PRR RRR RR NDMP WNPRPOWOHDH SWwNP ae ee od WS Wr rs © Ww oc DIGITALLY RECORDED SWORN STATEMENT OF OIG CASE #: 2019-010614 DEPARTMENT OF JUSTICE OFFICE OF THE INSPECTOR GENERAL JUNE 21, 2021 RESOLUTE DOCUMENTATION SERVICES 28632 Roadside Drive, Suite 285 Agoura Hills, CA 91301 Phone: (818) 431-5800 MR. : The recorder is on. name is . I ama Senior Special Agent with the U.S. Department of Justice Office of the Inspector General New York Field Office and these are my credentials. This interview with Federal Bureau of Prisons correctional officer is being conducted as part of an official U.S. Department of Justice Office of the Inspector General investigation. Today's date is June 22, 2021 and the time is 10:09 a.m. This interview is being conducted at - what is the location - 15 -? MR. FOY: 15 Bergen Street, Hackensack, New Jersey. MR. a. Thank you, sir. MR. FOY: Bergen County Bar Association, second floor conference room. : Okay. By the way, that was Jason Foy 3 My MR. MR. FOY: speaking. WR. WM: Yes. Also present are DO) OIG Special Agent ; Correctional officer ; Ms. attorneys, Jason Foy, and Eric Sarraga of Foy & APPEARANCES: RR ae ee RR i) RPRRRR UD in ew OFFICE OF_THE INSPECTOR GENERAL BY: BY: WITNESS: OTHER APPEARANCES: JASON FOY, ESQ. ERIC SARRAGA, ESQ. SERINE GREG 4 Seplowitz, LLC; as well as union representative Serine Greg of the Local 3149 with the BOP. This interview will be recorded by me, Senior Special Agent . Could everyone please identify themselves for the record and spell your last name. To start again, I am D0) OIG Senior Special Agent (i I am DO) OIG Special Agent MS. : I'm ' . MR. FOY: Jason Foy, F-0-Y, attorney for MR. SARRAGA: Eric Sarraga, S-A-R-R-A-G-A, attorney for MS. GREGG: 3148. WR. MM: | Thank you everyone. Ms. HMMM, you are here today as a subject in this DO) OIG investigation. This DO) OIG investigation concerns your alleged misconduct to include allegations of false statements, job performance failure, security failure, and reporting false information. This is an official DOJ OIG investigation and you are Serine Gregg, G-R-E-C-C, Local EFTA00117643

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RR rPFCowW OND SwhN re RPRRR We Wr RR SD 18 19 20 21 22 23 24 25 RR SwWOHNDN FWwrNP RPRRPR RRR SD SwWwNPe ee ee ed eS WwrN Pr CO wc nm wm 5 being asked to voluntarily provide answers to our questions. Will you agree to a voluntary interview with the DO) OIG? MS. :_ Yes, MR. Alright. Great. And then everyone that does voluntary interviews with the DOJ we provide them with these voluntary interview forms. I don't know if you guys were sent that at the time, but it says, “United States Department of Justice Office of the Inspector General, Warnings and Assurances to Employee Requested to Provide Information on a Voluntary Basis. You are being asked to provide information as part of an investigation being conducted by the Office of the Inspector General. This investigation is being conducted pursuant to the Inspector General Act of 1978 as amended. This investigation pertains to your alleged misconduct to include allegations of false statements, job performance failure, security failure, and reporting false information. This is a voluntary interview. Accordingly, you do not have to answer questions. No disciplinary action will be taken against you if you choose not to answer MR. FOY: I know there’s no sort of protection with regard to the disciplinary internally the administrative thing that -- MR. : Correct. MR. FOY: -- will happen at some point. But I just wanted to make that clear. But go ahead, you_can sign (i. MR. a. Now obviously, that is pursuant to you answering questions truthfully. MR. FOY: Right. Of course. That's the exception to our agreement. WR. WM: There's a line that says employee signature. MS. + Mm-hmm . MR. : Alright. And the rest will be filled out by the two of us. MR. FOY: Okay. MR. a. Thank you, sir. MR. FOY: Yep. wR. ~ e And thank you for signing Ms. MM. Alright. So I’m going to sign where it says signature of the Office of the Inspector General Special Agent. Again, this is a: printing my name. And Special Agent , can you fill out the RR ROW OHM fwrKP —— wr RPRRR oN Du MmNmenNrre rmrROow mre re WW = Ww Wey DHfwrP RR eo PRR RRP RRR Oo OUD wr mre reo Mmmenmrn Ww Wr 6 questions. Any statement you furnish may be used as evidence in any future criminal proceeding or agency disciplinary proceedings or both. And of course, there's the DPA waiver. I understand the warnings and assurances stated above and I am willing to make a statement or answer questions. No promises or threats have been made to me and no pressure or coercion of any kind has been used against me. You can take a look at this and review it. If you agree, there’s a section there for your name and signature. MR. FOY: So the only thing that this is actually subject to is the deferred prosecution agreement. MR. Well so there’s the agreement that you had, so that’s the part where I'm talking about the specific part where it says criminal. MR. FOY: _Mm-hmm. MR. GM: | That’s something I think that was worked out with the U.S. Attorney's Office -- FOY: ae 8 MR. MR. rest for signature of witness, name of witness, date, time, and place. MR. : This is Agent [I signing on the signature of witness. MR. —. And then do you understand the form as you read and you review? MS :_ Yes, I do. MR. : Great. Thank you. Before starting the interview, I'd like to place you under oath. Can you please raise your right hand? Do you swear to tell the truth and nothing but the truth during this interview? MS. : Yes, sir. MR. : Thank you, Ma'am. Alright. Please let me know if you do not understand any of my questions. I'l] try to rephrase or_ask it a different way. MS. :_ Okay. MR. : Alright. So this is something we ask everybody. Do you - what's your current home address? MS. : Exactly. So -. MR. : Thank you. What's your EFTA00117644

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rR CSCwWOmOANDMDS fWwNHP RPRRRR We WN Re RPRRR Oona MmMNrnNrnrry WN r Oo nm w RR SCwWOnHtDUN SwWwrP date of ii i | your last four of your sca secur number. highest level of education? MS. : A bachelor’s degree. MR. : And what was your bachelor’s degree in? MS. WEB: Criminal justice (Indiscernible *00:06:14) in law. WR. QM: 9 And where did you receive that degree from? . : John Jay. . : John Jay in New York . : Yes, sir. : And when did you graduate? MS. : 2017. MR. | Thank you. What did you do - just briefly - prior to working with the BOP? ws. Hg: you in the Army? MS. : Six years. MR. : From when until when? MS. : 2008 to 2014. MR. : And what did you do with the military? MS. : Iwas a patient administrative specialist. MR. : And what is that? MS. : Patient admin. MR. : Patient as in like a hospital? ‘sie Okay. So you worked in a And what was your rank when you left What's your Prior to working with the BOP I hospital. the "ie ? E4 Specialist. And did you leave - were you har Sischarge? Yes. Okay. Can I - one second real quick? For the post office, you said 16 - 17 but you started MCC in 18. wS. WE: Yeah. PRR RR SwWwKN PCW OHMS SwMN Pe RPRRR COND ee od Wr Ow mrNm oe Re CWO HM fWwrNP 10 worked at the Post Office. Okay. What did you do I was a mail handler And for how long? Uh, six months. Six months? : And that was in 2016, 2016? When did you do that? MS. Yes. MR. : 2015 and 2016? MS. : No. At the post office, I was there 2017. ‘17. Mm-hmm. : "16, . : Oh, okay. And do you have any military service? Oh 2017. And what is that? Military service? Yeah. Can you tell me what the service? The Army. . > Army. MR. FOY: So would it be 17 into 18? : 18 yeah. : Oh you did start with the Yes. And how long were 12 Not in '16? . : No. That was an error in the (Indiscernible *00:07:49). MR. FOY: Right. So it’s °18, then she left the Post Office in ‘17, going to - so I think it’s 16 -. No 17 - 18. 18 - Mm-hmm. Post Office. Then MCC. Okay. And did you work for anybody prior or in between your military service and the post office? No? Okay. So you were unemployed at that time? MS. :__No I was going to school. MR. | = Oh that’s when you went to John Ja MS. : That’s when I was going to John EFTA00117645

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rR CSCwWOmOANDMDS fWwNHP 13 Yeah. wR. QM: «Okay. Thank you. And when was your Enter on Duty Date with BOP? : June 24, 2018. : Okay. And when did you MS. MR. graduate from BOP training down at the Federal Law Enforcement Training Center? MS. MB: Um, I want to say September of 2018. WR. WE: Okay. But you did graduate from there? MS. : Yes, I did. MR. That was a correctional officer training? MS. Yes, MR. : Alright. And when and where was your first office assignment with the BOP? MS. :_ Say that again? MR. : When and where was your first office assignment with the BOP? So where did you start - did you start working in MCC and work there the entire time? MS. : Yes, sir. MR. : Okay. MS. : Yes. MR. : Okay. Any other cell phone numbers? MS. : No. MR. : Okay. And your current email address? Um Jay. And what positions 15 Okay. Great. And have you had that one also for years? 1 Yes, Okay. Any others? What are the others? Same? You’ve had that for Okay. Both in 2019? . Okay. Thank you. Um, do you have any current -? I should have asked this. Are you currently employed right now? MS. No. =— ROW OHMS fwrNP PRR RRR RR OCOD Sw R mm nd MmeMmnNr Ww = Wh Re CWO HM fWwrNP have you held with the BOP? Okay. Yes, sir. Alright. And when you id you report to? Who was your direct supervisor? Or did you have one? MS. : Lieutenant J. MR. : And do you know how to spell that last_name? MS. |S | errr MR. : Thank you. What is your current -? Again, this is something we ask everybody. We won’t be contacting your client. But what is your current cell phone number? The entire time? MS. : . MR. : Okay. you had that number? MS. : Years. MR. : Years. And how long have So for a long time. And to include in 2019? By no other means? . :_ No. MR. : Jast work at_the MCC? August 10, 2019. Okay. And when did you MS. MR. : And was that the same supervisor that you mentioned? MS. :_ Yes. MR. Okay. Briefly, what training have you attended or conducted during your employment with the BOP? You mentioned the correctional officer training at FLETC. What other trainings have they provided for you? MS. BB: Um, their two-week training when you first start at BOP. I forget what it’s called. IF training. Yes. MR. IF training? MS. Mm-hinm . MR. And any other training? MS. MR. training? MS. | | I have one. : Okay. MR. Annual refresher So you've gone to EFTA00117646

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RR rPFCowW OND SwhN re RPRRR Ww = Wh RR SD 18 19 20 21 22 23 24 25 RR SwWOHNDN FWwrNP RPRRRR we wre RR SD ae ee od WS Wr rs © Ww oc 17 annual. And what about like a SHU training course? : No. : Okay. But you did - and MS. MR. this is just - you guys can take a look at this if you would like. This is the training that we have for you. That we asked for your list of training. I’m not asking you to necessarily verify that you've conducted all of it, but it shows the last time you did your annual training was on 3/8/2019 was when you actually completed that week of training. MS. : Yes. MR. Does that sound correct? MS. : (Correct. MR. Again, this just goes along with it. It shows -. It shows what the syllabus was as well as the sign-in sheet where Ms. signed in. Again, it’s - we're not asking to you -. MS. af Mm-hmm . MR. : For - if you want to take a look at it you can. It just shows that you did that training in March of 2019. And anything that I'm going to provide to you, can 19 MR. Okay. Did they include things like ethics, standards of conduct? MS. :_ Yes. MR. counts and rounds? WS. MMM: I don't recall them talking about counts and rounds. MR. Okay. So did they go over like MCC policies and guidance? MS. :_ Yes, MR. Okay. And did they ever provide you with the policies and guidelines or did they just speak to you about it? MS. For in this training? MR. : Yes. MS. They just spoke about it. MR. At another time did they provide you with the polices and guidelines? MS. Yeah. It’s on like the computer. MR. : Okay. . : The -. . : Do you have to certify that you've like received it and you reviewed Okay. What about like RR ROW OHMS fwrNP —— wr RPRRR oN Du ee od Wwrerow mr oe RR ae ee RPRRR Ww Wr MRRP RRR Pow OAS mre wh 18 you just initial and date? And that’s just a way for us to verify that that’s what we showed Okay. Each page or just to top? Nope, just the top of each page. MR. FOY: Okay. *00:12:34)? MR. MM: No, you do have that. So just briefly, you don't have to like list off the course syllabus. But what did they cover during that annual training? MS. BEB: Um they spoke about different areas like dealing with inmates. They spoke about the issues on the job like dealing with shortages. They spoke about um, basically like mask fitted I remember. Mask fitting? + Mm-hmm. Was that back in 2019? People were wearing masks as well? MS. : No like um. MR. : It’s for OC's sprays? MR. Oh, for OC spray. Is (Indiscernible 20 it? Polices and guidelines? MS. MBB: 1 think I signed that like you receive it. WR. MM: Right. Okay. If you don't mind, just -. MR. FOY: You want it in the lower right? MR. Doesn’t matter. Top or bottom. You know wherever there’s room. I typically do top, but bottom is totally fine. MR. FOY: This one, that one. MR. Today’s date is June 22nd. MR. FOY: That's part of the same document. MS. > Hm. MR. FOY: And just the top page. MR. And now you mentioned that you didn’t quite remember them going over training when conducting counts and rounds in this training. Did you - were you - did you ever receive training on conducting counts and rounds? MS. 1 Yes. MR. | Okay. When would that have been? MS. MBM: In an IF training. EFTA00117647

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RR rPFCowW OND SwhN re RPRRR Ww = Wh RR SD 18 19 20 21 22 23 24 25 PRR RRR RR NDMP WNPRPOWOHDH SWwNP ae ee od WS Wr rs © Ww oc 21 WR. GY: | And what does IF stand for? ws. MB: Hm. MS. GREGG: You want some clarity? I can tell you -- MR. Sure. MS. GREGG: -- just what it stands for. Institution Familiarization training. MR. Okay. Great. And that's something that the MCC provided directly? MS. :_ Yes. MR. Okay. Great. And then you had mentioned - did you ever receive policies on counts and rounds? MS. :_No. MR. I know you said you certified. Do you remember that specific policy - like receiving that? MS. Like specifically on counts and rounds? WR. GM: «I'm not asking you to like verbatim tell me what it was. I’m just saying like were you provided and you reviewed it. DO you remember? MS. Not specifically on counts and 23 an injury, the lieutenant asked me to sign because when they had program review, they need to show that I received the training. But I never did. She just asked me to sign. That’s why I wonder why. Who asked you to do that? So that supervisor you st line supervisor asked you sign without providing you the training? MS. : Yes, MR. : And she didn’t’ like provide you anything to review? MS. :_No. MR. | = She didn’t go over anything with you? MS. : No. MR. : Did you discuss this with her - that how can you sign something without being provided the training? MS. QM: Well I just told her I wasn’t here. I was out on an injury. She said she knows but she needed me to sign it because they need it for program review. MR. : What's her first name? RR ROW OHMS fwrNP —— wr RPRRR oN Du ee od Wwrerow mr oe RR ae ee RPRRR Ww Wr MRRP RRR Pow OAS Mmmenmrn Ww Wr rounds. Just like a general - . Right. . : Like -. MR. : Like you know the housing orders or unit policies and things like that. When you’re supposed to conduct counts, when you're supposed to do rounds, that type of thing. | | The post orders. : Post orders. Right. MS. MR. Okay. Great. You mentioned you didn't remember ever going to quarterly SHU training. This is a sign-in sheet for quarterly SHU training. I just want to -. Is this your signature on there for June 26, 2019? MS. MB: You see how I’m the last one on the bottom of all of them? MR. Correct. MS. : Because I wasn’t at the training when I came -. MR. Did they provide it to you one-on-one though? . : No. So how come -? : Because when I came back from 24 . : And is she a lieutenant? . : She's a - I don't know what she is now. But she’s not at MCC anymore. She's at somewhere in Jersey. MS. GREGG: I'm sorry. you done with that question? MR Actually, let me um, I Before you go, are didn't do this. MS. GREGG: Because I want to (Indiscernible *00:17:14) MR. And I did forget to do this. There’s an advisory to the union representative. MS. GREGG: _Mm-hmm. MR. Can you review this? And I do apologize. But since you're speaking up a little bit, let me hand this to you. and then you can review that. And then if you want to just take a look. After you’re done reviewing, you may sign it if you agree. MS. GREGG: Will you be able to give me a copy of it? MR. Yes. I think it says on there that we will forward you a copy of that. EFTA00117648

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RR SwWOHNDN FWwrNP RPRRRR Ww Whe RR SD ee ee ed eS WwrN Pr CO wc 25 MS. GREGG: I didn’t even see that part. MR. Should I continue asking questions while she’s reviewing that or do you want to wait? MR. FOY: Yeah, you can ask questions. Absolutely. WR. a. Sure. So there’s another training that you - it says that you conducted on also June 26, 2019 for SHU suicide prevention training. Did you also not receive that training? MS. : Yeah. MR. : training? MS. :_No. MR. Did you receive - so there's slides in the back that shows the training and how they conducted it. Did they provide you with those slides? MS. : No because I wasn’t there. MR. You weren't there? MS. I was out on an injury. MR. Okay. Can you -? When were you out on the injury? What are the dates? I didn't. You did not receive that 27 interrupt the interview because we have a lot of questions to get through. MS. GREGG: _Mm-hmm. MR. If the attorneys ask that, that’s not really -. But if you would like to -. MS. GREGG: So based on the agreement we just signed, right? WR. a. Sure. MS. GREGG: It acknowledges the right to have me representing her. And part of those rights are the ability to assist in representing her. Right? And so I don't want to dispute and I don't want to hold up the process at all. I just want to say something to her. WR. MM: Sure. We'll let that - we'll do that this time, but if this continues to happen, I’m going to have to give you a different form that says you can stay here voluntarily if you want, but we're going to ask you not to interrupt the interview. And if you do, then we're going to ask her if she wants to continue with the interview without you. MS. GREGG: So but that form says PRR RR Se ee a RPRRR COND mreNyre rmrROow mrer WW = Ww Wey DHfwrP RR eo PRR RRP RRR OOD fwr mre reo mrr = Wr 26 MS. QB: From March 2019 to - I came back in June. So when I came back in June, that's when I was told to sign this. Okay. > Mm-hmm. . Alright. Thank you for signing the Advisory to Union Representative. I signed it (Indiscernible MS. GREGG: *00:19:02). MR. I am just going to sign that form as name of OIG special agent. Again, I do apologize for not providing that up front. MS. GREGG: So I just -. MR. I'm sorry, what was your question? MS. MB: I want to call because (Indiscernible *00:19:15) I’m just saying that well I know that the dynamics are that I should interrupt you in the middle of a question. But interrupt her answering a question. So I was asking were you done because I wanted to just step out for just one second. You want to step out? Mm-hnm . Okay. We don't want to 28 something contrary to what you're saying. MR. a. I'm going to give you a different form that says that I'm going to let you interrupt the interview now to talk to her out there. And if you do it again, I'm going to ask that you not be here any longer so that we can continue with the interview. Obviously, her attorneys would stay here. So I just want to make sure that we don't just continue. MS. GREGG: I just need clarity then. I need clarity. MR. Sure. MS. GREGG: So the representing of and talking to the employee who I have the right to represent is considered by you an interruption of the interview? MR. into the questions yet. MS. GREGG: Well -. MR. -- yes, we need to continue with the interview. But we're now -. I can allow you to do that now. I’m just not going to be able to allow you to continue to stop the interview and leave the room. MS. GREGG: I'm just asking for clarity We haven't even gotten So -. EFTA00117649

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RR ROW OHM SWwrNP RPRRR We Wr RR SD 18 19 20 21 22 23 24 25 RR SwWOHNDN FWwrNP RPRRPR RRR SOW WNP ee ee ed eS WwrN Pr CO wc nm wm right. So it was kind of -. MR. Sure. Absolutely. MS. GREGG: And I don't mean to be difficult. It kind of was a yes or no. So you're saying to me based on the document that I signed -. WR. QM: I'm saying that you can assist her. MS. GREGG: I didn’t get to -. MR. : Sure. Go ahead. MS. GREGG: Okay. So you're saying based on the document that I signed, in my right to represent the employee, which is asking to caucus and say something to Ms. I is interrupting the interview even though I have the right to do so based on the document I signed? WR. QM: «It's more for her to be able to ask you for a question. MS. GREGG: So it’s just a yes or no. MR. Oh, no-no. I’m the one that’s leading the interview here. So if she stops and asks you for clarity, absolutely. You stopping to inform her? No. MS. GREGG: I never identified to you that 31 WR. QR: §=I'm asking you not to interrupt my questions. MS. GREGG: Okay. It doesn’t make sense to me. What I’m interpreting is my ability to represent is only if the employee asks a question that’s what you're saying to me. MR. Correct. So her attorneys are here. MS. GREGG: I got it. I got it. MR. Her attorneys are here. I’m asking if she has a question for her union representative -- MS. GREGG: — Mm-hmm. MR. -- she may at any time ask you. MS. GREGG: MR. interrupt. . GREGG: I got it. . These questions are not I got it. I'm asking you not to ~ GREGG: _Mim-hnmn. They're not directed at . GREGG: = Mm-hmm. Wey DHfwrP RR eo PRR RRP RRR OOD fwr mre reo MmmenNn Ww Wr 30 I would be informing her of anything. MR. Okay. But so yes. To answer your question, you can be here to represent here if she’s asking you for the information. I don't want you stopping our interview. MS. GREGG: MR. And then asking to leave the room. I’m going to allow that this time. After that, I will consider that an interruption of the interview. MS. GREGG: _Mm-hmm. MR. QM: | And then we'll have to proceed from there. And then there's a different form to provide you. So does that make sense? MS. GREGG: MR. not to interrupt -. MS. GREGG: Wait. It doesn’t make sense but I’m not - that was -. MR. So I’m asking you not to interrupt the interview. She may defer to you and ask you for questions. MS. GREGG: Mm-hmm. Mm-hmm . No it doesn’t. Okay. So I’m asking you 32 WR. QM: They’re directed at Mrs. MS. GREGG: I'm not answering questions. I was just trying to -. I'm representing her But I understand that there has been a determination of how I’m able to represent. And so I'l] deal with that in a different venue. You can move forward. MR. MM: Alright. Let me read this real quick in this paperwork so that we're not going to have any disputes. MS. GREGG: We don't have to. You don't have to continue. Right. Because I don't want to interrupt. So you can go on ahead and move forward. WR. MM: Okay. So it just says that you may not attempt to answer the questions. MS. GREGG: _Mm-hmm. MR. Or dictate the employee's actions to question or otherwise take charge of proceedings. MS. GREGG: _Mm-hmm. MR. But again, please feel free to go confer with Ms. a EFTA00117650

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RR SwWOHNDN FWwrNP RPRRRR we wre RR SD ae ee od WS Wr rs © Ww oc 33 I appreciate it. Thank you. MR. I am going to pause the recording. It is currently 10:32 a.m. (Whereupon, the above-entitled matter went off the record and went back on the record.] Okay. The recorder is back on. It is 10:38 a.m. Tuesday, June 22, 2021. This is Senior Special Agent . We’re resuming the interview. Ms. I just remind you that you are under oath and this is a voluntary interview. I’m sorry. What was your question? MS. GREGG: You need me to initial (Indiscernible *00:24:24)? MR. If you don't mind. And again, it’s just to show that you know, what we are looking at. MS. GREGG: Okay. MR. Now since we took that break, is there anything else we want to discuss or -? MS. FOY: No, we can move forward. MS. : No, thank you. MR. Thank you again very much for your cooperation with this matter. Is there anything else you wanted to -? No? MS. GREGG: 35 into work and the lieutenant asked me to go see Lieutenant And she asked me to sign and I said but I wasn’t here. I was out on an injury. And she said she’s aware but they need me to sign it for program review. MR. : Okay. So I signed. . So both trainings when you signed, they didn't actually even provide you anything? MS. :_ No. MR. Verbally? Electronically? Nothing? MS. :_No. MR. Okay. And that was on the date that was signed that that happened? MS. MBB: Actually she told me not to date it. I remember when I was signing, she said don't date it. MR. But you dated it anyway? Did you have a conversation about that? MS. : No. MR. didn’t say why did you date it or anything like that? After you dated it, she RR ROW OHMS fwrNP —— wr RPRRR oN Du ee od Wwrerow mr oe RR ae ee RPRRR Ww Wr MRRP RRR Pow OAS 34 Alright. DO you know where we left off I? What was the last question that we asked? MR. : It was what we asked for (Indiscernible *00:24:53) about the injuries. MR. Okay. So you were telling us you said March through June you were injured? MS. : Yes. MR. And you were not actually working during that time? MS. :_No. MR. Do you remember around when in March and when did it end? Was it the beginning of March, end of March, middle? MS. MBB: Um I’m not sure. I just know it was March. MR. Sometime in March? Yes. But when you came back, was it around the 26th when they asked you to sign those? MS. MBM: 1 came back in June. recall the date exactly. : Okay. But I remember the day I came 36 . :_No. as. Okay. Did you receive that training though in the annual training courses as well? Like the suicide prevention or the - you know how to operate in the SHU during MCC annual? Or the - I think you call it the IF training? Or during the correctional officer training at FLETC? MS. MB: Those trainings are like general overall training. It’s not specifically speaking about SHU. Like SHU may come up in the conversations, but it’s not specific to SHU or how to operate or run the . : Okay. . > Mm-hmm. . : Do you know if they were doing this with other employees as well? Having them sign training that they weren’t actually conducting? MS. : I don't know. MR. : Okay. But did you do this per the direction of your supervisor? MS. : Supervisor. Yes. MR. So she - did she I don't EFTA00117651

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rR CWO D SWwrNP RPRRRR We WN Re RRR CoN DD a de ood SWwWNr Ow PRR RPE RR Re rm CON Dw SW N rR OW ON DW Sw Nr “ a a ee ond We wWwrr Ow specifically you must sign this? Okay. And again, that And you said - I “don t know if we were Where did you say she is and I apologize. interrupted when - currently? WS. WEB: She is in Jersey I know. trying to -. MR. : At the FCI Fort Dix? MS. : Yes. MR. : Okay. MR. FOY: Question real quick. MR. : Absolutely. Do you want a more precise answer to when she was out and when she came back? I’m Uh, so far -. Because I happen to know -- Oh sure. If you'd like. -- the approximate dates. Sure. You can provide * FOY: OY: . FOY: And this is based on my review 39 June 20-whatever to August 10th, I worked the SHU. WR. QM: Okay. And that was your quarterly assignment was in the SHU from - for that whole summer -- -- in 2019? Okay. Thank you. So I know that you said that you didn’t - they didn’t provide you with the SHU training. Did they provide you with the policies of the SHU? MS. : No. MR. : So you never received those policies? Would it have been when you received and you said you had to initial and date something electronically? I think you said when you provided -? That’s the employee code of : Okay. . : That’s the - like the handbook that’s online. WR. QM: «Should have they provided you with the polices and post orders in the =— ROW OHMS fwrNP —— wr RPRRR oN Du ee od Wr Ow mre oe RR ae ee RR i) MRRP RRR RRR POoOwCmBADH ew Mmmenmrn Ww Wr 38 of discovery and conversations with Ms. J. We're looking at about March 15 to June 24-ish. MR. a. Okay. MR. FOY: And I note that the execution was on the 26th. But I think there was some time, you know, it’s not like the first minute she was there they had her sign the document. . : Okay. . : Right. MR. FOY: So those are the estimated times. I could be off by a day or two, but -. Perfect. The 15th of March to June 24th. And thank you attorney . FOY: No problem. | During your time at the MCC, how often were you assigned to the special housing unit_also known as the SHU? MS. : Mm. MR. : And this is an approximate. I'm not asking you for like exact amount. MS. MBB: when I came back from the injury, my assignment was the SHU. So from . FOY: Foy. SHU? “Ss. HE: orders. MR. QM: 0h, okay. So in the SHU there's the post orders. . : Yes. : And were you provided a copy of that to review? MS. Yes. MR. revi n tate that? When I came back. So sometime in that June MS. : So in June. MR. : -- or July timeframe? MS. : . MR. : Okay. So aside from hose post orders, did you receive any other SHU training! sn No. And who was In the SHU there is post And had you reviewed Okay. And when did you EFTA00117652

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rR CSCwWOmOANDMDS fWwNHP RPRRRR We WN Re RR SD ee ee od Se wWwNr Ow CO nm w RR SwWOHNDN FWwrNP PRR RP RRP RR COND WMH a a ee ond We wWwrr Ow 41 responsible for making sure that you actually did receive SHU training? MS. :_ I don't know. MR. You don't know was that a lieutenant issue -- :_ I assumed -. . -- or your first line supervisor? MS. MJ: I would assume the lieutenant. My supervisor. I don't know. MR. And when you say the lieutenant, who was the lieutenant in the SHU at the time? = . Lieutenant . WR. | ae HBB. Do you know his first name? MS. : . MR. : Okay. And would he be responsible for making sure that you were training when you were in the SHU? MS. BB: I mean, I’m going to direct that question to her. I don't know. MR. I don't want you to direct a question to her. MS. : Okay. WR. QM: «No. Okay. Did you receive training on how to conduct rounds? Yes. 43 And when was that? In IF. In IF? Okay. And what did it ting rounds? That you need two people to And one person goes The other person goes and counts. MR. ou confirm the numbers of counting. — Okay. MS. : And make sure when you're counting that you’re counting everybody's standing at their bed when you’re counting. MR. Okay. And did you receive suicide prevention training during the MCC annual refresher training? MS. I don't recall. MR. You don't recall. MS. MR. Okay. What was your understanding if an inmate was placed, you 1S. count and conduct rounds. and counts. And then =— ROW OHMS fwrNP —— wr RPRRR oN Du ee od Wr Ow mre oe RR ae ee RR i) MRRP RRR RRR POoOwCmBADH ew Mmmenmrn Ww Wr 42 MR. MM: «But if you need to like, yeah, that's fine. MS. : Mm-hmm. Yeah. MR. And if you don't know, that's totally acceptable. MS. :_ Yeah because I don't know. MR. Okay. No-no, that’s a totally acceptable answer. MS. + Mm-hmm . MR. a So yeah, if you know - if you don't know something or you do know something, that’s great. You don't really want to ask other people for the answers. MS. il ae MR. : You know, obviously if you need to confer, and you know with your attorneys or your union representative, absolutely fine. But we just want to try to get away from them answering for you. MS. Okay. MR. Alright. And then from your recollection though, you don't remember receiving SHU training during the annual refresher training? MS. No. 44 know, is suicidal or placed on suicide watch? What was your understanding of how you should treat those inmates? MS. If an inmate is placed on suicide watch, I don't deal with them. They go downstairs to suicide watch and they're being watched by other inmates. MR. —_ Mm-hmm MS. : But and then when they’re cleared, they come back to the unit. MR. a. And are you trained - are you supposed to handle them differently when they come back to the unit? : Uh, no. You’re not? MS. : No. , MR. : Not at all? MS. : Because they're cleared to come back. MR. : Okay. MS. : So once you’re cleared, you’re back to normal. EFTA00117653

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RR rPFCowW OND SwhN re RPRRR Ww = Wh RR SD 18 19 20 21 22 23 24 25 RR SwWOHNDN FWwrNP RPRRPR RRR SD SwWwNPe ee ee ed eS WwrN Pr CO wc nm wm 45 WR. MM: Okay. And were you assigned to the SHU on August 9th and 10th of 2019? :_ Yes, : Do you recall what time MS. MR. you began working on the SHU on August 9th? MS. : 4:00 to midnight. MR. Four to midnight. And then on August 10th? It was? MS. : Midnight to eight in the morning. WR. QM: Okay. You said, again, that was your quarterly bidded post. + Yes. : Quarterly assignment. MS. MR. And what were your overall duties and responsibilities when you were assigned to the SHU? wS. MMM: It varies because I'm new and because I don't know how to run the SHU. I just always rely on the senior person that I’m working with. So even if the roster reflects that I’m the senior officer, because sometimes I’m assigned SHU 1, I don't do what SHU 1 is supposed to do because I don't know how to do should have provided you with the proper training and information on how it was technically supposed to be done. MS :_ Mm-hmm. MR. : And were there any requirements - special requirements - for inmates who are assigned to the SHU? MS. : I don't know. MR. : That’s fine. in the SHU have cellmates? MS. :_ Yes, MR. : Okay. And are they required to have cellmates? MS. I don't know. MR. You’re not sure? MS. MR. Are there any inmates that don't have cellmates? MS. :_ Yes, MR. : And do you know why they wouldn’t have cellmates? MS. :_I don't know. MR. : Did you ever - were you ever told it’s because another inmate could harm that inmate? Or there were certain Do inmates PRR RR Se ee a RPRRR oN Du MmNmenNrre rmrROow mre re WW = Ww RR ae ee PRR RRR Dw wr ed ool mel ro wo 46 it. I rely on the senior officer that I’m working with. MR. Okay. So you didn’t really know what your duties and responsibilities were? Is that what you’re saying? MS. MM: In the SHU like um, to give out food, to collect the trays, to give out linen, collect linen. Whenever we would go down range to give out those, we count that as a round to make sure the inmates are good. You shower I think every other day. Count, that’s it. MR. —. So rounds and counts are a part of that though? MS. Rounds and counts are a part of it. But I’ve never worked in the SHU and actually done rounds every 30 minutes. We go down range to do stuff and we count it as a round. MR. Perfect. And that’s going to be something that we’re going to discuss. > Mm-hmm. : And ask you things like MS. MR. who told you that and houses that, you know who 48 classifications of an inmate? They never discussed that with you? MS. :_ No. MR. No? Okay. Did you ever see training on medical emergencies? With inmates? MS. MBB: Mm. No. I just know like if you are making a round and something happens to an inmate, you call and you wait for somebody to come before you enter the cell. That's all I know. MR. Okay. But did you - were you provided like CPR training or any kind of like you know, if something were to happen in front of you how you would respond? MS. : Yes. We had CPR training (Phonetic Sp. *00:35:08) MR. a. Okay. And when would you conduct training like that CPR training or you know if someone is trying to kill themselves or something like that. When did you receive that training? How you would respond to a medical emergency? MS. : That was in IF. : IF as well? MR. EFTA00117654

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rR CWO D SWwrNP RPRRRR We WN Re RRR CoN DD a de ood SWwWNr Ow nm w RR SCwWOnHtDUN SwWwrP 49 MS. Mm-hmnm . MR. : Okay. So who is or was Inmate Jeffrey Epstein? Reg number 76318-054? MS. : Who was he? MR. : Who was he? Was he an inmate assigned to the MCC? : Yes, : Was he assigned to the :_ Yes, : Okay. Do you know what he was at the MCC for and why he was incarcerated by the BOP? MS. WBBM: Actually I didn’t even know who he was when I worked with him. It was the other coworker that told me who he was. I didn’t know who he was. MR. : And who -? MS. : As in I knew his name but didn't know like what he was there for and who he actually was. MR. a. So and when you say the other coworker told you, who told you? MS. : . . : . Was he with his attorneys? MS. MR. MS. MR. MS Mm-hmm . MR. : Okay. Do you remember anything else about that conversation when he told you about him? MS. Eh No. MR. : MS. :_No. MR. Beas No? Just that he was famous and in the SHU? MS. Mm-hmnm . MR. : Okay. Why was - do you know why Epstein was assigned to the SHU? MS. : No. MR. as Did anyone ever tell you it was because he was a risk for suicide or safety concerns? MS. : No. MR. | No? We're going to get into this a little later, but do you know what the hotlist is? wS. MB: um... That was it. Did he tell you why he Are those -? I think PRR RR SwWwKN PCW OHMS SwMN Pe RPRRR oN Du ee od Wr Ow mre oe Re CWO HM fWwrNP 50 . : Uh-huh. . | And what is IMM first And what did he inform you? MS. J: He basically said that this is Jeffrey Epstein. You don't know who he is? And I said no. And he was like he’s in the news every day. And I was like okay. I didn’t know. MR. MM: Do you remember when you had that conversation? Like at least if you think about August 9th, August 10th? MS. : Mm. No. MR. Was it obviously it was then prior to August 9th? MS. : Yes. MR. Okay. working in the SHU together? MS. : Yes. MR. Okay. Was Epstein in the SHU when you had that conversation? But you were 52 the hotlist is like um, how should I say, like inmates that are like -. Inmates that are like - mm. WR. GM: §1'm just going to show you this and ask you if you ever received this training either. MS. + Mm-hmm. MR. Or if you’ve ever seen it. This will spell out exactly what the hotlist is. MS. MR. York special housing unit. (Indiscernible *00:38:01) MR. :_Oh sorry. MR. This one is special housing unit management suicide prevention. MS. + Mm-hmm. MR. So can you just have - there's two different tabs here which -- MS. : Mm-hmm. MR. -- the first one is going to say -. I'll just read it for the record. SHU hotlist identifies inmates with mental health conditions who may become dangerous, : Mm-hmm. So this is the MCC New Slides. EFTA00117655

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rR CWO D SWwrNP RPRRRR We WN Re RRR CoN DD a de ood SWwWNr Ow PRR RPE RR Re rm CON Dw SW N rR OW ON DW Sw Nr “ a a ee ond We wWwrr Ow 53 self-destructive, or suicidal when placed into > Hm. . : And that - did you know . :_No. . | = So do you know what I’m talking about when I say hotlist? There was a list in the SHU of -. WS. MBM: No. I actually thought that the hotlist was something else. Like that was on the computer. No. I don't know that. MR. ez . Okay. And then it talks about when someone is on the hotlist, it’s supposed to be a special notation on the hotlist, a special notation on the cell door, and there's also a special notation on the SHU board. wS. WB: om. There was never none of that. WR. I: So did you ever -? Can you just take a look quickly? You don't have to look through that. Just basically the -- WR. Ae two tabs. MR. : == two tabs as well as 55 WR. QM: 9 You never even heard the term? MS. WBBM: I thought that hotlist was like inmates that were like, um.... Like the inmates that were up on 10 South. Like those high inmates. Like El Chapo and those type of inmates. . : Sure. . : That’s what I though hotlist WR. QR: Okay. And because you brought u 10 South, what’s 10 South? MS. : The level above the SHU. MR. a And is that a specialized unit that_are even more secure than the SHU? MS. : Yes, MR. And can you just explain to me a little bit about who goes there? What the cell makeup is? Are there cameras in each individual cell? MS. : I don't know. MR. : Oh, you don't know? MS. :_Hm-mm, MR. : Okay. Are inmates that are in those cells only one inmate per cell? =— ROW OHMS fwrNP —— wr RPRRR oN Du ee od Wr Ow mre oe RR ae ee RR i) MRRP RRR RRR POoOwCmBADH ew Mmmenmrn Ww Wr the front. MS. + Mm-hmm. | = Was that ever provided to MR. you? Did you ever see this? . : Hm-mm. No. ; <= No. Okay. . : Do you want her to initial? MR. a. If you could. Yeah. Just so that we can -. You can do it on the top page. _No-no. Sorry. The front page. MR. ON the front page. MR. FOY: Just the first page. MS. : Oh. MR. : And do you know who would have been required to provide you that -- MS. : No. MR. a} -- information? No? And no one discussed that with you? MS. : No. MR. : Did anyone ever discuss the hotlist with you? MS. : No. MR. : Had you ever heard of the : No term hotlist? 56 :_ I think so. : And are they monitored . : Yes. . : Okay. But you don't know how they’re monitored? MS. + No. MR. : Okay. But they're for like a terrorist, high-profile, drugs -. MS. MR. MS. MR. Okay. floor above where the SHU is? MS. : Yes. MR. : Is it kind of in the general location of the SHU though? MS. :_ It's upstairs. MR. : Can you get to it through the SHU? MS. : Yes. MR. : And would it be considered as - I know it’s 10 South and it’s unique. But is it also part of the general SHU? Yes. You know? And that’s one EFTA00117656

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rR CSCwWOmOANDMDS fWwNHP RPRRRR We WN Re RR SD ee ee od Se wWwNr Ow CO nm w RR SwWOHNDN FWwrNP PRR RP RRP RR COND WMH a a ee ond We wWwrr Ow 57 MS. MJ: I mean when you come into the SHU, you go up the stairs and it’s right there. MR. a. Okay. Can you get to it by other means? No. So you have to go thought Go through the SHU. -- to get -- . -- into it? Okay. And how many correctional officers are placed in the 10 South? Um, one. One? And there’s no way in or out other than n through the SHU? MS. Mm-hmm, through the SHU. MR. : Okay. So when they come in and out, do the officers that are working in the SHU - you know where you are working - are you the ones that have to allow them to get in and out of the SHU? MS. i: Yes. Okay. Do you know approximately how long Epstein was assigned to the SHU? MS. : No. MR. : Was he assigned to the SHU for the most part of when you were doing you assignments in the SHU? MS. WBBM: When I came back and I was working there? MR. : Correct. MS. : . MR. : Okay. MS. MR. : Yes? Okay. So does July and August sound about right? That he was in the SHU? MS. 2 Mm-hmm. MR. : Yes? What was Epstein’s routine while he was assigned to the SHU? We talked about it briefly. He was with attorneys and stuff. So was that like a daily routine? Can you just tell me when he would come and go? And when he would be in the SHU and not be in the SHU? =— ROW OHMS fwrNP —— wr RPRRR oN Du ee od Wr Ow mre oe RR ae ee RR i) MRRP RRR RRR POoOwCmBADH ew Mmmenmrn Ww Wr 58 Do you recall who "R. I: | Okay. was workin on 10 South on August 9th or 10th? : Okay. Was that August 9th or 10th or both? MS. MB: I don't know about the 9th but the 10th. MR. MM: That's fine. And some of this stuff I'll probably at some point give you a list of the people so you can refer to like the roster so you don't have to -. MS. ‘Okay. MR. : You know you can recall that way if you remember that those people were in (Indiscernible *00:41:35). MS. ‘Okay. MR. : But you did say Epstein was assigned to the SHU on August 9th and August 10th, 2019? MS. Yes, MR. : Okay. And he was assigned to the SHU on the days leading up to August 9, 2019? 60 MS. MM: 0h I come in at 2:00. And I come in at 4:00. And when I come in he’s not there. He would come back like around after 8:00. MR. : 8:00 p.m.? Yes. Okay. And did you typically work after 8:00? So you come in at 2:00 or 4:00. When would you typically work until? MS. MM: 2:00 to 10:00 or 4:00 to midnight. _Mm-hmm. MR. QM: | And then would you typically do overtime shifts after that? MS. MBB: No because I usually do it on the front_end. MR. : Okay. MS. : So I usually come in the 8:00 to 4:00 and do 4:00 to 12:00. MR. QM: | And when you would come in 8:00 to 4:00, would he be gone already? MS. :_ Yes, MR. : Okay. But he would come back around -? So he would be gone before 8:00 a.m. and come back around 8:00 p.m.? EFTA00117657

