no requirement, I 2 guess, for them to do it, but that would 3 certainly indicate to that person that they 4 probably, there was an issue. Right? 5 MS. : Yeah. But when you say that, 6 when you say that, it depends on, see, if the 7 manner in which he committed suicide, he did it 8 because he was in there by himself. Yes. 9 MR. : Right. 10 MS. : But there is instances where 11 you have cellmates, if you are on, you could 12 have - an inmate could have tied a ligature 13 around his neck, if he was in his bed, and just 14 hung himself that way. So, again, there are 15 things that were not done on line with policy, 16 but I can't say for certain because we have, we 17 do have successful suicides, where staff do 18 follow procedure and follow policy. 19 MR. : But in this case, I 20 guess, you know, you know, correct me if I'm 21 wrong, but I would think that the two most 22 glaring things were the fact that he was 23 required to have a cellmate, and he didn't; and 24 that, also, staff were not conducting rounds as 25 they were required. Would you agree with that EFTA00127379

LIMITED OFFICIAL USE 176 1 assessment? 2 MS. : Yeah. We know that those 3 things did not happen. 4 MR. : And do you believe 5 anything else, you know, basically, if we are 6 looking at what all, you know, what could have 7 helped prevent this from happening in the 8 future? If we are looking at it as, you know, 9 like, well, what can we do better next time? 10 Aside from making sure, you know, cellmates 11 that are required to have cellmates have them, 12 and then, aside from making sure that staff are 13 actually conducting their rounds and counts, is 14 there anything else that should have been done? 15 MS. : Just -- 16 MR. : It sounds like you didn't 17 agree with putting him in a cell with a camera. 18 So, I'm just wondering if there is anything 19 else that -- 20 MS. : No. I'm not saying necessarily 21 I agree or disagree. I'm saying that there is 22 inmates that are in cells without cameras, and 23 they don't necessarily commit suicide. So, 24 what was the difference? Why did Epstein have 25 to be in a cell with a camera? So, I'm saying, EFTA00127380

LIMITED OFFICIAL USE 177 1 we don't -. That's not part of our policy, 2 that cameras have to be present. So, that is 3 not the -. That does -. That in and of itself 4 doesn't determine or make a difference whether 5 someone commits suicide or doesn't. 6 MR. : Sure. 7 MS. : Like, that's not a requirement. 8 MR. : So, I guess the - and I 9 probably got you off on track, on the camera 10 thing - I'm just saying, is there anything else 11 we are missing here, aside from, you know, what 12 we just discussed, as far as reasons that 13 allowed for Epstein to be able to take his 14 life? 15 MS. : No. 16 MR. : No. 17 MS. : I don't know. 18 MR. : Okay. What do you 19 believe the failures of the BOP - if you 20 believe there are any - that allowed for 21 Epstein to die? 22 MS. : I don't believe that the BOP is 23 responsible for him committing suicide. I 24 believe that, as you investigate, that there 25 are things that - may not have been with the EFTA00127381

LIMITED OFFICIAL USE 178 1 policy, but I don't believe that that 2 contributed to the suicide itself. Because, 3 like I said, I know we are looking at it after, 4 like, Monday morning quarterbacking, but there 5 are, there are some instances where there is a 6 successful suicide, where does not follow 7 protocol from top to bottom. And it happens, 8 unfortunately. And in this instance, they 9 didn't do everything that they were supposed to 10 do, or they didn't do a lot, but I don't 11 believe that it contributed to him committing 12 suicide. I don't. I don't really believe 13 that. 14 MR. : So, you don't believe - 15 and we didn't get into staff members sleeping - 16 but you don't believe that a staff member not 17 conducting rounds, a staff member sleeping on 18 the job, staff members not, you know, making 19 proper notifications and getting a new cellmate 20 into them, you don't believe that that is 21 contributed to him taking his own life? 22 MS. : I'm -- 23 MR. : The ability to do that? 24 MS. : hmm. Because when you are 25 saying staff members sleeping, yeah, if, even EFTA00127382

LIMITED OFFICIAL USE 179 1 if a staff member is awake, and that I'm saying 2 that because I'm aware of a successful suicide, 3 staff members can make their rounds every 30 4 minutes. And when they go by, unfortunately, 5 if someone actually is intent on committing 6 suicide, they can wait for you to make your 7 round, and they know that you don't have to 8 come back until another 30 minutes. 9 MR. : Sure. And I didn't say 10 that staff members -- 11 MS. (Indiscernible *02:47:32). 12 MR. : -- caused him to die. 13 what I said is, helped contribute, and allowed 14 for him -- 15 MS. : Yeah. 16 MR. : -- to take his life. So, 17 what I'm saying is, like, the job -- 18 MS. : Okay. 19 MR. : -- performance that 20 wasn't done, and that's why this investigation 21 pertains to security failure and job 22 performance failure, because it seems to me 23 that there was a lot of job performance failure 24 here, at the very least, in the sense that 25 people weren't doing their jobs. EFTA00127383