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rR CSCwWOmOANDMDS fWwNHP RPRRRR We WN Re RR SD ee ee od Se wWwNr Ow CO RPE RP RP RRR rE rm SOW SwMre re COW ON DW Sw wr “ ae ee od WS Wr rs © Ww oc 61 . > Mm-hmm. : Would he eat when he was in the SHU? MS. MB: He gets common fare. all I know. I don't know if he eats it. he gets common fare. WR. QM: | Would that be something you supplied after 8:00 p.m.? MS. : When he comes back. Yes. MR. : Okay. What time is typically feeding time? In the evening? MS. : Um...after 4:00? MR. : And so because he was away, does he get -? Would he get an individual tray that was saved for him or provided when he returned? MS. : Yes. MR. | Okay. And would you provide that try to him? MS. MB: Not necessarily me just whomever. MR. : Did you ever? MS. : Yes. MR. : Okay. that to him on August 9th? That's But Did you provide 63 after 8:00 p.m. - even when he was coming in or out, you wouldn't even say hello? MS. :_No. MR. : No? Okay. For the one interaction you can think of with the phone call, do you remember if that was a positive or a negative interaction? Do you remember it at all? Was it -? MS. : It was regular. MR. : Regular? MS. :_ Mm-hmm. MR. : Did he seem upset? MS. . MR. : No? Abnormal? Anything out of the ordinary? MS. : No. MR. : No. What were your instructions with regard to Epstein being assigned to the SHU? MS. :_ There was no instructions. MR. : So no one said Epstein was a high priority here? Pay closer attention to him? MS. :_No. MR. | Alright. So even when RR ROW OHMS fwrNP —— wr RPRRR oN Du ee od Wwrerow mre oe RR ae ee RR i) MRRP RRR RRR POoOwCmBADH ew Mmmenmrn Ww Wr 62 You were the one who did? === = pDamDn Okay. Did you ever have any communications with Epstein during his stay at the MCC? MS. : No. MR. : Never any conversations at all? MS. : No. MR. : Okay. Did you even verbal say hello - hello back? Anything like that? MS. MBM: om. He was in the shower to make a phone call. And he was calling because he wanted to come out of the shower. And I told him that he had to wait because there were other inmates out. And you can’t move him and them out at the same time. That's the only conversation I ever had with him. MR. GM: And we'll get into that but was that phone call on August 9, 2019? MS. 1 Yes. MR. : Okay. But when you would provide food or anytime he would come back you had that interaction with the one individual who told you that he was a high- profile person, that he was in the news all the time, there was never a discussed that we need to pay close attention to him? MS. :_ No. MR. : And Lieutenant I, you said was the lieutenant in the SHU, he never told you to pay special attention to Epstein? MS. :_No. MR. a Okay. Was Epstein assigned any cellmates when he was assigned to Yes. And do you know when he was assigned to the SHU was he always assigned a cellmate? vs. Hi: cellmates. VR. (: | Okay. ones? Um, I just know he had two Two different Yes. Alright. speak with you about Epstein needing a cellmate when he was in the SHU? Did anyone ever EFTA00117658

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rR CSCwWOmOANDMDS fWwNHP RPRRRR We WN Re RPRRR Oona MmMNrnNrnrry WN r Oo nm w RR SCwWOnHtDUN SwWwrP 65 : No? Who was the officer in charge or the OIC in the SHU? Me. Um, are you talking about at a m eae m.? Yes. On (Indiscernible *00: i ic In general, was there tke 0 one e officer in “charge that has like is considered the OIC in the SHU? MS. MB: That's what I’m telling you. On paper, it says me. But I don't know how to run the SHU. So I rely on the senior officer. Well on the roster, it ays that I was the OIC. But - _ I think I’m just not asking. the question correctly. I’m not talking about like from 12:00 a.m. to 8:00 a.m. on August 10th. I mean in general. Like in July and August when you were in the SHU, was there one person that was considered the officer in charge? Like how there’s one lieutenant of the SHU which was INP Was there also an officer 67 =— ROW OHMS fwrNP —— wr RPRRR COND ee od Wr Ow mrNm oe Can you give me just like a layout? How many desks and computers were there 4 the SHU where the officers sat? It was two desks. Qne this way and “ a on wa a So kind of like an L type of ft Yes. And computers, about About three computers? Mm- he. And had you sat at all three af those computers at least one time during ) your shifts? Um yes. Okay. So it’s just - it You can sit at each one? I mean you can sit at any one. And do you remember ever there” beim a sign posted on any of the computers saying that Epstein was required to have a cellmate? MS. : No. MR. | Alright. And then Re CWO HM fWwrNP tree rate. in charge of the SHU? No. Do you know who - wasn’t it Grill? MR. : F . | el know who [a Yes. Would he be considered the officer in charge? MS. BM: See I don't know. Because on the roster, it can be a different person. "R. Okay. Did have like a desk or a computer area that he always sat in when he was there? MS. : No. MR. : Specifically? MS. : It's the one that we all sit at. MR. QM: | But he didn’t have one specific location that he would sit at? Like - . : No. . : No, he would sit wherever? me. wt Pon that_right? MR. Yeah MR. : How do you spell that last name? Do you remember? MR. . MR. : Thank you Agent J. So he didn’t have a specialized computer where he would have posted a sign on a computer? MS. : No. MR. : No? What about - do you recall ever seeing a sign posted on Epstein’s . : No. MR. a Saying that he was required to have a cellmate? MS. No. MR. : No? Okay. Inmate b Who was “MS. BIN: uh, his first um cellmate that he had. . : Epstein’s first cellmate? . + Mm-hmm. : Was that his cellmate in July of 2019? EFTA00117659

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rR CSCwWOmOANDMDS fWwNHP RPRRRR We WN Re RPRRR Oona MmMNrnNrnrry WN r Oo nm w RR SCwWOnHtDUN SwWwrP 69 MS. JHB: I'm not sure about the month, but that was his first cellmate. MR. : Okay. Do you recall if was already in the SHU or was he brought in specifically to be Epstein'’s cellmate? I don't know that. You don't know that? Okay. Are you aware of issues that took place between Epstein and when they were cellmates? No. Were you aware that on or around July 23 of 2019 um that Epstein allegedly attempted to commit suicide? MS. MMM: I wasn’t at work that day but I was told. WR. QR: Okay. And were you told anything else about the incident? MS. : Are you aware if was his inmate at the time? And you said you didn’t 71 MS. + Hm-mm, MR. : Do you know if it was like linens or a shirt or any kind of -? MS. : I don’ t know. MR. : No? No one discussed that with you? MS. | | No. MR. : anybody about it? MS. :_No. MR. : Do you know if Epstein was placed on suicide watch or psychological observation? MS. MMM: I think he was placed after But I don't know which one. WR. QM: Okay. Is it usually that someone will go on suicide watch for about 24 hours? Then after that they would go on what's called psychological observation. I'm not sure. You’re not sure? And you didn't ask that. Is that done in the SHU PRR RR SwWwKN PCW OHMS SwMN Pe RPRRR COND ee od Wr Ow mrNm oe Re CWO HM fWwrNP 70 have any involvement in that matter though? MS. :_ IT wasn’t at work. Hm-mm. MR. : Do you know if was removed as Epstein’s cellmate? At that point? MS. :_ After that he had another cellmate: And do you know why they . i But I don't know why. : Okay. Do you know who would have made that decision to change cellmates? No. Had you ever heard attempted to harm Epstein? No. You didn't even hear that Okay. Do you know what was used in the incident when Epstein attempted to - ‘ee atteapted to take his life? or else t's done downstairs. 7 And when you say domstairs what - do you know where? MS. : Where the suicide watch is or Unit ia Okay. So second floor? Mm- hn. And do you know who makes the detaretarien to be able to place someone on suicide watch or psychological observation? MS. : No. MR. : No? Okay. Does it sound right that he was placed on suicide watch on or around July 23, 2019? And returned to the SHU on or around July 30, 2019? That sounds about right? And at that time, was Who - which cellmate? EFTA00117660

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rR CWO D SWwrNP RPRRRR We WN Re RRR CoN DD a de ood SWwWNr Ow nm w RR SCwWOnHtDUN SwWwrP 73 > Mm-hmm. MS. MR. : On or_around July 30th. And who was Inmate - = MS. :_ His cellmate. MR. : Do you know anything about him? MS. :_No. MR. : Okay. But you do know he was his cellmate from that point until about August 9, 2019? MS. :_ Yes, MR : Okay. And do you know if Inmate was already in the SHU? Or was he brought in specifically to be Epstein's cellmate? MS. I don't know. MR. : You don't know if he was already in there? MS. :_No. MR. : Now do you ever -? Do you have any involvement with the inmates when you're in there? Would you like converse with them or do you just kind of -? MS. : No. MR. . No? so you don't -. was removed? MS. : Yes, MR. : And did you know that he was removed on August 9, 2019? MS. : No. MR. iw. So even on August 9th you didn’t know that he was removed? No. Did 75 . You knew that Epstein had a cellmate. You just didn't know that he didn’t have a cellmate on that day? MS. MM: He had a cellmate. I didn’t know that the cellmate was removed and wasn’t coming back. MR. Okay. So you never learned on August 9th or August 10th for that matter, prior to 6:30 that there was no other inmate within Epstein's cell? MS. :_No. MR. And do you know if anybody was aware that was departing the MCC or SHU prior to August 9, 2019? MS. :_I don't know. MR. : You don't even know that - you know at this point- if anyone was aware? Okay. PRR RR SwWwKN PCW OHMS SwMN Pe RPRRR oN Du ee od Wr Ow mrNm oe Re CWO HM fWwrNP 74 you ever know why people were specifically in the SHU? MS. No. MR. : No. Do you know why Inmate was removed from the MCC on August No. . So even at this point do you know why he was removed? MS. No. I didn’t even know he was removed. MR. QM: «No, I’m saying even today do you know that? MS. : Oh, no. MR. You don't even know that he was removed? MS. MM: No. I’m saying at that point in time, I didn’t know that he was removed. MR. Yeah. So I’m even saying as of today -. MS. But for now, I don't know the reason why he was removed. Okay. But you do know that he 76 MS. : No. MR. : No. Do you know if it was anticipated or not an anticipated move? MS. : I don't know. MR. : No? So on August 9th during your time from 4:00 p.m. even to just 12:00 a.m. That was not discussed with you at all or within the SHU? That Epstein’s roommate HB vias removed? MS. Never. MR. Never? MS. MR. confident_about that? MS. : Yes, MR. Okay. Are you aware if Epstein should have been reassigned a cellmate after Inmate IMJ was removed on August 9, 2019? Okay. And are you pretty So you're not aware? If he should have been? So your understanding was EFTA00117661

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rR CWO D SWwrNP RPRRRR We WN Re RRR CoN DD a de ood SWwWNr Ow hr nm SCwWOnHtDUN SwWwrP w PRR RP RRP RR COND WMH rR wo 77 he had cellmates. You just didn’t know if one of them was removed that he should be reassigned one? MS. : Exactly. Mm-hmm, MR. : Okay. Do you know who was responsible for assigning Epstein a new cellmate? MS. : I don't know. MR. : No. Could SHU staff have assigned Epstein a new cellmate? Would you have the authority being - working in the SHU - if you knew someone was supposed to have a cellmate? Do you have the authority to place another inmate with that person? See I don't know. _-_ Okay. : So like I said, I rely on the senior person a lot. So I don't know. like that would be a question I would ask them. So I don't know. WR. QE: | when you were - during your time in the SHU, which you said I guess was from you know late June through August 9th or 10th. Did you ever see that happen before? 79 . BE: And you were working in : Nope. . | = Do they typically tell you when an inmate in the SHU is - has left and is not coming back? MS. : Nobody said anything to me. I don't know. WR. QM: © Because don't you have to be able to keep your counts correct? And be able to know how many people are in the SHU? So if someone is removed, don't they have to tell you? This person’s not coming back so your count_is going to be lower. MS. MH: Mm-hmm. But it wasn’t told to me. So I don't know. WR. QM: Um okay. Do you know who the MCC staff psychologists were in August of 2019? MS. : No. MR. : Do you have any dealings with them at all? MS. :_ No. MR. : Does the name Chief ring a bell? Because I’m =— ROW OHMS fwrNP —— wr RPRRR oN Du ee od Wr Ow mre oe RR ae ee RR i) PRR RP RRR Wonymnufw 78 SHU staff assign inmates with other inmates? MS. MB: when an inmate comes, they place them with another inmate. WR. MM: «And would they do that based upon their own responsibilities and duties or would someone tell them to do that? See I don't know. You don't even know? “Okay. So you saw people be assigned with other ones, but you don't know -- that was determined? ” Okay. So you don't even know if you could have assigned Epstein a new cellmate? MR. : I don't know. MR. : Do you know if SHU staff should have assigned? You know like -. Or I guess you just answered that. So you said you know. And again, on August 9th, no one notified you that [MM was gone from the SHU? MS. : No. No? How about staff I know her. Mm-hmm . Okay. Who is she? She's one of the psychologists. Okay. And did you heave deal ings with her? MS. I had dealings with her after. MR. : You after August 10th? MS. : Like on August 10th she came to the unit. WR. MM: Okay. Prior to August 10th did you have any dealings with her? MS. :__No not really. MR. : No. What about a Samantha Demisa? MS. :_ Yes I know her. MR. : And who is she? MS. : A psychologist. MR. : Did you have any dealings with her? MS. : No. So only with J EFTA00117662

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rR CSCwWOmOANDMDS fWwNHP RPRRRR We WN Re RR SD ee ee od Se wWwNr Ow CO RPE RP RP RRR rE rm SOW SwMre re COW ON DW Sw wr “ ae ee od WS Wr rs © Ww oc 81 MS. MBB: Yes but she came after the incident. MR. But what was your dealing MS. : She just asked was I alright. MR. Okay. Did she ask you anything like that? MS. : No. iw. No? So it was specific to you? MS. Epstein meeting with staff psychologists during his stay at the MCC? MR. No. Would have he met with them I guess during suicide watch and MS. :_ Yes. MR. Okay. So that. Did you MS. I don’t know if he did, but I'm going to assume he did. with her after the incident? anything about Epstein or his cellmate or MR. | 4 Yes. MR. : Okay. Are you aware was MS. | | No psychological obviously? know that_he did meet with them then? Okay. But you do know 83 correctional officer training at FLETC. Did they discuss suicide? MS. I mean if someone is like explains to you that they're feeling a certain kind of way or they want to harm themselves, then you report it to them. They will place them on suicide watch. But as far as when they return, there’s no - nothing special that we’re told to do when someone returns from suicide watch. WR. QM: So they don't tell you like this person’s on suicide watch, he’s returning, he needs, you know a high likelihood of attempting to harm himself. MS. : No. MR. : We should place him with another cellmate. MS. : MR. MS. MR, hasn't harmed himself. MS. : No. MR. Or pay special close attention to that individual. That we should watch him. Or make sure that he RR ROW OHMS fwrNP —— wr RPRRR oN Du ee od Wwrerow mre oe RR ae ee RR i) MRRP RRR RRR POoOwCmBADH ew Mmmenmrn Ww Wr that he was placed on suicide watch? MS. : Yes, MR. . And they never - no one from psychology ever provided you instructions with regard to when he returned - how he was to be treated? MS. : No. MR. : Or that he was - needed to have a cellmate at all times. MS. : No. MR. : Or that you needed to watch him? MS. : No. MR. i. Do you know who placed him on suicide watch? MS. : No. MR. : No? So what is your understanding of suicide watch? When someone is on suicide watch and comes back. What is your understanding of how you're supposed to treat those people? Now my understanding is that you would have received this training you know. Now I know you said you didn’t do the SHU training. But the other trainings that you attended - the IF, the MCC annual, and the 84 MS. : No. MR. You said suicide watch though, that_is on the second floor? MS. : MR. Okay. So you're not aware that the requirement that if someone is returned to the SHU that they’re required to have a cellmate if they were on suicide watch? MS. : No. MR. Do you know the difference between suicide watch and psychological observation? MS. : No. MR. No? Are they both done in - on the second floor? MS. : MR. know what_that is? MS. : No. MR. Okay. But you don't even Did you know that Epstein was also on psychological observation? MS. MR. MS. MR. No. No? Just suicide watch? Mm-hnm . And to you it’s one and EFTA00117663

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MR. QM: © So you don't even remember there being a hotlist in the SHU? MS. :_ No. MR. : Would you like look around at the boards and look at the walls and see different things? There is no board. No? There’s no like -- the same thing? MS. : Yes, MR. : Okay. MS. : Mm-hmm. MR. : And I did ask about suicide watch, but do you know who placed Epstein on psychological observation? MS. : No. MR. : No? And you don't know - Are inmates that come from psychological observation required to have a cellmate? MS. : MR. : You don't know? -- where the post orders y kept as -. MS. : It's on the desk. MR. : Was there also on the desk something called the hotlist? . : No. MR. : Was there a list on the desk that had like inmate's names and anything next to them? Like a description? MS. : There’s a roster. MR. : A roster like of all the inmates in the SHU? Total? MS. : . MR. : Well what about like - and I only say this because I know that there was one. So you don’t recall saying like - 87 88 visited him when he was with his attorneys? I don't know. . You don't know. So did anyone - so psychologist, peers, supervisors, or anyone else - ever tell you that Epstein was required to have a cellmate? MS. : Nobody. MR. : Nobody. Did you ever receive any emails? So any type or form of communication? So not just verbal. Emails and writing, text messages - anything? MS. : No. MR. : No? Do you have that email? This isn't an email that was sent to you. I just want to see if you - if someone ever forwarded this to you. Did anyone ever forward you -? This is -. First of all, this is an email fron MM. It says suicide watch / psychological observation update. It's what was sent on July 30, 2019. It says inmate Epstein is being taken off psychological observation and needs to be housed with an appropriate cellmate. Did anyone ever forward this information to you? Being that you worked in the SHU where he was Pe row OnN Dw &SwhN re a rPowon4Dnuw Swrr RR wr RPRRR Ww = Wh i — So were you aware of any e SHU that were on suicide watch - came from suicide watch and psychological observation? MS. : No. MR. : And again, that hotlist. Did you say that you do remember there being RR a rR ~ RPRRR oN Du ee od Wwrerow No. In the SHU? nm > 18 19 20 21 22 23 24 25 nm Ww seeing like one list where there's special people assigned to that list called the hotlist? MS. : No. MR. : No? And you did work there all June, July, and August? Or not all - end of June, July, and then it’s August. MS :_ Yes. MR. : Did any staff psychologist visit the SHU? MS. :_ Yes, MR. : Did they ever visit Epstein in the SHU? MS. :_No. MR. | = No? What time typically would they come to the SHU when they would visit? MS. MMB: Um like after -. When I worked the 8:00 to 4:00. I don't know. Sometime in the day like maybe around 12:00. MR. : And would they not have come to the SHU to see Epstein because he wasn't there at 12:00? MS. | | Because he wasn’t there. MR. : Do you know if they ever RR SwWOHNDN FWwrNP RR ae ee RR i) RPRRPR RRR SD SwWwNPe PRR RP RRR Wonymnufw mre reo mre wh ae ee od WS Wr rs © Ww oc nm => nm wa EFTA00117664

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RR ROW OHM SWwrNP RPRRR Ww = Wh RR SD 18 19 20 21 22 23 24 25 RR SwWOHNDN FWwrNP RPRRPR RRR SD SwWwNPe MmMYyrRe re Oo wc assigned? MS. :_ No. MR. : No? So no one ever discussed that with you in the SHU? Like none of the other employees in the SHU that would have received this? MS. :_No. MR. : Do you know why other employees would have received this and you wouldn’t have? MS. HB: I'm not going to say that they received it and I didn’t. WR. QM: 9 Well if you look at the back it’s all the people that it was sent to. So if you go to the last page, do you recognize any of the people on there that worked in the SHU with you? The names. Look at the last - sorry, that middle page and toward the bottom. The following page I think. Middle, toward the That's the lieutenant. Do you recognize on there? . : Yes. But this is not sent - This is not the workers. 91 MS. MM: On that specific day or in general? wR. WE: Yeah. From June to August. When you worked in the SHU. Did the SHU receive any new inmates? MS. :_ Yeah. MR. : When they came in, how did you assign the inmates? MS. MMMM: I didn’t. did. WR. WEB: Senior officer. Did you see them assign inmates? Assign a cell to them. MS. : Like they put them in a cell? Yes. WR. WE: Were they ever put by themselves? MS. : I don’t remember. MR. : Do you recall any inmates being placed by themselves in the SHU? MS. MB: I think there was one inmate by himself. WR. WE: Any reason why he was placed by himself? MS. : I don't know. MR. : So of all the inmates, The senior officer RR ROW OHMS fwrNP —— wr RPRRR oN Du ee od Wwrerow mr oe RR ae ee RR i) MRRP RRR RRR POoOwCmBADH ew 90 MR. MY: None of those people were assigned to the SHU? Towards the bottom of that? MS. : No. MR. : No? Okay. So just the only person that you see on that is Lieutenant MS. i Lieutenant J. MR. : And he never discussed that matter with you? MS. :_No. MR. : If you don't mind, could you initial and date it? I initialed. And date. The 22nd. 6/22/21. Agent WM just has a couple questions on that. Here. During your time in the SHU - Mm-hmm . MR. : Did any new inmates come in during your shift? 92 there was only one that was by themselves? MS. MBB: 1 think it was an inmate by himself on G tier. MR. ME: © Now you mentioned that day were you on August 9th you were notified that was removed. But during your time in the SHU, were you ever notified if an inmate was ever removed from the SHU for whatever reason? Were you notified about it? MS. : No. MR. : How would you find out if the inmate was supposed to be in the SHU or not? MS. MB: How would I find out if an inmate is supposed -? MR. : Let's say the morning started. MS. > Mm-hmm. MR. : You came on shift at 2:00 p.m. or possibly 4:00. After that, there’s counts and rounds. When you do the counts, right. I just want to know in terms of how would you know if an inmate was removed or not? MS. MBB: When I count and he’s not there. WR. WR: You wouldn't be notified any EFTA00117665

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rR CSCwWOmOANDMDS fWwNHP other way? :_ No. : That's all I have. MR. : And I know we discussed the cellmates, but were you ever told you needed to keep a close watch on Epstein -- MS. :_ No. MR. : == when he was there? No? Who was the MCC warden in July and August of 2019? MS. . MR. Is that J? MS. MR. Okay. What communications did you have with the warden with regard to Epstein being housed within the MCC or the MCC SHU? : None. MR. : None. And he never provided you special instructions with regard to Epstein? MS. :_ No. MR. Did the warden ever tell you that Epstein was required to have a cellmate? WR. QR: «None? Would you have communications with any of the AWs? MS. :_No. MR. ever speak with them? MS. : Not in the SHU. MR. Not in the SHU. would you speak with them? MS. Pr On the regular housing unit when they made rounds. MR. So in July and August did you ever speak with them that you recall? MS. : No. MR. of No. So not since you were assigned to the SHU at the end of June. MS. : Mm-hmm. MR. : Okay. What about the warden? Is that the same thing? Mm-hmm No communications? Don't know. :_No. 95 No? So did you not even When * FOY: No? Don't answer if you don't know. Okay. . FOY: PRR RR SwWwKNrPOCOW OHMS fWwNP RPRRR COND ee od Wr Ow mrNm oe Re CWO HM fWwrNP 94 . : No. MR | Did the warden ever visit the SHU during Epstein’s stay at the MCC? I don't know. Not on my shift. Not during your shift? No? Okay. Do you know with Epstein during his . : I don't know. MR : Who were the MCC associate wardens in August of 2019? Um, associate warden was Anyone else? That you're MS. :_No. MR. Okay. And what communications did you have with or the other AW with regard to Epstein being housed within the MCC or the MCC SHU? MS. HBBB: None. 96 MR. FOY: Okay? MR. a. Do you know if any of the AWs ever visited the SHU during Epstein’s stay? MS. : I don't know. MR. You don't know. during your watch though? MS. + No. MR. Okay. Do you know if any of the AWs ever met with Epstein during his stay at the MCC? MS. : I MR. when you Not don't know. You don't know. were in the SHU? MS. : Not on my shift. MR. Who was the MCC captain in July and August of 2019? MS. : Captain MR. Is that MS. MR. : Okay. And what communications did you have with Captain [a with regard to Epstein being housed within the MCC or the MCC SHU? MS. : None. MR. None? And did he ever But not | i EFTA00117666

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rR CWO D SWwrNP RPRRRR We WN Re RRR CoN DD a de ood SWwWNr Ow nm w RR SCwWOnHtDUN SwWwrP 97 provide you with special instructions with regards to Epstein? MS. : MR. Captain JP MS. MR. Did the captain ever tell you that Epstein was required to have a cellmate? MS. : No. MR. | In the SHU? No? Did the captain ever visit the SHU during Epstein stay at the MCC? MS. | | Not on my shift. MR. : Not during your time? Okay. And do you know if the captain ever met with Epstein during his stay at the MCC? MS. : I don't know. MR. You don't know. So who - ? I'm going to give you now just because -. Uh okay, where are the rosters? I’m going to ask her about some of the supervisors that were on duty. So are you familiar with these rosters? Like just by looking at it are you able to decipher who was on duty and who wasn’t? Or who was on duty on August 9th and would make a round. MR. would that_be? MS. day? wR. QM: «Yes. On August 9th and August 10th. I’m wondering who had responsibility of the SHU? If Lieutenant [i wasn’t there. He was the SHU lieutenant. wS. WM: In the daytime, it was a regular officer acting. . Okay. : From the when I was on at 4:00 What other lieutenant Whoever was on. You mean that : Okay. And then from midnight it was Lieutenant MR. Okay. So would that other person that you're referring to. Do you know who that was? MS. : The acting? That was acting? MR. :_ Acting. MS. . MR. : $0S HP MS. : Say that again. PRR RR SwWwKN PCW OHMS SwMN Pe RPRRR oN Du ee od Wr Ow mre oe Re CWO HM fWwrNP 98 10th? I’m giving you the MCC New York daily assignment roster. So there’s August 9th and August 10th. So who were the MCC supervisors on duty with responsibility for overseeing the SHU on August 9th and 10th? Do you recall if Lieutenant was there on August 9th or I don't recall. You don't recall. . Okay. So he wasn't there. So if he’s not there, who has oversight over the SHU? . :_I don't know. . : Do you - would it be the operations lieutenant or the activities lieutenant? : I don't know. MR. : You don't even know who is - that would have responsibility if the lieutenant of the SHU wasn't there? Would anybody if wasn't there check in with you? I mean the other lieutenant 100 VR. : was it sos IP Senior Officer Specialist JN? : Is that ? (Indiscernible *01:11:25) I might be saying that name wrong. MS. but -. WR. QM: That’s fine. Okay. So those are the two that you remember: —, and MS. MR. looking at that. it says ? MS. : Yes. MR. Would that person have oversight over the SHU from - does it say that that person was the operations lieutenant? MS. QM: That’s what it says here but I didn't see Lieutenant J. MR. And do you know as being the operations lieutenant would they be responsible for overseeing the SHU? If -? I'm not sure of her first name, : ‘Was Acting in the day. Yes. Okay. What about by Would the - do you see where EFTA00117667

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rR CWO D SWwrNP RPRRRR We WN Re RRR CoN DD a de ood SWwWNr Ow nm w RR SCwWOnHtDUN SwWwrP 101 . : I don't know. | You don't even know that? 0 you don't know if after -. Is it true that after JE, replaced him as the operations lieutenant? MS. :_ According to this, yes. MR. Okay. And you're not aware that that person would have oversight over the SHU? . : I don't know. MR : You don't know. No one ever talked to you about {MJ isn’t there. Who should you go to if there are any problems or who would check in with you? WS. MBB: No. I would call downstairs to the lieutenant's office. MR. And would you just talk to whoever_answered? MS. :_ Yes, MR. lieutenants office? MS. The lieutenants. MR. All of them? MS. MR. And who would sit in the So it wouldn't be like WR. QM: “Okay. So he was physically in the SHU? MS. : Yes, MR. : Alright. So when he wasn't there, would any other lieutenant come visit the SHU? MS. | | When they make rounds. MR. : Okay. When they make rounds. And do you remember if that person was the acting or the operations lieutenant or the activities lieutenant? The person that would do those rounds? MS. : I don't know. MR. | = You don't know. knew that they were a lieutenant. MS. :_ Yes. MR. Okay. So would you even be provided that information where there's a duty agent roster? Is that something that would be like, hey. It’s up. If I need to get in contact with somebody, I can look at that roster and see who is where? No. Just call the lieutenant’s you just Just call the PRR RR SwWwKN PCW OHMS SwMN Pe RPRRR oN Du ee od Wr Ow mre oe Re CWO HM fWwrNP 102 the operations lieutenant and the activities lieutenant? MS. :_No. All the lieutenants. MR. : Okay. They all just sit in there together? + Mm-hmm. : Not one of them answers the phone though? Just -? No. Anybody. Okay. Do you remember -? Again, Lieutenant was reportedly off on August 9th and August 10th. MS. + Mm-hmm.. MR. Do you recall ever seeing R : him on August 9th or August 10th? MS. + Hm-mm, MR. : Where would Lieutenant MM sit? When he was at the MCC? MS. : Upstairs. MR. : When you say upstairs, upstairs where? MS. BBM: There’s an office right next to 10 South upstairs there. MR. al Within the SHU? . : Yes. lieutenant's office. MS. + Yes, MR. : Okay. And I believe you answered this, but did you have an communications with Lieutenant Epstein at_all? MS. + No. MR. : So he never provided you any special instructions with Epstein? MS. No. MR : 104 regarding And you never - Lieutenant never told you Epstein was required to have a cellmate in the SHU? MS. : No. MR. : Do you know who Operations Lieutenant was from August 9th? Do you know that individual? MS. Yes, MR. : But as the operations lieutenant, you don't know that he was responsible for overseeing the SHU on August 9, 2019? MS. I don't know. MR. : Did you have any communications with Lieutenant [i regarding EFTA00117668

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RR SwWOHNDN FWwrNP PRR RP RRP RR COND WMH a a ee ond We wWwrr Ow 105 Epstein being housed at the MCC or in the SHU? He never did - did Lieutenant ever provide you with special instructions with regard to Epstein? MS. : No. WR. Did Lieutenant IM ever tell you that Epstein was required to have a cellmate while he was assigned to the SHU? MS. BBB: No. I’m going to ask you these questions with a couple people. So I just want you to like really think about those people and they're going to be repetitive. MS Okay. MR. : Because I know you can just simply say I didn’t have any communications. But I want you to really think about that individual and any communications you had with that person with regard to Epstein and the SHU and your assignments. Okay? Okay. | Who is Lieutenant [a iL A lieutenant. : A lieutenant. By looking 107 . | | An officer. . : And on August 9th, was she the acting lieutenant responsible for overseeing the SHU? MS. I don't know if she was responsible for overseeing the SHU, but I know she was the acting lieutenant. I don't know for the whole building. But you said she -- -- conducted a round? She did. Okay. So if she conducted a round, would that lead you to believe that she was probably -? Hey, Lieutenant [MM isn’t there, she’s conducting the round here, she’s probably got oversight over the SHU? MS. WM: I don't know. It could be another lieutenant also. I don't know. MR. Okay. Did she visit the SHU on August 9, 2019? MS. : Yeah, she did. MR. : And what time was she on duty on August 9th? By looking at that roster. =— ROW OHMS fwrNP —— wr RPRRR oN Du ee od Wr Ow mre oe RR ae ee RR i) MRRP RRR RRR POoOwCmBADH ew Mmmenmrn Ww Wr 106 at that roster, was he on it on August 9th? . + No. MR. : No. Do you know if he was physically present at -? Do you recall if he was physically present on August 9th? MS. :_ I don't recall. MR. He was reportedly on sick leave. I just want to make sure that he wasn’t there. . + Okay. So you don't recall communications with him? No. having an MS. MR. Alright. And did Lieutenant ever provide you with special instructions with regard to Epstein? MS. : No. MR. No. Did Lieutenant WM ever tell you that Epstein was required to have a cellmate while he was assigned to the SHU? MS. No. MR. And then this is who you were just referring to. Who was senior officer specialist — i: Can you tell? MS. : It says 8:00 to 4:00. MR. | I think it would just be on that first page. MR. Is that August 10th or 9th? This is 9th. It just says 8:00 to MS. : Yes. MR. Can you check on the lieutenants column up top? MS. :_ (Indiscernible *01:17:34) MR. : Is there a name? MR. It should be under activities lieutenant. MS. : Oh yeah. 4:00 to midnight. MR. 4:00 to midnight? Okay. So you knew that - you do recall having an interaction with her. Did she have any communications with - we're talking about now - with regard to Epstein being housed within MCC_or the SHU? MS. : No. MR. No? And did she provide you with any special instructions with regard EFTA00117669

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rR CSCwWOmOANDMDS fWwNHP RPRRRR We WN Re RPRRR Oona MmMNrnNrnrry WN r Oo nm w WOoOntDWNSwWwrP 109 to Epstein? MS. :_ No. WR. : Did SOS MM ever tell you that Epstein was required to have a cellmate when he was assigned to the SHU? :_No. Okay. Now we're going to go on to some staff members. Who was present in the SHU when you worked in the SHU on August 9, 2019? So you said you were from 4:00 to midnight on that August 9th. Do you recall who that was? MS. : and . WR. : Just and Hi? When you arrived to the SHU was anybody else there? Do you recall replacing? MS. : I don't remember who I relieved. MR. a: Do you know a f | | MR. Alright. And 111 WR. QM: «Just walk me through. This one is one of those ones I'll ask you to explain a little more. Can you just from eh start of the conversation to what you did with Epstein to the finish. WS. WE: Okay. So Epstein stays in attorney conference all day. So I guess when it's time to use the phone, he’s not present. So when he came upstairs, [INI gave him the hone in the shower to use the phone. And then left. He called on the phone. I happened to answer and he said, “Hey can you take the phone from Epstein? Because the time is up." So -. WR. QM: | So when he gave him the phone he left and no one else was present with Epstein when he was on the phone? MS. : No. Nobody was there. MR. : Do you know that to be a legitimate practice? MS. : I mean it’s in the SHU, so So is no one supposed to be - because is the SHU a recorded line? WS. WB: 1 don't know. MR. : Were either of them in the SHU on August 9, 2019? But while you were there, . I don't remember. But I remember because he spoke to me. MR. : Okay. So a. ma are the people that you remember that were in the SHU? MS. . MR. : Okay. And you said that you remember speaking with you? MS. : . MR. : About what? MS. : He told me he placed Epstein in the shower to use the phone. And he called and told me to take the phone from him. WR. WM: Can you give me a little more detail on that? What do you mean? MS. BEB: So because he -. 112 MR. QR: 9 So do you know if someone is calling from a non-recorded line, are you supposed to take notes of that call? MS. :_I don't know. MR. : Do you know if you're supposed to log the telephone call in any kind of a logbook? MS. : No. . : Okay. So your understanding is gave him - plugged in the line, gave him the phone, and then left? MS. :_ Yes. MR. a No one was there to monitor? MR. _ Okay. So he -. MS. : We were in the SHU, but nobody was monitoring him. MR. a. How far away from you was he when he was making this call? MS. MMM: He was on G tier. And like that's far from the desk. WR. ME: Approximately - do you know how to like -? MS. : I don't know. MR. : Is it like from here to EFTA00117670

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rR CSCwWOmOANDMDS fWwNHP RPRRRR We WN Re RR SD ee ee od Se wWwNr Ow CO hr nm SCwWOnHtDUN SwWwrP w RPRRPR RRR a ee an Oe ee ee oe od Wr © Ww oo 113 like that fire extinguisher over there? Or is it further? WS. MEM: No. AC to over there. WR. CE: Okay. 25 feet? MS. :_ Mm-hmm. MR. : Could you hear his conversation from there? No. Maybe from the wall by the So approximately And were you asked to listen to his conversation? Prior to placing the call, did speak to you at all? : So just after he placed the call, he called you and what did he say? MS. MMI: He said to take the phone from him because the time is up. WR. [: §=Do you know how long he was on that phone? . : No. : Were you watching him while he was on that phone? 115 the call in the shower, cell closed behind him, it was approximately 25 feet from you but you didn’t hear gytring? i No. : And he didn’t - and — didn’ t instruct you? No. 7 : Did you ever experience that prior to that instance? Where an inmate would do that in the SHU? wS. MMMM: Yeah. If they have to use the phone and where there cell is, it’s not working. They place them in there because they have to plug it close to where they can have access to the phone. MR. —. Okay. So in their cells do they have cell lines that they can typically call from? No. Are the inmates provided anything to be able to make calls? MS. No. MR. : Some kind of a card pass or number or like something to be able to -? WS. WBBM: 0h, like a pack and - yeah. RR ROW OHMS fwrNP —— wr RPRRR oN Du ee od Wwrerow mre oe RR ae ee RR i) MRRP RRR RRR POoOwCmBADH ew Mmmenmrn Ww Wr 114 . : No. MR. | = Was it abnormal for an inmate to be out by himself on the phone in the . : No. ,_ = So they can just freely - that's not an abnormal ci rcumstance? MS. MBB: No because he wasn't free. He was ina cell. He was in a cell on the phone. _ Oh so he was in a cell? : Yeah but he was - he was in the shower because the jack - where his cell is, the jack didn’t work. So he was placed in the shower to use the phone there. But the shower is like acell. WR. | Okay. closed -- MS. 1 Yes. MR. : == in the cell? So he was in the shower area. Was he by himself? MS. :_ Yes. MR. : Were showers running? MS. : MR. : He was just - he placed 116 WR. QM: Okay. Can you explain what that_is? MS. BB: =I mean I don't know too much about it. I just know that they have a PIN that they use to use the phone. WR. QM: Okay. Do you know if Epstein had that PIN to use the phone? MS. :_ I don't know. MR. : But specifically with regard to the shower, having an inmate call from the shower, have you ever experienced that So was the door Yes. When was the last time you had experienced that prior to August 9th? MS. : If the jack is not working. The jack that’s closest to their door. If it’s not working, then it's being plugged at the bottom where the shower is. So you place them in the shower just so they can reach the phone. MR. a And do you know if that was an authorized practice? MS. :_I don't know. MR. : Okay. And did you ever place anybody in the shower to do that? EFTA00117671

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rR CSCwWOmOANDMDS fWwNHP RPRRRR We WN Re RRR CoN DD a de ood SWwWNr Ow nm w RR SCwWOnHtDUN SwWwrP MS. : MR. : No? MS. : MR. : Who typically does that? MS. : The officers. MR. : Okay. right? MS. : No. MR. : Would you ever allow inmates to But not you, You personally. When I come on, they have already like got their phone calls. MR. a. Oh, okay. So it’s not typically one of your responsibilities? MS. : No. MR. : What was unique about this situation with Epstein? MS. MMM: Well I guess because he’s always downstairs, so they made an exception for him to make acall. Okay. Do we need to take MR. FOY: DO you need to use the bathroom 119 where did he call you from in order to say get the phone from him? MS. WEB: A phone in the building. I don't know where because it doesn’t say where. Like the phone rang and I answered. And he just told me to take the phone from Epstein. His time is up. MR. : Is that weird to you at all? That he again, he gave someone a phone, put them in the shower and then left? MS. : MR. : That’s not weird? Okay. But without roviding anybody -. Did you know if he - i] - provided anybody instructions prior to him departing the SHU? I don't know. You don't know. . Who else was in the SHU with you at_that time? MS. : and MR. And did you recall when around that took mace? PRR RR SwWwKN PCW OHMS SwMN Pe RPRRR oN Du ee od Wr Ow mrNm oe Re CWO HM fWwrNP or aye No. 7 FOV We can continue. Alright. So what MR. Creat. were instructions. You said that he’s - his time is up. So what's - how much time ic he allotted? I don’ t know. Do you know how long he was " viet shower? I don't know. Mn "You don't know. like ; mes 10 minutes -? It wasn’t 5 minutes. He was in tere ao maybe 20 minutes. 20 minutes? Okay. ere : 7 was gone. Like left the SHU altogether’ Was it And | hmm . So he placed him in there = Sorry. -- left the SHU, and then ike “we vm chad. nA “have been about after 8:00 because that’ s the time he comes back from attorney conference. Okay. So around 8:00 “After 8:00 p.m. - ish? Okay. Are you able to look? Was assigned to the SHU when he gave him his phone call? MS. No. MR. : Where was he assigned? That's fine. Do you know what a - why went to the SHU in the first place? Was the escorting Epstein back from his attorneys? MS. : I'm not sure. MR. : So you don't know the reason why he actually entered the SHU? MS. :_ No. I don't know. MR. : And you -? Do you remember if he walked into the SHU with Epstein EFTA00117672

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RR rPFCowW OND SwhN re RPRRR Ww = Wh RR SD 18 19 20 21 22 23 24 25 PRR RRR RR NDMP WNPRPOWOHDH SWwNP ae ee od WS Wr rs © Ww oc 121 and immediately placed him into the shower area? Or do you think that he went and retrieved Epstein from his cell? MS. No. He didn't retrieve him from his cell. He came in and said that he was going to give him a phone call. WR. —. So he was with him at the time? wS. MBB: Yes. shower. WR. QR: | So do you recall then if he walked in the SHU with Epstein? MS. MM: I don't know if he walked in with him. But after because you could come in and he could have been -. There's a holding cell there. That’s why I’m saying I don't know. And then he came in after with him. But from that door to the shower, he walked in with And he placed him in the WR. GE: Okay. in his own cell? MS. :_No. MR. He could have potentially been in a holding cell? MS. Yes. So Epstein wasn’t 123 with those two other individuals? MS. MBM: I don't know who was in charge. We just kind of worked together that day. But I don't know as far as who is the -. MR. Is everyone considered equals? When you’re working together? MS. : Well I'm the newest person there, so and - I don't know how long they've been there, but -. MR. Does it - does then when you work with someone else, is it based upon how long they’ve been with the Bureau? : No. pa So is there -. I know MS. MR. you're saying you’re the newest. So you might ask them questions. But is there like when there's three of you in there, is there someone that’s supposed to be in charge? Or are you all equally -? MS. : On the roster it'll say who is supposed to be in charge. WR. Okay. *01:28:25) -. MS. But that doesn’t necessarily - that's not necessarily the case. So (Indiscernible RR ROW OHMS fwrNP —— wr RPRRR oN Du ee od Wwrerow mr oe RR ae ee RPRRR Ww Wr MRRP RRR Pow OAS Mmmenmrn Ww Wr 122 MR. MM: | Alright. But you don't know who brough Epstein -- MS. :__No because -- MR. -- back there? MS. : == somebody could have brought him up and then - so I don't know. MR. Okay. Now in order to ia into the SHU though, either you, [ll or MS. :_Had to open the -. MR. : == open the door. remember who opened the door on that day? I don't know. It was not you? Do you Okay. And I'm sorry, you I do apologize. What work there until? was 4:00 to 12:00 and time did and MS. : HB was 2:00 to 10:00. MR. : Okay. And what was the hierarchy with the three of you that were present at that time? Is there someone that was in charge as an officer in charge? Or how does that work when you’re working together 124 MR. QR: «On that roster on August 9th of those three people, who does it say should have been in charge? MR. : It’s on the first page. MR. It's on the first page. If you look all the way to the left, you'll see SHU assignments. And then you can look - go over to the right and see their names. I believe. MS. mm: I don't see MJ. I’m looking for . I don't see that. MS. GREGG: Really quick, can I just show her how she reads -- Absolutely. -- a roster? Oh I see him here. MS. GREGG: So - sorry. Most of what they're asking you would be on page one and page two, right? So these are your shifts. These are the posts. And then these are the people who worked that shift too. If morning watch, 3:00, 6:00 to 2:00, 6:00 and 8:00 is day watch. This is the p.m. 12:00 to 8:00, 2:00 to 10:00, and this is all your evening watch. This is like a person with a day off, sick EFTA00117673

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RR rPFCowW OND SwhN re RPRRR Ww = Wh RR SD 18 19 20 21 22 23 24 25 RR SwWOHNDN FWwrNP RPRRPR RRR SD SwWwNPe ee ee ed eS WwrN Pr CO wc nm wm 125 leave, so on and so forth. These things I don't believe apply to their questions because these are all the changes that took place on the roster. WR. QM: «Most everything is going to be on the first page. MS. GREGG: Yeah, so this can be a little bit confusing. MS. : Okay. MS. GREGG: And it probably doesn’t apply to the stuff that they’re asking. MS. MM: Okay. MS. GREGG: So you would just focus on -. WS. HEB: These two pages. MS. GREGG: Yeah. The shifts are up top. MR. FOY: So how does she determine who's the boss? Because that’s the question. WS. MBM: Yeah. MS. GREGG: So this - these positions will tell you who is in that position for that shift. Right? I don't want to answer the question for you, but when you look at the SHU MR. FOY: Can you show her where the answer is on the paper? 127 MS. : Yes. MR. | a And do you know what SHU I means he was the officer in charge? MS. : Yes, MR. : What does SHU II and SHU III represent? Are there different duty responsibilities - duties and responsibilities based upon if you’re SHU I, SHU II, or SHU III? MS. MB: I just know whoever the number one is would be the person in charge. But as far as two and three, I don't know the difference in responsibility. MR. : Now in the time that you worked there, did that actually play into anything? If someone was SHU I or SHU II or SHU III? MS. : No. MR. : No? So -. MS. : Because we’re always short- staffed. So. WR. QM: «Okay. So would that mean that like if the person SHU I even though on paper they're the officer in charge, they’re actually not providing orders or anything? Everyone's equally -. RR ae ee PRR RRR Dw wr ed ool mel ro wo 126 MS. GREGG: Here. SHUI. That’s your OIC. MS. MMM: Okay. MS. GREGG: Straight across. SHU II. SHU III is your 6:00 to 2:00, 2:00 to 10:00. And SHU IV is straight across. Right? So for example, SHU IV was vacant on evening watch. And then this is showing that = was SHU number one for the evening watch shift. And this one to what time? Shift III is 6:00 to 2:00. Oh, okay. . GREGG: And then shift ten is 2:00 to . : Okay. . : Thank you very much for that assistance. MS. GREGG: Mm-hmm. MS. : So basically on this it would have been Okay. [J would MR. MS. :__In charge. MR. : Okay. have been -? . | | Doing what we need to do. MR. : Okay. So everybody basically has the same job responsibility. MS. : Yes. MR. Okay. So you don’t look to someone as the actual officer in charge. MS. MM: 1 do because I don't know. So - but not necessarily the officer in charge, just whoever that I’m working with. MR. Okay. And what was your -? I don't know, this may have just answered that, but what was your role in the SHU on August 9, 2019? What SHU number were you? MS. :_Number two. MR. Number two. Like again, you don't believe that actually provided you with a different responsibility that SHU I or SHU ITI? : :_ No. MR : No? Okay. And what conversations did you have with the SHU staff that you worked with on August 9th regarding Epstein? : None. | a So you said that the one ~ GREGG: Mm-hmm . Because he was SHU 128 MS. MR. EFTA00117674

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rR CWO D SWwrNP RPRRRR We WN Re RRR CoN DD a de ood SWwWNr Ow nm w RR SCwWOnHtDUN SwWwrP 129 was with . MS. + Yes, MR. : Correct? With regard to the phone call. MS. : Yes. MR. : Now try to put yourself back then. MS. 4 Mm-hmm MR. : Any other conversations at that point with regard to Epstein? MS. : Um... No. MR. Any follow on to when he said get the phone from Epstein? MS. MMMM: No. When he said to get the phone, I got the phone. And I spoke to Epstein. WR. QM: «Okay. And what was it that you spoke with Epstein about? MS. I was told that your time is up and I have to take the phone. And he said okay. WR. Okay. And did say to then place him back in his cell? Or was that understood? MS. MMMM: No. That was understood. 131 people to move him. And I went to the bathroom. WR. QM: Okay. So you used the restroom at the time that he was transported -? MS. : Back to his cell. Yes. MR. Okay. And did you have any conversation with the individuals after they placed - before or after they placed him into the cell? MS. : No. MR. Did you instruct them, hey I just took the phone from him, can you place him back into the cell? MS. + Yes, MR. them about that. MS. MMM: Yes. I said I was going to the bathroom and he has to go back to the cell. MR. Okay. That was the extent of it? MS. : That was the extent of it. : Alright. And again, we MR. a briefly talked about him, but Now do you know if he Okay. So you did talk to MS. : Yes, MR. PRR RR SwWwKN PCW OHMS SwMN Pe RPRRR oN Du ee od Wr Ow mre oe Re CWO HM fWwrNP 130 MR. = And is that what you did? MS. : I didn’t place him back in the I went to the bathroom upstairs on 10. Okay. : And when I came back, he was placed back in his cell. MR. Okay. So what did you do? You went to the shower and just instructed him through the door? MS. Yeah. MR. To hang up? MS. : No. I told him that I was told that his time was up and I have to take the phone in. And he said okay. And then he handed me the phone. It’s like a slot. a Okay. And then you walked away? . Yes, MR : And he just stayed there and waited? MS. : MR. And then who brought him from the shower to his cell? MS. : I don't know. well it had to be MM and because it takes two worked that day? In the morning. : And who replaced him? Yes. : Because he worked 6:00 to 2:00 comes in 2:00 to 10:00. MR. : Okay. So when someone gets replaced, do they typically give a briefing? Like so would - and I apologize about the name but - Would they - would he typically be responsible to provide HB with information so that he - you know with regard to what happened on his assignment so that he can utilize that for when he’s not replacing him? MS. : I don't know. : Does that make any sense? : I mean I don't know if he's MR. MS. typically required to, but I guess if there's information to give, he would give it to him. But I don't know if he has to. MR. Okay. And during your time, was there any conversation with any information that — gave to MP or EFTA00117675

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RR ROW OHM SWwrNP RPRRR We Wr RR SD 18 19 20 21 22 23 24 25 RR SwWOHNDN FWwrNP RPRRPR RRR SOW WNP ee ee ed eS WwrN Pr CO wc nm wm passed along? I wasn't -. For the replacements? I wasn’t there at 2:00. I came But nothing was told to me. So MM never informed Okay. So there was no to be reassigned a cellmate? MS. : No. MR. And again, you didn’t even know that his cellmate wasn’t there? MS. :__Wasn’t there. MR. Okay. And should have you known that his cellmate wasn’t there? MS. :_I don't know. MR. So when you're doing rounds and conducting counts, wouldn't that be when you would know if someone was with or without a cellmate? Because you said only one other person there didn’t have a cellmate. Correct? MS. BEB: But people move al] the time. 135 inmate in the cell? MS. MBB: No. Vike if I'm counting and the person is not there. Like say the count was 66. And I counted 65, that’s just what I'l] count. WR. : «And you wouldn't try to like figure out where is the 66th? MS. MB: No because whoever moved the person would have I guess documented where they moved them to. MR. So you wouldn't - it is after you count at 65, then would you have to just go try to find paperwork. Hey, is there another guy that someone else moved? MS. :_No. MR. : Okay. So how do you reconcile the numbers? Rather than me saying so many words, you tell me how -- MS. : Okay. So let’s say -. MR. -- do you know who's in the SHU? MS. MMM: So let's say like if there was 66 people in there. And one person moved to wherever. They would have already did that. So it wouldn’t be for me to do. When I count RR ROW OHM fwrKP —— wr RPRRR oN Du MmNmenNrre rmrROow mre re WW = Ww Wey DHfwrP RR eo PRR RRP RRR OOD fwr mre reo MmmenNn Ww Wr 134 When you're in SHU, like let’s say if you did something and you’re in trouble. So you're in the SHU. You could be sent back to your regular unit. So it wouldn't be odd like if I was counting and the person wasn't there. It would just be lesser the count. But it wouldn’t be odd if the physical person wasn't there to me. Because people move back all the time. MR. ME: But wouldn't they have to advise you if you knew that there was only one person without - you know, one person that doesn't have a cellmate. Wouldn't they have to advise you? Hey, this person left, so this persons’ in there by himself. MS. MN: I don't know. Because nobody said anything to me. MR. a. So I’m not -. I’m just saying in general now. So like if you're conducting your rounds and your counts, in order for you to know who you’re supposed to be counting and what -. During both rounds and counts, you know, who are you supposed to be checking on. Wouldn't you need to know if a cellmate was removed and now there’s only one 136 now because the person is not there, I'm going to just count 65. But the number is not going to be off because whoever moved the body already moved them to like let’s say back to the unit or wherever. So I wouldn’t be trying to find or figure out where the person went. I’m just counting. MR. : Okay. So and you're counting during the counts, right? Not during the rounds? S During the counts. MS. : Right. MR. Beas Rounds are every 30 minutes approximately? MS. :_ Yeah. MR. .. So during those rounds, are you supposed to be when you're conducting the rounds, what is the intent of those rounds? MS. BBB: Whoever is in there to make sure that they're okay. MR. : So if you don't know who is in there, how do you make sure that they're there and_okay? Because they would have already If the person is not there, like they would have already been moved in the system. EFTA00117676

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RR ROW OHM SWwrNP RPRRR We Wr RR SD 18 19 20 21 22 23 24 25 RR SwWOHNDN FWwrNP RPRRPR RRR SOW WNP ee ee ed eS WwrN Pr CO wc nm wm 137 So if I’m making a round, I'm not going be like well oh this person is not in here. Because people go to different places. They go back to the unit. They go to court. They go to different places. So again, it wouldn’t be odd if somebody is not there. I mean I could ask the person that I’m working with. Like oh hey, whatever happened to so-and-so, but. MR. a. Alright. So you're saying that even though you knew only one inmate didn’t have a SHU and especially, it sounds like you're working later. MS. Z Mm-hmm MR. : So everyone should pretty much be back from wherever they went to. Correct? MS. : Correct. MR. | cy So at that point, you only know one person doesn't have a cellmate. You're walking through and you see that someone doesn't have a cellmate. You're not asking -- MS. : But see I don't know -. MR. : -- where is that person? MS. : But see I don't know that the person has to have a cellmate. So again, even 139 come on shift, right. You're responsible. I’m not saying this is the case. But you're responsible to know how many inmates are in the SHU at that time. Right? MS. MMM: When I come on shift, I just come on and relive the person and just -. Like when I come on at 4:00, it’s time to feed. So I’m doing trays and I'm feeding. I’m not looking to see who’s on the roster or -. You would probably wait for count time to count and then count to see how much people is in there. But I’m not looking to see okay the roster says 75 and I’m counting to make sure there’s 75 people. Only at count time. MR. a. So when you're doing your rounds, all you're doing is the people that you see, are they okay. If someone escaped, you wouldn’t know that until count time? MS. : TI wouldn't. No. MR. : Okay. And that’s basically - that answers it. So she's saying that she’s not even worried about if someone is not there. She's only worried about the people that are there. Is that correct? WS. MMM: Yes. Yes. RR ROW OHM fwrKP —— wr RPRRR oN Du MmNmenNrre rmrROow mre re WW = Ww Wey DHfwrP RR eo PRR RRP RRR OOD fwr mre reo MmmenNn Ww Wr 138 though the one person doesn’t have a cellmate, it’s not odd to me because I don't know that they have to have a cellmate. What if the person went back to the unit? I didn't know went to. Okay. Can I ask her something? Yes, please. Mm-hnm . I just want to clarify. When you comme in, right. Let’s say you come on re- shift. Is there somewhere near the computer that tells you how many inmates are supposed to eb in the SHU? On the roster. On the roster? Yes. And now let's say - do you review the roster when you come in? MS. No. MR. : So how do you know? Let’s just say someone went missing. How do you WR. GR: | Alright. MS. GREGG: What - I’ve got a question. WR. HM: | Absolutely. MS. GREGG: Would procedural clarification help with the question? MR. a. Sure. We have all the polices here. Would you like me to show her the policies? I’m happy to do that. MS. GREGG: Yeah. Or I could explain it. MR. MM: 1'11 give her the policies and just ask if she’s familiar with them. That's fine. So she knows what she should have done. MS. GREGG: I'll just say this to you. The policy is very general for the entire agency, not specific to MCC New York. MR. —. Okay. MS. GREGG: So. MR. MMM: While he’s looking, I just want clarificati MS. MR. : When you came in, if an inmate was removed, would that roster have been edited? vs. Ha: I don't know. But isn’t that - when you 140 It should be. EFTA00117677

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RR rPFCowW OND SwhN re RPRRRRR SOD Se Wwh 18 19 20 21 22 23 24 25 RR rPOwWOH4DMH fWwrNP RPRRR Ww Wh RR sO ee ee ed eS WwrN Pr CO wc nm wm 141 MR. MM: Do you recall if that roster - was there a roster on your desk? MS. There’s always a roster. don't look at the roster. WR. QM: But you don't recall if there was anything - if there was a notification or anything written down saying inmate was removed from the SHU? MS. : No. MR. Is that something the previous shift should have communicated to you? MS. : They could have. MR. Alright. So I’m going to read this out loud and then I'll provide it to you. This is the Metropolitan Correctional Center, New York, New York specific post orders. This is specifically says SHU number one. And I think that would be the officer in charge as we just discussed. But I think that they're, like you said, everyone's kind of responsible for the same thing. But it discusses right here, I’m going to go down to the third paragraph on page 2 of 18. It says report for duty by telephone with the operations lieutenant and receive any But I 143 both your shifts? Because this is specifically talking about 12:00 a.m. What were you at 12:00 a.m._on August 10th? MS. :_I think I was number one. MR. Alright. So this actually is pertaining to your shift during 12:00 a.m. to 8:00 a.m. So -. MR. FOY: You mean according to what you just read? WR. QM: shat I just read. This says for -- MR. FOY: Right. MR. -- the specific (Indiscernible *01:43:58) so we're SHU number one. So I guess what you were supposed to do per post orders was when you get on board, you're supposed to call the operations lieutenant. And then you're supposed to say hey, is there any information I need to know. And then you're supposed to start making your counts. And that would be like where you would find out Epstein doesn’t have a cellmate. Make sure that when you're doing your rounds, you know there's nobody in there. You know I would think. Is that - was that your understanding Yes. a CWO HUDMS fWwrNP —— COUT fwr re mre nd MmmrenNrn Ww WPM Wey DHfwrP PRR RRP RRP RRR WeonyDwVfwrNro mre reo MmmenNn Ww Wr 142 additional information. Begin making 30 -. So according to this, it says when you're report to duty, you’re supposed to talk to the operations lieutenant and receive whatever information you're supposed to on your shift. It says, “Begin making 30-minute rounds ensuring you document the findings into True Scope (Phonetic Sp. *01:42:49). Staff will observe all inmates in continued lockdown status once in the first 30-minute period of the hour. Example, 12:00 to 12:30 a.m. Followed by another round in the second 30- minute period of the same hour 12:30 to 1:00 a.m. This will ensure an inmate is observed at jeast twice per hour. These rounds are to be conducted on an irregular schedule and no more than 40 minutes apart. All observations must be documented. It should be clearly understood that none of these activities are to take place until the evening watch officer is relieved. It should be noted that it is understood that not all of the above will be accomplished by or before the count.” Then it talks about official count time. The SHU number two officer you said you were working, is that for MS. : No. MR. : practice? WS. QM: No. Nobody ever calls the lieutenant when they get on shift. So no one ever talked to . : No. MR a. Okay. Is there - I don't know if I need to continue reading this because we're going to take a lot of time with it if we do. Just because I read it, if you want to take a look. And just initial and date there. And then we’re just going to move on. MS. + Mm-hmm. MR. Because that’s - this is taking up. MR. FOY: Initial the top. MR. But the point on that matter was that you knew you were supposed to observe the people that were there. You weren't too concerned about people that weren’t there. WS. WEB: Nothing. Correct. at all? I’ve never -. Was that ever put into EFTA00117678

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rR CSCwWOmOANDMDS fWwNHP 145 WR. GM: «Is that a correct understanding? MS. : Yes, MR. : Alright. On August 9th do you recall having any discussions with = regarding Epstein? MS. :_ No. MR. : And again, [I would have been the one - did you say he was the one who replaced -? MS. WM: Relieved I. MR. : Okay. So if provided with information, did not provide you with that information. MS. |S I don't know if J -. MR. Yeah-yeah-yeah, I know. I’m asking that -. . : Oh, about MM didn’t -. MR ah If he did that, [i certainly didn’t provide it to you. MS. : No. MR. Okay. And [ED didn’t provide you with any special instructions regarding Epstein? MS. : No. =— ROW OHMS fwrNP —— wr RPRRR COND ee od Wr Ow mrNm oe the one to allow them? MS. :_No. MR. Alright. So he didn’t actually have any responsibilities in the SHU? MS. : No. MR. And aside from the telephone conversation that you had with —. with specifically with regards to get the phone away from him, his time is up. Any other conversations? MS. : With EB, no. MR. : No. About Epstein or otherwise. MS. :_ No. MR. : No. with him in person? MS. : Only when I took the phone from him WR. GM: = No-no, not Epstein. 7 . : Oh, no. MR : And that’s what I was asking about before. It’s just to make sure that we're clear. Any other conversations aside from that one conversation on the phone Re CWO HM fWwrNP Any conversations 146 MR. MM: No? Did you discuss the need for Epstein to be reassigned a cellmate with anyone on August 9th? MS. No. MR. : No. When did depart the SHU? On August 9th? 10:00 p.m.? Correct? You said unit manager He actually wasn’t in the SHU? I'm MS. + No. MR. : He was just in there in order to facilitate the start of this telephone conversation? MS. | | Phone call. Yes. MR. : And you don't know why he was in there in the first place? MS. : No. MR. aw. So you don't know if he brought Epstein in? MS. : No. MR. of He just - and you're not 148 where he said get the phone from Epstein his time is up. MS. : And when he came in, he said I’m going to put him in the shower to use the phone. MR. MM: And that was the extent of it? MS. : That was the extent of it. MR. | mits Okay. Nothing to do with Epstein being housed with MCC or SHU? MS. : No. MR. Ps Or the need for a cel|mate? MS. :_No. MR. : Do you know who authorized to provide Epstein with that telephone call? MS. : I don't know. MR. : No. Who plugged the telephone line into the legal line in the shower area? MS. : . MR. : did. And do you know if he did that per * direction? WB: vo. MS. EFTA00117679

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rR CWO D SWwrNP RPRRRR We WN Re RRR CoN DD a de ood SWwWNr Ow nm w RR SCwWOnHtDUN SwWwrP 149 WR. QM: «You're not sure. And to you, that_was an authorized practice? MS. To use the phone in the shower? Yeah. WR. GM: «What is that line in the shower area for? MS. :_I don't know. MR. Is it -? Okay. Is there usually a phone that’s plugged in there? Or is it just a-- MS. MR. -- line that’s available? MS. The jack is there. MR. Just the jack. know that to be a legal line like for attorneys? MS. : I don't know. MR. : You don't know that that’s what that is - a legal line? MS. : I don't know. MR. : But what is just your overall understanding briefly about policy for inmates assigned to the SHU when they need to make a phone call? How often do they get to do it? How do they do it? And you 151 MS. : No. MR. | = And no one informed you to watch or listen? MS. : No. MR. : And previous instances when people have used that line, were other - were people watching and listening to those people? MS. : No. MR. : And around what time was Epstein brought back to his cell did you say? MS. : Maybe about after 9:00. MR. : So he did the telephone call sometime before 9:00 and around after 9:00 is when he was put back into his cell? MS. WM: Probably because I was in the bathroom. WR. WM: And you went to the bathroom you think around 9:00? MS. : I'm not sure. MR. Sure. MS. But around. MR. I'm not asking for specifics. wS. WEB: Yeah. Like around. PRR RR SwWwKN PCW OHMS SwMN Pe RPRRR oN Du ee od Wr Ow mre oe Re CWO HM fWwrNP 150 MS. MB: Um. When they had them the phone in the cell and they use that PIN - the number - to make the phone call. How often, I don't know. Because that's usually done before I come in. But I know showers are every other day. I don't know if phones is every other day also. WR. MMM: Okay. So you're not sure? :_I'm not sure. : You said you didn't hear MS. MR. any part of that telephone conversation? MS. : No. MR. Did you see any part of that telephone conversation? MS. : Only when I went to go get it from him. MR. : But while he was on it? MS. MR. : Discussing? MS. MR. : And no one observed him? MS. MR. : So no one watched him or listened? MR. : Around 9:00 p.m. MS. + Mm-hmm. MR. : Okay. And you said you're not the person who brought him. Someone else did. After someone else brought him to his cell, did you have any more conversations with Epstein? MS. : Yes. MR. : Okay. What - when was that and where? vs. HE: counted. MR. : When did you count? MS. :_ At 10:00. MR. : At 10:00 p.m. you counted? MS. : Yes. MR. : So you actually went through each tier and counted? MS. : Yes. MR. : And did you go into the tier? Or_did you just go up to the door? MS. : I went into the tier. MR. : Okay. So you didn’t head around at 10:00 p.m. you didn’t stop at the Not a conversation when I EFTA00117680

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rR CWO D SWwrNP RPRRRR We WN Re RRR CoN DD a de ood SWwWNr Ow nm w RR SCwWOnHtDUN SwWwrP 153 door and just look in? You actually went through? :_ Yeah, I went through. : And looked through and MS. MR. counted each person? MS. Yes because he was on the floor. And I knocked. And he put his hand up. MR. Okay. So that wasn’t just from the outer door of the tier MS. MR. That was actually -. MS. No, that was in there. MR. Okay. And you said you don’t know who brought him back to the cell. MS. : No I was in the bathroom. MR. Okay. And when - around 10:00 p.m. you looked in and you said he was on the floor_and he put his hand up? MS. Yeah. He sleeps on the floor. The mattress - he puts the mattress on the floor. wR. QM: Okay. So you never actually see his bunk. He would sleep on the floor. MS. WBBM: The floor yeah. you said MS. ou knocked? : Yes. MR. a with him at all? And did you communicate : You okay? No. So it was just a No communication. Just visualization. Yeah. And notice anything that time? MS. : No. MR. : No. around 10:00 p.m.? MS. MB: I think he asked for the CPAP machine to be plugged in because he had a CPAP machine. . _ What’s a CPAP machine? . : When people have sleep apnea, I guess they use that machine. You said that was PRR RR SwWwKN PCW OHMS SwMN Pe RPRRR oN Du ee od Wr Ow mre oe Re CWO HM fWwrNP 154 MR. MM: | Take the mattress off the bunk? . i And put it on the floor. . : Sleep there. Is that typical? For him. a. For him? Which other MS. MR. inmates do that? MS. MM: Not in the SHU, but sometimes they do that. MR. And is there anything up with policy that prohibits people from doing that? . il Not that I know of. MR. : No. So it wasn't anything of concern? MS. : No. MR. : Okay. But he - did you - did he verbalize anything or just put his hand : He put his hand up. | Just like, I’m accounted iL 7 : Okay. : Okay. : So the cord has to be ran from outside of his room all the way down to be plugged in. MR. : It's for sleep apnea? MS I don't know what else it's But that's what I know people use it for. MR. And did you get it for And is that after 156 for. him? MS. MM: It's in his room. It’s just for it to be plugged in. MR. : Oh. in for him? MS. : MR. Okay. So you did have some communication with him then? MS. MB: Well he asked and I just nodded. And I plugged it in. MR. : So okay. So when I ask you these things, I just really want you to be clear with like -- MS Mm-hmm . MR. : = if there’s communications just really think about like what communications you actually had. And did you plug it Yes. EFTA00117681

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rR CWO D SWwrNP RPRRRR We WN Re RRR CoN DD a de ood SWwWNr Ow PRR RPE RR Re rm CON Dw SW N rR OW ON DW Sw Nr “ a a ee ond We wWwrr Ow 157 MS. : Mm-hmm. MR. | So just tell me about specifically what you can remember. Because again, if this is the last time you saw him. Just try to recall -- MS. : Remember it. MR. -- what it is he said. MS. : I remember he put his hand up. And he asked about the CPAP machine to be plugged in. MR That’s it. . Do you remember his words? Like -- MS. : NO. MR. -- did he say, “CPAP machine." Or, “Can you plug this in for me?” MS. MB: I don't remember how he said it, but basically he asked for it to be plugged in. But I don't remember exactly what he said or how he said it. MR. Alright. So at that point you went and plugged it in? MS. : Yes. MR. Alright. And that’s like a cord that runs like under his cell door or something? 159 MR. : Okay. So the control center, they don't call for it first and the control center pops the first door? And then you have keys for the second door? :_ No. 7 Alright. Okay. So I’m MS. MR. going to stop talking. You tell me exactly how they do it. Somebody knock or they call or buzz or what? MS. MB: Somebody knocks. Or sometimes they use the radio. And then we go to the door and open the door. MR. So do you have a - from your desk is there a buzz to -? No. You've got to open it with . : The initial outer door? . : Both doors. . : So you go, you open the inner door to you and then go to the -- Door. -- outer door -- -- and do the second? =— ROW OHMS fwrNP —— wr RPRRR oN Du ee od Wr Ow mre oe RR ae ee RR i) MRRP RRR RRR POoOwCmBADH ew Mmmenmrn Ww Wr . Okay. conversations afterwards? MS. : No. MR. No. Alright. Can you just briefly explain the process of people entering and exiting the SHU? MS. :_ There's double doors. MR. : Okay. MS. : And we open the doors to let the person in. MR. So is there somebody that they have to go through an outer door first to get to your door? MS. MMM: Yeah. There's two doors. And so they come in the first door, then the second door, and then you're in the SHU. MR. a. How do they get into the first door? MS. MR. MS. MR. So you're able to - from the first door before they get to your door, you open both doors? And then any We open the door. Not the control center? 160 MS. : Yes. MR. | And you have control over both doors? MS. : MR. Alright. Does the operations center also have control over that outer door? MS. MM: 1 don't know. I don't think for SHU the do. I don't know. MR. a. Alright. Anytime people enter and exit, you've always - MS. The person on the inside yes. MR. For both doors. Yes. . Alright. And that’s the same as when they leave? MS. : Yes. MR. second outer door -- MS. + Mm-hmm. : == you go, you lock that So after they leave that MR. manually -- MS. + Mm-hmm. : -- and then lock the MR. other one? EFTA00117682

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rR CSCwWOmOANDMDS fWwNHP 161 MS. : Yeah. MR. | ae Manually? Both manually from the SHU? wS. QM: If that one I think - the outer one like once you pull it in it locks. MR. : Okay. Which one is that? MS. :_ The outer door. MR. : The outer door. And who entered and exited the SHU on August 9, 2019 between let's say for the first shift: 9:00 p.m. and 12:00 p.m. So if you have to open up two doors, I’m assuming that’s kind of a process and there aren’t many of you in there. . : Lieutenant fot . : Lieutenant a . : No you said on the first shift? . First shift. From 9:00 to 12:00 a.m. - 12:00 a.m. sorry. MS. : From - I don't know. MR. : So it would be the people that were in there. Correct? Would that be p.m. . And me. And you. Anyone else? I'm trying to remember because 163 : :_No. : Alright. And who was present ‘with you in the SHU after midnight? From approximately 6:30, 6:33 a.m. on August 10, 2019? ve and J. Anyone else? Visitors? Lieutenant [- At around what time did she visit? MS. : I don't remember the time. MR. | Does around 4:00 a.m. sound right? "s. i: be honest. WR. WM: Okay. Was there another officer that you remember around like 5:30 a.m. visiting? WS. MRM: No. I don't remember the time. To The officer upstairs - he left to go get food and come back. . a. So would that be 10 PRR RR SwWwKNrPOCOW OHMS fWwNP RPRRR COND ee od Wr Ow mrNm oe Re CWO HM fWwrNP 162 you said between 9:00 p.m. and 12:00 a.m. I don't remember exactly when | made her rounds, but - "R. PM: kay. [EI would have showed up at one time or another though? Yes, Do you nema that conversation when she showed up? _ Did she talk to you about anything? i = Did you specifically sea : her at i : I nean I said hey. Just hey. What’s up. Okay. And who allowed Ls enter and exit? I don’ t remember that. Alright. Do you know who : shen and left, who allowed them io leave? I don't remember that. You don't remember that. Mm. = : 164 WR. QM: | Alright. And then when he leaves 10 South to come to the SHU, do you also have to allow him access into the SHU? Or is he able to get into the SHU by himself? Coming down from 10 South? Mm-hmm . relieved him. And then he came “down and went. VR. SR: GY relieved the person on 10 South? MS. :_ Yes, MR. : So MEM wasn’t assigned to the SHU? He was assigned to 10 South. MS. :_ He was assigned to the SHU. MR. : So can you just explain what you mean by relieved? You mean he relived him temporarily while he got food? MS. MBM: He called and said that the lieutenant said that he could go get his food. So can one of us relieve him to go get his food. So MM went, relieved him, and he came down_and he went out to get his food. WR. QM: Okay. So you were the only person in the SHU at that point? MS. BBM: Downstairs I guess. EFTA00117683

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RR ROW OHM SWwrNP RPRRR Ww = Wh RR SD 18 19 20 21 22 23 24 25 PRR RRR RR NDMP WNPRPOWOHDH SWwNP ae ee od WS Wr rs © Ww oc 165 MR. = And MP MS. : As far as the time, I don't know. MR. Okay. So are they the only two people that were in the SHU between -? MR. FOY: Do you want the context of when that request from to get coverage to get food? Because there's a context there. MR. : Sure. I mean. MR. FOY: Alright. So I want you to talk about what you were doing before when he asked | 11 you. Right. ws. J: MR. FOY: doing, right? MS. I-. MR. FOY: This is a three event, there’s a five event, and then -. MS. Oh! Like I counted with [i upstairs at that time. And when I came back downstairs, he called and he said that the lieutenant said to relive him to get food. I didn't believe him, so I called the lieutenant’s office. And I said, did you say 167 MS. MB: When I came back downstairs he called. WR. QM: «0h so not while you were doing the count. Re CSCwWOHUMDMS fwrP Okay. You remember what you were I remember what I was doing but So you left. Came back downstairs. He called and said I just t? WS. WRB: He said the lieutenant said for when you had to relieve me to get food. MR. And then you said you verified that? MS. MR. RR ae ee ——a wr I called. The lieutenant? MS. MR. Was this both [- HM both times? Was that who it was? MS. MBM: No. When I called, Lieutenant HBB answered and he said he didn’t know. MR. : $0 it was Lieutenant HMB. So this would have been at like 5:30 then probably? MS. Z Probably. MR. : Okay. MRRP RP RRR POW OUHHN mmr =e Wh If you look at the} 25 166 for me to relive MM to get food? But another lieutenant came on, so he said well I don't know if the lieutenant before said that. So I said okay and I hung the phone up. And HEM said 1°11 go relieve him so he could go get his food. MR. apologize. MS. MR. : And you're talking about the individual in 10 South. MS. : Yes. MR. : And then you came back to the SHU and then relieved him? : Yes. Okay. And I do You counted with him? : Yes. . Um. MS. : But I don't remember if it was at the 3:00 or the 5:00. I don't remember which one. MR. Alright. And I do apologize. I just want to make sure I have this clear. So when you went up at either 3:00 or 5:00, and I’m assuming it was 5:00, you helped him count. And at that point he’s - when he said he wanted to go get food? 168 schedule, can you tell me what time i came MS. on? : On here it says 8:00 to 4:00. MR. = Are you looking at 8/10 - August 10th? MS. MMMM: Yes. But it was before that. It was (Indiscernible *02:00:18). MR. Oh, sorry. So there’s a little caveat there. So the officers’ times are two hours before, do he would have started at 6:00. But I believe he actually - his would be 6:00 to 2:00 as opposed to 8:00 to 4:00 like the roster. So it’s confusing. Um, they allowed the lieutenants to come in two hours earlier and end their shift two earlier. MS. > Hm. MR. But I do believe he arrived at 5:30. So this would have been probably you said - you said there were two different lieutenants you spoke to. So I’m assuming one - MS. BB: No I spoke to Lieutenant ma. asking did he say for me to relive to get the food. So he said he doesn’t know. Maybe Lieutenant MMM told him. But I EFTA00117684

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rR CWO D SWwrNP RPRRRR We WN Re RRR CoN DD a de ood SWwWNr Ow nm w RR SCwWOnHtDUN SwWwrP 169 didn’t speak to her. WR. WM: Sure. And what I'm - I think that he started around 5:30. So he probably called around like 5:28, spoke with lieutenant - and then you probably called shortly after 5:30. Does that sound like potentially could have happened? MS. : Could have. Yes. MR. : Okay. So does around that 5:30 timeframe right before you know you were going to feed the inmates. Does that sound about right? MS. : Right. MR. : Okay. So the 5:00 a.m. count. That (Indiscernible *02:01:18)? : Right. . Okay. So he is - and I'm sorry, who was in the 10 South? MS. : . MR. : It was [J and then who else visited the SHU where Epstein was housed between 12:00 a.m. and 6:30? Lieutenant Are they the only two people that visited the SHU aside from you and 171 So I ask the =— ROW OHMS fwrNP —— wr RPRRR oN Du ee od Wr Ow mre oe know everything because I'm new. senior officer. WR. WM: Okay. Do you any conversations you had with not remember that As far as -? Just were you conversing? thite -_ were there? Just the two of you? MS. : I'm not -. MR. : I'm not asking for what conversations at this point. I'm just saying were you vexing to one another? No not really. You guys didn’t really communicate or alk? MS. : No. MR. : Okay. Do you remember any conversations with regard to Epstein at a 7. No. Alright. So it’s = Nou two, you said I, anc The only four people from that - those Re CWO HM fWwrNP periods when you started your shift at 12:00 a.m. to 6:30? | MS. : . MR. : Okay. MS. : . MR. : Okay. When you were in the SHU with , was there a hierarchy then? MS. MM: On the paper it says that I was the number one. WR. ME: And would that be - I know you said a lot of time it’s because you're new, you would ask other people for guidance. Is that because that was your quarterly post? MS. :_ Yes. The post. MR. : And was I in there as an overtime post? MS. : Yes. MR. : Not his regular assignment? MS. : Correct. MR. : Okay. So on paper, you were in charge. But in practice, you're both the same. MS. MM: In practice, I ask because I don't know. So even if I'm in charge, I don't 172 No one else? MS. : Correct. MR. : What was the purpose of aa. visit? MS. : To conduct a round. MR. : Okay. And what is she required to do during a round? MS. : I don't know. MR. : Are you aware if she was supposed to conduct a count with you during her round? Or -? MS. BEM: She's not supposed to conduct the count. But I don't know how she’s supposed to conduct her rounds. MR. QM: § So do you understand if her round is at a round of her staff members? Or is it also she’s supposed to do anything with inmates when she does rounds? MS. :_I don't know. MR. : You don't know. And do you remember when she entered and exited the SHU who let her in and out? MS. :_I did. MR. : Both times? Both in and ws. HB: Yes. out? EFTA00117685

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rR CSCwWOmOANDMDS fWwNHP 173 MR. _ Okay. And then what about when departed the SHU? Who let him in and out? . : That I don't remember. . : Would it be -? . : But it probably would have been wR. QM: -- you since relived him -- Right. Went upstairs. -- Correct? MS. MR. I would think [RY went up there, then you probably would have -- MS. : Let them out. Mm-hmm. MR. : Okay. And both with ee , you verified that that those doors were shut and sealed? MS. : Yes, MR. And no one else got in and out between those times? MS. :_ No. MR. And were they - those two individuals authorized visitors - and authorized visits - within the SHU? MR. 175 the count, I don't remember if it was her that took the count. But. MR. Okay. So you don’t recall any other conversations with [il aside from when she visited at 4:00 to check in? MS. : (Correct. MR. : And she never provided any special instructions? MS. : No. MR. that shift? About anything during MS. No. MR. : She never told - HE -ever told you that Epstein was required to have a cellmate? MS. : WR. | Didn’t ask about I or anything? No. MS. : No. MR, ; being place in? MS. :_ No. MR. : Alright. And we just briefly mentioned that who was Lieutenant Or about a new cellmate PRR RRP RRP RR CONDO SWKH POW OHM WNP mre row MmeMmnNr Ww WPM Re CWO HM fWwrNP 174 MS. Who Lieutenant [? MR. : Was their presence in the SHU authorized? MS. :_ Yes. MR. : Was it justified. And did you see them the entire time that they were actually in the SHU? MS. :_ Yes. MR : Was there anything out of the ordinary? MS. : No. MR. : No. Any - either of them have any conversations about Epstein? MS. :_ No. MR. Bas And you say [aii was the operations lieutenant on August 10th? MS. : Yes. MR. a Did you have any conversations with her on the phone? MS. : No. MR. : That you recall? No. What about like when you guys would call in counts? MS. MB: I don't remember who took the count, but when I got called control to give 176 ? MS. : The lieutenant that came on in the morning. MR. Okay. And he started - we believe around 5:30 based upon what we just talked about. MS. : (Correct. MR. Okay, 5:30 a.m. on August 10th. And during that conversation, you said that you called Lieutenant [M. What all was spoken about during that call? MS. MM: If I should relive [to get If that's what he said. MR. Any discussion about inmates? MS. : No. MR. | Any discussion about Epstein? . :_No. . = No. He didn’t’ provide any special instructions or ask about anything about your shift? MS. : No. MR. MS. : No. About him coming on? EFTA00117686

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rR CSCwWOmOANDMDS fWwNHP RPRRRR We WN Re RR SD ee ee od Se wWwNr Ow CO RPE RP RP RRR rE rm SOW SwMre re COW ON DW Sw wr “ ae ee od WS Wr rs © Ww oc 177 WR. QM: «No. Do you remember if the control center, R&D, or anyone else called the SHU on August 9th or 10th during your two shifts? About Epstein’s cellmate leaving? MS. MBM: I don't know. If they did, they didn’t speak to me. MR. a, You didn't speak with anybody? MS. MR. MS. MR. : If an inmate is removed from the SHU and is released from the MCC, how does the SHU find out? MS. I don't know. MR. You don't know? MS. MR. you before? MS. : Where an inmate had gone? No. MR. : When an inmate goes to court or something and then is released? MS. But I don't -. If that happens, like I'll give the phone to the senior officer because I don't know. But that never 179 Epstein is required to have a cellmate. What should have happened? MS. I don't know what should have happened because when I came in at 4:00, the cell was empty. So I don't know what should have happened. Epstein came back and went to his cell. I don't know where I is or if he’s coming back. So I don't know what should have happened. MR. Okay. So if an inmate is required to have a cellmate, such as Epstein, when the cellmate -. Sorry, I don't know if I just misspoke. If Epstein was required to have a cellmate, as Epstein was, after his cellmate departs, which was , do you know if there’s a - how long it should take for him to get replaced? MS. :_ Oh. MR. MS. MR. Do you know who the decision-makers would be on that? MS. :_I don't know. MR. Do you know if you were authorized to assign Epstein a cel lmate? R&D or anyone else?> Has that ever happened to 9th from the SHU. I don't know. You don't know that? RR ROW OHMS fwrNP —— wr RPRRR oN Du ee od Wwrerow mre oe RR ae ee RR i) MRRP RRR RRR POoOwCmBADH ew 178 happened where like an inmate was released when I’m there. MR. So from 4:00 p.m. on August 9th, you don't recall that call coming in -- . :_NO. MR : -- or a discussion happening -- MS. : Not to me. MR. os. -- about I not coming back? . : Not to me. No. . | os And you didn’t have a conversation with anybody at all? MS. : Nope. MR. : And you don't know if control or R&D or anybody spoke with anyone else? MS. : I don't know. MR. : Even if they didn’t discuss the details of it. You didn't overhear that conversation? MS. : No. MR So what is your is released on August 180 MS. | | I don't know. MR. : Again, no conversations at all with -? MS. : None. MR. : He's gone. No? Um and you don’t remember him being removed from the roster list so when you're doing your rounds and your counts. MS. : No. MR. a. You know how many are supposed to be counting. MS. : No. MR. Alright. We're just going to talk a little bit about counts and rounds. According to you, what is a cell count and you have it in front of you if you need to refer to the policy. But what is your understanding of a cell count? Or sorry, an inmate count. MS. You count every inmate to make sure that they're alive. MR. a. To make sure that they’re alive? And accounted for? MS. : Yes. MR. understanding? If Alright. And can you EFTA00117687