LIMITED OFFICIAL USE 180 1 MS. : Mm-hmm. 2 MR. : And that, that helped 3 cause, you know, and again, I think you 4 mentioned it, if a person wants to kill 5 themselves, they're probably going to be able 6 to find a way. But there is also things that, 7 when an inmate is in our custody, it is our job 8 to try to do everything we can to keep them 9 alive, and prevent that from happening. 10 MS. : Mm-hmm. 11 MR. : So, my question to you 12 is, you don't believe that, by though, you 13 know, them not doing those things, that that 14 helped contribute? 15 MS. : And I know this might sound 16 but you sound bewildered by my response, but I 17 believe that it contributed to some failures, 18 but I don't really believe that the failure 19 equals the contribution of the suicide. I 20 really don't believe that. 21 MR. : Okay. Yeah. I don't 22 know that I look at it as a contribution. I'm 23 just saying, the failures that allowed for him 24 to be able to take his own life. And so, 25 again, I'm not saying that they helped assist EFTA00127384

LIMITED OFFICIAL USE 181 1 him with taking his life, but by not doing -- 2 MS. : Mm-hmm. 3 MR. : -- their job, that, you 4 know, provided him ample opportunity to do so. 5 Would you agree with that? 6 MS. : Again, I'm going to - my thing 7 is going to be the same. 8 MR. : Okay. No. You're just 9 the first person I've talked to that said that. 10 MS. : Yeah. 11 MR. : Okay. That's totally 12 fine. Okay. Well, is there anything else that 13 I missed, or that you would like to add to 14 this? 15 MS. : Hmm-mm. No. 16 MR. : And , are you still 17 there? Is there any follow up questions that 18 you have, before we end this thing? 19 : No follow up questions. 20 MR. : All right. Great. Well, 21 you have my information. My cell phone. My 22 email. 23 MS. : Mm-hmm. 24 MR. : If there is anything you 25 need, please feel free to contact me. But EFTA00127385

LIMITED OFFICIAL USE 182 1 otherwise, I would very much greatly appreciate 2 if you get me that stuff we talked about, 3 specific with regard to the documents that you 4 5 MS. : Okay. 6 MR. : -- that you kept on file, 7 and I think you took - there was something else 8 that we discussed. What was the other thing? 9 Was it -? 10 MS. : You said it was about the bad 11 (Indiscernible *02:49:59). I made some notes 12 about the bad count. And then, about the court 13 document. 14 MR. : Perfect. Yeah. So, 15 there would be those specific things. But 16 again, anything -? I think you said you made 17 records of things that you produced, that would 18 be very much appreciated, as well. 19 MS. : Yeah. 20 MR. : It is 1:24 p.m. on 21 December 2nd, 2021. This is Senior Special 22 Agent and I am going to turn 23 off this recorder. 24 MS. : Okay. 25 (Whereupon, the above-entitled matter went EFTA00127386

LIMITED OFFICIAL USE 183 1 off the record and back on the record). 2 MR. : This is Senior Special 3 Agent It is currently 1:26 4 p.m., 12/02/2021. Prior to hanging up the 5 call, Associate Warden asked if I could 6 turn back on the recorder so she could make a 7 clarifying statement. So, Ms. , go ahead. 8 I'll just remind you, you are under oath, and 9 this is a voluntary interview. 10 MS. : I wanted to clarify whether I 11 feel that, some of the things helped, I guess 12 helped to, or contributed to, Epstein's ability 13 to commit suicide. While I understand that 14 this is something that no one wanted, there 15 were things that were not done, that were in 16 line with policy. That were required to be 17 done, and had those things been done, maybe we 18 would not be questioning the liability aspect. 19 But I just want to ensure that it's understood 20 that I have - I believe that staff should 21 follow policy, to ensure with certainty that no 22 inmate is able to hurt themselves, or that no 23 other inmate is able to hurt them. 24 So, with that knowledge, again, I really 25 hope that staff would have done everything EFTA00127387

LIMITED OFFICIAL USE 184 1 within their power to follow policy, so that 2 there would be no question as to what should or 3 should not have been done. And with 4 acknowledgement that there were not things done 5 that should have been done, as it relates to 6 following policy. 7 MR. : All right. Thank you 8 very much. Is there anything else you wanted 9 to add before I turn off the recorder and we 10 end this interview? 11 MS. : No. I think that's it. I just 12 wanted to add that as a sentiment, that I 13 understand that this is a serious matter, and 14 that it required care and attention, and that 15 it requires me to clarify what I believe 16 actually, you know, the staff did or did not 17 do. 18 MR. : Perfect. Thank you so 19 much. Again, if there is anything you need 20 from me, you have my email, and I will greatly 21 look forward to the information you can provide 22 following this interview. It is 1:28 p.m., 23 12/02/2021. This is Senior Special Agent 24 , and I am turning off the 25 recorder. EFTA00127388

LIMITED OFFICIAL USE 185 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 See,7s 45- -- Brianna Rose Burton, Transcriber EFTA00127389