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rR CSCwWOmOANDMDS fWwNHP RPRRRR We WN Re RR SD ee ee od Se wWwNr Ow CO RPE RP RP RRR rE rm SOW SwMre re COW ON DW Sw wr “ ae ee od WS Wr rs © Ww oc 181 just explain the process? WS. WEBB: The first officer goes down and counts. And then the second officer goes down and counts. And we confirm the numbers. MR. Okay. And prior to confirming the numbers, do you tell the other officer how many you counted? MS. : No. MR. Alright. So you get your number, then another officer goes down, gets their number. MS. | 4 And when they come back. MR. : And is that tier by tier or do you -? MS. : Tier by tier. MR. Tier by tier. Just one person stands outside while the other person -- MS. :_ Yes. MR. counts the inmates? MS. : Yes. MR. So do you have to like see the person moving, see - what do you need to do when you're doing that count? MS. You need to see the prisoner 183 Yes, -- goes down range and difference? What's a round? WS. MBB: 1 mean the round you're walking down the tier basically checking to see if they're okay. But you're not counting. You're just checking to make sure. WR. a. So you're doing the same thing you're just not counting -- MS. : Counting. MR. -- the inmates? Alright. So you’re making sure that they're okay and they're alive. But you’re not just -- MS. : Counting. MR. -- actually making sure they're -. MS. WM: Yeah like you don't need a number. WR. QM: §=But one CO goes down, checks, and then does the other one? Or does there only need to be one? MS. : Well it's one. MR. : So both don't need to actually do that? MS. :_No. MR. goes down. Alright. Does the other CO have to remain at So just one CO RR ROW OHMS fwrNP —— wr RPRRR oN Du ee od Wwrerow mre oe RR ae ee RR i) MRRP RRR RRR POoOwCmBADH ew mre wh 24 25 182 move. WR. QR: «Do you have to like talk to them? Make sure they’re responsive or anything? MS. MM: Or you could see them breathing. MR. Just as long as you see some life. Okay. So what are the requirements in the SHU on how often is a count conducted for counts? MS. MBM: Counts is at 4:00. I mean it’s been a long time. I really don't remember. But I think 4:00, 10:00, 12:00, 3:00, and 5:00. MR. Okay. So 4:00 p.m. 10:00 p.m., 12:00 a.m., 3:00 a.m., and 5:00 . Yes. MR : And is that every day or is it Nonda through Friday? Do you know? MS. : Every day. MR. : Every day. And you're just making sure they're alive. You don't actually have to speak with them? MS. : No you don't. MR. Okay. And what’s the the door to make sure that CO is okay? MS. : Yes. MR. Okay. difference then? us. i rounds. Yes. MR. WM: «Only one CO is required and that’s per your understanding of policy. MS. : Yes. MR. ae Okay. And during a R round, do you have to speak with the inmates? MS. : You don't have to. MR. : No? But on both instances both COs have to be present. You're just saying with rounds, only one CO actually needs to go down. MS : Go down range. Yeah. MR. : You said the purpose is to make sure they're okay and they’re alive? MS. : Yes. MR. : And are they - are the counts and the rounds both documented? MS. :_ Yes. MR. : And do you have to sign documents when you conduct counts and rounds? So is that the Between the counts and the EFTA00117688

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RR rPFCowW OND SwhN re RPRRR We Wr RR SD 18 19 20 21 22 23 24 25 RR SwWOHNDN FWwrNP RPRRPR RRR SD SwWwNPe ee ee ed eS WwrN Pr CO wc nm wm 185 Okay. Now if you and another officer like on the case of when you work 12:00 a.m. to 8:00 a.m. If you and another officer are the only ones assigned to the SHU, are you both just as responsible for documenting the round sheets and the count slips? So if you’re the one documenting all the rounds for the 30-minute rounds, is your documentation - does that also carry weight for the other person that’s with you? Are you signing for both of you? MS. MM: I don't think so because it’s just my signature. MR. a, So you would take responsibility for the cell count rather than saying that you're both responsible? Or the round -? MS. MMM: Well the rounds and the counts have to be done with two people. MR. But - MS. But on the - MR. Let me “just show you so you know what I’m talking about. I’m just going to show you for August 9th and 10th the 187 Okay. So what I’m asking here is ‘by you placing those initials is that now fall on you? Or if you're only two people in there Vike on August 10th -- MS. Mm-hmm . MR. -- are you basically signing for both people? Or do you think you're only signing for yourself there avowing that the round Was conducted. MS. I don't know. MR. Okay. MS. I guess because like you're trying to say ‘i the rounds have to be conducted with two people, when I sign it would be -. I don't know. WR. Okay. But you did sign and certif that they were conducted? MS. : Yes. MR. Okay. And what do you do with the rounds - the sheets - how are they maintained? MS. WM: Well I usually fil] it out like prior in hopes to conduct the round. Like when I work in the SHU, I've never actually done the wont nfwnrP 10 MMM NR NYRR RRP RRP RRP RR AWN OWSOAUDH EWN Wey DHfwrP RR eo PRR RRP RRR Oo OUD wr mre reo Mmmenmrn Ww Wr 186 cell counts and the rounds so that there’s no misunderstanding. So this first one is going to be the 8/9/2019 for the 30-minute check sheet. And the other one is going to be 8/10/2019. Can you just let me know if you see your handwriting and initials on these two documents? MS. Yes. MR. both? MS. Yes. MR. Okay. And I guess we'll first discuss August 9th. Where do you see it and from what time to what time? From 4:00 to 11:30. And are you ever one of Okay. Do you see it on Yes. Okay. So every 30 minutes, you have your initials. And you wrote those. That’s actually your initials on that Yes, And what about on August 10, 2019? 188 round every 30 minutes. Like when you go down to give out toilet paper, that’s counted as a round. To pick up trays, it’s counted as a round. To give out food, that’s counted as a round. But and then you fill it out either after or before. You're not sitting like every 30 minutes like filling it out. MR. Okay. And you’re - you said you do it a lot of times prior to actually conducting the round? . 1 Yes. : Alright. And with rounds, “do you call anybody with that information? MS. :_No. MR. What's done with the sheet? Is it at the end of the shift something done with it? Are they logged into the BOP database at all? What happens with those sheets? MS. MM: I don't know. Because it’s left on the table. I don't know what they do with them. MR. So as far as you know, you just fill it out and you leave it there? EFTA00117689

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rR CWO D SWwrNP RPRRRR We WN Re RRR CoN DD a de ood SWwWNr Ow PRR RPE RR Re rm CON Dw SW N rR OW ON DW Sw Nr “ ae od rr 189 MS. : Yes. MR. | = Okay. You don't ever provide it to anyone. MS. : No. MR. : And you don't ever go into any BOP database and enter those rounds. MS. :_No. MR. : Do you know if someone else does? MS. :_I don't know. MR. : You don't know. Okay. What about with counts? Do you call people after you do the counts? Yes. Control. You call control? And do you recall on Oth you called - did you call anyone with those numbers? MS. :_ Yes. MR. : Okay. And do you remember which counts you called? MS. :_I don't remember which. MR. = You know you did some of them you just don't remember specifically which 191 MS. | | Control. MR. : Control? Okay. And you provide them the number that you wrote on that document? MS. : MR. Sorry, we did this. My question was supposed to be what do you do with the physical pieces of paper? MS. MBM: Stick it in the door and then internal takes it. MR. Yes, So no one actually comes . : No. MR a. -- to the SHU? You stick it in what door? MS. ii The outer door. MR. : So you open up the interior - the inner door and then you go to the outer door and you -- MS. : Stick it in there. MR. -- there's like a special slot for it? MS. the door. wR. QM: «Okay. Internal never Not a slot. It’s just between =— ROW OHMS fwrNP —— wr RPRRR oN Du ee od Wr Ow mre oe RR ae ee RR i) MRRP RRR RRR POoOwCmBADH ew Mmmenmrn Ww Wr ones? MS. | § Which ones. MR. : Okay. And do you remember speaking with lieutenants when you're there or with regular officers assigned to the control center? MS. MR. QM: You don't remember. Well with the count slips, you said you just leave those round slips on the table. When you're done - when you do the count slips, what do you do with those slips? MS. BBB: We did the same thing. We filled them out before. MR. Before you actually conduct the count before you filled them out. MS. Yes, MR. So before actually even getting the number, you fill out the number? MS. : Because we know the number. Okay. So do you then MR. : call somebody with the number? MS. : Yes. MR. Pe Who do you call? I don’t remember who I spoke to. 192 comes in though? vs. HB: know if they ever come in, but they didn’t (Indiscernible *02:17:51). They didn’t that day. I don't MR. Okay. On August 9, 2019, you said you filled all that out. What rounds did you conduct during your shift on August 9, 2019? MS. MM: That's hard for me to tell because I didn't conduct it every 30 minutes. It was give out food, pick up the trays, give out toilet paper, go down. So those were the rounds that I conducted. Bu it don't. MR. So you were counting a round as just doing something with an inmate? MS. : Yes because I actually physically walked. . Every tier all six? Yes. Is there six tiers in the Yes. Okay. Two floors - two levels. Yes. Yes. EFTA00117690

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RR ROW OHM SWwrNP RPRRR Ww = Wh RR SD 18 19 20 21 22 23 24 25 PRR RRR RR NDMP WNPRPOWOHDH SWwNP ae ee od WS Wr rs © Ww oc 193 WR. QR: © So when you do these rounds, when you would go down range and handle an inmate or give something to an inmate, you would then also do all six? MS. 1 Yes. MR. Alright. So about how often -. Let’s ask it a different way. About how many of those didn’t you do on August 9th? MS. MM: I don't know. I can’t give a number of how much I didn’t do. But. MR. Are some of those that were documented, were they not done? MS. : Yes. MR. Alright. So you didn’t do some of them. You just don't know which -- MS. : Ones. MR. MS. : Right. MR. . FOY: MR. . FOY: -- ones? Alright. And -. Okay. Let me just say to help clarify. Absolutely. The times that you wrote down. Okay. Right? Mm-hmm . 195 . BB: Some do it before, some do it during, some do it after? MS. : Yes, MR. : And just this instance you did it all before? MS. :_ Yes, MR. : Alright. And some - at least some of them. Would you say the majority were not done or were done? MS. : On the 9th? Majority was done. MR. | = You believe the majority. Now I know we’re doing estimates because you don't know exactly. You think like 51% or do you think -? MS. MR. MS. MR. Alright. But again, for the ones that you did do, you're not just going down one tier. MS. : No MR. tiers? MS. MR. . FOY: I don't know. You don't know. You’re going down all six | | I'm doing all. : You are? RR ae ee ——a wr MRRP RP RRR POW OUHHN Mmmenmrn Ww Wr 194 MR. FOY: When did you write the times down? MS. HB: Before. MR. FOY: Alright. So when you did a round to take toilet paper, did you change the time to reflect that particular round? Did you do anything with the paperwork to change -- MS. : No. MR. FOY: -- the actual time? MS. : No. MR. And why did you do that? Is it because of the requirement? MS. : Why did I fill -? MR. Why did you fill these ahead of time? Were you just trying to stay on top of what the actual requirement was to conduct a 30-minute round was? MS. MH: 1 mean I don't know why I did it. I just always did it that way. MR. : Did someone train you to do it that way? MS. WEB: I mean I've seen it done that way before - after. And three’s people that actually do it as they do it. It’s been done all three different ways. 196 MS. : Yes. MR. | And that's - this is the under-oath thing. We've got to make sure because the video is and all that kind of stuff. . > Yes. MR. | a That’s your understanding? MS. : Yes. MR. : Alright. That you're actually checking every door. MS. : Yes. MR. : And when you go give that one-person toilet paper or whatever, you're actually looking at all the different doors? MR. FOY: Can we take a break real quick? Because I need to take a break. . : Absolutely. . FOY: (Indiscernible *02:20:53) . a. Yeah-yeah. Absolutely. Alright. So it is currently 12:35 p.m. We are going to take a quick break. [Whereupon, the above-entitled matter went off the record and went back on the record.] The recorder is back on. This is Senior Special Agent MR MR MR EFTA00117691

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RR ROW OHM SWwrNP RPRRR We Wr RR SD 18 19 20 21 22 23 24 25 RR SwWOHNDN FWwrNP RPRRPR RRR SOW WNP ee ee ed eS WwrN Pr CO wc nm wm 197 WS. t is 12:49 p.m. vs. remind you this is a voluntary interview and you are under oath. MS. + Mm-hmm. MR. Alright. Is there anything that we wanted to revise before we continue? MR. FOY: Yeah. I want her to go back. This was from earlier about the double door How they operate. —. Okay. MR. MR. FOY: I think there were some unintentional inaccuracies on that. MR. : Sure. MR. FOY: That we clarified. start with that first. MS. MJ: The outer door control pops the outer door. I control the inner door. So the outer door can only be opened by control. MR. —. Okay. So we were talking about like popping the -. It was just your memory was foggy? MS. I don't remember a lot of stuff. But yeah. The outer door, you have to call control to pop the 27 door. And we So let's 199 to the SHU trainings. But not too far from when this happened, you were only on for a little over a year. And you conducted all three of those trainings. Correct? MS. MB: Iwas only on for a little under a year. The training that I received in Georgia is specific to camps and not necessarily high rises. And the in-house training, the roster reflects all these trainings but we didn't’ actually receive all the training because sometimes there was nobody to train us. MR. | pont Okay. MS. : So when I say I don't know, I don't know. WR. QM: «Yeah, no. It’s just almost every question. I feel like we've gone through 18 pages so far and so many of them are MS. | | Because I really -. MR. : == like I don't know. So. : I really don't know. , = Alright. It's just MS. MR. because you know people are going to say like RR ROW OHM fwrKP —— wr RPRRR oN Du MmNmenNrre rmrROow mre re WW = Ww Wey DHfwrP RR eo PRR RRP RRR OOD fwr mre reo MmmenNn Ww Wr control the inner door. MR. Okay. And then just while we’re going back. It’s something I was probably going to follow-up on later. But there's been a ton of questions of like you don't know. MS. : Yes. MR. I just want to remind you - you did go to the Federal Law Enforcement Training Center -- MS. :_ Yes. MR. -- where you were trained as a correctional officer. And you also received this IF training which I think you said was like a two-week in-house training. MS. : Yes. MR. Is that what that was? As well as you received the annual training. And all this stuff that we're talking about isn't like the real detailed stuff. This is like you know conducting counts and rounds. And the essential duties as a correctional officer. So I'm assuming you -. Is it safe to assume that you received this training you know during those trainings? I know you didn’t go 200 well you went to all these trainings. You should know at least some of this stuff. So I just wanted to try to get you to like think back on your training. MS. > Mm-hmm. MR. And your duties and your responsibilities when I’m asking these questions just so you can really like think. Do I really now know or is that you know, did I know that these things should be done. Does that make sense? Correct. And then um -. Can I say -? Yes, please. Just to clarify. I know you might not have received some of the official trainings. Some of this stuff you might learn From your daily duties. Right. : Like it’s repetitive. Some of the stuff that you do. So you might have known this based on the fact that you've done EFTA00117692

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RR rPFCowW OND SwhN re RPRRR Ww = Wh RR SD 18 19 20 21 22 23 24 25 PRR RRR RR NDMP WNPRPOWOHDH SWwNP ae ee od WS Wr rs © Ww oc 201 it on a daily basis. So if you say I don't know and you actually done it as part of your daily duties, it kind of contradicts each other. MS. : I understand. MR. And I just had a question. You mentioned the door. Was at any point in time - on the 9th, 10th or - was there a practice to ever leave the doors propped open in the SHU? MS. :_No. MR. Alright. I think my last question, I just want to revisit it just to make sure that we're of the same understanding. So again when you're pre-populating all of these rounds. Correct? MS. : Correct. MR. But you're saying you believe you did more than 50% of the rounds that were listed. MS. MMM: I can’t give you a percentage - MR. : Sure. MS. : -- because I don't know how to put a percentage to a round. But I can only 203 paper. WR. WE: So aside from eh times you're now giving toilet paper and giving food and collecting trays, which are a handful of those times, granted. :_Mm-hmm. Are you doing any other Yes. And if somebody calls -. On August 9th -- -- we're talking about. On the 9th. If somebody calls and asks for something, yes, I conduct a round. MR. And that’s kind of what I’m getting at. You're - if you're handling one specific inmate, because they called and asked for something. You're then also addressing the other five tiers? MS. Yes. MR. : Okay. MS. Because usually when one calls, everybody else hears and everybody wants something. So I just do it. MR. a. Alright. So on August RR ROW OHMS fwrNP —— wr RPRRR oN Du ee od Wwrerow mr oe RR ae ee RPRRR Ww Wr MRRP RRR Pow OAS Mmmenmrn Ww Wr 202 tell you that I conducted rounds as I went to go do something. But I can’t give you a number. MR. And I want to make sure we understand too, if you're going down range to give some inmate like toilet paper or something, that you're also at that time where you're saying you did a round, not just talking about that tier, but all six tiers. MS. 1 Yes. MR. Alright. So you’re going down to give somebody a toilet paper. At that point -- MS. MBM: Because I’m giving toilet paper to everybody. MR. Alright. just addressing one inmate. MS. :_No. MR. You’re saying when you're giving everybody toilet paper. MS. : Yes. MR. : So on August 9th -. MS. When I’m giving food, I give everybody food. When I’m collecting trays, I’m collecting all the trays. I’m giving toilet 204 So you're not 9th, you didn’t conduct all the documented rounds. MS. :_ No. MR. : But you did do some of them? And you don't have a -- A number. -- half or anything -- . -- like that. Okay. MR. FOY: But I think the clear point is when she did it, it’s not based on the times on the paper. MR. Okay. MR. FOY: Ri ht? So that doesn’t match. WR. MEM: Atright. So -. MR. FOY: The times she did it versus the time on the paper. Because that paper is done at the beginning of the shift. With the time already selected. MR. Oh, are you filling out the entire paper at the beginning of the shift? MS. :_ Yes. MR. ate Oh! So you're not doing EFTA00117693

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RR rPFCowW OND SwhN re RPRRR We Wr RR SD 18 19 20 21 22 23 24 25 RR SwWOHNDN FWwrNP RPRRPR RRR SD SwWwNPe ee ee ed eS WwrN Pr CO wc nm wm 205 it every 30 minutes just prepopulating before you do the round. MR. FOY: Right. MS. : No. MR. You’re going at the very beginning of the shift, filling everything out the -. . : Yes, sir. . : So that -. When did you fill out the August 9th round sheet? MS. WM: Like how the numbers are like the round sheets before, like the times. So I just fill it out because that’s what I've seen being done. Like it's filled out before or sometimes at the end after. So I fill it out all before. WR. QM: Okay. So you prepopulated that entire thing at the very beginning of your shift? M : Yes, MR. And then you just conducted rounds as needed? MS. :_ Yes, MR. people do that? Alright. And you've seen 207 people doing this? MS. Yes. MR. : But no one ever told you to do that? MS. : No. MR. aw. And did you know that it was wrong to do that? MS. : No. MR. : You didn’t know that it was wrong to prepopulate the rounds you conducted when you weren't conducting those rounds? MS. MB: No. I mean if I’m putting the time on there saying that I conducted the round at this time, and I didn’t conduct the round at this time, that’s wrong. But I didn't think it was wrong to fill it out all before or after because that’s how they do it. MR. So that's a contradicting statement. You know that it’s not right to conduct a round at the time that you conducted it, but you didn’t know that it was wrong to (Indiscernible *02:28:16). MR. FOY: She knows that now. the way it was done. But this is RR ROW OHM fwrKP —— wr RPRRR oN Du MmNmenNrre rmrROow mre re WW = Ww Wey DHfwrP RR eo PRR RRP RRR Oo OUD wr mre reo Mmmenmrn Ww Wr 206 Who else have you seen do name, but I’ve seen it done. MR. Did anyone ever tell you to do that? MS. MMM: This is actually I think the first time I’ve ever done the round sheets because I've never actually done the round sheets in the SHU. But those two days were the days that I've done the round sheets in the SHU. WR. QM: So if this was your first time doing a round sheet, did someone instruct you on how to do it? MS. MB: No because I just followed what I seen. But I've worked with people before that was filling it out and that’s how it’s been done. WR. MY: | And did you have discussions with them when you were -? No. I never had a discussion So you just observed 208 WR. | Yeah. MR. FOY: She followed. But like when you look at the policy and now that we're here and we've had discussions. Okay. That’s not how it's supposed to work. MR. But at the time that you're filling this out on August 9th at the beginning of your shift saying that you conducted these rounds at a time that they weren't conducted yet. You had to have known that that wasn't -. Maybe you saw people doing the wrong thing, but you couldn't have possibly thought that that was correct. MS. : Well I-. MR. Because you're falsely certifying that rounds are completed when you didn't. There's times even that they're events in the future. MS. MMM: 1 understand but I didn't know that. I just followed whatever I saw that was being done. WR. ME: 1 absolutely understand the defense that you said other people have done this and you’re following their guidance. But you can't possibly think that it’s okay to EFTA00117694

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rR CSCwWOmOANDMDS fWwNHP RPRRRR We WN Re RRR CoN DD a de ood SWwWNr Ow nm w RR SCwWOnHtDUN SwWwrP 209 fill out certifications saying that you conducted rounds in the future that haven't taken place and that you actually didn’t do at the same time. Is that something being lost in translation? Do you follow what I’m asking you? Do you think it’s okay to sign on the round sheet that you conducted a time -? Conducted a round -? MS. MMM: But it’s the same thing as the end. Like if I do it all at the end at the times that I’m putting, I’m not going to remember all those times specifically. WR. QM: «Absolutely. I would also argue that anytime you’re falsifying a record, you always know that that's wrong. MS. : So. But. I mean. MR. : So I do understand that you're saying other people do it. And that's why I want to get into who else is doing this? Who trained you on that? How do you know that was the way that things were done? So that’s where my question of who talked to you about it. You said no one actually spoke to you about it. But you -- MS. MBB: No. I just seen people do 211 HBB, is that the sos No. A different JM. a gentleman's name? What’s that person's name - first name? MS. : I don't know the first name. MR. : TB who worked in the SHU? Yes. You mentioned [IM before. : in =. Say that again? It's like (Indiscernible *02:32: 40). MR. FOY: It's a first or last name? ? Is the first name PRR RR SwWwKN PCW OHMS SwMN Pe RPRRR oN Du ee od Wr Ow mrNm oe Re CWO HM fWwrNP 210 that. r. a: who did you -- MS. : Because I never had -. MR. : -+ observe do that? MS. : I never had a conversation with about filling out round sheets. MR. a. Right. So if that’s going to be the argument that you're doing it based upon your training and experience, I need to know more about this training and experience. Who is it that you experienced do this in the past? . : People that I’ve worked with. : So I’d like you to think about al right, I know this because I saw that person do it. Who? = MS. Um. . MR. : So you've witnessed prepopulate or at the end of the shift? MS. BM: I don't remember exactly. it’s done either or the way. WR. GM: Alright so you saw and who else? -- observed people. So But . FOY: Oh. : Yes. ? . : Mm-hmm. . : Anyone else aside from ? So in the recoTlections of the three people that you named, what did you observe them do? vS. MM: Fill it out after or fill it out before. MR. WM: | And was that on numerous occasions? MS. : Yes. MR. : Alright. So during your time in the SHU, which I think was from around June 24, 2019 through August 10th, was it on many of those days that you were working in the SHU - this is how it was done? MS. Yes, MR. : Where the rounds weren't conducted and they were prepopulated or EFTA00117695

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RR rPFCowW OND SwhN re RPRRR Ww = Wh RR SD 18 19 20 21 22 23 24 25 RR SwWOHNDN FWwrNP RPRRPR RRR SD SwWwNPe ee ee ed eS WwrN Pr CO wc nm wm populated at the end? MS. + Yes, MR. : And it was never spoken . : No. . | And you never asked? Hey why are we you know certifying that we're conducting rounds that we're not actually conducting? I never asked. MR. : Never asked? MS. : MR. : And they never told you to do that_though? MS. : Who? MR. : No one ever told you that this is the way that it’s done? wS. MMM: 1 mean that’s the way that I've seen them do it. But no one ever -. WR. QM: 9 You observed it. that people did that. MS. WM: Because I never asked so nobody ever told me. But that’s just what I saw. WR. QM: «So on August 9th, you believe that’s the first time you filled the 215 You saw conduct rounds and counts. But if -. WR. WE: | And document it at the time it's been conducted. MS. : And document it. MR. : Right. So it's a cultural - it’s a culture of falsification of records? wS. MMM: In MCC? Yes. Like the lieutenant told me to sign I did SHU training and I didn't. WR. QM: Absolutely. There's a lot of it_yeah. MS. : Yeah. MR. a. So my point being is it sounds like this is a cultural problem. MS. : Yes, MR. : But you have to - as a person who received a college degree. A person that went to you know standard - conducted ethics training. You have to know that -. I understand other people are doing it. And you're saying I'm going to do what they’re doing. But you have to know - you have to question like hey. I didn’t conduct this training. I didn’t conduct those rounds. So RR ROW OHM fwrKP —— wr RPRRR oN Du MmNmenNrre rmrROow mre re WW = Ww RR ae ee PRR RRR Dw wr ed ool mel ro wo Mmmenmrn Ww Wr 214 sheet out. No one actually directed you or instructed you that’s how we do it, you just saw people do it that way? MS. : Right. MR. : Alright. And this goes back to -. I understand - your attorney did say that you know now that it was wrong. MS. : Yeah. MR. : But at the time, you thought it was okay to certify times that you know you conducted rounds when they weren't conducted? MS. J: Because that’s the culture of it there. I didn’t consider it as being like I’m falsifying a time or a document. No I didn't. WR. QM: 9 Is this something that’s addressed in training and policy? Hey when you conduct a round, it’s documented? At the time you conducted it. MS. : No. MR. : So it’s not in the policy that I provided for you? MS. BBB: I don't know if it’s in the policy. But in training, you’re just told to 216 you had to know that you shouldn't have done it. . : But - : "You’ re saying that you're doing it because that’ s how other people are doing it. But you’re all doing it wrong. Correct? MS. MMM: But -. But in a case like this, who am I telling because like -. WR. HM: 1'm not asking you to tell anybody. MS. : No-no-no. When I say telling, I’m like okay. If it's -. Okay. I understand you're saying that I know that it’s wrong. But I’m saying like okay, like how the lieutenant. Like when you said to me, does she know that I didn't do the training? And I said yes she knows that_but_she still told me to sign that. MR. : Absolutely. MS. : So again, I'm not going to think. Like I said, I’m not thinking of this as like I'm falsifying a document. It’s just the culture of MCC and I just followed. I’m new. I don't know. I just lean on the senior officer or the people that I’m working with for EFTA00117696

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RR SwWOHNDN FWwrNP RPRRPR RRR SD SwWwNPe RR ‘© oo - to do what they do. Okay. Or to guide me so to speak. Let’s ask it this way. Did you “know that you were supposed to conduct rounds every 30 minutes? MS. :_ Yes, MR. : Yes. Did you know that those rounds that are supposed to be conducted every 30 minutes are supposed to be documented on that sheet? MS. : Yes. MR. : And they're supposed to be documented on the time that you conducted those rounds? MS. BM: No. it on the time. wR. QM: «I understand that that's why you did it. But do you understand that in training, every 30 minutes and they’re supposed to be not as it’s corrected, they’re not supposed to be on the exact dot 30 minutes. You're supposed to do it within like a 30- to 40-minute window. Correct? So that's not a regular occurrence? 219 mS. MM: I never seen nobody do that that I’ve worked with. So you never saw J do it that way? MS. : See like when -. MR. : And hey -. If everybody's doing it wrong, obviously that's a huge problem. vs. J: I’m not next to them. Like okay, let's say if they're doing the sign-in sheet, I’m not - that’s why. Like how you're saying like if js turning a sign-in sheet, I don't necessarily have to be next to him. I could only tell you the people that I've seen. Do I don't know like I can’t speak for everybody on this -. On there that I see. WR. QM: Right. But what I'm saying is you know that you need to conduct 30- minute rounds. You know those rounds need to be documented. You know those rounds need to be documented on that sheet. MS. + Mm-hmm. MR. : Correct? MS. : Correct. Because nobody documents No, but what I’m saying is like RR ROW OHMS fwrNP —— wr RPRRR oN Du ee od Wwrerow mr oe RR ae ee RPRRR Ww Wr MRRP RRR Pow OAS Mmmenmrn Ww Wr Yes. Irregular rounds. Irregular rounds. Correct. So you know that you’re supposed to do them every 30 to 40 minutes. MS. : Yes. MR. Aas Two rounds and hour. those rounds are supposed to be documented. MS. : MR. MS. MR. : So obviously that leads to the training of they’re supposed to be documented when you conduct the rounds. Correct? And Okay. . So I’m - I do understand that you're doing it because other people that you just mentioned did it that way as well. You have to know that you were supposed to do it the way I just explained. Correct? MS. : I know now. MR. a Well you had to know then too because it's like you're supposed to do a 30-minute round and you’ve got to document when you did the 30-minute round. Correct? 220 WR. QM: 9 Therefore, you knew that what you were doing was false. Correct? MS. MBB: As in putting the time and the time that I conducted the round. And I didn’t do that at that time. See again -- So you knew it -- -- with the time. -- that what you were writing in there wasn’t true and accurate as you wrote it. Correct? MS. : Correct. MR. : And the reason you did it was because the people that you observed in there before did it that way. MS. : Correct. MR. : Is that correct? I think that’s how satisfies us. Any -?> So you knew it was wrong, you knew what you were -- MS. : But -. MR. -- writing was wrong, but you did it because it’s how they did it. MS. BBM: Right. But didn't -. I'm not thinking it’s wrong. Like specific to the times because I've never seen it done every 30 minutes - every 30 minutes - every 30 minutes. EFTA00117697

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RR rPFCowW OND SwhN re RPRRR Ww = Wh RR SD 18 19 20 21 22 23 24 25 RR SwWOHNDN FWwrNP RPRRRR we wre RR SD ae ee od WS Wr rs © Ww oc MR. : Right. MS. : I've never worked -. MR. : So it’s always been falsified. Ever since you've been there, it’s always been falsified record is what you're saying. WS. WM: That - at the times that I’ve worked and the people that I’ve worked with, I’ve never seen it done every 30 minutes like that. No. MR. : Correct. MS. : I’ve never seen it. MR. : So you're trained on conducting 30-minute rounds and documenting when the 30-minutes -. Your experience has taught you that that’s not how they do it there. They always falsify those records and just put in whatever in order to satisfy the 30-minute requirement. MS. : Correct. MR. MR. MR. MR. : You mentioned that was the first time. Those two days were the first time 223 WR. : | Alright. And did you -? MR. FOY: You haven't gotten to this yet. You know, I'm trying to lay back -- WR. a Absolutely. MR. FOY: -- and let you do your thing. WR. GM: «Absolutely. MR. FOY: But at some point you'll learn, she never worked midnight to 8:00 -- Yep. -- a.m. before. Right? And we never -. MR. FOY: And there’s a reason. WR. QM: «And we have that. Do you want to give her a duty roster - her daily assignment -- . FOY: te . FOY: Right. -- roster so that she can . -- where she -? . FOY: So there were events in her personal life. Because she used to do that I come in early to avoid being mandated. MR. a. Sure. MR. FOY: But she couldn't do it that day RR ROW OHMS fwrNP —— wr RPRRR oN Du ee od Wwrerow mr oe RR ae ee RPRRR Ww Wr MRRP RRR Pow OAS mmr =e Wh 25 222 you filled out a round sheet in the SHU. Prior to the SHU, before you got to the SHU, did you fi11 out those round sheets? MS. : Prior to working in the SHU? MR. : in the SHU. Did you fill out MS. MMM: On other units, we don't have um round sheets like this. MR. QR: 0 you have to conduct rounds in the other_units? MS. MBM: Yes. on a round sheet. MR. QM: But this was the first time you would have to? MS. MB: In the SHU it’s documented on the sheet. MR. QM: Alright. So is it the first two times that you can recall documenting? Are we going to find other round sheets that you -? MS. : The first two times that I can recall -- MR. WM: | These were the first two times these two times? MS. MBB: -- that I recall documenting. 224 and got mandated. So now she’s the officer in charge for the first time at midnight with a senior officer, even though he’s really worked there regularly. And he’s not there for guidance so to speak. Sure. And you know. So this one -. This was your daily assignments and I see where it says you're relieved without pay for a great amount of time up until -. It looks like 6/26/2019 you were assigned SHU number three. And then through - what we’re looking at is 8/10, SHU number one. So if you want to reference this on days that_you worked or -- Mm-hmm . -- assignments you were But it's not documented . FOY: Where? UR. a: That's that thing. So I understand what you're saying is that this is your first time and she was the one in charge and she wasn’t having an officer in charge to confer with I guess. MR. FOY: Right. EFTA00117698

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RR ROW OHM SWwrNP RPRRR We Wr RR SD 18 19 20 21 22 23 24 25 RR SwWOHNDN FWwrNP RPRRPR RRR SOW WNP ee ee ed eS WwrN Pr CO wc nm wm 225 WR. QM: | And that’s why I’m getting back to -- MR. FOY: Right. MR. -- the fact that she observed, you know, she knew that what she was writing was false. But she did it because she saw everybody else doing -- MR. FOY: Right. a. -- falsifying records. MR. MR. FOY: So part of it is, right, and you're not wrong when you say, “Well that’s falsification of documents.” And all that. Right. And I can understand and can appreciate how it looks that way. MR. Sure. MR. FOY: Right. And I'm not - we're not disputing that. Okay. But I think there’s also another way. It’s like well it's inaccurate. Right. MR. Mm-hmm . MR. FOY: But that’s not committing a fraud to try to deceive the institution because I just want to collect a paycheck and not do my job. It’s not for those reasons. It’s just because there’s a BOP formal way and there's an 227 WR. QR: «you know and she knew that she was entering the wrong information when she did it. MR. FOY: We don't disagree. MR. : Sure. MR. FOY: She understood I didn’t really do a 6:03 round or whatever. Right? MR. Absolutely. MR. FOY: But I don't know if she experienced that as I'm falsifying records to my job. MS. ME: Mm-hmmn. MR. FOY: Right? 1m, I: Richt. MR. FOY: Which she is in her mind doing is well we're supposed to do rounds. But no one ever really does them every 30 to 40 minutes. But you've got to fill out certain paperwork that's required. So you fill out the paperwork. Now I know from looking at the discovery not every single officer did that. Right? MR. Sure. MR. FOY: I saw in the discovery that there were people who - there would be blanks PRR RR Se ee a RPRRR COND mreNyre rmrROow mrer WW = Ww Wey DHfwrP RR eo PRR RRP RRR OOD fwr mre reo MmmenNn Ww Wr 226 MCC way of doing things that she’s assimilating to that’s not the proper way. That what should happen - a person needs to have the strength to step up and say no and be the -- MR. : Mm-hmm. MR. FOY: -- whistleblower or whatever. She didn’t do that. Right? And I can so appreciate Right. . : And that's why I say this is a cultural, institution problem MR. FOY: Right. MS. > Mm-hmm. MR. : And I agree with that. MR. FOY: an MR And I’m saying this was wrong that she observed this. And those people that were doing that were absolutely wrong. MR. FOY: Right. MR. : All I was trying to get to is that we can all agree that that - you know every 30 minutes is when the round is supposed to be entered in there. MR. FOY: So -. ‘WR. FOY: "R 228 where the rounds should have been. So they accurately reflected I suppose when they did. But I think a lot more common is it’s not that. MR. : Absolutely. MR. FOY: Right? So she followed the strain. WR. ME: Absolutely. MR. FOY: She did not chart her own path which is with - you know, why she’s got to take responsibility for that part. MR. a. And that’s also why we discuss this isn’t all about you. It's about the institution. MR. FOY: Yeah. Understood. MS. + Mm-hmm. MR. And this seems like this is an institutional problem. And that's awful that you're one year on and this is what you've observed -- MR. FOY: Right. MR. : == this entire time. MR. FOY: And I only say that because I feel like - in watching your interaction, you're kind of talking past each other on your focus on if it’s the falsification knowing it’s EFTA00117699

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RR rPFCowW OND SwhN re RPRRR Ww = Wh RR SD 18 19 20 21 22 23 24 25 RR SwWOHNDN FWwrNP RPRRPR RRR SD SwWwNPe ee oe od eS WwrN Pr CO wc nm wm 229 wrong. And she's like, well yeah, but I’m just kind of doing. I’m not trying to commit a crime. Like it wasn’t like - and that’s kind of been my pitch the whole time. She wasn’t out to commit a crime. This isn’t about hiding my behavior because Jeff Epstein died. MR. > Mm-hmm. MR. FOY: Right? It’s all there. Right? Even the theory of the case is when asked what happened. We messed up. Right? That's the like they tell the truth. There's no deceit - deception -- MR. Mm-hmm MR. FOY: -- in frustrating the investigation or the response. Now we're here, we're trying to clear it up. We understand the job that you have. You know address some of the specifics here, but it’s a much broader vision. So we're trying to bring light to that and she’s doing the best she can to do it. I think the issue is we're doing this almost two years later. Right? MR. MR. FOY: MR. : Sure. That's the problem. And -. And the next day might be 231 WR. QM: «Correct. And what about cell counts? And I’m only trying to move past because we have a lot more to get through. MR. FOY: —_Mm-hmm. MR. But if there’s something else we want to address on there. MR. FOY: Yeah. No. We're good. MR. So the cell counts. did you conduct cell counts - sorry, inmate counts during your shift in the SHU on August 9, 2019? MS. & a that’s 9th? MR. : August 9th. So we're talking now the 4:00 p.m. and a 10:00 p.m. MS. : 10:00. MR : Did you conduct those counts? MS. : 10:00. MR. : Just 10:00? Not he 4:00 “WS. : Not at 4:00. MR. | Now you do recall actually conducting the 10:00 as you're supposed to do it? WS. WEB: No because my partner was on a When p.m.? RR ROW OHM fwrKP —— wr RPRRR oN Du MmNmenNrre rmrROow mre re WW = Ww RR ae ee RPRRR Ww Wr MRRP RRR Pow OAS Mmmenmrn Ww Wr a little easier to address. MR. FOY: Right. MR. : So -. And we can jump right into that. MR. FOY: Okay. MR. E So on August 10th, is that also in front of you? I can’t remember at this point what I provided you. The round sheet for August 10th. MR. FOY: The round sheet. MS. : Yeah. MR. = Did you conduct any rounds on August 10th that are -- MS. : No I did not. MR. a -- not -. And did you also prepopulate that? MS. : Yes. MR. a Alright. So you knew everything you wrote in there - again, I understand that you said this is what you observed. No one told you to do it this way because you saw other people doing it this way. But you knew that you didn’t conduct any rounds that you listed on that sheet. MS. Yes. 232 triple. WR. MM: Okay. So he was doing a triple shift? MS. Yes. consecutive shifts. MR. : Okay. MS. : So I conducted the 10:00 by myself. MR. MY: «And you actually went around and counted every inmate? MS. 1 Yes. MR. And we want to show the count slips. ; of it? MR : We'll start I guess with just the August 9th because we don’t want to give her too many stuff. Alright. So what I’m going to show you here is this first page is going to be like the institutional count. And it’s going to show you like ZA. Is ZA correct for the SHU? Do you know that that is what ZA stands for? MS. :_I don't remember. MR. Alright. So ZA is going to be the number that's going to reflect for He worked three EFTA00117700

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RR ROW OHM SWwrNP RPRRR We Wr RR SD 18 19 20 21 22 23 24 25 RR SwWOHNDN FWwrNP RPRRPR RRR SOW WNP ee ee ed eS WwrN Pr CO wc nm wm 233 the SHU. And then I'l] tell you what the total number is in this count. On this page it'll say 75. And it looks like this was beforehand. And then at the end, you're going to see that actual count slips and I’m going to ask you - you know who was on the count slip that you filled out_and who else was on there with you. MS. : Okay. MR. In this instance I believe it’s on the second-to-last page. So that you don't have to flip through all this. But you can let me know if that’s accurate. So sorry. It looks like that one was the 4:00 p.m. and I believe this one is the 10:00 p.m. MS. So let me (Indiscernible *02:47:46). MS. GREGG: You went (Indiscernible *02:47:49) sheet. MR. — This the 10:00 p.m. MS. GREGG: Right? MS. MB: Mn-hnm. MS. GREGG: When you call into the control, this is how they determine that your count matches their learning base count. Right? So ZA is 9 South, ZB is 10 South. wS. QR: Mm-hmm. MS. GREGG: Or should have called in. MS. HB: n-hnm. MS. GREGG: That number is supposed to match ... these are all outcounts. That number is supposed to correspond with these count slips for your respective housing unit. MS. : Okay. MS. GREGG: Right? And then I guess she’s asking you to review your respective -. Tell me if I’m wrong. MR. : Yep. MS. GREGG: Review your respective count slip for your unit on your shift. And then I guess you wanted to confirm signature on the -? MR. Sure. I just wanted to see the second. So one page back, that second- to-last page, can you just find if there’s a count slip that you created or you signed in there? WS. MM: I see here it says -. It has my name on it. And it says 4:00 p.m. count. I don't recall _at 4:00. MR. Does that look like your signature or your handwriting? PRR RR Se ee a RPRRR COND mreNyre rmrROow mrer WW = Ww Wey DHfwrP RR eo PRR RRP RRR OOD fwr mre reo MmmenNn Ww Wr 234 WS. MBB: Okay. MS. GREGG: They match. This is all of our counts. Right. And then what they do is - this is at the handwritten outcount from employee. This is what they (Indiscernible *02:48:16) entry. MS. Mm-hmm . MS. GREGG: This is what's keeping this entry and it reflects on here. These are the outcount areas an inmate could be. Right? So 5 South's count was 75. Their unit count is 78, three people were in food service. MS. Okay. MS. GREGG: So when they actually counted living, breathing bodies, they only had 75. WS. MBB: Right. MS. GREGG: So now just apply that to SHU. This is your SHU count. You had a one inmate outcounted to attorney conference. MS. MBB: Okay. MS. GREGG: Right? So you come down here's one. So the actual count - the total count that’s supposed to be there is this number. This is the inmate outcounted. this is what whoever counted called in. And 236 . BB: where the MM is - no. . : How about your signature? . : The signature looks like my signature. But where the is -no. But I don't recall doing. I may have done the 4:00. I don't recall. But I know I did 10:00. WR. MM: Alright. So you don't recall if you did the 4:00 p.m. or not? MS. Z I don't recall. MR. : You can only recall doing the 10:00. And is that because you said you did it by yourself? MS. : Self. Yes. MR. ae Do you believe you did .m.? . : I don't remember. You don't recall. Alright. What is the n there? On that count? MS. : 75. MR. | And that is your actual signature? MS. :_ Yes. MR. | Alright. And it says 75? EFTA00117701

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RR ROW OHM SWwrNP RPRRR Ww = Wh RR SD 18 19 20 21 22 23 24 25 PRR RRR RR NDMP WNPRPOWOHDH SWwNP ae ee od WS Wr rs © Ww oc 237 MR. : Okay. What is there on the first page. what does it say that the number is? And that’s the count for the SHU. MS. : 75. MR. signature. 4:00 p.m. MS. : I don't recall. MR. Alright. And I’m sure that in preparation for this did you discuss at all or review or kind of - you know at two years now, did I do that 4:00 p.m. count or not? No? MS. :_No. MR. Okay. who called in that number? : No. 75. Okay. So your You're claiming you can’t recall Do you remember No. Alright. That's ow the 10:00 p.m. count is next to you. MR. FOY: Right here. MR. Can you do the same thing? Go to that last page. it could potentially be on the last page or potentially the second-to-last. You're going to look for 239 out? I know it’s your signature. But you said it didn’t look like your handwriting. But for the 4:00 p.m. now we're talking about. I’m just reverting back. Do you know who actually completed that count slip? MS. BEB: The count slip? Who filled it out? I don't recall. on that were on it? WS. WEB: Just me and MM that’s on there. WR. QR: | And this didn’t look Tike your handwriting? WS. HB: For the I - no. signature. WR. QM: Right. For the - and I think you're looking at the 10:00 right now. I’m just reverting back to the 4:00. That doesn’t look like your handwriting as far as counting out? It just looks like your signature on it? MS. : MR. And you simply just don't recall if you did or did not do that count? MS. I don't remember. No? But it was you and For the Yes. RR ROW OHMS fwrNP —— wr RPRRR oN Du ee od Wwrerow mr oe RR ae ee RR i) MRRP RRR RRR POoOwCmBADH ew anything you recall, you signed, or you documented. MR. FOY: Look at (Indiscernible a MS. : Here. MR. : Okay. Is there somewhere that you signed you signed on that? f Yes. On the bottom. : And who was - and I do MS. MR. apologize. Let me before I even go to that. Who else was on the count slip with you on the 4:00 p.m.? MS. : . MR. | * HM? Alright. So he signed that one? Or you? MS. : According to the sheet. MR. Do you know if they were prepopulated? The 4:00 p.m. is that also how you did the rounds? Did you also prepopulate the count slips? MS. MB: On the midnight to 8:00. But not on -. MR. : Not that one? MS. : No, not on this one. MR. : Do you know who filled it 240 WR. QM: Alright. The 10:00 p.m. now we’re looking at. Who was on that with . ve and . : And who - can you tell by looking at_the handwriting who filled that out? MS. MBB: I don't remember. But I signed. And I know -. MR. Does that look like your handwriting that filled it out? Can you tell? MS. : No. MR. : You're not able to identify your handwriting? MS. No. I’m saying this doesn’t look like my handwriting. But that’s my signature. MR. QM: | 0h that’s your signature. But it doesn’t look like you actually completed the slip. I’m asking did you complete that slip? MS. MM: Yeah. I don't -. And this is right here. The 73, I wrote that. But 10:00, I don't write my numbers like this. MR. acl Okay. MS. : So. Yeah. I don't put the EFTA00117702

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rR CSCwWOmOANDMDS fWwNHP RPRRRR We WN Re RPRRR Oona MmMNrnNrnrry WN r Oo nm w RR SCwWOnHtDUN SwWwrP 241 zero-zero in a cross. So I don't. MR. Is that the (Indiscernible *02:53:11)2___ MR. : Is there anything next to 73 on that? I put plus one. What is that for? I don't remember. . You don't know why you put 73 plus one? MS. :_I don't remember. MR. Is that abnormal to write 73 plus one? MS. MBM: =I don't even know they there's a plus one on there. MR. But you wrote 73 and somebody else may have put the plus one? MS. MBM: I don't remember. But the 73 is mine. MR. Okay. what plus one would mean? MS. :_No. MR. Alright. And then what is the first page say - that the institution counts were then for ZA? And you don't know 243 WR. QR: Alright. But not with another (0. MS. :_No. MR. : And who was the CO that was supposed to have done it with you? MS. MR | at WE cid sign it even thou h he didn’t? MS. : Yes, MR. ae And did you have any discussions with him at that time? MS. He was tired. He was on a triple. wR. QM: Okay. And what did he MS. MR. He was tired. Did he leave then? Or did he just stand it? MS. He was asleep. MR. He slept? Alright. So he was sleeping when that was conducted? MS. : Yes. MR. A Okay. Do you know how : No. PRR RR SwWwKN PCW OHMS SwMN Pe RPRRR COND ee od Wr Ow mrNm oe Re CWO HM fWwrNP 242 MS. : 73. MR. | 73? Alright. So again, that plus one you’re not sure. MS. : No. MR. And now can you just explain to me -. You said you do specifically recall conducting that count? MS. : 10:00 yes. MR. And you actually went through and counted all of the inmates? MS. Every inmate. MR. On ever tier? MS. MR. count slip? MS. =. No. That was for the midnight to 8:00 in the morning. Alright. : We filled it out before. So 10:00 p.m. wasn't But it was a prepopulated prepopulated? MS. : No. MR. conducted the count? mS. BBB: Yes. You did that after you 244 long he slept for? MS. : Until it was time for him to go home. MR. : So like 10:00 to 12:00? MS. : Approximately. MR. : Okay. But you're certain you conducted that count? MS. : Absolutely. MR. Okay. And are you confident_that that number is correct? MS. What the 73? MR. Yep. MS. MR. Alright. Now let's show the 12:00.a.m. Does this go there? MR. MM: It’s (Indiscernible *02:55:07) MR. MM: Alright. So before we -. I guess first, can you go to the back of the thing and see the counts? Find the count slip? Can you find if -. Are you on there? : Check the last page. :_ Yes. And is this the one you said you prepopulated? EFTA00117703

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rR CWO D SWwrNP RPRRRR We WN Re RRR CoN DD a de ood SWwWNr Ow nm w RR SCwWOnHtDUN SwWwrP 245 Yes. Okay. And did you fil] that count slip out? did? And you signed it? So BEM is the one that We filled all of them prepopulated it? WS. WEBB: Yeah. out. WR. QM: «0h you filled out all but three? wS. BBM: Yeah. All. WR. QM: Alright. So the 12 and the 3 and the 5, you did it all at once? MS. :_ Yes, MR. : Alright. number is written on there? : 73. he. Now look at that first What pee is written on there? “Ss. HE: 7 . | | I don't know. . : Do you remember any inmate being removed from the SHU after 10:00 p.m.? MS. : No. MR. a. Alright. Can you show her this count? Here’s the 3:00 a.m. count. Can you see that top sheet right there? Can you find ZA? How many - what number is it on that? MS. : 72. MR. : Alright. So 72 again on that. That’s the institution count. That's how many people are actually in the SHU. What does it say on the count slip? MS. : 72. MR. a 72. So what happened between 10:00 and 3:00? MS. WM: Why the numbers are -? I don't know. WR. QR: «Why are the number different? MS. WB: I don’t remember. MS. GREGG: Let me see this again? wS. WEB: Yeah. He wrote and I signed. And then what page. PRR RR SwWwKN PCW OHMS SwMN Pe RPRRR oN Du ee od Wr Ow mre oe Re CWO HM fWwrNP MR. GM: | Alright. So what happened with that? MS. :_ I don't remember. MR. : At what point did an inmate disappear? MS. : I don't remember. MR. MM: 1f you called in 73, did you actually count 73 people? MS. : Well we didn’t count at 12:00. MR. : I know but at 10:00 you did you said. MS. : Did. Yes. MR. : So at 10:00 you did. But there's only 72 people there at 10:00. So did you actually do the count at 10:00? Did you call - did you actually count the inmates? MS. : I actually counted all the inmates at 10:00. Absolutely counted all. MR. QM: «And you counted at 73 of MS. MMM: 1 actually counted all the inmates at 10:00. MR. MM: | So where did the one inmate go? I called in 73. them. 248 MS. GREGG: It's in the (Indiscernible maybe you did a round at 10:00. Are you sure you did a count at -? MS. : No. I did a count at 10:00. MR. : You counted all the inmates and it added up to 73. MS. MMM: Because that’s what on the -. I wrote 73. WR. MM: Right. And then if you notice you wrote 73 again at 12:00. That wrote it at -- But there's actually 72. -- 12:00 and then on the front it says 72. But then the count -. But then if the numbers didn’t match, the count wouldn't have cleared. MR. MY: And that’s what I'm going to ask you. Did you have any conversations? MS. : I-. MR. : So here’s the 5:00 a.m. and this one also says 72 for the official count. And I believe you guys wrote 72. So did you discuss this with anybody that the EFTA00117704

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RR ROW OHM SWwrNP RPRRR Ww = Wh RR SD 18 19 20 21 22 23 24 25 PRR RRR RR NDMP WNPRPOWOHDH SWwNP ae ee od WS Wr rs © Ww oc counts were off? MS. : Uh, no. I think discussed. was on the phone with -. Because the count wouldn't have cleared if it said 72 and 73. So think QM had a conversation. But I didn’t have a conversation with anybody. MR. oar you have a conversation with with regard to the count being off? MS. Z No. MR. : So if you did all the prepopulating at 12:00, why does the 12:00 say 73 and the other two say 72 and 72? wS. WM: Because on the -. I remember at the other one, had the count slips all and I couldn't find - I couldn’t find the count slip. And I remember I rewrote it. But as far as why the count changed to 72, I don't remember why. MR. a. Well I can tell you why. Because the count was off. MS. : Mm. MR. : So that's what I'm asking. If you actually did that 10:00 p.m. 251 through and you -. Tell me how a count works. Do you add them up? wS. WBBM: Yes. Like I write it. Like K Tier. And then I write it. L Tier and then I write it. And then we add it up. WR. QM: «Alright. Do you want to follow-up with that at all? WR. QB: © Do you recall that night that during your evening shift? MS. + Mm-hmm. MR. : So let's say from when you came on from 4:00 p.m. Or did you come on at 2:00 p.m.? What you said. MS. : 4:00. MR. : 4:00 to midnight. any inmates removed from the SHU? MS. :_ When I came on? MR. : Yeah. MS. : Not that I know of. MR. : If there were inmates removed from the SHU, would you have been aware of it? MS. : I mean if I was there. Yes. MR. : Do you recall -? And so you don't -. Do you recall two inmates -? MS. BEB: Going to suicide watch. Were there Yes. RR ROW OHMS fwrNP —— wr RPRRR oN Du ee od Wwrerow mr oe RR ae ee RR i) MRRP RRR RRR POoOwCmBADH ew Mmmenmrn Ww Wr count, how did you get 73? MS. :__I don't know. MR. : But you're sure you counted 73? MS. : I absolutely counted at 10:00. MR. | = But no inmates left after . No. I mean, I remember I counted by myself. And I (Indiscernible *02:59:23) counted with somebody and we compared the numbers. But I counted at 10:00. MR. QM: | Could have you been mistaken during your count? MS. : Probably. MR. : Do you believe that you were probably mistaken? MS. f Probably. MR. : Okay. you conducted the count. MS. : Yes. MR. : But you think you probably just counted wrong? MS. : Wrong. Maybe. after. MR. a. Okay. 252 Do you recall about that? So you're certain Because it’s 72 And you went What happened with that? .... I'm not really sure because I renienber HE told me. But I remember the two inmates didn’t go to suicide watch but I don't recall as far as (Indiscernible *03:00:58). MR. MM: Did that happen during your shift? Or did it happen before your shift? MS. : During. MR. : During your shift. after the 4:00 p.m. count? MS. MMM: I don’t -. I think if I would have been after 4:00 p.m. because I came in at . : Okay. : If you look at the numbers on the 4: 00 p.m. count, does it - is it correct? MS. | | (Indiscernible *03:01:12) MR. : It says 75. MR. FOY: I don't think that’s 4:00 p.m. No. It’s at the bottom of page Was that EFTA00117705

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rR CSCwWOmOANDMDS fWwNHP RPRRRR We WN Re RR SD ee ee od Se wWwNr Ow CO nm w RR SwWOHNDN FWwrNP PRR RP RRP RR COND WMH ae od rr It's just -. Look at the time on the : You’l] be able to figure . : It says 75. MR. : And then two people went to suicide watch. Correct? MS. : Correct. MR. Alright. left the SHU. Correct? MS. :_No. MR. So that’s what we're saying. Somewhere between 4:00 p.m. and 3:00 a.m., either an inmate went missing or the counts weren't conducted or they were off. MS. :_ The counts was off. MR. They were off. But if your job was actually to count the inmates, how were they off? Usually what you're saying is you're just taking the number. You're prepopulating this a lot of times saying what But no one else MS. : That I counted? MR. : Yep. MS. : . MR. : Okay. MS. : But the number could have been But_I counted. MR. _ Okay. And that’s why -. MS. : Because if I was counting with somebody. If I would have said 73, he would have counted and he would have got 72. That's why you’ve got to count with two people. MR. : Sure. And at the 12:00 a.m. you said you remember [I speaking to someone - . : Qn the phone. . -- but you don't know off. 0 . : No. : And did you have any at that time? Except for he changed the and I signed. conversations with MS. BBM: No. count sli MR. : slip? MS. WM: The one that has 72 on there. He changed which count =— ROW OHMS fwrNP —— wr RPRRR oN Du ee od Wr Ow mre oe RR ae ee RR i) MRRP RRR RRR POoOwCmBADH ew 254 number you believe it’s supposed to be in there. But if you actually conducted the counts, you would actually know that there was only 72. Correct? MS. | | I counted. MR. : But you couldn’t have counted 73 because - MS. MM: Well I maybe -. That's what I’m saying. Maybe there’s where the error is. But I counted. MS. GREGG: No. See at 4:00 count. MR. You counted but you counted wrong. Is -. MS. : Yes, that’s what I'm saying. Because I absolutely counted. Because I remember was tired. He was ona triple and he was falling asleep. MR. Again, and I'm not saying you didn’t conduct a round -- MS. And then I went. MR. -- I'm asking if you conducted a count. MS. :__And I went and I counted. MR. Okay. And you're positive of that? 256 MR. QM: So he changed the 3:00 a.m. and the 5:00 a.m. at that time? MS. He changed one of the count slips and then I was looking of for the other one and I couldn't find it. And then I did -. I remember. I filled out one. MR. But if you -. So you're saying -. I thought you said at 12:00 a.m. you prepopulated all the count slips. . We did. So - but the 12:00 a.m. Yes. And the 3:00 and the 5:00 . : Right. So is the 72 that was submitted and then he talked to you and then -? MS. MMM: Well I believe that because then it would have been - when it got submitted it would have been that the count wouldn’t have cleared. It would have been off. So then it would have been (Indiscernible *03:03:45). It would have been had to have been changed. MR. Okay. The count slip EFTA00117706

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rR CSCwWOmOANDMDS fWwNHP RPRRRR We WN Re RR SD ee ee od Se wWwNr Ow CO nm w RR SwWOHNDN FWwrNP PRR RP RRP RR COND WMH ae od rr And would have had to have changed is what you're MR. Peer . If a count is off, like MR. MR. In this case do you MR. : No. MS. No? MR. Do you remember redoing 257 saying. MS. :_ Yes, : Is that the time -? MS. : If the count doesn’t match what's on here, then it would have had to have it was -. MS. :Mm-hmm. : What happens? MS. : You redo the count slip. redo the count. recall them telling you to redo the count? MS. :_No. And did J say that hey I just spoke to the lieutenant and they said to redo the count? MR. MS. that slip that says 73 whereas the institution count says 72? 259 ee You don't know. And when did sign that? Would it have been before he went to sleep? MS. :_ Yes. MR. before 10:00? MS. WEB: I don't remember the exact timeframe. WR. QM: «when you wrote that count slip, was the time accurate to when you conducted the count? MS. MMM: Yeah because you count at 10:00. wR. QM: Okay. So the time that - is there a time reflected on -- MS. But -. MR. -- the actual count slip? MS. It says 10:00. MR. Alright. So if around that time, he would have just signed it and you went up. :_ And I went up. : And you actually did the MS. MR. Not a round. But you did a count. wS. WEB: 1 counted. Would it have been much Yes, count. =— ROW OHMS fwrNP —— wr RPRRR oN Du ee od Wr Ow mre oe RR ae ee RR i) MRRP RRR RRR POoOwCmBADH ew Mmmenmrn Ww Wr 258 . : Let me see. MR : Because I just want to make sure because the video shows that no counts were done at 10:00. I mean unless you're just -. MS. I saw that also in the indictment. But I did count at 10:00. MR. And this is again part of that whole under oath thing because there was only 72 people on there. So if you're saying you did the count, I just want to reconcile that now before we have a potential problem in the future. WR. ME: So MM never assisted you with the 10:00 p.m. count right? MS. : No. MR. : So you wrote 73 plus one. I wrote 73. So you don't recall the plus MS. MB: The plus one, no I don't recall that. MR. QM: Does that look like your handwriting? The plus one? MR. I don't know. 260 WR. QM: Okay. And you just have no explanation for why the count is off? MS. You can miscount. So I'm not saying that the number couldn't have been off. But as far as the count, like I counted. It could have been a miscount but I counted. MR. Alright. I've got a follow- up. Do you recall an inmate being moved to dry cell that night? MS. : Dry cell. No. MR. FOY: Do you know what that is? MS. BBM: Yes. MR. FOY: Okay. MR. Do you remember an inmate named Fernandez? MS. :_ No MR. your shift. MS. : No. I don't -. MR. If an inmate was moved to another cell. Let’s just say dry cell. Where is dry cell located? MS. :_ I don't know. MR. Is it in - you know where R&D You don't recall. During The inmate wasn’t moved? is? EFTA00117707

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RR ROW OHM SWwrNP RPRRR Ww = Wh RR SD 18 19 20 21 22 23 24 25 PRR RRR RR NDMP WNPRPOWOHDH SWwNP ae ee od WS Wr rs © Ww oc MS. : Yes. MR. Is it in R&D? MS. :_ I don't know. MR. Have you -? Okay. If an inmate was moved to R&D, would you still include the inmate as part of your count? MS. WEBB: If the inmate was moved, I would think they’d be on the outcount. I’m not sure. WR. WE: © But you wouldn't include because you can't see the inmate. MS. MBB: Right. They’d be on the outcount. WR. WM: Yeah. You only count the people that are Physically present. MR. Present. MR. : Right. And that’s what number goes on that count slip. MS. : Count slip. MR. Right. MR. Do you recall any instances of why anyone would write plus one? What was that plus one? We've been trying to figure out what the plus one is. MS. : Plus one. I don't know. 263 you prepopulated that? And then counted? MS. = I could have been. I don't remember. MR. So you may have written the slip first and then counted? MS. :_ I don't remember at this point. MR. Okay. But at the 12:00 a.m. count when you guys were told this count is off, you didn't then go as you should have recount. MS. : No. MR. And you do understand that if a count's off you're supposed to do a recount? Correct? MS. : Recount. MR. : Alright. So the 12:00 a.m. there’s not dispute. The 12:00 a.m., the 3:00 a.m., and the 5:00 a.m. you guys didn’t do it. . : Correct. : And you both signed those slips knowing that the counts weren’t done. 10:00 you're claiming that you did. You don't know when you filled out the slip and you don't know why it’s inaccurate. RR ROW OHMS fwrNP —— wr RPRRR oN Du ee od Wwrerow mr oe RR ae ee RR i) MRRP RRR RRR POoOwCmBADH ew 262 I’m more concerned Now MR. Yeah. with the 73 when there was only 72 people. I’m not going to doubt that you counted at jeast one tier. You counted all six tiers? MS. : Yes. MR. : And you added those up and it equaled 73? MS. : That’s what I have on here. MR. : Do you remember? I mean I know you have that on there. But that’s what I’m saying. That’s inaccurate. So I'm trying to - MS. | | But I don't -. MR. : I'm trying to reconcile MS. MM: But see I don't remember that at this point. Like I mean I wrote 73. I counted. I remember [MM having a conversation. the number was switched to 72 but I don't remember like physically like adding it up like I don't remember that. And again, maybe I miscounted because I counted by myself. This was before. But at 12:00 - MR. And being that [I signed before you did the count, do you think 264 MS. : Right. MR. | And the 4:00 p.m. you’re just saying you don't remember. MS. : The 4:00 yes. MS. GREGG: Can I see the 10:00? MR. So you don't remember if it was conducted or if it wasn’t conducted. MS. MM: Well the 4:00 would have been conducted because we feed at that time. MR. Well that’s not a count though. Again, I’m talking -. I don't want to . : Like a-. . : I want to make sure that Right but I don't remenber physically at 4:00 counting. remember. MR. WM: Okay. So you don't recall counting. You know that you did people at 4:00. . : Right. . : So that would be what you call a round. vs. Ha: that. I don't Right EFTA00117708

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RR rPFCowW OND SwhN re RPRRR Ww = Wh RR SD 18 19 20 21 22 23 24 25 RR SwWOHNDN FWwrNP RPRRPR RRR SD SwWwNPe ee ee ed eS WwrN Pr CO wc nm wm 265 WR. GM: | What you classify your understanding of a round. But the count. MS. : Right. I don't recall. MR. : You don't recall conducting the 4:00 p.m.? . : No. I counted -. MR : Do you believe that you did conduct_a count at 4:00 p.m.? I don't know. So you just can’t recall. I don't remember. > Okay. I counted at 3:00 and 5:00 upstairs. MS. GREGG: That’s incorrect at 10:00. In 10 South? Yes. : Alright. Right? So this -. MR. So you - is it safe to say that you did the feed, which you classified as a round but you didn’t count at 4:00 p.m.? MS. :_I don't know. MR. You don't know. Okay. We're going to just move on. 267 recorder is back on. It is currently 1:46 p.m. This is Senior Special Agent . I’m just reminding you Ms. you are under oath and this is a voluntary interview. Thank you again for your cooperation. So when we took a break, is there anything that you wanted to add from the last thing we were talking about? The difference between the 4:00, the 10:00, and the 12:00, and the different numbers. MS. MM: On the plus one. I don't know where the plus one came from. I absolutely counted at 10:00. I don't know why is there a plus one. And then when the number changed, like there’s something that's sometimes it’s called like a ghost count. I don't know. I don't remember if that’s what happened. So whereas, control will call you and say, put it as a ghost count. So the inmate is not physically there but they know there the inmate is. Because they didn’t redo the count sheet. So that’s the only thing I can think of - the ghost count. MR. I could think it may be a ghost count for the plus one. But if you're RR ROW OHM fwrKP —— wr RPRRR oN Du MmNmenNrre rmrROow mre re WW = Ww RR ae ee PRR RRR Dw wr ed ool mel ro wo Mmmenmrn Ww Wr 266 MR. FOY: Let me do this real quick. I just want to try to clarify this. Let me because this is something we haven’t discussed in advance. WR. QM: «Of course. MR. FOY: Because I didn’t know there was an off on the number. MS. MMM: 1 didn’t even remember that. MR. FOY: Alright. So we can take this out with us and speak on it real quick? a a MR. FOY: Or you want to keep it in here? MR. | How about we leave and let you discuss it in here? MR. FOY: Okay. That’s fine. MR. Does that work? MR. FOY: That’s fine. MR. Just because I don't really want to have documents removed. MR. FOY: Yeah-yeah, okay. MR. Alright. So it’s 1:38 .m. This is Senior Special Agent and I am pausing the recording. (Whereupon, the above-entitled matter went off the record and went back on the record.] The 268 writing the numbers and it’s supposed to be -. I mean when you're -. MS. : No. I’m talking about for the 73 and then how it changed to 72. As far as the plus one, I don't know about the plus one. I’m talking about the 73. MR. a. But when you do a count, that you list on it, isn’t it the physical inmates that are there? MS. :_ Yes. MR. You can’t ever say that - you can’t list somebody that is not there on that count. Correct? : Correct. Right. So you see? : No but what I'm saying. Okay. Like I’m like I said, I really don't remember, but let's say if I counted 72. And they said ghost count John. And I put 73. As far as the plus one, I don't know. And I put 73 because they know where the inmate is. And then after for the next count they fixed the roster. Because that’s why it's called a ghost count because they didn’t move to where the person is supposed to be. And then they fix it on the Yeah. EFTA00117709

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RR rPFCowW OND SwhN re RPRRR Ww = Wh RR SD 18 19 20 21 22 23 24 25 RR SwWOHNDN FWwrNP RPRRRR we wre RR SD ae ee od WS Wr rs © Ww oc 269 next one. That could have been how the count went down in 72. But as far as the plus one, I don't know where the plus one went. MR. Alright. So who was in the SHU at 10:00 p.m. when you conduct this count? wS. WM: Me and . MR. : Just the two of you? MS. : MR. : He's sleeping. MS. MR. : What conversations did you have with anybody about that count? MS. WBBM: That's what I'm saying. I don't recall. That’s the only thing that could have happened. But I don't recall. MR. But if they told you to do that at 10:00 p.m. as you just noticed, at 12:00 a.m., the count - that’s when they catch that the counts are wrong. MS. : Right. MR. So if I told you that - MS. : Well not at that time at the 12 time. I’m saying like when it changed from - I’m not looking at the time but when it changed 271 WR. QR: «Correct. MR. FOY: Right, so the control and her slip matches. MR. the number -- MR. FOY: Right. WR. ee -- and right. So she’s calling in because somewhere before 10:00 p.m., an inmate wasn't removed from the list. MR. FOY: Right. a: present in the SHU. count -- Right. So she calls in Although they were not So if they’re doing a WR. QM: -- that's where it's supposed to say that’s the actual number that’s in here. FOY: Right. ~ And at that point, MR. MR. contro] would say we have 73. Where is the problem here? But she called in 73 -. MR. FOY: ane MR. Or yeah instead of the 72. MR. FOY: Right. RR ROW OHMS fwrNP —— wr RPRRR oN Du ee od Wwrerow mr oe RR ae ee RPRRR Ww Wr RRR oo 270 from the 72 to the 72 at that time. MR. : Right. So no inmate was removed from the SHU after 10:00 p.m.? MS. : No. MR. There’s only 72 inmates in the SHU at 10:00 p.m. MS. I don't - as far as the numbers go, I don't remember accurately the numbers, but no inmate moved. MR. Right. MS. : There was no movement. MR. And that's just where we're just trying to get to this. If you're swearing up and down, you know under oath, I conducted this count. MS. : I did. MR. But there’s only 72 people there. At 12:00 a.m., that’s when the lieutenant catches. Hey guys, there's only 72 people in there. You've got to redo this count and give me a new count slip. When did - when did this happen? MR. FOY: Let me just say something on here it says that at 10:00. I’m looking at the 10:00 that it was 73 on the outside. 272 MR. QM: So you're right. The master list is off but so is the count slip. The count slip is provided first. MS. GREGG: But they’re not off, right? Technically, at 10:00, the master list is that front page. MR. The master list is wrong. MS. GREGG: It said 73. MR. : Correct. MS. GREGG: So there may be something you know that_we don't. MR. Oh we've already talked to hundreds of people about this. MS. GREGG: I'm sure. MR. So that’s where - I mean not hundreds - by you know what I mean. MS. GREGG: A few people. MR. A lot of people. So this is where we're just asking the only person that was there that was actually. You know the other guy was sleeping. There's only one person physically present in there. MS. GREGG: _Mm-hmm. MR. And that was you Ms. EFTA00117710

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RR ROW OHM SWwrNP RPRRR We Wr RR SD 18 19 20 21 22 23 24 25 RR SwWOHNDN FWwrNP RPRRPR RRR SOW WNP ee ee ed eS WwrN Pr CO wc nm wm So that’s why we're asking you. Everyone else clear as day says well it just shows - it’s just proof that the count wasn’t conducted. That’s what everybody else says all the way up to the highest of levels. So that’s why if you're saying that the count_was conducted, you’re just saying -- MS. :_ I did do the count. -- you just counted . HB: I did do the count. MS. GREGG: So I get -. And I'm asking this because I think if we're confused, Ms. is - might be confused. Correct me if I’m wrong. MS. MMM: Right. Like because I didn’t even =. MS. GREGG: If she - if the employee - let's use a simple number for the sake of it. Right. I’m an employee. I count 4 living breathing bodies on Unit A. MR. > Mm-hmm. MS. GREGG: And then I call you who is located eight floors downstairs and I say I 275 saying. WR. MN: So that's why I’m asking. It's hard for me to get past this question if you're saying yes I counted 73 -- MS. : I did. MR. ar -- bodies when there were only 72 bodies in there. MS. MM: No. I absolutely counted. As far as the number, like I said, in remembering how much bodies I counted, but I counted. So you counted, you just The count may have been off. : You didn't maybe have the numbers up? MS. : Right or it was -. MR. : And that’s why I wanted to make sure the difference between a round and a count. MS. No. I counted. MR. : You counted but -? MS And the reason why that always stood out to me because I remember he was on a triple and he said he was tired. And I counted. RR ROW OHM fwrKP —— wr RPRRR oN Du MmNmenNrre rmrROow mre re WW = Ww Wey DHfwrP RR eo PRR RRP RRR OOD fwr mre reo MmmenNn Ww Wr 274 have four bodies on Unit A and you say to me, Ms. Gregg, that’s a good count. Right? MR. Mm-hmm . MS. GREGG: That's what these documents imply took place. Because the front page is prepared by a completely different person in a completely different area. MR. a. Exactly. So what these documents actually imply is that the institution count showed that there were 73 people in there. MS. GREGG: Yes. MR. There were only 72 people in there. So what they imply is that the count wasn't conducted. Because there were only 72 people in there and it was just based on the number that should have been based upon the system. The system showed there were 73, so they wrote 73 on the slip. That's what the documentation implies. MS. GREGG: I get that (Indiscernible *03:16:28) wrong. MR. 72 people in there. MS. GREGG: Now I understand what you’re 276 WR. QM: «So just give me a little more information on what you're just saying. You know you counted but what? MS. No. I’m saying I know I absolutely counted. And that always stood out to me because I remember he was on a triple and he was tired. However, there were only . : Sure. . : And I counted by myself which I’m not supposed to. So I remember that. But as far as the numbers go, I don't remember this because I didn’t even remember something about a plus one until I seen the count slip. Like I don't recall nothing about a plus one. MR. Right. MS. : So as far as the numbers, I'm not sure. But as far as counting, I absolutely counted. MR. MM: | Are you sure you counted MS. MM: That’s what I’m saying. As far as the numbers go, I don't remember. But I counted. MR. Let’s see. You counted what? So I mean what did you do with the 73? EFTA00117711

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RR rPFCowW OND SwhN re RPRRR Ww = Wh RR SD 18 19 20 21 22 23 24 25 RR SwWOHNDN FWwrNP RPRRRR we wre RR SD ae ee od WS Wr rs © Ww oc 277 numbers that you counted? MS. MBB: what I'm saying is, the count could have been off. But I'm just letting you know that I actually did count. As far as the actual number, that’s where the discrepancy -- MR. > So -- MS. : == comes in. MR. : So did you count and then look at the - what the system showed was in there. And you just decided -- MS. : I didn’t -. MR. : -- to put what the system showed? WS. MM: Because I don’t know how to look for that. You don't even know how m &f system. No. WR. QM: «So where would you -? If you're prepopulating things, where do you get the numbers from in order to -? MS. MB: When you come in, the person that you’re relieving will be like I got 72 or I got 75. 279 wS. MM: Yes. I counted each tier. I don't know if I added them up. But usually when I’m counting, that’s what I do. I write it down, K Tier with the number, L Tier I put the number, and I add them up. MR. : Okay. MS. : But if I miscounted, remember I counted by myself. So if I miscounted, I would have called control and I would have said 73. They would have been like no, your count is wrong. . : Well that’s the -. . : But on -. : It's weird that your miscount just happened to show what the system said that was what the system thought was in there. . : But at - : That’ s where I’m having difficulty because it’s like the system says 73. So if you miscounted 73, and the system said 73, but there’s only 72, how are you saying you actually counted? Bu there at 10:00, it’s 73 on here nd it's 73 on here. Look for the count in the Re CSCwWOHUMDMS fwrP ed ae ee ol od oo od ee ee AWN OWSOAUDH EWN RR ae ee RPRRR Ww Wr MRRP RRR Pow OAS Mmmenmrn Ww Wr 278 MR. QE: So someone who you relieved would have told you that there were 73? MS. : Correct. MR. : Alright. And do you know who would have told you that there were 73? e I don't know. : Would it have been — before he fell asleep? I don't remember. WR : Alright. So again, just help me try to understand if there’s only 72 people in there, how you wrote 73 if you counted? MS. MBM: Again, that’s what I’m saying. I could have miscounted. I don't remember what happened. As far as the actual number of the count. I can only just tell you that I counted. As far as the numbers go, I don't remember. . a: each tier. MS. 1 Yes. MR. : And then you added each of those counts up? 280 WR. QM: Correct. Because that’s the - the institution count it off. MS. : Right but at -. MR. : So-. MS. : So - but I’m confused because at 10 it says it’s 73. MR. FOY: But they're saying this is wrong. This paper is wrong. MR. =. And it was caught at midnight. MS. MMB: Okay. But this is -. then I don't know. I don't know. MR. QM: Do we want to continue on this or keep going? MR. :_ Oh keep going. MR. : Alright. So prior to 6:33 a.m. on August 10, 2019, when was the last time that you conducted a round within the SHU? Now we're talking about a round. MS. MB: I don't remember the time, but I didn’t conduct no round between 12:00 and the 12:00 to 8:00 shift. WR. WM: So this - what we're talking about - what you’re calling a count that you're saying would then that the last Right. So you counted Wel] EFTA00117712

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RR ROW OHM SWwrNP RPRRR Ww = Wh RR SD ee oe od wm Se wrN Pr CO Ww Cc PRR RRR RR NDMP WNPRPOWOHDH SWwNP ae ee od WS Wr rs © Ww oc 281 time be that you conducted either a round or a count? MS. :_ After 10:00. MR. Would that -? When we're discussing at the 10:00 p.m.? Would have you done something between then and 12:00? MS. I don't remember. This is the last that_I remember with the count at 10:00. MR. So the last one that you can recal]_is the one that we’re discussing -- MS. :_ Yes. MR. count? -- on the 10:00 p.m. . :_ Yes, MR. : Okay. So probably around 10:00 p.m. would have been the last. MS. : You can say that. MR. What time does that count slip show? MS. QB: The count slips shows 10:00. On here is says 10:30 p.m. MR. : 10:30 p.m.? MS. > Mm-hmm. MR. : Do you - no-no-no. That's the institutional count. 283 MS. : Yes, MR. | a Alright. So do you remember -? MS. MR. MS. MR. So would that - do you remember if that would have been at 10:00? A little after? A little bit before? And again, this is the last time you saw this big guy whose caused your life to flip upside down. MS. MMMM: But I can’t -. That’s what I'm saying. _ Okay. : It's somewhere around after Until the incident. Right. : But would he -. : You just got to ballpark the time of the count. wS. MBM: Yeah. With the counts, even if -. Because remember, on the unit, you're waiting to count. So let's say you fill out the 10:00 slip. But let’s say we didn't So you just always write RR ROW OHMS fwrNP —— wr RPRRR oN Du ee od Wwrerow mr oe RR ae ee RR i) MRRP RRR RRR POoOwCmBADH ew 282 MS. MB: On the count slip, it says 10:00. It’s always going to say that. Like even if -. Like on the count slip, let’s say if I counted at 10:15, it’s still going to say 10:00 because -- : Alright. -- it’s the 10:00 count. : So-. So that’s what I’m saying. A WR. MMM: So this one -. I just want you to try to kind of -. Because this would have been if you actually conducted the count and you actually looked at the people, this would have been the last time you saw Epstein. Correct? MS. : Correct. MR. | ay Alright. So I just want you to consider that with all that’s surrounding this, you've got to kind of in your mind think, “When is the las time that I saw him?" MS. > Mm-hmm. MR. : Is this the last time you can remember seeing him? 284 actually go down range until 10:30. You don't actually put 10:30. It’s a 10:00 count. So it’s always going to say 10:00. MR. : Okay. MS : So that’s what I’m saying. Just ball ark it. = So approximately 10:00 p.m Or after 10:00. Okay. So on the round sheet. Does that also say 10:00 p.m.? I mean I know you said you prepopulated that one. But what does that one say? And that’s for August 9th. You already said August 10th, none of the rounds were conducted. On August 9th, I guess around the 10:00, you know that nothing after 10:00 was actually conducted on the round sheet? MS. i It has after 10:00 on here. MR. : Okay. So those ones. Those ones from then on you know those weren’t conducted. us. this out. WR. QM: «You prepopulated it. MR. : “ws. MI Yes. MR. : Right. Remember I didn’t fill EFTA00117713

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rR CWO D SWwrNP RPRRRR We WN Re RRR CoN DD a de ood SWwWNr Ow PRR RPE RR Re rm CON Dw SW N rR OW ON DW Sw Nr “ a a ee ond We wWwrr Ow 285 Right. So I’m just - want to make sure we know that -- -- you said some of them You don't remember which MR. But I just know that those ones weren't conducted. Right. After 10:00 p.m. Right. . Okay. Alright. So that last -. You're saying the last round and the count were one and the same. And was that an authorized practice? Is a round and a count if you're doing a 10:00 p.m. count, does that also what you can document on the round sheet as something you did at 10:00 p.m.? MS. : Yes. MR. overlap for that. wS. BBM: Yes. Okay. So they can 287 MR. : You think that they’re supposed to do that? MS. : Yes, MR. And during your time in the SHU, did a lieutenant ever participate or observe a count or round while you were in the did. did. MS. : did because she went down on the tiers. But on the midnight to 8:00, Lieutenant MY didn’t walk the tiers. wR. QM: Okay. So when I did on August 9th, she actually walked the tiers and checked -- MS. MR. MS. MR. She did? Okay. And around would have that been? Do you remember? MS. :_I don't remember the time. MR. Did she do it by herself? Or did she go with you guys while you were conducting a round or a count? Yes she did. -- out the inmates? =— ROW OHMS fwrNP —— wr RPRRR oN Du ee od Wr Ow mre oe RR ae ee RR i) MRRP RRR RRR POoOwCmBADH ew Mmmenmrn Ww Wr 286 MR. GY: «Were any supervisors present for any cell counts or rounds in the SHU on either August 9th or August 10, 2019? MS. : No. MR. No? Should any supervisors have been present for any cell] counts or rounds in the SHU on August 9th or August 10, 2019? MS. : No. MR. : Is there a requirement -? Or was there at that time that a supervisor - every supervisor at least one per shift should have conducted a round or a count with you guys in the SHU? Not of you staff members, but of the inmates? MS. BB: You're saying if the supervisor should have did -? MR. Should a supervisor, you know like a lieutenant -- MS. : Mm-hmm MR. -- observed or participated in a round or a count of the inmates during their shift? At least once? Do you know of that? MS. BBB: 1 think so. 288 MS. MM: No. She didn’t do anything with us. MR. : So she did it by herself? MS. : (Correct. MR. : She walked up and down each of the six tiers? MS. : She went down the tiers. MR. Do you know if that is a requirement that a lieutenant does that in the :_I don't know. MR. : Had you ever observed anyone prior to August 9th - I doing that? MS. Observe a lieutenant going down the tier? WR. QM: Either do it themselves - the lieutenant do the round themselves - or watch the staff members do it? MS. MMM: 0h no, they never -. never watch us do -. MR. observed? MS. : No. MR. with you? No they Never watched? Never Did they ever conduct it EFTA00117714

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RR rPFCowW OND SwhN re RPRRR Ww = Wh RR SD 18 19 20 21 22 23 24 25 PRR RRR RR NDMP WNPRPOWOHDH SWwNP ae ee od WS Wr rs © Ww oc . : No. . a. But they would occasionally do it themselves? MS. : They'll make -. The lieutenants will make a round. Yes. WR. BEM: «So not just pop into the SHU, but they’1] actually go up and down the -? MS. : Yes. Some. Not all. MR. : Some? Alright. And that’s what I’m asking. Do you know if it’s a requirement that -? MS. MB: That I don't know if it’s required. WR. WE: | So you don't know what policy or -- MS. BM: I don't know what the lieutenant -. wR. QM: -- rule or what they’re supposed to or not do? MS. : What’s supposed to do. MR. : Alright. But that didn’t happen. Did that happen more often than not? Or -? When they were actually doing a round with the inmates. Lieutenants. MS. BBB: If it happened that they walked 291 WR. QM: Alright. You're saying you don't recall the 4:00 p.m. You may have. You might_not have. MS. :_I don't recall. MR. : You just don't recall. Alright. So 12:00 a.m., 3:00 a.m., 5:00 a.m. We don't need to go into these specific things. You said none of them were conducted. They were false. You both signed them and submitted them. Correct? Correct. For the - And you knew that you - and you “knew that you had to do the count. You Yes. What conversations did you have with about doing that? MS. MBB: We didn’t have a conversation. He was exhausted and he was sleeping. MR. : MS. : Yes. MR. : So at 12:00 a.m. until -. Because you said you filled them all out at about 12:00? wS. WB: Yes. RR ROW OHMS fwrNP —— wr RPRRR oN Du ee od Wwrerow mr oe RR ae ee RPRRR Ww Wr MRRP RRR Pow OAS Mmmenmrn Ww Wr the tiers? Correct. Some of them do. Not all. Which ones would do it? Lieutenant [J was the SHU lieutenant so he walks the tiers all the time. MR. : Okay. MS. : And then the other lieutenants that's on, when they come, they sign the round sheets. MR. WM: | But do they actually do rounds themselves? Or they just sign your sheet and check in with you? MS. BBM: They don't do it all the time. They sign the sheet. And they check in with me. And they'll say like is there anything going on. But they don't physically actually walk it all the time. WR. MM: Okay. So it's occasionally. MS. > Mm-hmm. MR. a Alright. But you don't - Okay. "S. Mi: requirement. I don't know if it’s a 292 WR. QR: «And you didn't have a conversation about filling them out at 12:00? MS. MBM: No because we do that all the time. Like when he came in, we filled them out. And then, I think when the phone rang, he had the conversation. And then there was another time when I was looking of for the counts slip, he had it and I couldn't find it. So I had to like wake him up to resign the count slip. MR. a. Now give me - can you walk me through that? So he gets acall. You already filled out the count slips. Was one submitted? You put it through the door and internal came and got it? MS. : Yes. MR. : called him back? MS. MMM: And he spoke to whoever. And then he wrote on the count slip. And we filled it out. And I put it back through the door. MR. a. For the corrected one that said 73? Then you made it 72? MS. MB: 1 don't remember. filled out a new one. And that's when they But I know I EFTA00117715

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RR rPFCowW OND SwhN re RPRRR Ww = Wh RR SD 18 19 20 21 22 23 24 25 RR SwWOHNDN FWwrNP RPRRPR RRR SD SwWwNPe ee ee ed eS WwrN Pr CO wc nm wm MR. : MS. + Yes, MR. : And did you have to at that time fi1] out a new 3:00 a.m. and 5:00 a.m.? WS. WEB: Yeah. Because I couldn't find the count slips that he had and I filled it out. And I woke him up and he filled it. I remember that. MR. So this was later? So he gets a call. He falls asleep. And then later you have to wake him up to resign? WS. MM: No. He gets the call, he does it. And then he falls asleep. When he gets the call to change whatever, we change it. And then he falls asleep. MR. So you only changed the 12:00 a.m. He falls asleep and then you have to wake him up to change the 3:00 a.m. and the At 12:00 a.m.? . + Yes. MR. : Okay. And you just never talked about what you were doing? MS. QB: No we didn’t talk about it. As far as like -. 295 number. Is that correct? WS. WM: Correct. And you fill it out. Even on a regular housing unit, I fill it all out. And then I count. Because even if it’s wrong, you can just rewrite it. MR. : Right. MS. : Because even if I come in and you say it’s 72. And I fill it out and I put 72 on all of them. I know nobody there's no movement between 12 and 8. So even if I did that and I put 72, and I counted and it’s wrong, I could just change it. So that’s the way I’ve always done it. MR. : Does that sound weird to you? Or just me? MS. : What? MR. : That that’s the way it’s done. That you prepopulated all these numbers and then you just change them later if they end up being off? M No. Because they're usually > Um. - And then like if I’m working a If I work that unit and I did a double MR. MS. unit -. wont nfwnrP 10 MMM NR NYRR RRP RRP RRP RR AWN OWSOAUDH EWN RR ae ee PRR RRR Dw wr ed ool mel ro wo mnrr =e Wh 25 294 MR. QM: | Because that’s just common practice there? MS. What? To fill out the count slips before? MR. QM: § To prepopulated count slips. You're supposed to count inmates to make sure that they’re there. And write the number of what you counted. MS. : Yes. MR. You just -. Common practice is you just fill that out first. And you said that you don't have access to what the count number is supposed to be. It’s just -- MS. MBM: I never said I don't have access. I don't know how to. I don't know if I have access. I don't know how to find what it’s supposed to be. MR. So how do you get the number that you write on the slip? MS. : We're not -. The number that I wrote on the slip the officer gave it to me. MR. a. So whoever you replace, they tell you what number to write? MR. : You prepopulated that 296 there, I counted, so I know that’s what it is. So it doesn't sound crazy that I fill it out. MR. Well in this instance it does because your count was wrong - the one you said that you counted. MS. : Okay. But that’s that case. But I’m saying like it’s not -. If I worked a double on 11 North and I’ve been there the shift before and the shift after, and I filled it out. I know there’s no movement. So no, it's not crazy that I filled it out. MR. : Right. So. Had you worked with prior to this instance? You never did? . And there was no conversation with him about these not doing the counts or prepopulating these count slips? MS. No. About prepopulating the count slips, he came in, he filled it out and I signed it. It wasn’t a conversation about that. When it was time to do the - when it was time to conduct the count, I tried to wake him up and he was really tired. He was like I'm EFTA00117716

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RR rPFCowW OND SwhN re RPRRR Ww = Wh RR SD 18 19 20 21 22 23 24 25 PRR RRR RR NDMP WNPRPOWOHDH SWwNP ae ee od WS Wr rs © Ww oc 297 tired. And I didn’t - we didn’t conduct the count. WR. QM: Alright. And that was at - what time was that? At 12:00? MS. : I don't remember what time. MR. What count would have that been for that you tried to wake him up he said he was tired? MS. I don't know. MR. You don't know? MS. MR. Would have it been the 12:00? Because you're already -- MS. WEB: It could have been the 12:00, it could have been the 3:00, I don't know. MR. Alright. MS. : He was tired. MR. So that was the one conversation -- MS. MMMM: Because I counted upstairs. Like why would I go upstairs and count a unit and leave my unit? So I woke him up. He was tired. So I went upstairs and I counted with WR. ME: And what time was that? conduct the counts and just write them? MS. :_ No. MR. it common? MS. MM: You're saying if it’s not common to conduct the count or if it's common to (Indiscernible *03:33:51) it? MR. Is it common not to conduct the counts at night or the early morning hours? S. first time ever not doing it. if it's common not to conduct the count. it is common to fil] it out before. MR. FOY: You need to make that more clear. Did you ever work midnight to 8:00 a.m. to have an experience to say what happens? MS. : No. Not in the SHU. MR. So you've never worked midnight to 8:00 a.m. prior to this instance? MS. : In the SHU? No. MR. Okay. On the other times you were in the SHU, was it common to fill out count slips that weren’t conducted? MS. In the other times that I've No it’s not common or is I don't know because that’s my So I don't know But RR ROW OHMS fwrNP —— wr RPRRR oN Du ee od Wwrerow mr oe RR ae ee RPRRR Ww Wr MRRP RRR Pow OAS Mmmenmrn Ww Wr 298 You just didn’t do the 1:00 in your_unit? MS. : Right. MR. : Okay. Um. Um. I’m just -. The only problem I -. I’m trying to reconcile the fact that you've never worked with before. You didn’t have any conversation with him about it. MS. : No. MR. He didn’t -. That's why I’m saying it sounds like it must be just common practice. : Yes. You just don't conduct out eh forms. MS. MBB: We didn’t have a conversation about filling it out. No because that’s common in there. MR. MM: | Alright. So it’s very common. Is it very common from like 12:00 a.m. to the 5:00 a.m. count? Those three? Not to 300 worked in the SHU we fill -. MR. So you're saying you’ve never worked in the SHU and we got the schedule in front of you if you want to take a look to just help refresh your memory. Um. When you were in the SHU, was it common to fill out count slips that weren’t conducted? MS. : Count slips, we fill them out and the counts were done. The rounds, it was common to fil] them out and the rounds weren’t all conducted. MR. So you're saying it’s common to fil] them out ahead of time, but it’s not common not to conduct the counts? MS. : The counts. Correct. MR. Okay. How often were they - when you worked in the SHU, how often were the counts not conducted? MS. : They were done. MR. They were always done when you were in there before? MS. : Yes. MR. And this is again one of those things if we go back to video from the days prior, because we had to get video from EFTA00117717

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RR rPFCowW OND SwhN re RPRRR Ww = Wh RR SD 18 19 20 21 22 23 24 25 PRR RRR RR NDMP WNPRPOWOHDH SWwNP ae ee od WS Wr rs © Ww oc 301 these days. If we review that, are we going to - it's going to show you conducting the counts? MS. = Yeah. I don't have to conduct the count because if I’m working with two more people, they could have did the count. So it doesn't necessarily have to be you’re going to see me on the video, but you will see the counts being done. If you get what I’m saying. MR. —. No I understand what you're saying. MS. : If three of us are working, those two could have did it. It doesn’t have to be me. WR. WE: «So when you were in the SHU, did -. If you didn’t do it, did the two other people always do it? MS. : Yes. MR. a Alright. Were you ever on count slips - your assigned count slips - that you personally didn’t conduct? MS. : The - no. MR. : So you never signed -- MS. : But they're -. If I ever signed the count slips but that the night before the round sheet, I did. 303 he didn’t want to count. So we didn’t count. wR. QM: «But then you also say at 10:00 p.m. also was exhausted? : So -- And -. : -+ that's -- And -. : o--nota-. . And -. Yes and I know because I did it and I wasn’t supposed to do it. That's why I didn’t continue to do it. Because I’m really not supposed to count - to go down range by myself. So I didn't continue to do it. WR. QM: You didn’t continue to do what? MS. il The count by myself. MR. : Alright. But you did the entire count at 10:00 p.m.? MS. : Yes. MR. : Were there other instances that you worked in the SHU where other people were too tired to conduct their rounds? RR ROW OHMS fwrNP —— wr RPRRR oN Du ee od Wwrerow mr oe RR ae ee RPRRR Ww Wr MRRP RRR Pow OAS Mmmenmrn Ww Wr 302 MR. : I’m sorry, what was that? MS. : The rounds sheets I did. The count slips no. MR. a. The rounds sheets you did what? MS. BBM: On the 9th, when I filled out the entire count slips, I didn’t conduct every single round. MR. QM: You didn't conduct every single round. MS. :_No. MR. : So what about on previous incidents? We can switch over to rounds, that's fine. In previous instances when you worked in the SHU, were the rounds conducted as displayed on the count sheets? MS. : No. MR. : But the counts you're saying they were always conducted when you worked in the SHU? Yes. So this was just a rare instance. MS. MBM: It wasn’t a rare. It was because he was exhausted. And he was tired and . : No because I usually -. MR. | = Or the counts - not rounds. Counts. MS. MMM: Because I usually come in on the shift prior. I don't work that so I don't know what goes one. Because that’s the tired time. MR. : Right. MS. : So I usually come in before so I don't have to deal with that. Alright. . | | It was just that one day. MR. : It's the one day. No conversations were had. You try to wake him up. He didn’t wake up. So you just didn’t do them. And then you didn’t even have to say like hey man, we need to do these things. Or like there was just an unspoken thing that he was tired. So you weren’t just going to do them? . :_ Say that again. : I'm just trying to like it sounds like it would be common practice to do this if there's no conversations that were But it was just EFTA00117718

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RR ROW OHM SWwrNP RPRRR We Wr RR SD 18 19 20 21 22 23 24 25 RR SwWOHNDN FWwrNP RPRRPR RRR SOW WNP ee ee ed eS WwrN Pr CO wc nm wm 305 had. Usually, it would be like hey if this is the first time I'm not going to do something. I would say like, hey is it cool that we’re not going to do this? Or some kind of a conversation. Unless it was something that you had learned or experienced in the past. That like we don't do counts at this time. MS. MMM: But I never worked the SHU at that time. MR. FOY: This is calling for you to explain your interaction with MS. Mm-hmm . MR. FOY: As it relates to the count in particular. Right? MR. a. Correct. MR. FOY: He asleep. What’s the interaction? What did you say? What did he say? Did you ask one time? Did you ask multiple times? Did he affirmatively say no? Or did he just continue to sleep? That’s the level of detail they're asking for. MR. Yeah. We're asking you to explain all of your interactions with with regard to these counts. MS. Well when it was time to count, 307 HBB, that’s who I would have told it to. She was there. And she saw it. MR. So she knew. So you didn't as far as like if you were going to report someone sleeping on duty, she’s -. You didn’t’ need to report it because she saw it with her own eyes. MS. : Exactly. MR. And he was literally - fell asleep in front of her? MS. In front of her. Yes. MR. How long was she there? MS. Maybe like five, then minutes. MR. And that little brief interaction he actually went to sleep in front of her? MS. : MR. Okay. So no discussions with . Just when you would wake him up he just said he was tired. MS. : Yes. MR. up for each count? MS. MM: I tried to wake him up for the 12:00 and the 3:00. I don't remember if I Yes. Did you try to wake him wont nfwnrP Wey DHfwrP PRR RRP RRP RRR WeonyDwVfwrNro mre reo MmmenNn Ww Wr 306 because remember I’m going upstairs to count. So I wake him up to count. And he was like I’m tired. He was like we have the count slip. I’m tired. He went back to sleep. When the lieutenant came, I woke him up because the lieutenant was coming. He fell back to sleep in front of the lieutenant. She said hey, you need to stay awake. He couldn’t’ stay awake. I went upstairs and I counted again. MR. FOY: Go back to the lieutenant. Explain that in more detail. There’s details ou're leaving out of the interaction between = and the lieutenant with respect to him sleeping. MS. MB: 0h. I woke him up. The lieutenant came. She came, she found the round sheet. He fell back asleep in front of her She said, hey you need to wake up. She had papers and she hit him. She says, hey you need to wake up. MR. FOY: That's what I'm talking about. MS. BBB: She hit him with a stack of papers. So saying that to say like everybody knows like because we're understaffed and overworked. So let’s say if I was to tell on 308 tried to wake him up for the 5:00. Because by that time he went upstairs. I remember he went upstairs to relive And I don't remember what happened between there as far as waking him up. WR. GM: Alright. And as far as the inaccuracy of the one count, specifically now we’re talking about the 12:00 a.m. that it was actually - it’s off. He got a call but he didn't talk to you about what was said on the other line? MS. MM: No. He just said we got to change the count slip. And he wrote it. And he changed it. And I signed. MR. Alright. MS. : But he didn’t say like oh the lieutenant this happened or that happened. No. MR. a. Alright. And have you ever experienced previous instances where the count was off from when it was called in? Like if you give the number and they say no that’s not right? MS. :_ Yes. MR. = And what happened in those instances? EFTA00117719

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RR rPFCowW OND SwhN re RPRRR Ww = Wh RR SD 18 19 20 21 22 23 24 25 RR SwWOHNDN FWwrNP RPRRPR RRR SD SwWwNPe ee oe od eS WwrN Pr CO wc nm wm MS. : You recount. MR. | You actually did a recount? MS. MM: On - not in the SHU. In other In other units though. But do you know that that’s what is supposed to be done? You need to do - if you call ina wrong number, you're supposed to do a recount? MS. MMB: Right. But I don't think that was the case with that. Like they called in and gave -. Okay. That was a case where like if I counted wrong, and then they’l] say no it’s wrong. And then I recount and I get the right number. But in this case, they gave him the number because of whatever I guess they knew where the inmate was or was supposed to be or wasn’t moved. That’s what I'm saying. I don't know what happened between the 73 an the 72. But when he changed the number, he said the lieutenant said so I just signed it. But he didn’t tell you the Tieutenant said do a new count? MS. No. MR. He never informed you of Neuter No the phone rang. Alright. So who called the _ in at 12: 00 a.m.? MS. : Me. MR. | And did you call - also call the 3:00 a.m. and the 5:00 a.m. in? MS. : Yes. MR. : Alright. And obviously you called it in without actually conducting the counts. Correct? MS. : Yes, MR. : Alright. Now it sounds like your attorney has - and you have had this conversation but what was the reason you didn’t conduct the counts? MS. QM: I didn’t conduct the count in my area because he was tired and we're supposed to do them together. So I just didn’t do them. MR. —, Okay. So would have you done them if he was awake? MS. MMMM: Yeah. Because I did them upstairs. WR. QM: «Okay. And you're saying that you never worked that night shift before, RR ROW OHM fwrKP —— wr RPRRR oN Du MmNmenNrre rmrROow mre re WW = Ww RR ae ee RPRRR Ww Wr MRRP RRR Pow OAS Mmmenmrn Ww Wr that? . :_ No. - Okay. So you didn't really get into detail about what he said. MS. No. MR. Okay. But you do believe at 12:00 a.m. a new slip was created. Just not that one. That's not attached to that. The one that actually says 72. MS. BBB: (Indiscernible *03:42:12) Is that a 12? At 12 here it says 73. MR. : Correct. But that was actually - the top page says 72 and I thought that's the one that you said they made you recreate a count slip. MS. : Right. MR. don't see that -- MS. :_ That count slip. MR. : == new count slip on there. Correct? Alright. And I know you -. Did they have the conversation with because at 12:00 a.m. he called that count number in and they said he was wrong? Is that when he had that conversation with the And that's not -. You 312 but all the other counts you had conducted that you've documented from previous. MS. MR. Documented. You're saying you may have worked with three other people and two of them may have done the counts, but there are - when you've been present in the SHU, all the counts have been conducted. MS. Yes. MR. Okay. And do you know of any other Gs or employees that have falsified count slips . ount? No. No. SO you don’t know any other. I know you said you prepopulated them in a sense. But like as far as -- As far as other units. -- not conducting the counts and actually writing a number when a count -. Do you know? Oh. No. So all counts that have been submitted to this point when you're in the SHU - someone conducted them. EFTA00117720

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313 314 MS. | | Yes. Senior Special Agent [NS and I am MR. : And you said you've never pausing the recording. [Whereupon, the above- actually had a conversation with anyone about entitled matter went off the record and went counts and how they’re documented. You just back on the record.] Okay. The recorder is observed as well like on the round sheets? back on. It is 2:28 p.m. Again Ms. i you MS. MMB: As far as having a are under oath and this is a voluntary conversation? interview. Thank you for your cooperation. WR. QM: «Did anyone ever train you Alright. So if you don't mind, just all the on how to write count slips? documents I have in front of you, can you just MS. : . initial and date those just again so that we -- MR. : No. MR. FOY: Yeah. Just on the first page. MS. :_ Hm-mm. MR. MY: | -- know what it is that MR. : So you just from watching you were looking at during this interview. other people fill them out - that’s how you Thank you very much for initialing and dating learned? all of those. MS. MM: Yeah because it’s just your MS. : Mm-hnm. name and the number of the count. MR. : Alright. We're just Sure. going to talk briefly about the SHU layout. + Mm-hmm These are papers that have the SHU layout. Now Okay. You want to take a are the - just for your reference if you need to look at them. Are the COs assigned to the SHU located together on one social - one centralized location? Sorry, so the officers that are working in the SHU. Are you all together? You mentioned there’s a desk in the 316 WR. QM: “Three? And you said no one had like an assigned computer like the -- MS. :_ No. MR. : == OIC doesn’t have one computer? MS. : You -. MR. : Everyone just uses one computer? MS. > Mm-hmm. MR. | = What can you see from that desk in the SHU? Can you just mark on there where is the actual L desk setup located? So it’s the two floors - the two layers. I don't know if you’re able to look at the L Tier where Epstein was. That might give you like a what's the first and what's the second. Is it correct that he was on the second level? MS. : Yes. MR. : And was he in L Tier? So that might help you out to be able to differentiate between - you see where the cells start with like a letter and then the numbers? MS. :_ Yes. MR. : So that will probably help you to be able to decipher what's the PR PSoOwmn DH wr P a Pow oH Dw &SwhN re PPP PpPE ow wr Pee > wr rR ~ RPRRR oN Du mre row break now? MR. FOY: —Mm-hmm. > Okay. We've got to eat. It is 2:21 p.m. This is mnrr Se wr 18 19 20 21 22 23 24 25 nm Ww shape of an L. MS. Yes. MR. : Is everybody together at that location when you're not doing rounds and counts? wS. WEB: I mean no not really. Somebody could go upstairs to the bathroom. MR. —, Okay. During your shift on the 10th. . i Mm-hmm . MR. : Is that where you and - aside from when you said you a out. Is that were the two - you and were located at that -- MS. :_ Yes, MR. : =- one central area? There's not another officer station though, correct? MS. :_No. MR : There’s just one officer’s station? :_ There's one. Okay. And approximately how many computers are there at that station? MS. : About three. RR SwWOHNDN FWwrNP RR ae ee RPRRR Ww Wr RPRRPR RRR SD SwWwNPe RRR oo mre reo mre wh ae ee od WS Wr rs © Ww oc nm => nm w EFTA00117721

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RR ROW OHM SWwrNP RPRRR Ww = Wh RR SD 18 19 20 21 22 23 24 25 RR SwWOHNDN FWwrNP RPRRPR RRR SD SwWwNPe MmMYyrRe re Oo wc 317 first level and what's the second level. MS. GREGG: Do you know what you’re looking at? WR. MB: So each of the cells have a letter in front of it. MR. That's to identify the tier. That will be the letter. And then the numbers will be the cell numbers. MS. : Uh-huh. Okay. MR. So by - can you figure out by looking at that? So if the one that begins with L that would be the second level. Do you follow that? MS. :_ Yes, MR. And then there’s the first level. Is there actually almost like third level where the officers sit? It is like two different - the way it’s tiered. MS. : No. It's on the main level. MR. Okay. So where the first set of inmates are. MS. See it’s stairs. You’ve got to go down and you've got to go up. _ Right. Okay. . : So it’s not where we’re Um. MR. FOY: Because I'm thinking is it? Because you have to be able to see in here. MS. GREGG: This is your unit entrance. This is where you enter. This is L Tier. Right. The - you walk in. L, M, J, K. this is J, this is you walking into your housing unit. ws. Zi: turning left. MS. GREGG: Yes. So. MR. And maybe put X and a circle just so I know what it is that you just changed. MR. FOY: Put a circle around that X and that will be the desk. MR. MR. FOY: MR So if (Indiscernible *03:51:16) by Perfect. Alright? . Alright. And then you - is it correct where you identify where -? : Epstein Epstein. What number was 988. You believe that he was RR ROW OHMS fwrNP —— wr RPRRR oN Du ee od Wwrerow mr oe RR ae ee RR i) MRRP RRR RRR POoOwCmBADH ew 318 sitting. You've got to go down and you've got to go up to get to the cell. MR. a. Okay. So on that looking at like the first level of inmates, can you just kind of identify where it is that that L shape setup is? MS. :_ Over here. MR. : Can you just mark it? Maybe like an X or a circle or something. Okay. Thank you. And from where you're sitting can you see all the cell doors from Not all. Not all. Could you see the door to ere? MS. MR. Alright. Can you mark on there where you recall Epstein to have been? Alright. Thank you. And does that have a cell number on it? MR. MM: =I think those numbers correspond with this. MR. : Yes, That’s fine. 320 in - was that L988? MS. MBB: 1 don't remember the number that he was in. I just know when you go up the stairs, it's the first one on the right. MR. Let me just so that we're not. I just want to make sure that we're not - Huh. Okay. So they don't actually correspond with the numbers. . : No (Indiscernible *03:52:08). We have that. : Do you remember what room he On L Tier? Yeah. L Tier. The first cell on the right. . The room number by any chance? MS. MB: 0h I don't know the room number. MR. : Okay. MR. : Um. Okay. But you could see his actual door from where you were sitting? MS. : MR. Yes. Yes. Okay. And could EFTA00117722

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rR CWO D SWwrNP RPRRRR We WN Re RRR CoN DD a de ood SWwWNr Ow nm w RR SCwWOnHtDUN SwWwrP 321 you see inside his cell from where you were sitting? MS. :_No. MR. : No. Approximately again we're talking about like that’s where the shower was - what you were talking about. Approximately how far was Epstein’s cell from where ia were seated? Mm. To like where that chair Ten to 15 feet? Probably Okay. Alright. So the reason nity I’m asking that. Did you or anyone else ever go in or out of Epstein’s cell on August 10, 2019? MS. : No. MR. : And would have you known if someone did? 7 | = Okay. While you were —_ resent in the SHU of course. Yes LL And you said the only tines -_ weren't present in the SHU on August 323 aay Although he may have been ea Mm- shan. Okay. And are you - of the reavle that we've talked about, you said that the lieutenant visited the SHU — i 4:00 a.m. That was Lieutenant MS. : . MR. : Who else from 10:00 p.m. until 6:33 a.m. were in the SHU? MS. :_(Indiscernible MR. :_ Well so -. MS. . MR. : left at around 10:00. MS. :_ Mm-hmm. MR. | HE eft around 12:00 a.m. Anyone else? MS. : No. WR. : What about when J came thought the SHU? So I just want to make sure you're -. I know we've kind of discussed some of this stuff. 322 -. Or let's talk from you said 10:00 p.m. is the last time - around 10:00 p.m. is the last time you saw him. MS. :_ Yes. MR. : From 10:00 p.m. until approximately 6:33 a.m., what times did you - when did you leave the SHU? I know one time you said you helped with the counts up in 10 South. And you may have said you were gone in the bathroom around. MS. :__(Indiscernible *03:53:38) MR. : When would have those times have occurred? MS. BBB: Um 3:00 or right after 3:00, 5:00 or around after 5:00, going to the bathroom I don't remember the times. MR. QM: Okay. So around 3:00 a.m., around 5:00 a.m., and then one other time to use the restroom? MS. Yeah. MR. : And where is the restroom located in the SHU? MS. : Upstairs where I go to count. MR. : Okay. But was present any time you were not there? 324 MS. J: 0h you’re talking about the people that’s working there? WR. MM: | Everybody that’s been in the SHU. So there's you, there's JM. who else was actually in the SHU from 10:00 p.m. - the last time you saw Epstein - up until about 6:30 when he was discovered? HE, icutenant , And HP He left at 10:00. At 10:00. So at 10:00 he They’ re the only: other people there? Okay. No one else? No one else. And you're confident positive about that? MS. Yes. MR. : Alright. And did any of those individuals that visited the SHU go near Epstein’s cell? MS. : No. MR. : So no one even went near it? EFTA00117723

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rR CWO D SWwrNP RPRRRR We WN Re RRR CoN DD a de ood SWwWNr Ow PRR RPE RR Re rm CON Dw SW N rR OW ON DW Sw Nr “ a a ee ond We wWwrr Ow Let alone go in it. No one went in it? . : Okay. That’s all we need to talk about with the SHU. Do you mind just initialing and dating that? And are you aware -? I guess the one other thing I'll ask. I know I asked when you were there. But when you were gone to do the counts in 10 South as well as use the restroom, are you aware of anyone visiting the SHU during those tines? I have a follow-up question. When you left to go assist, did you ‘take the keys with you? : Yes. So could Mr. have let anyone in_and out? MS. : No. MR. : Oh so he wouldn’t have even had the ability to let anyone in based in or out? MS. :_No. MR. : Okay. Are you aware of any cameras were not recording within the SHU on August 9th or 10th 2019? MS. :_No. MR. : You're not aware? Are you aware at this point? Not just at the time. But are you aware now if any cameras were or were not recording? MS. :__I mean I’m aware now. MR. : That’s what I mean. is your - what are you aware of now? MS. WBBM: 0h I don't know like what specifically. I just heard that some of the cameras were not working. As far as which ones . a: ones? MS. > -- or no. MR. = Okay. you didn’t know? MS. :_No. MR. : So you don't know if they weren't working when they stopped working? What But you don't know which And at the time =— ROW OHMS fwrNP —— wr RPRRR oN Du ee od Wr Ow mre oe RR ae ee RR i) MRRP RRR RRR POoOwCmBADH ew Mmmenmrn Ww Wr 326 upon you having the keys the whole time? MS. :_ Yes, MR. : And did you have the keys because you were SHU officer number one? MS. BM: I guess. I mean I just had them. WR. GR: Okay. discussion -- MS. : No. MR. : -- like I’m SHU one, I get the keys? MS. : No. MR. : Do you know that SHU one is supposed to be the one who has the keys? Do you know that (Indiscernible *03:56:05)? MS. : I think so. MR. : Okay. ou know if you have any conversations with about if you had the keys or he had the keys? MS. : No. MR. : Okay. Anyone that entered or exited the SHU that day, are you the one that let them in or out? Yes. WE didn’t Jet anybody 328 . : No. a. Are there any like - do you have the ability to monitor cameras from the SHU? MS. : No. MR. : So if you’re sitting in there, there’s not like camera down range that you can like - you can see what’s going on in each range? MS. No. MR. : No? Do you know if someone is live monitoring either - anywhere in the SHU during operations? MS. :_I don't know. MR. : You don't know if you're being monitored or the inmates are being monitored? MS. BB: I don't know. cameras on the tiers. WR. QM: | Right. Do you know if anybody's live monitoring them? MS. : 0h. I don't know. MR. : You don't? And do you know if there’s any cameras pointed at you in the desk area? There wasn't a I know there is EFTA00117724

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rR CWO D SWwrNP RPRRRR We WN Re RRR CoN DD a de ood SWwWNr Ow nm w RR SCwWOnHtDUN SwWwrP 329 MS. : Oh, I don't know. MR. | And you don't know if anybody is monitoring those either? I don't know. (Indiscernible *03:57:54) . I think it will be fine. So you are not - we can just skip the rest of those questions. You're not aware of any cameras at the time not working? MS. :_No. MR. : So no one reported that to you and you didn’t report it to anyone else? I didn’t know anything MS. : No. about cameras. WR. QM: Alright. And we talked a little bit about sleeping on duty. So it sounds like was Pe asleep pretty much the entire shift then? MS. :_ Yes, MR. : From pretty much 12:00 a.m. until he -. . i Until he went upstairs. : Until he went upstairs? Went upstairs to do what? To feed? WS. HB: To relieve IM. 331 WR. QM: «For the period that you were sitting at the desk for like two hours without moving were you awake? Yeah on my computer. You were on the computer? seated next to one another? : No. We were seated next to each other but not facing each other. Like he was faced that way. I was faced the other way. a: Okay. Close proximity to one another? ws. J: here. . a: feet from each other? MS. MMMM: Yeah. But the back is turned because he’s that way and I was that way. WR. QM: Okay. But: you were not sleeping? MS. : No. MR. : Now are you guys authorized to sleep in the SHU? MS. :_No. MR. : No? And have you ever fallen asleep previously while on duty at the Yeah. Like he’s there and I’m So about three or four PRR RR SwWwKN PCW OHMS SwMN Pe RPRRR oN Du ee od Wr Ow mre oe Re CWO HM fWwrNP 330 VR. GM: To relieve MP Alright. I might be getting confused. I thought you were relieved . MR. : She went up there to do the count. Then reached out to her to ask her to relieve him. She called the lieutenant. Verified with the lieutenant and then Mr. HE went up to relive him. MR. —, Okay. And around what time was that? MS. After 5:00. MR. : Okay. So basically from 12: a ° i. 5:00 he was sleeping? I mean in intervals. He kind of woke up. Right. But ‘he went back to sleep. Okay. But he wasn't He was sleeping. Correct. Did you sleep during the . : No. . : You didn’t sleep at all? . : No. Not in the SHU. Not in the SHU but other places? MS. :_ Yes. MR. “a Where would you - where did you sleep at other places? MS. : Where did I fall asleep? MR. + Mm-hmm. MS. Ona regular housing unit. MR. : The regular housing unit? MS. MR. : Can you just give me a little more information on that? What do you mean? Were you allowed to sleep there? MS. : No. MR. : And where were (Indiscernible *04:00:15)? MS. MB: Like I worked consecutively like five days of overtime. And I would like doze off - caught myself like that. But not sleep. WR. QM: Okay. So you've fallen asleep in other housing units. MS. BBM: Like dozed off. Like I tne , doing. his duties. EFTA00117725

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rR CWO D SWwrNP RPRRRR We WN Re RRR CoN DD a de ood SWwWNr Ow nm w RR SCwWOnHtDUN SwWwrP 333 WR. GM: Right. Because you were overworked? MS. Yeah when I work like three or four days of 16 hours, yes. MR. And how often would that happen? wS. WM: Every - how often would I fall asleep -- MR. : Yeah. MS. :-- or the overtime? MR. : How often would you fall asleep? MS. MM: Oh that was like for one or two times. But I don't -. WR. QM: «I understand. But in the SHU you had never fallen asleep before? MS. JM: No because I don’t work that graveyard shift. MR. Well I just mean even during your regular shifts -- MS. : Right. MR. Because it sounds like you guys were working a lot. :_ Yes. Um so but in the SHU, you 335 Yes. But he said he was just Yes. And you said you didn’t report the matter to a lieutenant because he actually fell asleep in front of the lieutenant? MS. : Yes, MR. And at that time, she hit him with a piece of paper and said wake up. MS. : . MR. : And how did he respond to that? He woke up. . Was there a conversation at all? Did he say oh I’m just exhausted? MS. MMB: Well he didn’t say that. But she said that. She was like that’s the problem in here. The overwork and the understaff. MR. So with him falling asleep that’s how she responded? MS. WM: Lieutenant I? MR. Yeah. MS. : Yeah. But she didn’t respond PRR RR SwWwKN PCW OHMS SwMN Pe RPRRR oN Du ee od Wr Ow mre oe Re CWO HM fWwrNP 334 didn't fall asleep that night and never before in the SHU? MS. MM: In the SHU no because it’s daytime I'm on. MR. MM: | You said that was your first time working with ? MS. Yes, MR. Was that ever with J or just in the SHU? Did you ever work with — outside of the SHU? MS. MR. Would you ever like - met with him or interacted with him -- + Yes, MR. : == prior to this? Just socially or -? MS. MM: He brings inmates to the units to give out stuff. So we've spoke and said hello. MR. Okay. Do you know if HE - have you ever heard of sleeping on the job previous to this incident? MS. : I don't know. MR. : No? And you said you did try to wake him up a couple times? : No. 336 like that to him. She was saying that to me. That's the problem in MCC. Everybody's overworked and understaffed. MR. Okay. he fall back asleep? MS. Yes, MR. Have you ever witnessed any other staff member fall asleep at the MCC? MS. MM: No because you're in a unit by yourself. MR. You’re in what - the housing units or the SHU? MS. MM: Yeah. Like when I’m in the housing unit -. Remember I don't work the SHU that time, so I wouldn’t know if people are sleeping at that time. In the housing unit you're by yourself. So I can’t witness nobody. MR. a. Okay. And you have your own little office there -- MS. Yeah. MR. -- when you're in the housing unit. And that’s where you might be able to doze off? MS. Yeah. MR. As far as in the SHU did After she left did EFTA00117726

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RR rPFCowW OND SwhN re RPRRR Ww = Wh RR SD 18 19 20 21 22 23 24 25 RR SwWOHNDN FWwrNP RPRRRR we wre RR SD ae ee od WS Wr rs © Ww oc 337 you ever experience anyone else sleeping aside from ? MS. : that day before. MR. : Okay. And I do apologize. It’s just been so long now. long did he sleep for? “S. J: who SP MR. : Yeah. MS. : From about after 10:00 until it was time for him to go. MR. So 10:00 to 12:00? Okay. And did you try to wake him up at all? MS. : No because he was on a triple. MR. Okay. Alright. Now we're going to do -. You said you were on the internet. Are you authorized to use the internet when you’re in the SHU? wS. WEB: 1 don't know if I’m authorized to use the internet in the SHU but I did. I don't know if I’m authorized. MR. Alright. And did you conduct internet queries when you were assigned to the SHU on August 10, 2019? MS. I: What do you mean? Like internet searches. How On August 10th? No? Okay. Does that surprise you for me to ask that question? MS. :_ If I don't remember doing that? MR. I don't know. Had you queried him before? Had you looked up Epstein previously? MS. I don't recall looking him up. MR. : No? MS. No. because when you open the computer, and when you click on it, like he's there in the - in the Google search. Like he’s there. : Epstein is? : Like when you click on the MR. MS. browser. You know like if you open it Emerson or Google, like how it has that little news piece. Like one time he was there. WR. QM: | And was that on August 10th? WS. MBM: No. I don't recall that being on August 10th. I don't remember. But I don't recall it_being on August 10th. MR. =. So as in like maybe RR ROW OHMS fwrNP —— wr RPRRR oN Du ee od Wwrerow mr oe RR ae ee RPRRR Ww Wr MRRP RRR Pow OAS Mmmenmrn Ww Wr 338 MR. GR: | Did you like Google things or look things up when you were in there? : Yeah. : Well just tell me. What MS. MR. did you search for? MS. Well yeah that’s what - I was looking at um a benefit page for something. I was checking for one of my benefits. And -. MR. FOY: Continue with it. I've just got to - this is a jail call. MR. a. Okay. So attorney Foy is stepping out. However attorney is it Sarraga? MR. SARRAGA: _ Yep. MR. Sarraga is still present. MS. : Yes. And then I think I looked at I think it’s furniture. MR. Okay. Did you do any -? Do you remember conducting any internet queries related to Epstein? MS. No. I don't remember doing that. MR. So you don't remember actually conducting queries on Epstein around 4:00 or 5:00 a.m.? 340 somebody else was looking him up and it just prepopulated when you turned on the computer? MS. I don't think it does that. Like on the searches, like the current news will be there. So he’s in the current news, so he'll be there. MR. Oh. Alright. MS. : It won’t like load the page. Like when you click on like Internet Explorer or you click on like Firefox or whatever. When the page loads, the news is there, weather. MR. Okay. So if you prepopulated something and then you searched on that day, Epstein at the MCC, that possibly could have been something that was like on a news feed? MS. MB: When you say prepopulated, like that as soon as you click it like it was there. Not like you said a search. a. So you weren't. Yeah. MR. Like a search. Like you were actually looking at it. Orif like a news feed. MS. Oh yeah. Like I'm looking at it because it’s there. But not like typing it in. EFTA00117727

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rR CWO D SWwrNP RPRRRR We WN Re RRR CoN DD a de ood SWwWNr Ow nm w RR SCwWOnHtDUN SwWwrP 341 WR. GE: «So you're not like actually going to Google or Yahoo or some kind of a search engine and -- -- saying Epstein? Alright. Do you remember reviewing news articles on Epstein -- MS. Yeah. MR. : == on August 10th? MS. : On August 10th? I don't recall if it was August 10th but I remember when I saw it I like scrolled and read it. WR. WM: Okay. And what was the purpose of that? MS. : What was the purpose of that? MR. : Yep. MS. : Because he’s in there. scrolled and -. WR. QM: Sure. So you're trying to learn about the inmate that was -. And read it. Okay. Because remember, I was asked like do I know who that was. And I was like 343 . : That does surprise you? . > Mm-hmm. : So do you think that would not be accurate then? MS. : Yes, MR. : You think it would be accurate or not be accurate? MS. MM: Oh no. It wouldn’t be accurate. WR. QM: It wouldn’t be accurate? You do not believe that you actually conducted those searches? No. I just Okay. And since you had the keys, no one could have visited the SHU without you knowing. Correct? MS. : Correct. MR. : And the individual on 10 South - - or anyone else. Are they able to access the SHU without someone in the SHU allowing them in? Can they get out of 10 South and enter the SHU by themselves? Or does someone from the SHU like you and [MM need to authorize them entry? MS. WBBM: He needs to call like I have to PRR RR SwWwKN PCW OHMS SwMN Pe RPRRR oN Du ee od Wr Ow mre oe Re CWO HM fWwrNP 342 no. and they was like he’s always in the news. So when I saw it, I just briefly like skimmed to see like what he was in the news for but -. MR. QM: Okay. And do you recall at 5:42 to 5:52 on August 10, 2019 looking at articles related to Epstein? You do not recall that? Do you remember searching for him? MS. : No. MR. : Or having anything to do with when _you’re on the internet? No. : With Epstein in (Indiscernible *04:07:02)? 5:52? No? Does it surprise you to hear that you know internet searches would show that that’s what you were doing from 5:42 to 5:52 a.m. on August 10, 2019? MS. MBM: Yeah. call control to pop that door MR. a. So he has to call control? MS. MM: Because there's a door that lets you into 10. You have to call control. MR. MM: And then is it like the entrance? Is there also a second door that you have to use a key for? MS. : Yeah. MR. : So there's also two into 10 South? MS. Yes. MR. : And that second door is that the one that -? don't have the key for. So Wg would also have a key? Or is it just. MS. MM: No I don't have the key for upstairs. MR. | Alright. open his own? MS. : Right. MR. : And then control pops it vs. Ha: So he needs to Pops it. EFTA00117728

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rR CSCwWOmOANDMDS fWwNHP RPRRRR We WN Re RR SD ee ee od Se wWwNr Ow CO RPE RP RP RRR rE rm SOW SwMre re COW ON DW Sw wr “ ae ee od WS Wr rs © Ww oc 345 WR. GM: -- to then allow him into the SHU? MS. : MR. So he could theoretically get into the SHU without your knowledge? MS. No. I have to call control to pop me into the SHU. MR. Yeah-yeah. I’m saying " ability to get into the SHU where you and were, MS. : Be he can’t do that because he can't leave unless -. Because remember has to go up to relive him. So [MM is getting the door popped. But he can’t just come out and get the door popped because he would leave the unit with nobody up there. MR. Right. What I’m saying is like could he? Does he have the ability to? Not policy dictates that he can’t do it. I'm saying would he be able to if he wanted to? Take policy out of the way. MS. : (Call for them to pop the door? MR. : Right. So like point being, could have he accessed the SHU theoretically without you and ’ Yes. 347 WR. QM: 9 Who was that last person to have physical contact with Epstein? MS. : . when would have that been? When he was feeding. No-no-no. You mean like a time? . : had physical contact with Epstein during his shift on August 10th prior to 6:30? MS. MM: 0h no. Not prior to the 6:30 I'm talking about at the 6:30. MR. a. Right. So you’re the last person to see him. MS. :_ Mm-hmm. MR. Who was the last person to have physical contact with him? MS. Oh! Whoever put him in the When I went to the bathroom. WR. QM: Okay. So you're not sure? :_No. : Alright. When you saw MS. him, please explain in detail like -? Or I a.m. cell. MR. RR ROW OHMS fwrNP —— wr RPRRR oN Du ee od Wwrerow mre oe RR ae ee RR i) MRRP RRR RRR POoOwCmBADH ew Mmmenmrn Ww Wr 346 knowledge? vs. HE: pop the door. MR. Right. But he would have had to call control in order to do so. 1 Yes. MR. : Alright. And does anything allow control to know if that door was never locked or closed or anything behind him? MS. :_I don't know. MR. You're not sure? Would an alarm sound if a door wasn’t closed or anything? MS. : I don't know. MR. : You're not sure. Who was the last person to see Epstein alive prior to August 10, 2019 at 6:33 a.m.? MS. WEB: The last person to see him S alive? I would guess me. Because I got -. MR. : You were? MS. : Because I counted at 10:00 - or after 10:00. MR. MY: And on that occasion, you didn't actually enter his cell you said? MS. No. Yes. Because he could go and 348 You said when you saw guess you already did. him he just put his hand up. MS. > Mm-hmm. MR. : And then he - you said he also asked for -. MS. : CPAP machine to be plugged in. MR. : And that is something that he has every night? MS. MR. Yep? Did he seem - did anything seem unusual with him? MS. MM: No. See there's exceptions being made for Epstein because it’s Epstein. You're not supposed to have -. A CPAP machine has a long cord. So other inmates don't have a CPAP machine in the SHU. Like you're not supposed to have that. Who authorized it, who gave it to him, I don't know. vR. MM: Okay. And that’s kind of what I was asking earlier - and this was much earlier - about like where like did Epstein was he treated differently than others? MS. :_I mean -. MR. Were there other instances that you can think of like people : Yes. EFTA00117729

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rR CWO D SWwrNP RPRRRR We WN Re RRR CoN DD a de ood SWwWNr Ow hr nm SCwWOnHtDUN SwWwrP w PRR RP RRP RR COND WMH a a ee ond We wWwrr Ow 349 said pay him special attention because he’s different_from eh other inmates? MS. No. Just the CPAP machine and one time he wanted two mattresses. MR. He wanted two mattresses? MS. : MR. mattresses? MS. : No. MR. | So he just had the one mattress? MS. > Mm-hmm. MR. | = So the only thing you can think of is that? Is that. Is it like C-P-A-C? What the CPAP? C-P-A-P. CPAP. Yes. Was he provided two Okay. . Is it the one with like a mask that's attached to your face? MS. : Yeah. MR. And there’s actually like a cord that goes with that? 351 MS. : Not that I know of. MR. No? And do you recall if any other inmates were on - came from suicide watch? MS. : No MR. So you don't remember any other inmates being handled differently than others? MS. : No MR. No? Or like special instructions with regard to this inmate or that inmate. MS. : I don't know. MR. And you don't remember inmates complaining about the lights you said. MS. : No. MR. How do the lights work? Do they stay on in the range all times - uh 24/7? MS. : The -. MR. In each tier? MS. : I don't know. But the light is in the hallway for the room. MR. So for an interior room. What about the down the hallway to each for rE T l =— ROW OHMS fwrNP —— wr RPRRR oN Du ee od Wr Ow mre oe RR ae ee RR i) MRRP RRR RRR POoOwCmBADH ew Mmmenmrn Ww Wr 350 MS. MM: Yeah. The cord has to be plugged in. MR . Now do you consider that like a safety issue or anything like that? MS. =. But see that’s the thing. I don't authorize those things. MR. : Sure. MS. : That’s why I said when a person -. You see how the question was asked when somebody comes back from suicide watch. Like is there like something like special being said. Like no because he’s cleared. Because if there was then why would he be allowed to have that in his room? So once you’re cleared and you come back, you’re back. MR. Okay. Were there any other issues with any inmates on August 10th from 12:00a.m. to 6:33 a.m.? MS. : No. MR. disturbances? MS. No. MR. Were there any inmates complaining about the lights being left on or anything like that? Do you recall? No? So there was no each tier? MS. MR. MS. MR. lights off? MS. + No. MR. No? Okay. Now we're going to get into a little into more of the specific stuff. Was there a medical emergency in the SHU in the morning of August 10, 2019? MS. Yes. MR. emergency called? MS. Because when I opened the grill went to go feed, he knocked on the He got no response. And he opened the door. And then he started saying get the cutter. And I heard -. I was on the grill. I heard when he ripped something and he started CPR. WR. ME: Okay. when was the medical emergency called? MS. : At that time. MR. a How soon after um J Oh yeah. It stays on. Were they on 24/7? Yeah. Do they ever turn those Why was the medial and door. EFTA00117730

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rR CWO D SWwrNP RPRRRR We WN Re RRR CoN DD a de ood SWwWNr Ow nm w RR SCwWOnHtDUN SwWwrP 353 entering -- MS. WEB: When he opened the door, he yelled get the cutter. MR. : -+ the cell? MS. : I had the audio on. MR. : Was he already in the cell at that time? Or had he not yet gone in? MS. : He was in the cell. MR. : So he walked into the cell and he yelled out? Did he come back out of the cell and yell to you? : No. He yelled from within? Could you see him at that Could I see him? No. : No? And from eh time that he was discovered to the time of your call, about how much time passed from him saying - entering the cell - and the time that the medical emergency was called by you. MS. :_ A - MR. five seconds -- Are we talking about like 355 the room, and he said get the cutter, before I got the cutter, I heard him tear something. And then when he lowered him to the floor, that’s when I saw him and he started CPR. MR. Alright. So he never said like Epstein hung himself or what he saw. He just said get the cutter. WS. MM: He said get the cutter. And then he started CPR. And he kept saying, “Breathe, Epstein, breathe!” And he was like, “We're going to be in so much trouble.” MR. : And where were you when he was doing that? MS. : On the grill. MR. : Were you in a position to be able to see anything in there? MS. : No. MR. : At any time did you see anything in there? MS. : No. MR. : Did you ever see Epstein in the cell? MS. :_No. MR. : So you never even went over to like look in? PRR RR SwWwKN PCW OHMS SwMN Pe RPRRR oN Du ee od Wr Ow mre oe Re CWO HM fWwrNP MS. : Yeah. MR. : -- one minute or -? MS. : A second. As soon as he said it I did it. MR. MM: 0h so like there’s just button that _you hit? MR. WM: | And did you call it in at that time? “S. coming. WR. QM: Alright. So there's nothing that you call in. You just push a button. : Yes, : Alright. So at the MS. second he told you get the cutter, you hit the MR. medical emergency? MS. Yes, MR. . Did he say anything about what he saw? vs. HE: MS. : No. MR. Okay. So you didn’t actually have to call anything over the radio. It was just_a simple push of a button. MS. : A button. MR. And around what time did you say Epstein was last fed? . After 10:00. : After 10:00 p.m.? . : I mean - not after 10:00. When they fed him in the cell around - I guess after 8:00 or 9:00. MR. MY: | Sometime between 8:00 and 9:00 p.m.? MS. MBB: When I came back from the bathroom. MR. GY: «And who was it that fed MS. MR. MS. MR. And did you say at that point did you actually talk with him? MS. : No. MR. . Okay. And did you or No once you hit it, everybody's When he got - when he entered him? You fed him. EFTA00117731

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rR CWO D SWwrNP RPRRRR We WN Re RRR CoN DD a de ood SWwWNr Ow nm w 1 2 3 4 5 6 7 8 9 10 PRR RP RRP RR COND WMH a a ee ond We wWwrr Ow 357 anyone else recover his food tray? MS. WEB: I don't know if somebody did. Not me. WR. QM: Okay. it? MS. : No. MR. : Who else could have done it if it wasn’t you? MS. MM: I don't know because after the medical emergency, nobody’s allowed to go in the room. So. WR. MMM: So you’re just not sure if by the time you fed him, in that medical emergency, if it was ever recovered? MS. + Right. MR. : Okay. Alright. So when you fed him - can you just again refresh my memory - what is it that you saw with Epstein when you gave him the food? MS. : He gets like microwaveable So I just handed it to him. Through the And he took it. WR. MM: Okay. And any instances where you saw him from the shower to the last time you said you saw him between 10:00 and . : Mm-hmm, . : Okay. . : When you looked through his could you see? MS. MMM: Um his head, his hand, and like maybe to mid-there. MR. : The best of the body was -? MS. :_ Like under his head. Mm-hmm, MR. : So he was laying facing the wall? wS. MMMM: Yeah. He was facing like this big (Indiscernible *04:18:24) is this way. The mattress was here on the floor. Like in front of the bunk on the floor. WR. MBB: And the CPAP machine was it already attached to him? MS. : Yeah. He had it on. MR. : I'm not following what you're saying about that. So the mattress was laying like -. WS. MJ: The mattress was like how you just take it off the bunk and you put it on the But you didn’t do food. slot. Mm-hmm Right. What of his body =— ROW OHMS fwrNP —— wr RPRRR oN Du ee od Wr Ow mre oe RR ae ee RR i) MRRP RRR RRR POoOwCmBADH ew 358 10:30 or whatever that was. Anything unusual? MS. No. MR. : Nothing that caught - raised suspicion? . : No. : No like distress or anything Vike that with him? MS. No. MR. : And you're sure when you saw him at 10:00 - 10:30 he was alive? Yes. (Indiscernible *04:17:41) I'm sorry what? He put his hand up. He put his hand up. Yes. And he wasn’t like Where was he located? on the floor. On a mattress. So he was like sleeping? He was laying on the floor on the nattress and he had the machine. And he had the machine on . : Yep. . : Well he shoves it to the MR. GE: And he was laying on - was he laying on it like the direction of the mattress lines? MS. MMM: That the mattress is going. Yeah. WR. ER: | Alright. like L or aT shape -- So he wasn’t -- with the -. Alright. So he was like . : Direction of the mattress. Ba Okay. You want to ask more on that? MR. : No. Just had that quick. MR. : And you said to your knowledge, no one else saw him between the time you last saw him and when discovered him. vs. Ha: Right. EFTA00117732

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rR CSCwWOmOANDMDS fWwNHP RPRRRR We WN Re RR SD ee ee od Se wWwNr Ow CO nm w RR SwWOHNDN FWwrNP PRR RP RRP RR COND WMH a a ee ond We wWwrr Ow 361 WR. GM: «Did you hear anything from Epstein’s cell between 10:30 p.m. and 6:33 a.m.? MS. : No. MR. : No like movement, talking, ora crash? MS. :_No. MR. : Anything like that? And about how far were you from Epstein’s cell when went in? MS. MBB: I don't know. The grill is right here and the door is right here. WR. QM: «So I mean is it like - so this is a foot, this is two feet, this three feet. MS. : A foot. MR. : A foot? MS. : From the grill to the door right here. But he’s inside. So. MR. : Right. MS. : I'm not in there. So from the grill to the actual door about a foot. Only about a foot? Yes. Now was the grill door - 363 So that’s he knocked, he didn’t get no answer. when | opened the door and went in. I stood on the grill. And as soon as he opened the door and he went in, he started screaming, “Get the cutter!” So I hit the body alarm because I have to - when everybody's coming, I have to let them in. I never went in. WR. QM: Okay. So after he made the call, did you go get the cutter and bring it back to_him? MS. MMM: No. I didn’t get the cutter because he didn't need it. WR. GE: © Because he ripped something? MS. :_ Yes. MR. : And you actually heard it rip? MS. :_I heard the rip. MR. : Okay. And the reason why - and then you left the grill to go let people in? Yes. Alright. So how long after Mike went into the room did you leave the grill station door that was a foot =— ROW OHMS fwrNP —— wr RPRRR oN Du ee od Wr Ow mre oe RR ae ee RR i) MRRP RRR RRR POoOwCmBADH ew Mmmenmrn Ww Wr 362 is that a door that is closed? Was it closed or was it_open? And then [a I opened it. Okay. So was it open entered Epstein’ s cell? I opened it. I opened the qn Por him to go in. . Right. And did it remain aa | | Yes but I’m -. : Or did you close it MS. MR. behind you? MS. BBB: No. open. MR. MM: | So you're only a foot away from Epstein’s cell door though? I’m standing there so it’s And you never looked in? Was it because - why didn't you look in? MS. MM: Because usually the door is not open. His intentions is to feed. So he would just open the slot and put the food in. When 364 away from Epstein’s door? MS. :__Maybe like two three minutes. MR. : So you were there for two or three minutes while he was conducting CPR? MS. : Yes. MR. : And at that time, never once did you actually look in to see what he was doing? MS. : No. MR. | Even though it was just a foot away? MS. : Right. MR. : And that's what I'm asking you. MS. MBM: No by that time, when he’s conducting CPR, I can see because he lowered him to the floor and I could - WR. MY: | And that's what I'm asking. So you could see him lower him to the floor? MS. MM: Yeah. I could see when he lowered him to the floor. WR. WM: | This is where I want to make sure that we're -. I’m asking you what could you see inside? EFTA00117733

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RR rPFCowW OND SwhN re RPRRR Ww = Wh RR SD 18 19 20 21 22 23 24 25 PRR RRR RR NDMP WNPRPOWOHDH SWwNP ae ee od WS Wr rs © Ww oc 365 MS. MMM: 0h no. I can’t see inside the cell. I could only just see MMMM doing CPR. WR. —. But you saw him lower him to the floor? ws. J: floor and I -. MR. So this is what I want to know. What did you see? So what you could see from where you were standing? What could you see? Everything. Because I’m getting confused with what you're telling me. I thought you said you never looked in. You never saw anything. What did you see? From the moment the medical emergency occurred. So he walked to the door -. MS. : When he -- . -- what do you see? MS. : == goes in the door first, I don't see anything. I hear the rip and then he lowers him to the floor -- MR. Okay. So just back up -. What do you mean by lowering him to the floor? Did you watch him rip or just heard? MS. : I heard the rip. MR. Okay. Yes. He lowered him to the 367 WR. QM: «Okay. And at any time did like - and we have to ask this just because of you know, the autopsy and things like that. Did his head smash against the floor? MS. : No. MR. Alright. was like a gentle like -- MS. Yes. MR. MS. Yeah. MR. From you heard it rip. Did you ever hear like [sound]? Hear him like land on the floor? MS. :_No. MR. So you didn’t hear like alright, he ripped this thing. So you think he ripped it and then maintained control of him? MS. MB: Probably. I didn’t see that . I just only heard the rip. MR. a. Alright. But you did see -. Did you see his body after the rip hit the floor? MS. :_No. MR. floor. So everything -- fluid movement? Alright. So he’s on the Maybe like his butt’s on the floor and RR ROW OHMS fwrNP —— wr RPRRR oN Du ee od Wwrerow mr oe RR ae ee RPRRR Ww Wr MRRP RRR Pow OAS Mmmenmrn Ww Wr 366 MS. MM: I only see -. It’s just like this. He's holding him like this. And he puts him to the floor to start CPR. MR. Did he put his arms underneath Epstein’s arms? MS. = I don't remember how he held him directly. But he just lowered him to the floor. I don't remember how he - the details of how he lowered him to the floor. MR. : So he - somewhere on his upper body then lowered him to his like butt to the floor? MS. : MR. : And then he then allowed him to . Or did he place him -? Yes. MS. : No. He didn’t allow him to He had him all the way. WR. MM: So at all times he maintained control of Epstein’s body and brough him to the floor? Yes. drop. And you witnessed all of I just only witnessed when the top part of his body went to the floor. 368 his upper body is up. And that’s when you witnessed him now bringing him down to the floor? MS. MBB: He brought him down to the floor. I can’t see that other half of his body. So I don't know. Just -. WR. ME: «what part of his body do you see? MS. MM: Just the top part like torso up and he’s bringing him down. MR. a. Alright. And then did you see him -? When you say CPR, what kind of CPR was he giving him? . : Chest compression. MR. Pc Any kind of mouth-to- mouth of breath? MS. : No. MR. Did he ever check for his vitals? Did he ever check to see if he was alive first? MS. | | I don't know. MR. : You don't know. Did you witness him check for breath or check for a pulse? MS. MMM: 1 didn’t see that. EFTA00117734

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RR rPFCowW OND SwhN re RPRRR Ww = Wh RR SD 18 19 20 21 22 23 24 25 RR SwWOHNDN FWwrNP RPRRRR we wre RR SD ae ee od WS Wr rs © Ww oc 369 MR. : You didn’t see either? MS No. I just seen him giving compressions. MR. Alright. Did you see him like try to wake him up or hit him or anything like that? MS. : No. Just compressions. MR. :_ Did you have any communication with while he was doing this? MS. :_No. MR. : What were you saying about we're going to be in so trouble. When was that -? MS. said that. MR. : That’s what I’m asking. Did you have a conversation - did you have any communication with JM -? MS. : Oh no. No. MR. Well you did have that right? vs. i: so much trouble. MR. did he make to you? No he said we're going to be in I didn’t say anything. Okay. So what statements 371 still wasn’t thinking like the trouble that we're in now. I was just probably thinking because I know we didn’t do the count. But I never responded because all the inmates by this time are on the door. MR. watching? MS. : Yeah. MR. : This all take place? MR. :__I've got a question. MR. : Yeah. Go ahead. MR. : You said you opened the -- MS. : The grill. MR. : -+ the grill. Did he have keys to open Epstein’s cell? MS. :_ Who ? MR. : : MS. : Yeah. He as the door keys. So there's two separate set of keys? MS. : Yes. MR. So he - that’s the keys that stayed with him the whole time? MS. : Yes. MR. But those door keys -. So on the keychain that you have. What does that Because they're all RR ROW OHMS fwrNP —— wr RPRRR oN Du ee od Wwrerow mr oe RR ae ee RPRRR Ww Wr MRRP RRR Pow OAS Mmmenmrn Ww Wr 370 MS. MMM: Get the cutter. And then I heard the rip. He lowered him to the floor. He was doing CPR. He said, “breathe Epstein breathe” and he said we’re going to be in so much trouble. But I never said anything. MR. You didn't respond to “we're going to be in so much trouble”? MS. :_No. MR. ch Do you know why he said you're going to be in so much trouble? MS. Pt Because we didn’t the count. MR. : Okay. MS. GREGG: I think it’s important though that you convey to him like - that you didn’t understand the magnitude of what had just taken place. Right? Because that’s something that you had expressed. So like not knowing what a cutter was. And maybe that gives insight into why there wasn’t a more in-depth conversation. I think it’s important that -. MS. MM: Yeah. When he said to get the cutter, like I would have to go try to look for where a cutter was. But he didn’t need it because I heard the rip. And then when he said we was going to be in so much trouble, like I MR. : The grills. : That's it? MS. : There’s other keys. The grill, the front door, that middle door, but not the inside cell door key. MR. That’s with FP MS. : Yes. MR. Now when you look inside the cell, you said you could see only Epstein’s upper body. Where was he hanging? S. : I don't know. I didn’t see that part. MR. And when you heard the thud, or you know, the rip and then the body landing. Did you look inside to see what he was doing? MS. MB: When he - when the body -. Because when he lowered the body, he stepped back like to come like it’s almost like he was backing up because you're bringing him down. So that’s how come I was able to just see that part. But I didn’t like to go look in the cell. I was still on the grill. MR. MM: So that’s what I was trying to understand. Where exactly was he hanging? open? MS. EFTA00117735

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RR rPFCowW OND SwhN re RPRRR Ww = Wh RR SD 18 19 20 21 22 23 24 25 PRR RRR RR NDMP WNPRPOWOHDH SWwNP ae ee od WS Wr rs © Ww oc 373 MS. MBB: I don't know that because I don't know where he took him down from. I just only heard the rip and then when he was walking the body like down. WR. QR: So he was - basically his arms were behind Epstein? MS. Right. And he was bringing him -. MR. : And he was pulling him up? MS. :_ -- bringing him down. MR. : Was there a mattress on the floor? MS. MM: Well I'm assuming because the mattress was on the floor earlier. But I don't know. WR. QM: © So from where you were standing, you couldn't see the actual mattress? MS. :_ Mattress? No. MR. pa SO he wasn’t doing CPR like on top of the mattress? MS. Z No. Not that I can remember. MR. : Do you remember what Epstein was wearing? From what you could see from his -? MS. WEBB: He didn’t have a shirt on. 375 MS. : No. MR. | = No? What did his cell look like from what you could see? MS. I wasn’t really looking at his cell. By that point I was just looking at HE doing CPR. I didn’t look in there to see what was going on. MR. a. Okay. So you didn’t notice anything like unusual in his cell? MS. :_No. MR. a. When MM went to his door, did you notice if he actually had to use his key to open it? Or was it - do you know if it was actually already -? MS. :_He used a key to open it. MR. So are you confident that that door was locked? MS. MM: Yes. Because he knocked. And then he used the key to open it. He knocked. He knocked. He didn't get a response. And then he used the key to open. MR. Was there any indication that any of the other inmates could have gotten out of their cells? MS. MBM: No. RR ROW OHMS fwrNP —— wr RPRRR oN Du ee od Wwrerow mr oe RR ae ee RPRRR Ww Wr MRRP RRR Pow OAS Mmmenmrn Ww Wr 374 MR. MM: | So not even like a ripped shirt? Nothing was on? MS. :_He didn’t have a shirt on. MR. Okay. At that time when you saw him, did you see anything around his neck? :_ No. : And when you say no, are MS. MR. you saying there was nothing around his neck? MS. : No. There was nothing around his neck. MR. So there was nothing around his neck? Okay. What did he look like? MS. : Blue. MR. He looked blue? Did he look like bloated or puffy or anything? MS. : No. MR. aw. Did he look like he was deceased? MS. : His face looked blue. But. MR. : Any reason for you to believe that he was alive? MS. : No. MR. : No? Did you see any kind of breath or anything? 376 And you said you don't actually checked to see if he MR. : know if was alive? MS. il Yeah. I don't know. MR. : You just know he went straight into compressions. And did you say you were two or three minutes that you stood there? How long were you actually at the grill when they walked into the door? MS. MB: when I went to go get them to come in the door? Between the time - MR. So you let -. goes in. He goes into the room. He's making these - you know you're watching him do some compressions. He makes the statement, “we're going to be in so much trouble.” How long are you standing there while you’re observing this? MS. : About one to two minutes. Because I'm waiting for - the radio is going to tell me when everybody's -. Because remember, once I hit that button, everybody’s coming. So the radio is going to tell me when everybody’s at - when they’re at the door. And then when I pop the door and let them in. So I go to the door. EFTA00117736

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rR CSCwWOmOANDMDS fWwNHP RPRRRR We WN Re RR SD ee ee od Se wWwNr Ow CO RPE RP RP RRR rE rm SOW SwMre re COW ON DW Sw wr “ ae ee od WS Wr rs © Ww oc 377 WR. GM: «And you never entered Epstein’s cell? MS. :_No. MR. : Who was the second person to enter Epstein’s cell? MS. : That I don't remember because everybody came right at the time I don't remember. WR. QM: «Okay. So you don't remember the first person on the scene? MS. :_No. MR. : Did you assist at all with the medical emergency? MS. : No. MR. : No? So what actions did you take after people arrived? What did you do? MS. WEB: Nothing. They told me to get . a. So did you like leave the . Mm-hmm. . : Like observing? . : Mm-hmm. Yes. 379 . BB: And they didn’t know what they were responding to? They just knew it was a medical emergency. It wasn’t announced that it was Epstein. WS. MM: No. There ain’t nobody that (Indiscernible *04:31:48). WR. QM: «And is that typical for 10 to 15 people to respond? To a medical emergency? wS. MMMM: It - there’s no number. It’s when - whoever is in the building and the body alarm goes off once you’re not in a post - because when you're on a post you can’t leave your post. But everybody else in the building responds. WR. QM: And they just leave wherever they were? To respond? I was on the bottom of the I've got a question. When a body alarm is hit, who gets notified? MS. Control. MR. : And how do they differentiate RR ROW OHMS fwrNP —— wr RPRRR oN Du ee od Wwrerow mre oe RR ae ee RR i) MRRP RRR RRR POoOwCmBADH ew mmr =e Wh 25 378 WR. MM: | Okay. what did you observe from the bottom of the stairs? When people arrived? MS. MB: They got a stretcher. And they put him on the stretcher. And brought him out. MR. Did anyone take over for the CPR efforts that was doing? MS. : I don't remember. MR. : You don't remember seeing this? So this isn’t something that’s vivid in your memory? You know like this whole big occurrence. You're not almost like you’re playing it_in slow motion? MS. :_No. MR. : The details of it? MS. : No because when was doing CPR. Then when they came, they took the stretcher and put him on the stretcher and left. As far as when they're -. Remember it’s a lot of people. So I’m not really seeing like who's two steps - they’re coming out with him. MR. a. About how many people responded? mS. BE: vm. I don't know. Maybe 10, 15. 380 between an inmate altercation versus a medical emergency? MS. MM: =I mean the person that’s hitting the body alarm can say it. But there’s no differentiation. So either way the response is the same. WR. ME: | So you could have said it. You just didn’t say anything. MS. : Like when I hit the button, I could have said a medical emergency on the radio. Yeah, I could have said that. MR. = But you didn’t. MS. : No because it’s the same response. . Right. Mm-hmm . Has anybody ever hit it Yes. And same thing. And people just rush? Everybody comes. Yes. : Okay. Alright. You said you stood there for. a little while on the bottom of the steps. You observed some people going in. You don't know who took over CPR. EFTA00117737

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rR CSCwWOmOANDMDS fWwNHP RPRRRR We WN Re RR SD ee ee od Se wWwNr Ow CO nm w RR SwWOHNDN FWwrNP PRR RP RRP RR COND WMH a a ee ond We wWwrr Ow You just saw -- MS. I don't know. MR. : -+ who put up. remember who put him on a stretcher? MS. | | I don't know. MR. : Did you see the body like fall or anything going on the stretcher? MS. : No. MR. pats Did he ever fall off of the stretcher? MS. :_No. MR. : Did anyone drop the stretcher? MS. : No. MR. When they were moving him, did you see him like get knocked or anything like that? MS. : No. MR. No? Anything then - did you notice anything that could have caused additional injuries to his body aside from what the hanging would have caused? MS. :_No. MR. : No? What did | do after people responded? Do you 383 So you were there alone? Alone. And what did you do at that time? wS. WEB: 1 kept calling control. Like what's going on? And they was like somebody's going to come like to help you. Because remember we were supposed to feed. MR. Who was it -? How long were you in the SHU by yourself after they left? MS. MBB: Um... Maybe like 20 - 15 or 20 minutes. WR. QM: «So just -. Do you remember if -? Now I want to say these names to make sure that they were actually there. Do you remember if the first person to arrive in the SHU was Lieutenant Does that help spark a recollection of who arrived first since you were the one that let them in? MS. BBM: When the medical -. I don't know who arrived first. But he was in there. MR. Because you're the one that had to let them in. Right? =— ROW OHMS fwrNP —— wr RPRRR oN Du ee od Wr Ow mre oe RR ae ee RR i) MRRP RRR RRR POoOwCmBADH ew Mmmenmrn Ww Wr 382 MS. J: After they took him out on the stretcher, he left. UR. MEM: So not after the stretcher. Once at least one person showed up. Do you know what [I did? MS. No because I'm at the bottom of the stairs. So I don't know. Because they're - remember they’re on the top. I’m at the bottom. So I don't know. MR. So could you even see in at all at that point? MS. No. I could only see when they coming down with him on the stretcher. Because I’m at the bottom. I can’t see up there now. MR. Okay. So after you were standing there when you let people in, you really couldn’t see in the door anymore? MS. No. MR. Okay. What happened after they came out with the stretcher? MS. They left out of SHU with him. MR. Did you go with them? MS. : No. I had to stay. MR. You stayed in SHU? Did anyone stay with you? 384 MS. MMM: Yeah. But I don't remember who came in first. But he was there. When was there, I remember :_ Yes. : Do you know how to spell MS. MR. that last name? . : Okay. And did you say anything to the people that arrived? MS. + No. MR. : You didn’t say like it’s Epstein or Epstein hung himself or anything? MS. : No. The only thing they asked -. Because when they come on, they want to know where the emergency is. up the stairs. MR. Okay. Did you make any statements to anybody about saying we didn’t do rounds at 3:00 a.m. and 5:00 a.m.? MS. MM: No. After Lieutenant asked me what happened. When I was getting ready to answer him, came off the elevator and was like, “Oh it’s not her fault. We fucked up.” So I just pointed EFTA00117738

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rR CSCwWOmOANDMDS fWwNHP RPRRRR We WN Re RR SD ee ee od Se wWwNr Ow CO nm w RR SwWOHNDN FWwrNP PRR RP RRP RR COND WMH a a ee ond We wWwrr Ow 385 MR. So at first did you say, “We didn’t do rounds at 3:00 a.m. -- MS. :_No. MR. -- and then he responded it’s not your fault we didn’t do the rounds we messed up? MS. | | No. I didn’t say that. MR. : So that’s not your recollection that you saying we didn’t do the 3:00 a.m._and 5:00 a.m. rounds? MS. :_No. MR. Okay. So they’re saying that you said that. Do you think that they're mistaking? That you told them that? MS. :_ I don't recall saying that. MR. Okay. So you don't recall. But is it possible that you could have said that? MS. WEBB: Probably but I don't_recall saying that. I remember Lieutenant [J asked me what happened. And I was getting ready to tell him what happened. And came off the elevator and said that. But I don't recall saying that. MR. And this is after J 387 MS. MN: Nobody else. Just me, him, and VR. MEM: Okay. And he asked you what happened? MS. MM: He asked me what happened. And the elevator door opened. And came off the elevator. I was getting ready to answer him. And MM said, “It’s not her fault. We fucked up.” wR. QM: «And do you know why he made that_statement? MS. MMM: I think because we didn’t do the counts. Or he -. MR. But why did he say it wasn't your fault? MS. MM: Because I kept waking him up. So maybe that’s why he said that. WR. a. Was he trying to take more of the responsibility? MS. : I guess so. MR. Would that be? Um. Alright. Is it true that if the count is not done and the round sheet which is filled out after 30 minutes also cannot be completed? wS. WM: If the -? =— ROW OHMS fwrNP —— wr RPRRR oN Du ee od Wr Ow mre oe RR ae ee RR i) MRRP RRR RRR POoOwCmBADH ew Mmmenmrn Ww Wr 386 came back from bringing Epstein down? us. Well he went down with them. Yes. MR. WM: «And then he came back? So when you say by the elevator where was the elevator? . : In the hallway. . : Qutside the SHU? In the . : The first door of what? . : The SHU. . : So is that outside of the “vs. I: The SHU door. WR. QM: Outside of the second outer door? MS. : Yes. MR. : So right outside of the outer door? This is where you had a conversation with who? MS. iL Lieutenant J. : Who else was present? MR. 388 MR. QM: | From 12:00 a.m. to 6:33 a.m. That's not actually my question. From 12:30 to 6:30 a.m., none of the rounds or counts were completed. Correct? MS. : (Correct. MR. Alright. Is it true that end of the shift the supervising lieutenant signs and sends the completed log of the inmate movements from the day? Do you know if that’s true? MS. MBM: 1 don't know what they sign, but they sign something. I don't know what it is. WR. MEM: | Do they sign like for instance the round sheets? Do the lieutenants sign that? MS. | | Yes. MR. : count slips do they? MS. : MR. MS. MR. Okay. And what is your belief or understanding of how Epstein died? MS. MBB: Mm. He hung himself. Like right the door the first Like right outside the door. They sign that. But they don't sign the Just the round sheets? EFTA00117739

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rR CWO D SWwrNP RPRRRR We WN Re RRR CoN DD a de ood SWwWNr Ow PRR RPE RR Re rm CON Dw SW N rR OW ON DW Sw Nr “ ae od rr 389 MR. : So you believe he was dead upon entering into the cell? MS. : I don't know. Because I just assumed he hung himself. Because I read the (Indiscernible *04:38:24). MR. So do you believe Epstein took his own life? MS. : Yes. MR. Epstein’s life? MS. :_No. MR. Did anyone assist Epstein with taking his life? . : No. . Yo Did QM take Epstein's . : No. WR. | = Did MMM assist Epstein with taking his life? MS. : No. MR. : Did you assist Epstein with taking his life? . : No. . 7 Did you take Epstein’s 391 WR. QM: «Did anyone ever offer you anything such as something of value or favors with regard to harming Epstein or taking his . :_ No. MR | Did anyone ever threaten you in exchange for harming Epstein or taking Epstein’s life? MS. >No. MR. that those MS. MR. Do you know of anyone else being offered anything to hurt Epstein or taking his life? MS. : No. MR. No? Why wasn’t Epstein in his assigned cell on August 10, 2019? MS. : That was his cell. MR. It wasn't. first you're hearing of that? MS. + Yes, MR. assigned cell. vs. Hi: Did someone else take Do you know anyone else uestions would have applied to? :_No. This is the So he wasn’t in his What? I never knew that. =— ROW OHMS fwrNP —— wr RPRRR oN Du ee od Wr Ow mre oe RR ae ee RR i) MRRP RRR RRR POoOwCmBADH ew Mmmenmrn Ww Wr 390 MS. : No. MR. | = Did you have any part in Epstein’s death? MS. : No. MR. : Prior to Epstein dying, did you have any communications - verbal, electronic, handwritten, or otherwise - with anyone - BOP staff members or otherwise, about the safety and wellbeing of Epstein? MS. No. MR. : Alright. Do you need me to -? That was pretty long. Did you catch everything I just asked you there? MS : Yes, MR. : This is going to be another long one. Prior to Epstein dying, did you have any communications - verbal, electronic, handwritten, or otherwise - with anyone - BOP staff members or otherwise -. And when I say otherwise I mean like civilians, inmates, you know anybody on the streets. . Okay. MR. aes About the death of Epstein or taking Epstein's life? vs. HE: No. 392 MR. QR: «Did you - but it kind of doesn't surprise me because you said that you didn’t even know who was in what cell. You just looked to see if people -. So Epstein is assigned to the cell across the hall. He wasn’t in the cell that he was actually assigned to. Do you -? MS. MMM: Wait. You said across the hall? So like not in SHU? The same tier. But you . Oh. . : == they do inmate cell rotations? MS. : No. MR. : So you do not know that inmates are moved from different cells? MS. MB: Yeah. I know that. They move you said if I know how they do that? I don't know that. MR. = Do you know how often? . : Often they do that? I’m not MR. QM: «Are you responsible for reviewing - as your assignment, duties, and EFTA00117740

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rR CSCwWOmOANDMDS fWwNHP RPRRRR We WN Re RR a rR ~ ee ee od Se wWwNr Ow CO nm w RR SwWOHNDN FWwrNP PRR RP RRP RR COND WMH a a ee ond We wWwrr Ow 393 responsibilities within the SHU - of verifying that the inmates are in the cells that they're assigned to? MS. MBM: I don't know if I’m responsible for but there is -. Their ID cards are on the door. WR. MMM: «Was Epstein’s 1D card on his door? MS. | | No. MR. : else on the door? MS. :_No MR. Was there anything on the door that said something about him being required to have a cellmate? MS. :_No MR. So you don't know anything about him not being in his assigned cell? MS. : I never knew that. MR. Okay. So this is the first you're even hearing about it even since the incident? MS. : Right. MR. Not all of them. Okay. Was there anything So you -? 395 MR. Did you ever have any dealings MS. MR. s actual] with that? :_I never even knew that. so is this the one he was in? Yeah. MR. So he was in cell 220. He was assigned to cell 206. MS. + Mm. MR. you dealt with? MS. :_No MR. rotating MS. MR. with that? MS. :_No MR. rotated? MS. the 8:00 to 4:00. MR. While - yeah. That’s what I’m asking. I’m not saying just for Epstein. I’m saying like in general, have you ever witnessed inmates being rotated to But that’s not something Did you ever deal with the inmates into different cells? : No. Do you know who deals Do you ever see them get : On =— ROW OHMS fwrNP —— wr RPRRR oN Du ee od Wr Ow mre oe RR ae ee RR i) MRRP RRR RRR POoOwCmBADH ew Mmmenmrn Ww Wr 394 MS. [B: So you said he was assigned to the cell across from him? Because that had people in it. MR. He was - yeah. Because of cell rotations. It doesn’t mean that -- . + Oh, okay. MR. : -+ I think as far as you were concerned, he was in that cell. You didn't move him to a different one. But administratively, he was in a different cell and was moved and the assignment didn't follow him. . : Oh, okay. MR. | = So on paper, he was supposed to be in one cell. In reality he was in another. MS. Okay. MR. | So if you look in the system and find out hey where was Epstein supposed to be? He was supposed to be over here from the paperwork in the book. MS. : Oh, okay. MR. He was physically located over here. MS. Okay. different cells? : One time. MR. : One time? And how was that - how does that play out? MS. :_ I think I saw it, was doing it. Like I don't know. They told them to pack up. They pack up they stuff, two people move them, and they go to the cell that they supposed to go. MR. And then do you know what they're supposed to do at that point with - in order to make sure the paperwork follows them - - the day when Oh. I don't know -- -- to that cell? MS. MR. Would it be the lieutenant in your opinion? Or you just don't MS. know. : I just don't know. MR. : Okay. And is that anything you've ever dealt with as far as like : No. EFTA00117741

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rR CWO D SWwrNP RPRRRR We WN Re RRR CoN DD a de ood SWwWNr Ow nm w 1 2 3 4 5 6 7 8 9 10 PRR RP RRP RR COND WMH a a ee ond We wWwrr Ow training or that you recall? MS. :_ The cell rotation? No. MR. : Do you know if it’s supposed to be every certain amount of days? MS. MB: I know it’s supposed to be every certain amount of days, but I don't know. WR. QR: «Do you remember Epstein ever being assigned to cell 206? MS. : I don't know where cell 206 is. That's the_one across from where he was at? WR. QM: They're both on L Tier, so I'm just assuming. MS. : Oh. MR. : Because there’s the paperwork that shows that’s not even the number. MS. MMM: Yeah. The number is not on I don't know what cell is 206. But -. WR. QR: «So when you're in the SHU in July and August when he was - when Epstein was assigned to the SHU. Do you recall him ever being in a different cell than the cell you found him in - or round him in on August 10th? ws. HE: BOP database tracks that? MS. :_No. MR. : Why were there pill bottles found on the top bunk of Epstein’s cell? . :_ I don't know. : Do you know anything about like medication or what was found in there? MS. : No. MR. : Do you have any idea what was even -? Did you ever go in Epstein’s cell prior ° this incident? ‘es Do you know if Epstein was aiorined to have pills in his cell on the a here. Yes. He was downstairs. don’ t know. Do you know if that’s like abrarmal or are inmates allowed to have medications in the SHU? They're not allowed to? They’re not allowed. Even if it’s prescription =— ROW OHMS fwrNP —— wr RPRRR oN Du ee od Wr Ow mre oe RR ae ee RR i) MRRP RRR RRR POoOwCmBADH ew mmr =e Wh 25 MR. : Downstairs? MS. : On I think M tier with . Because that was his cellmate first. MR. MM: Alright. So what about on L Tier? You ever remember him being in a different_cell up there? No? Alright. So. So the incident happened on July the 23rd. He comes back on July 30th. From your recollection from eh time that he came back and he was with MM, he was always in that same cell? MS. MR: And in that (Indiscernible *04:44:20) cell? Yes. MR. = Alright. So maybe he wasn't rotated but on paper it was rotated? MS. : Maybe. MR. : But you don’t know anything about it? I don’ t know anything. No. Okay. Do you know what an I don’ t know. Do you ever provide inmater prescription medication when you're working in the SHU? No. The nurse does. The nurse comes around? " $0 js that surprising to hear that there were medication in his cell? . : Yes. And you knew nothing ort tn being in ‘there? Sa. Is it SHU policy for things. Tike medication - is it different than the other housing units? MS. MBM: Yes because I think on housing units they can have prescription medication in then cell Okay. But in SHU they can't. And do you know that to be a ra Or is that just your belief? I don't know it to be fact. EFTA00117742

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rR CWO D SWwrNP RPRRRR We WN Re RRR CoN DD a de ood SWwWNr Ow nm w RR SCwWOnHtDUN SwWwrP 401 WR. MM: Okay. Do you know if any other inmates in the SHU are allowed to have medications in their cell? MS. : I don't know. MR. : How many changes of clothing and linens are inmates allowed to have in the SHU? MS. 4 I think one. MR. : It’s supposed to be a one-for-one exchange? MS. :_ Yes, MR. : for both linens and clothing? "s. I: clothing. WR. QM: Okay. Why did Epstein have extra clothing and extra linens in his cell -- For linen. I’m not sure with I don't know. : == on August 10th? I don't know. You don't know. But you said that was something that you did though? As far as your duties? Is to be able to provide people with linens and clothes? 403 WR. QM: «No? And did you ever provide Epstein with additional clothing or linens? MS. : Never. MR. : Do you know of anyone that has? MS. : No. MR. : You never witnessed a a provide him anything extra? No. ‘ess Do you know if providing inmates with extra clothing and linens is a sory risk? I don’ t know. No? If you saw that an innate. had extra clothing or linens, would you do anything about it? MS. :_I mean I'd ask. MR. : Who would you ask? MS. : The officer I'm working with. MR. : And did you ever have to do that? MS. :_ No. MR. : So you never witnessed anybody? PRR RR SwWwKN PCW OHMS SwMN Pe RPRRR oN Du ee od Wr Ow mre oe Re CWO HM fWwrNP 402 MS. MM: I never gave out linen. Ever. Because that’s done on the shift prior. MR. : What shift is that? MS. : 8:00 to 4:00. MR. : And did you ever work the 8:00 to 4:00 shift? MS. MMM: Yes. But I worked the 8:00 to 4:00. When I come in to do overtime before. But it’s not always in SHU. MR. a. Okay. So have you ever worked 8:00 to 4:00 in the SHU? MS. :_I think I have. MR. : And do you remember doing giving - doing the linens? I never gave linen. : You never gave linens. What about the clothing? Never. When is that done? I give toilet paper. Say that again? WR. WM: when is the clothing done? vs. HE: 404 . : Because I never saw it. . MR. | Okay. And when you're looking in doing your counts and your rounds, are you looking for things like that? Of like : Not really. : You're just looking for the person? You're not looking to see what's going on in their cell? MS. BB: Correct. Sometimes they don't even let you see their cell. They're like standing in the window blocking the window. WR. GM: But it's your understanding though it’s supposed to be a one- for-one exchange? MS. : Yes. MR. : Do you know what material was used to take Epstein’s life in August of 2019? MS. : I don't know. MR. : Do you know if Epstein was given any special privileges to have extra clothing? MS. : I don't know. MR. | If he was, do you know I don't know. EFTA00117743

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rR CSCwWOmOANDMDS fWwNHP RPRRRR We WN Re RR SD ee ee od Se wWwNr Ow CO RPE RP RP RRR rE rm SOW SwMre re COW ON DW Sw wr “ ae ee od WS Wr rs © Ww oc who would provide that? :_I don't know. : Do you know if there was anything else that was in Epstein’s cell that should not have been here? MS. Only the CPAP machine. MR : Okay. Tell me about cell searches. What are the requirements for when - you said your typical shift is I guess the afternoon shift? Right? Or do you call it evening shift I guess? MS. : Yes, MR. : Is that the 4:00 to 10:00? MS. MR. MS 4:00 to midnight. MR. : 4:00 to midnight. Sorry. What are the cell search requirements during that shift? MS. :_ I don't know. MR. : Did you ever read the post orders with regard to that? MS. :_ No. MR. : But they’re in the SHU? You just didn't read them? MS. Right. 407 MS. : No. MR. | = Did they ever teach you that during training that you're supposed to do that? MS. Mm. I don’t recall. MR. : You don't recall? It’s just something that you never-ever witnessed? MS. : Never. Never saw it. MR. : Even when you were working that like earlier shift? You know when you're doing your OT or your regular shift? Never once witnessed a cell search. MS. : Never. MR. | = And do you know - of things that you do know in there, would any of that be considered contraband? That was in there? Now that you know that medication was in there. The CPAP machine. Or the extra linens. Or the extra clothing. MS. In his cell? MR, Mm-hinm . Do you want to show her just so she can get a - know what we’re talking about here? So is this RR ROW OHMS fwrNP —— wr RPRRR oN Du ee od Wwrerow mre oe RR ae ee RR i) MRRP RRR RRR POoOwCmBADH ew Mmmenmrn Ww Wr 406 MR. QM: Do you want to - have any? We're almost there. Well while I’m going thought the questions can you just find that? MR. °. MR. : Have you ever heard that during your shift you're supposed to conduct five cell searches? MS. MR. MS. MR. Did you ever witness anybody conducting cell searches when you -- Random cell searches? -- were working the SHU? . No. Do you know if any cell searches were conducted on August 9th or August 10th? MS. : No. MR. search is? MS. MM: when you go in there and search their cell. MR. GM: | Right. Of an inmate. And you never observed that in the SHU? Do you know what a cell 408 L Tier as we're referring to? And is the outer gate that you were standing at that you were talking about? MS. :_ Yes. MR. Alright. And then when you say you're staying at the lower part of the steps, is it about right there that you were standing? MS. | | I was standing over here. MR. : Over there? Do you have a pen? Do you just mind marking it? So that’s where you were standing? Alright. And in that picture, can you see where Epstein was? MS. :__ From down here? MR. No-no-no. his -? I’m assuming -. MS. J: Oh! No-no-no. this side. MR. MM: Right. So we can see part of the two when it’s crossed. But does this look like Epstein’s door? MS. BEIM: This is the first door on the right. Yeah. MR. And from what you can see from where you were standing, did that look I'm sorry. Is Because he’s on EFTA00117744

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rR CSCwWOmOANDMDS fWwNHP RPRRRR We WN Re RR SD ee ee od Se wWwNr Ow CO nm w RR SwWOHNDN FWwrNP PRR RP RRP RR COND WMH a a ee ond We wWwrr Ow 409 like what you saw? MS. =. I didn’t see all of this. I saw like here. Because I’m on the door. So he’s doing CPR like here. So I didn't see all that. WR. MM: Alright. So you couldn't see all that extra clothing and linens right . : No. MR. | Does that look like a lot of clothing and linen to you? MS. : Yes. MR. ae Here’s a couple extra pictures of some different like advantage point. Does that all look like extra clothing to you? wS. BRM: Yes. right here. And there’s the machine That’s the CPAC machine? MR. : Okay. Again though, you don't know what he actually hung himself with? : I don't know. Is this the way that he 411 WR. QM: Yeah-yeah-yeah. I'm saying during sleeping hours. Did you ever see Epstein prior to this instance? Prior to August 9th have you ever seen Epstein sleeping in his cell? WS. WEB: when he comes back he lays floor. WR. QM: «SO when : would observe this i. MS. : Oh be up. So I never md Like IBM is always up. wR. QM: «Is there only one bunk in MS. : It was these two. MR. : Yeah. So the one MS. : Yeah. One. MR. : So if I'm assuming if sleeping next to him. WS. MM: There. But I don't know if there on the floor. On the mattress on the that, would you see where was? Prior to seen like where that room? bunkbed? he’s sleeping on the floor then I would be this was because IMM wasn't there. Or he Wey fwrP 10 ed ae ee ol od oo od ee ee AWN OWSOAUDH EWN RR ae ee RR i) MRRP RRR RRR POoOwCmBADH ew Mmmenmrn Ww Wr would usually lay on his bed? . :_ Yes, a Was he the top bunk guy then? And do you know where ? would I don't know. Is it only like -? Because he’s always on the WR. MM: kay. But I see that the top one doesn’t actually have it. It doesn’t look like it has a -- MS. : Right. A mattress. MR. : == mattress. So do you know if would sleep like right next to him? MS. I don't know. MR. : You don't? Did you ever check in on them when you were - or that was the first night you said you -? MS : That was it. MR. : So did you ever observe him in a sleep state before? MS. MMM: Because he’s never really there. Epstein could have been on top. I don't know. MR Okay. So if this is where took him off of, is that what you couldn’t see that from the door form that vantage point? MS. : Yeah. I can’t see that. MR. : You couldn't see that. Okay. So did you ever notice that type of medication in there before? MS. :_No. MR. | = And that’s something you believe that shouldn't have been in there though? Yes. Does anything here look out of the ordinary to you? With what -? MS. MB: What's in the (Indiscernible 04:54:17) right here? MR. : I don't know. I’m asking you. Does any of that look out of the ordinary to you? MS. MMM: Yeah. There's couple. Whatever's in the bag. MR. in there. Okay. But you never went You never saw any of this? EFTA00117745

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rR CSCwWOmOANDMDS fWwNHP RPRRRR We WN Re RR SD ee ee od Se wWwNr Ow CO RPE RP RP RRR rE rm SOW SwMre re COW ON DW Sw wr “ ae ee od WS Wr rs © Ww oc 413 MS. : No. MR. : And cell searches were never conducted. So no one even went in to ever check to see what was in these cells. MS. : Correct. MR. : Here’s three additional pictures if you want to look. Does any of this stuff look abnormal to you? MS. : All these. MR. : Everything? Looks abnormal? MS. | 4 The medication. MR. : the medication? And it was never discussed with anyone about cell searches? Ever. In the three - you know two and a half months that you were in there? WS. QM: That (Indiscernible *04:55:35) in there. WR. QR: Okay. And did you ever get to see what it was that Epstein used to hang himself? MS. :_No. MR. No. Alright. Rather than have you do all those individual, I’m going to just separate this. If it’s okay with 415 MS. :_No. MR. | So did it even cross your mind that there was always a cellmate with him prior to that time? MS. :_No. MR. : Did you ever -? Were you ever told that was removed from the institution? MS. :_No. MR. And is that something - being that’s the high-profile nature that he is that like -? Is that something that you would notice though? That like hey this guy usually has a cellmate. He’s not in there right now. Where is he? him? Did even cross -? Didn’t cross your mind. the people in there and you're not worried about who is in there. The people in there are alive. That's all you're worried about? wS. WB: Yes. RR ROW OHMS fwrNP —— wr RPRRR oN Du ee od Wwrerow mre oe RR ae ee RR i) MRRP RRR RRR POoOwCmBADH ew Mmmenmrn Ww Wr 414 your attorneys. Just have her do the top one. Unless you prefer to -. MR. FOY: No. That's fine. WR. MM: Here. Keep these away from that. I'l] just keep everything next to her anyway. MR. : And the -. MR. : That’s fine. (Indiscernible *04:56:07) she didn’t know about it anyway. How were Epstein’s interactions with other inmates? MS. : I don't know. MR. : Did you ever see him interact with other inmates? MS. | | He's never there. No. MR. : Did you ever see him interact with his cellmates? MS. : No. MR. : No. You said -. But the last time you interacted with him was just that one raising of the hand. MS. : Yeah. MR. : Was it surprising you to notice that there was no cellmate in there with 416 MR. QR: | Did Epstein ever complain about anything? MS. : Not to me. MR. Do you know if he complained about anything to anyone else? MS. MBM: Just the time when he asked for the mattress. The extra mattress. That was a request Initial that one MR. : Was it a complaint? Did he say anything along with asking for an extra one? MS. BHM: Well how it was relayed that he was complaining that he needed another mattress. MR. : Okay. MS. : I don't know if you want to take that_as a complaint. MR. : Did you ever hear him complaining about other inmates? MS. :_No. MR. : No. Never complained about being in the SHU versus somewhere else? MS. : No. EFTA00117746

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rR CWO D SWwrNP RPRRRR We WN Re RRR CoN DD a de ood SWwWNr Ow PRR RPE RR Re rm CON Dw SW N rR OW ON DW Sw Nr “ a a ee ond We wWwrr Ow 417 WR. GM: © So no complaints other than that_mattress. MS. :_No. MR. Do you know if there were any threats made to Epstein? MS. :_I don't know. MR. Do you know at the time did you know why Epstein was in prison? MS. : Well he -. MR. You said you did some internet searches or you saw some things but -. MS. Right. After the fact. But initially no. WR. WE: Didn't you say there were things that would populate on the computer? MS. MM: Yeah. That’s why I said after. When he initially first came in there, no. I didn’t know. MR. 9th or August 10th. MS. Oh. MR. MS. MR. And did you have any specific feelings with regard to why he was in I mean prior to August Yeah. Yeah? It’s not a trick. MS. :_Hm-mm. MR. So you're not aware of you doing anything? MS. : No. MR. Alright. But you know went into the cell before he was supposed to. MS. : MR. He was supposed to actually wait for someone to come and respond? MS. Yes. MR. Yes, And why is that? MS. Why did he go in? MR. No. Why does he need to wait for them to respond? MS. MM: Oh I don't know. That’s the rule. I ues. WR. a. Okay. And by you standing outside at that gate, he still wouldn’t be allowed to go into the room? :_ Who me? So even the way you did. : Oh because I was there. No. =— ROW OHMS fwrNP —— wr RPRRR oN Du ee od Wr Ow mre oe RR ae ee RR i) MRRP RRR RRR POoOwCmBADH ew mmr =e Wh From what I understand, you're supposed to wait] 25 418 prison? . No. . | Did you ever speak about Epstein with other inmates? MS. No. MR. In your opinion when the medical emergency was discovered, did you and act appropriately, per BOP policy? Now that you've had time to reflect on it. MS. BB: Um I know now that when there's a medical emergency, you're not supposed to enter the cell until everybody gets there. So that would be the only thing that I would say like that wasn’t done correctly. But as far as everything else -. . Now was that per [I What I’m saying or -? . Yeah. So the one thing that you know that was incorrect. What about what you did? Was there anything that you did that wasn’t correct? : If it was I don't know. No-no-no. I’m asking. It’s a genuine question. 420 And then go in. Okay. And how did you until people come. a: learn that? MS. MB: After. That's what I heard them saying. MR. a. That’s what people were telling you_on August 10th? MS. MR. MS. :_ Yes. That you -. : Not telling me but just in conversation. Like after. MR. What conversations did you have with people after? MS. WEB: I didn’t have no conversations. I just heard them saying should have never went in there by himself. I don't even remember who said it. But somebody that was in the SHU. WR. WM: | Did anybody say anything about your reactions? MS. : No. MR. : No. Do you know if he needed to just wait for one person or a bunch of people? How does that - what did you hear with regard to that? EFTA00117747

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rR CWO D SWwrNP RPRRRR We WN Re RRR CoN DD a de ood SWwWNr Ow PRR RPE RR Re rm CON Dw SW N rR OW ON DW Sw Nr “ ae od rr 421 . | | I didn’t hear nothing else. . : When I said you I mean =z I don't know. . : Oh. MR : Do you believe that HEM acted appropriately? Being that you were there and you observed it. MS. WBBM: what the stuff that he did? Yes WR. WM: Yeah. Do you think he should have waited for someone or you think it’s like - there was a medical emergency and - ? MS. WEBB: 1 think it was a medical emergency and he was just trying to get to try to help him. WR. QM: Alright. And did you and HM know that Epstein was the only person in the cell then? Or did you not know if was in there or not? MS. MB: When I counted, I knew that he was in there by himself. MR. —, Okay. Just for background, I believe the reason why you're supposed to wait is in case it’s a ruse and 423 Yeah. We didn’t do the rounds. Yeah. . Any other questions other than that? MS. WEB: Um they asked me to go downstairs to the lieutenant’s office. And then I was just standing down there. . a. But no one spoke with ° No. . Beas Did anyone even ask you how you were? Oh the psychologist asked me you about the information -? MS. MMB: No. They didn't ask me anything about that. MR. mental wellbeing? MS. : Yeah. MR. And what time did you stay at the institution until on August 10th? wS. WM: I left like around after 8:00. It was just about your =— ROW OHMS fwrNP —— wr RPRRR oN Du ee od Wr Ow mre oe RR ae ee RR i) MRRP RRR RRR POoOwCmBADH ew Mmmenmrn Ww Wr 422 someone wants to trick you to get in and then you - the other person overpowers him. And now has a -. MS. : Right. MR. : So that’s my point. Do you know if was aware if anyone else was in there? MS. : I don't know. : You don't know. MR. Not something you discussed with [IN though? MS. : No. MR. : Did any supervisors or staff talk with you about the incident? . Okay. So I just want to - again, when I ask you these questions just make sure we say like aside from this or that. So any other things aside from that instance where they asked you what happened. And you said you don't recall saying we didn’t do the 3:00 a.m. and 5:00 a.m. rounds. But you do recall QM saying it wasn’t her fault. 424 WR. QM: «A little bit after your shift? : Yes, : You didn’t have to stick MS. MR. around for anything else? MS. No. MR. paperwork? MS. : No. a. You were left right MR. around the end of your shift. Did they tell you to leave? MS. I: Did you have to sign any My shift was over. They said I I just mean like did they instruct you to go home. You just had a traumatic experience. Or it’s just your shift was ended. And you left. MS. MM: My shift was ended and I asked can I go now. And they said go. MR. Okay. And who was that who said go? , MS. :_ The lieutenant. MR. : Do you remember which lieutenant? EFTA00117748

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rR CWO D SWwrNP RPRRRR We WN Re RRR CoN DD a de ood SWwWNr Ow PRR RPE RR Re rm CON Dw SW N rR OW ON DW Sw Nr “ a a ee ond We wWwrr Ow MS. MR. not MP MS. . MR. Okay. [E. But you didn’t have any other conversations with MS. :_ No. MR. : Okay. Did you ever handle or touch Epstein’s paperwork? Epstein’s file or paperwork? Prior to your departure from the MCC_on August 10th? MS. : No. MR. So in that time from - you said you were there by yourself for 20 minutes. Did you ever go near his file? MS. MM: I don't even know where his file is. No. WR. GM: | Alright. Do you know if they keep files on inmates? I think they’re called like - what is it a 292 or something like that? MR. : Yeah. : Eh no. : Do you know what's kept MS. in a 292? MS. MR. : After 4:00 a.m.? : No 4:00 p.m. MR. : 4:00 p.m. So when you say the earlier part of the day, you mean the later part of the day? MS. BEB: No like when the shift starts at 4:00 after you feed. That's the time I see them like log in to say okay they’ve been fed. But I’ve never really -. One day, I actually like was in there because [I was showing me how to do it. But I don't necessarily do that. Somebody else will do it. MR. And what was he showing you how to do? MS. : How to log it. MR. So what is it that you're supposed to log? You know in the system? MS. MB: I vaguely remember because I don't did it - he only showed me that one time. I think you're supposed to like log if they showered, log if they were feeding, and I don't know, if you gave out stuff. I guess. I don't know. WR. QM: «But you don't - you're not aware of an actual paper file? MR. =— ROW OHMS fwrNP —— wr RPRRR oN Du MmMNrNrNrYre SewWwNr Ow nm Ww RR ae ee RR i) MRRP RRR RRR POoOwCmBADH ew r Mmmenmrn Ww Wr 426 MS. : No. MR. | = Like when you feed an inmate or when you give them -. MS. MB: 0h that's like when you log into and you're - okay. MR. a. Is there also paperwork that follows that or is it just logging into the BOP system? MS. : That’s logging in to the system. MR. WM: Okay. When you - during the time that you were on your shift at all on August 10th did you ever log into that system? MS. + No. MR. So you never had to enter than you fed him or you went into -? MS. : No. MR. anything like that? MS. : No. : When would that be done? : At the earlier part of the day MR. MS. or when you feed. MR. So around what time? . : After 4:00. And you checked on him or 428 MR. : Where those things are monitored or tracked? MS. MR. for any inmates? MS. : No MR. You never filled out paperwork or kept files for inmates? MS. : No. Never. MR. So obviously you never handled or touched Epstein's paperwork? MS. : Never. MR. Or his file? Did you ever remove any of Epstein’s paperwork from his : No. And you never did that No MR. Did you ever remove or destroy any of Epstein’s paperwork? MS. : No. MR. Did you ever remove or destroy - that’s a repetitive question. Did you ever remove or destroy any signs related to Epstein to include signs that said he was required to have a cellmate? EFTA00117749

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rR CWO D SWwrNP RPRRRR We WN Re RRR CoN DD a de ood SWwWNr Ow nm w RR SCwWOnHtDUN SwWwrP 429 MR. : Did you access any BOP databases such as BOPWARE, SENTRY, TRUVIEW, after Epstein was discovered on August -- M MR. -- 10, 2019? That was no? S No R : “WS. BE No. MR : Did you report - was that the last time you reported to work? On August 10th? MS. : Yes. MR. : Were you placed on administrative leave? By whom? MS. :_ Yes, MR. : MS. : Mm. I don't know. I got a phone call saying that I was placed on administrative leave, but I don't remember by who. And then I got the letter. MR. : Did you ever receive an explanation verbally? MS. : No. MR. : No? So the person told you that you were on administrative leave -? outside of the elevator. MS Yeah-yeah-yeah. No. MR. : But you guys didn't actually converse? You were just both talking to the lieutenant? MS : Right. MR. : you ever converse? MS. : No. MR. aw. Didn’t you guys talk somewhere else? MS. : No. MR. : Since then? Like outside of work? MS. : No. MR. You don't recall anytime? So if he says that you guys talked it up, you don't remember that? MS. MBB: We never spoke until we had a union meeting. MR. : Ever. WR. QM: «0h never spoke until that union meeting. That was just like two weeks ago. But we never ever spoke. And at no point also did That’s what I’m asking. PRR RR SwWwKN PCW OHMS SwMN Pe RPRRR oN Du ee od Wr Ow mre oe Re CWO HM fWwrNP 430 . That was the extent of the conversation? MS. MM: And then I said so when do I come back? And they was like you'll get a call like when_or if you're supposed to come back. MR. a. Okay. And what did that administrative leave change to a different type of leave? . i Suspended without pay. MR. : Indefinite suspension? Was that it? Is that what you’re on right now? MS. : Yes. MR. : Okay. Did you communicate with P| after Epstein’s body was discovered? MS. : No. MR. MS. we was not allowed to communicate. before -. WR. QM: What about -? I'm talking about right after the body was discovered. People respond. And then did you communicate? You talked about the one instance 432 WR. QM: | That’s kind of like - when I say EVER, that means ever. Any time from then until this moment? MS. From then until the union meeting, we never spoke. MR. Alright. discussed at the union meeting? MS. MM: That we're going to have an investigation and the union is there for us. They're supporting us. Stuff like that. . But did you discuss this Did you communicate -? : We communicated never because Even - well So what was What? The investigation? . Did you ever discuss like what you were going to tell us? MS. MR. Or what you were going to say during an interview? MS. : No. MR. : So what did your communication entail? MS. BB: with MP It wasn’t with MMMM. But he was present. So basically the : No. EFTA00117750

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rR CSCwWOmOANDMDS fWwNHP RPRRRR We WN Re RR SD ee ee od Se wWwNr Ow CO RPE RP RP RRR rE rm SOW SwMre re COW ON DW Sw wr “ ae ee od WS Wr rs © Ww oc 433 union was saying you know they’re fighting for us. They're there for us. They're supporting us. You know that was along the line. We're going to have to meet with you guys to be investigated. Just tell the truth. That was along the_line. MR. Okay. MS :_ But my conversation wasn’t directly with J. It was - we were both being told. MR. So aside from the union and with that interaction with , was anybody else that you discussed the Epstein incident with since August 10th? MS. :_No. MR. : No. attorneys? MS. : More or less. Mm-hmm. : Is there anything else Aside from your MR. that you want to add to anything we've talked about? Being and just keep in mind the - under oath. What you just said. The union said just tell the truth. The way that you get in trouble from this point forward is basically if you don't tell the truth. You know, anything 435 WR. QR: After the incident happened, did you -? After Epstein was removed, did you see any lieutenants at the MCC? MS. :_ Did I see any lieutenants? MR. Yeah. Which lieutenants did you see at_the MCC? MS. WBBM: Lieutenant MM, but who was there? MR. QJ: Yeah whoever’s present. Did you actually see. MS. =. Lieutenant MJ, Lieutenant HB, Lieutenant was getting off but she came like to help feed. MR. She came back to help feed? MS. + Yes. MR. Did you have a conversation with her? MS. MM: Lieutenant I? MR. : Yeah. MS. : No MR, back to hel MS. MR. MS. How did you know she came feed? I was there. And where was she when -? : Where was she when? RR ROW OHMS fwrNP —— wr RPRRR oN Du ee od Wwrerow mre oe RR ae ee RR i) PRR RP RRR Wonymnufw 434 that we need to clarify. Anything that you can think about. Like maybe I should provide some additional background information regarding No. I don't of know anything. . Okay. So everything good for - because I just want to pass it over to see if there’s anything that Agent [| wants to ask. MR. MB: §=You mentioned there was an office in the SHU for the lieutenant. MS. : Yes. MR. Where is that located? MS. : Upstairs outside of the door for 10 South. Who normally sits there? The lieutenant. Who would that be? Lieutenant J. . Have you ever been in that office? MS. : No. MR. Do you know anyone else that utilizes that office? MS. No. 436 MR. QM: Yeah. When you were leaving. Where was_she? MS. : In the SHU. Okay. She was in the SHU in the SHU? : Helping feed. What time are we talking . : This is after the incident. : Oh, okay. : This is just for clarification purposes. MS. : Okay. MR. : I know you mentioned this before, I’m just going to clarify it. A couple of questions. Did you ever assist any inmates with making phone calls? MS. : No. MR. : Do you know that if an inmate wanted to make a phone call, how would they go about it? MS. MR. MS. : : They use their PIN number. Is every inmate assigned one? Yes. EFTA00117751

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RR ROW OHM SWwrNP RPRRR We Wr RR SD 18 19 20 21 22 23 24 25 RR SCwWOnHtDUN SwWwrP RPRRPR RRR SOW WNP ee ee ed eS WwrN Pr CO wc nm wm 437 WR. QR: © Can they call anybody they wanted to? MS. : I don't know. MR. Is there a restriction on certain people that they are allowed to call? MS. Pa I don't know. MR. Okay. Did you know that inmate calls are monitored? MS. : Yes. MR. Do you know the difference between a monitored line and the legal line? MS. : Meaning.... MR. So there was one line that’s used to make legal phone calls that’s just for attorneys. MS. MR. monitored. MS. : Oh. MR. But the other line is any calls that they make is recorded. MS. Okay. But I don't know where like which line is which. But I am aware that there's the recorded line and the other line. But I don't know which one is which. Or where 439 MS. MB: That I don't know. If any CO could just plug it in. I don't know. MR. : You don't know. Would you happen to know if Epstein had a PAC and PIN assigned to him? MS. WEB: =I would think he would. don't know for sure. WR. MM: Do you recall that night when HM set up the phone call. Did he tell you who Epstein was supposed to be speaking to? MS. : No. MR. : That's all I have. MR. And then the two final follow-ups. Just because we discussed it and I kind of gave it to you from memory. But this is the special housing unit post orders regarding cell rotations and cell searches. It just quickly says, “All SHU staff are expected to conduct searches of the special housing unit. The morning watch officers will conduct searches of the common areas and document their findings in the search section of the True Scrub Program. (Phonetic Sp. *05:14:00) The day watch officers will conduct a search of every inmate’s cell who attends recreation. : Okay. So those - that line is not But I a CWO HUDMS fWwrNP —— COUT fwr re mnmry Le mrer WW = Ww Wey DHfwrP PRR RRP RRP RRR WeonyDwVfwrNro mre reo MmmenNn Ww Wr 438 the legal line is. MR. Okay. You said it was not weird Epstein was left alone with the phone. Has this happened before? MS. : Where an inmate is in the tier using the phone? Yeah. MR. : Who - to your recollection - which other inmates were allowed to make phone calls like that? wS. MBB: I don't have a name, but it’s not because they're allowed to make a phone call like that. It's only if where their cel] is located, the jack's not working. So it’s not like they put inmates in the shower to have private phone calls. It’s just that if where your cell is that, the jack’s not working, they put you -. Because they can’t put you with another - in another inmate's room. And they can't leave you out in the open. So they place you over there because the jack is closest to it to make the phone call. MR. So you know who could set up a call like that? Can anyone - any CO just plug it in? Or does it have to be a specific person who plugs it in? 440 The evening watch officers will conduct a minimum of five cell searches during their shift." And that’s what I was just trying to get (Indiscernible *05:14:13). Just to make sure and that’s just to -. If you want to just initial it and date. And also when I do need to clarify when I said the getting in trouble thing. I was talking about legally. When I said about that being truthful. MR. So these things that you initialed. Can you date them also? Because this first set doesn't have a date on them. MR. What is that you want her a) wR. WRB: There's no dates. Next to her initials. On there. MR. Do you care if it has a date? I don't want her to have to go through everything again. She just wrote her initials. MR. FOY: Yeah. It doesn’t matter. Especially if we're only meeting one time. MR. =. Okay. Sure. So just next to where you wrote your initials, do you mind just dating? I don't know if there’s a reason to provide this here. I would just -. EFTA00117752

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RR rPFCowW OND SwhN re RPRRR Ww = Wh RR SD 18 19 20 21 22 23 24 25 RR SwWOHNDN FWwrNP RPRRRR we wre RR SD ee oll ood Wher © Wo 441 You might not -. You don't have to provide it to her. MR. + Yeah. MR. : Just read it after she’s done that. WR. MB: Were you aware -? Maybe subsequently that — wrote a memo pretty much stating that he was notified -. He was notified 1:50 p.m. that inmate | was not coming back to MCC. And he actually notified Officer MB, SoS MEM, and officer that inmate needed - that a cellmate needed to be assigned to Epstein. MS. :_ I'm not aware of that. MR. : Did you ever get instructions like that? MS. : No. MR. : When you came on shift, were there any instructions that came down about going in and removing Inmate J’ belongings from the cell? MS. :_ No. MR. : If an inmate was removed. Let's say someone was going WAB. Do you know what that is? 443 Tf it was? You just don't know leaving or -? I don't know. Anything? Okay. Get all this signed we'll go to nil os documents. anything about Yeah. They're all - I just -_ poorer to her. Anything else before we end this so that hopefully this will be a one- and- _ Nothing else. Nothing else that we shoule talk about that we missed? That we can handle now rather than having to circle back? MR. FOY: Uh nothing. I can’t think off of 7 top of my head. =, We're trying to cover a lot a MR. FOY: I am at the end. wR. QM: «Yep. From the union is RR ROW OHM fwrKP —— wr RPRRR oN Du MmNmenNrre rmrROow mre re WW = Ww RR ae ee PRR RRR Dw wr ed ool mel ro wo Mmmenmrn Ww Wr Um yeah. With Al] Belongings. Belongings. If an inmate let's say had to go to court and it was notified that the inmate is not coming back and was being removed by WAB. Does an officer in the SHU have to go in and remove all the belongings? MS. MJ: Um I don't know. Because I only know in the regular unit when they’re going WAB, they bring their stuff. MR. : They don't bring their stuff? MS. : No they do. MR. : If they were. But what if that person - let’s say that inmate wasn’t notified that they're not coming back until -. MS. MMM: Oh if it wasn’t. Then yeah. The officer would have to go in and take it out. === = pDamDn MR. QM: And there was no instructions for you guys to go remove it? MS. :_ No. MR. : And I may have just missed this, but you do not recall anyone coming in and retrieving * belongings? 444 there anything that you can think of that we should be discussing? Or 0? MS. GREGG: I mean I -. If OIG really wants to know what led up to the death of Mr. Epstein. I think that there needs to be a thorough investigation of the Metropolitan Correctional Center and it’s pitfalls. I'l] just you know kind of leave it at that. And I’m sure you're getting a little bit of insight into what the MCC is. Not just staffing but conditions for inmates as well. It failed a new employee. Yes there are some things that she absolutely should be taking responsibly for. But what led up to the unfortunate death of Mr. Epstein wasn’t just August 9th and August 10th. MR. WM: | Referring to the fact that she was trained on people not conducing rounds and counts? MS. GREGG: It's a cultural issue at MCC New York. Falsifying of documents to pass program reviews. Inadequate training of employees. Um an employee may go through an IF training but most of that training is three weeks or so. Most of the time, you'll find EFTA00117753

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RR rPFCowW OND SwhN re PRR RRR COND Fe WN 19 20 21 22 23 24 25 RR rPOwWOH4DMH fWwrNP RPRRR Ww Wh RR sO ee oll ood Wher © Wo 445 yourself sitting down in the training center I believe because they don't have someone to actually train you. But they’l] tell you sign the training sheets. So if something like this comes up, it implies that the employee received the training. When actually I was present to receive the training but nobody taught me. The same thing is you know for annual refresher training. There's a cultural issue at the Metropolitan Correctional Center. Is it agency-wide? I don't know. I’ve only been at MCC New York. But there are some pitfalls. There have been inmates that’s prior to Mr. Epstein and since Mr. Epstein and I believe the inadequate managing of the building plays a big role in those deaths. Assaults of staff and inmates. And you guys, I guarantee you've seen it. I’m sure there’s something you've seen that you're like, wow that’s a little bit crazy what just seems very egregious it’s because it’s not being run the correct way. It’s failing staff and inmates every day. MR. Well thank you for that. On that note, I know we talked about you know how you observed other staff members like 447 MS. BEB: No. Ask me to sign for that. No. WR. QM: Is there any instances you can think of that you like needed to sign for something that you thought oh I shouldn't sign for that. I didn’t take this training. I didn’t conduct these rounds. Is there anything else like that that you can think of that’s happened while you were at the MCC? MS. MMM: I mean, like for example, like she said in IF training, there’s a roster with a whole bunch of stuff that we're signing next to. But like let’s say, lieutenant so-and-so is supposed to teach that class and they didn’t show up. But I already signed that I received it. But I didn’t get the actual training. So I’m signing that I’m present and I’m here for the training, but I didn’t actually get it. WR. a. So you're showing up at training -- MS. | | But I can’t remember -. MR. : -- and they're actually not conducting it and they're certifying they're -- MS. WBBM: Right. Yeah. a CWO HUDMS fWwrNP PERE RPE RRR won wSewnrr MmMNrnNnNy Sewn oO PRR RRP RRR RR nm WOUDAEWNPOW SUM SWNP wa MmrenNrnrry SwWwrRer So nm w 446 pretty much not conducting the round sheets the way they did it, as well as the supervisor that told you to sign the training that you never actually attended. Can you think of anything else that you were asked to do like that from anyone? Or observed anyone else? As like a training or an experience that was - now that you're thinking back on it - wrong? mS. QB: Um.... I mean I haven’t really been there that long. So the_only thing I could recall was Lieutenant [J was oh. I think when I had my probationary year, like I’m supposed to get reviewed like every quarter. Like to get before I get off probation. I've only got it one time. I think it’s supposed to be done three times. I’ve only got it one time. WR. GM: «And were you asked to sign on a quarterly basis that you received that evaluation? WS. MBM: I know I signed it one time that I got it. But I never got the other two. So just basically just showing how -. MR. a. But they didn’t actually ask you to sign something? WR. QM: -- conducting the training? wS. MMMM: Yeah. There were a couple of training that we didn’t get because there was nobody there to teach the class. MR. And they certified that they actually - MS. Yeah. I remember when I was in IF, they would tell me stuff. But I never walked. You're supposed to get a tour of the building for when you sit in training and in the SHU blah-blah-blah - you have a visual. They never even did that. Like they would explain like when they say down range, you have to just imagine what's down range because I never been in that jail and I didn’t know. I’m saying that to say like the training is not -. You guys probably look at oh I signed or you're saying this training or that she should know this. But I don't actually necessarily have to know it because it wasn’t like taught. And if I kind of learn as you go along, that’s why I said like it’s wrong, but I tried to mimic or follow what I see. Other people do. And yes I've exercised poor judgment on things, 448 EFTA00117754

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RR ROW OHM fWwrNP PRR RRR COND Fe WN MmNrenrr mR Ow mre r Ww = Ww RR rPOwWOH4DMH fWwrNP MRRP RRP RRP RRR NRMP SCOWOOUDH wh mmr We Ww 449 but even sometimes you ask people and they tell you the wrong thing. That's MCC. So even if I don't know and I call and I say hey how do you do this? They'd be like oh just do this. MR. a. And what do you - now that you've experienced this, what do you blame that on? Do you also blame it on like poor management or like a lack of manpower? What is your thoughts on that? MS. It's both but every time something happens, the officers get in trouble. And the problem is it starts from the top. Because if my supervisor is telling me to falsify documents, and I do it, I’m in trouble. But Lieutenant (MM got promoted. You understand? Like the problem starts from eh top. And it comes all the way down. It’s not being managed correctly and the manpower is also not there. Like you can’t take somebody and tel] them to work 16 hours. And remember, it’s a thing where I'm on probation, so I can’t say, no I’m not working it. So you asked me to work 16 hours every day. I'm a human being. I’m not a robot. I fell asleep plenty of times going home. I remember one 451 I come to work. on it, this would be the time to say it. MS. BBB: I don't know what -. MR. FOY: Hm? MS. BB: (indiscernible *05:25:37) MR. FOY: Your experience of was it a friendly experience? Did you feel supported by your colleagues? Like -. MS. : Oh. No. MR. FOY: Right? Did you like it there? Did it feel safe? Like -. MS. MMM: 0h. No. Absolutely not. Absolutely not. MR. FOY: But you've got -. MS. I was actually trying to - like from the moment I started there, I didn’t like it there and I was trying to get out of there. But I’m not going to quit a job and go sit at home. So. The atmosphere was - like to me, I didn't feel safe because if you don't have enough people to work the units and something happens and you hit a body alarm, who's responding? If there's no nobody there. So that's a problem in itself. There’s been times where you got one officer working two units. So what if somebody died on the other unit and PRR RRP RRP RRR COOUDHSWNH POW OHM SWwWNP MmMNrnNnNy Sewn oO PRR RRP RRR RR nm WOUDAEWNPOW SUM SWNP wa MmrenNrnrry Sewnrre oO nm w 450 time I called the lieutenant’s office. Like I can't keep my eyes open because that’s just the reality of it. By the time you go home, it’s time for you to -. Some people don't even go home. They try to sleep in the locker room because the manpower is not there. And it’s absolutely ridiculous. For me, I started in June of 2018. The indictment said 2016. That's not true. To December. That's only 6 months. And I made my base pay because of all that overtime. MR. Okay. Thank you. That's all great insight. Anything else we want to add? MS. BBM: Mm. Nothing else. MR. FOY: The only thing I can think of, which you've kind of alluded to, is what it feels like as a new employee. The culture. The friendliness or lack thereof. The fact that in a way, your trust in your colleagues is undermined through your colleagues. Right? I mean which makes it a difficult thing. I mean if you want to talk about that part of it. Right. Because it’s all related. It's not just one thing. So I mean if you want to speak 452 the officer is on the other unit? But there’s been - and that's all not supposed to happen. But like I said, when nothing happens it’s okay because nobody died. Nothing happened. But when something happens, then that officer working the two units gets in trouble not the lieutenant that said hey I'm assigning you to work these two units. And yes, we know we're not supposed to work the two units. But again, I don't feel like I can override my lieutenant or I can override the senior officer because the instruction that’s being passed on from the top is not correct. But who am I going to tell? Because everybody in that building knows from the warden all the way down knows we don't have enough people. We don't have enough. From day one I entered that building, that's all I’ve been hearing. We don't have enough people. We don't have enough people. People get hurt because there’s not enough staff to respond to certain. Like when I’m on a unit and inmates are fighting -. Like if the inmates really wanted to take over and harm you, they could have. And then who's responding fast enough because maybe you hit EFTA00117755

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RR rPFCowW OND SwhN re PRR RRR COND Fe WN 19 20 21 22 23 24 25 RR rPOwWOH4DMH fWwrNP RPRRR Ww Wh RR sO ee ee ed eS WwrN Pr CO wc nm wm 453 the body alarm sometimes only three people come. MR. So with al] this in mind, is there anything that you can think of as a way to rectify these issues? MS. They need staffing. And I don't know if people don't stay there because like the culture of MCC is just -. It needs to start over. Like it needs to be cleaned out and start over. And people need to follow the rules and reinforce and show people the correct things. Then maybe - maybe it could get somewhere. But when you have new people coming in and we're taught bad - and again, I’m not blaming everything on me being taught bad. It’s what I see. What I know. And again, yes I could sit and read an employee handbook. Sometimes you ready stuff in the context of -. Like I’m not in a camp. I'm in a high rise. So the context of what you're reading in an employee book refers to like you know those types of institutions and not MCC. So sometimes when you try to put it into perspective -. You keep on saying camp. 455 housing unit, I know what I’m doing. In the SHU, I don't know what I’m doing. And I was even told usually they don't put probationary staff to work SHU. But again, because of seniority, that’s all that’s available. So that’s what _I have to get. MR. Okay. Anything on that? MR. : Do you recall any specific instances of policy violations by staff or any actions that you could bring into questions about other staff members at MCC? Any specific instances. MS. BB: Um no. MR. FOY: You're talking about like contraband, stuff like that? vR. MMM: Anything. Overall. MR. FOY: (Indiscernible *05:29:50) :_I mean it comes in some -. MR. : I think what he means more along the lines though of like a supervisor directing you to falsify a record. Like that's pretty big. If they're telling you sign this because you needed to take quarterly SHU training. Anything else like that. MS. I mean one time I got a drop a CWO HUDMS fWwrNP PERE RPE RRR won wSewnrr MmMNrnNnNy Sewn oO PRR RRP RRR RR nm WOUDAEWNPOW SUM SWNP wa MmrenNrnrry SwWwrRer So nm w 454 Do you mean like an FCI or a penitentiary? Or -? Or are you talking about? : Okay. MS. : . Versus a high-rise building. So it’s - the procedures are a little bit different. So that’s why I rely on the people inside to teach me. And you'll always hear this being said. There’s the BOP way and there’s the MCC way because at MCC, they do it their way. MR. Okay. Good to know. MS. : There’s been -. And again because I don't know because they probably don't give you the roster. Every single time that I’ve came to work, I've called to switch with somebody else because I don't want to work SHU. Because I don't know how to work SHU. And it’s very annoying that you have to keep having to ask somebody. There's plenty of times that I called across like somebody working 9 North, like hey you want to switch with me? And I switch. Because on a regular 456 note that said an inmate wanted to rape me. And I forward the email to the lieutenant and I never got a call back. And I called and I said -. Because that inmate is still on the unit. So if the inmate really wanted to rape me, then I guess he would have. So I called and I’m like did you get my email? And she was like yeah I got it, but that inmate ain’t going to do nothing to you. These are the type of things that happen at MCC. How do you know that inmate’s not going to do anything to me? What you should have did was remove me from that unit or remove that inmate, but that wasn’t done. Inmates have threatened me. they're supposed to remove them out of the building but they don't. Inmates have threatened me and I have sent them to SHU. then they'll release them and then they came right back to my unit. So again, it’s like who are you telling or complaining to at MCC? Because from the top there's no help. And I’m literally at the bottom. I was the last officer at_the time. MR. : Now do you know of (Indiscernible *05:31:04) corrupt officers like And And EFTA00117756

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RR ROW OHM SWwrNP RPRRRRR SOD Se Wwh 18 19 20 21 22 23 24 25 RR SCwWOnHtDUN SwWwrP RPRRPR RRR SOW WNP ee ee ed eS WwrN Pr CO wc nm wm 457 bringing in contraband? Is that like a problem at the MCC? MS. It is a problem. But I don't know who brings it in. I just always wonder like how did -? As far as smoking. Like there's smoking all in the building. I get headaches daily because of the smoking. So it comes in some way. But as far as who or how it comes in, I don't know. MR. And I would think it’s kind of easy to identify who is smoking. Correct? MS. MM: Oh - the - you'll be sitting in your officer’s station, and you smell smoke. But remember they're inmates. So by the time I get out, they always have a watch person. So by the time I feel like okay I smell it, it’s coming from here. Let me go walk the tier this way, they'll be like, she coming. So they already done -. MR. Now what are you smelling? What kind of smoke? Is it marijuana or is it -? . iL K2. . > -- K2? 459 it a very bad place to work. And it makes it a poor place for a new employee to work. Right? And I say that wholeheartedly understanding that there is some onus on Ms. There's just some things as an adult you have to say, I take responsibly for it. I don't think she's ever come out of taking that responsibly. But that MCC New York failed Ms. Il, Mr. = and Mr. Epstein regardless of what he was in jail for, I don't believe anybody deserves loss of life behind the walls of a jail especially in that manner. Right? And there’s just so many things so when you ask questions to Ms. = such as, “Are there any instances of falsifying documents,” you're not going to say to me, but I guarantee you that in reviewing rosters and training records, I’m sure you guys have questionable discrepancies. I’m sure you've caught rosters not reflecting what videos show. I'm sure you've caught employees on rosters - not on rosters but attending a training, but the roster says they’re on sick leave or annual leave. I would bet my next low paycheck that that’s absolute to what you guys have probably seen or experienced in a CWO HUDMS fWwrNP —— COUT fwr re mre nd MmmrenNrn Ww WPM Wey DHfwrP PRR RRP RRP RRR WeonyDwVfwrNro mre reo MmmenNn Ww Wr 458 . :_K2. MR | And you can - you know the distinct smell] of K2? . : Yes. MS. GREGG: It's the entire building and you know, I would welcome, right, if OIG said we want to tour the institution. (Indiscernible *05:32:11) and judges do. Attorneys do. Law clerks do. Right. Because it gives you a little bit of - you can actually put a visual besides seeing the photos. You can get a visual. You actually get to see what it is to be an employee there or even an inmate there. And the drug problem is absolutely rampant. The institution has no control over it. Right. So it boils down to that employee saying okay if you guys don't stop smoking, I’m locking everybody behind a door because it's making me sick. Or it’s making me -. It’s that kind of thing. Like they’re not holding inmates responsible for incident reports. None of that stuff is happening. And it just makes 460 investigating this whole thing. Is this falling on deaf ears? I don't know. I would like to hope that the death of an inmate leads to some change. But we're two years out and -. MR. : Sure. Well part of that has to do with we had to wait to interview. But yeah. MS. GREGG: Yeah. MR. : Do you have ...? MR. :_ Yes, MR. : It just made me think of something. I just want to make sure just going back like we were talking about to make sure that we've got the like - as truthful a statement as we possibly can with regard to the August 9th 10:00 p.m. count. Talking about video and things like that. When you remember doing that_count -- MS. + Mm-hmm. MR. : -+ although the count number was wrong, did you do the count from the outside grill or did you actually walk down the range? MS. il No. I walked down the range. MR. : And you're -? EFTA00117757

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RR ROW OHM SWwrNP RPRRR We Wr RR SD 18 19 20 21 22 23 24 25 RR SwWOHNDN FWwrNP RPRRPR RRR SD SW N Pe MmMNmMNrMNMYNRRR ee wWwrNr OC wc nm wn 461 MS. || And I know like for example, like in statement, he probably was like, I don't know if she did the count. Or I’m going to say she didn’t do the count because it needed to be done with me and I was sleeping. He was sleeping, so he don't’ know if I did the count or not. MR. Yeah. reconcile the review of -- MS. : He signed, but -. MR. : -- of the video. MS. : But no because I saw a lot of stuff. Even in the indictment. There's a lot of things in there that’s not true. Like the one thing I know I did do was that 10:00 count. For a fact. WR. QM: «But you just don't know how they reconcile the fact that -- The numbers no. -- the numbers are off. But the count. I did do that. Was that just - and be one of those big things that’s like well how do we -? If you're saying you did the count, and the numbers are 463 WR. QM: And yeah. It is -. MS. GREGG: I've got something. Can I just get a copy of the document that I signed? a. Absolutely. I'm just trying to MR. MS. GREGG: Or unless you just want me to take a picture of it. Whatever's easier. MR. Um yeah. I’1] get you a Either a photocopy or a picture. That’s fine. Okay. It is 4:20 p.m. on Tuesday, June 22, 2021. This is Senior Special Agent = GE and 1 an turning off the recorder. copy. 462 wrong, that’s the -. We're going to have to - MS. : Yeah. Like I don't remember - MR. -- review that video and MS. MM: -- what happened between like the 73 and the 72 and the phone call and what was said again. But I did do that count. MR. a. And again, we're not confusing a count with a round. MS. : Rounds. No. MR. Okay. Anything else? Well I just want to thank you all so very much for the cooperation. And to the union, I want to kind of apologize for the initial interaction. MS. GREGG: _Mm-hmm. MR. I think that now talking with you, I think that you're actually - I was maybe misunderstanding maybe what you were doing. I just wanted to make sure that we weren't going to be stopping this interview every time there was a question. But you were extremely helpful. So thank you for your participation. MS. GREGG: RR ROW OHM fwrKP —— wr RPRRR oN Du MmNmenNrre rmrROow mre re WW = Ww No problem. 464 CERTIFICATE I hereby certify that the foregoing pages 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 Marci Bratton, Transcriber EFTA00117758