1 DIGITALLY RECORDED SWORN STATEMENT OF OIG CASE #: 2019-010614 DEPARTMENT OF JUSTICE OFFICE OF THE INSPECTOR GENERAL JUNE 14, 2021 RESOLUTE DOCUMENTATION SERVICES 28632 Roadside Drive, Suite 285 Agoura Hills, CA 91301 Phone: EFTA00061698 2 ## APPEARANCES: OTHER APPEARANCES: NONE EFTA00061699 3 EFTA00061700 4 | EFTA00061701 | | :--- | :--- | This is a simple Markdown document with no headings or paragraphs. It contains a single line of text. 5 Requested to Provide Information on a Voluntary Basis. I’m going to read it out to you first. And then I’ll let you review it also. 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 job performance failure and security failure. This is a voluntary interview. Accordingly, you do not have to answer any questions. No disciplinary action will be taken against you if you choose not to answer any questions. Any statement you furnish may be used as evidence in any future criminal proceedings, or agency disciplinary proceedings, and/or both. Now this is the waiver part. This is for you. I understand the Warnings and Assurances stated above and I am willing to make a statement and answer questions. No promises or threats have been made to me and no pressure or coercion of any kind has been used against me. Do you understand? MS. : I understand. EFTA00061702 6 EFTA00061703 7 EFTA00061704 8 EFTA00061705 9 EFTA00061706 10 EFTA00061707 11 EFTA00061708 12 EFTA00061709 13 EFTA00061710 14 EFTA00061711 15 person during the course of a shift that I don't communicate with. Especially when I'm making rounds. And especially during that time, I communicated with them even more because we were below the bottom of the barrel then when it came to staffing. So we really didn't have a lot of -. We didn't have anybody back then. We didn't even have enough staff at that time to even respond to body alarms. Or to do uses or forces. You know. Especially on morning watch. It's already tight. But we was even tighter. So that was one of those nights when as much as -. Well that night as like every other night. As much as possible I tried to talk to staff because staff were doing back-to-back mandations then. And you had staff that were being mandated every day of the week Monday through Sunday. Or Sunday through Saturday as we say in Bureau. Because that's when our week officially starts - Sunday. MR. : When you say mandated what do EFTA00061712 16 you mean by that? MS. Mandations are mandatory overtime. That’s when you’ve exhausted your overtime roster. That’s the people that sign up for overtime. You’ve gone through that. There’s no one available. Or you get everybody from that list that wants to do overtime or that’s available. Then you announce it over the intercom system. That’s voluntary. Whoever wants overtime outside of that, you can assign them overtime from there. And then we go to mandatory overtime. That’s when we have nothing else left. And we have to utilize the staff that we have currently on duty that’s not officially on a double-shift. That’s not officially on 16 hours. Because there were days when staff would be late. There were days when there wasn't EFTA00061713 17 EFTA00061714 18 EFTA00061715 19 EFTA00061716 20 administrative duties, described how a count at the MCC works and that the lieutenants are responsible for supervising one count per shift. described that during the count, two guards assigned to the area are to unlock the main gate that separates the cells from the open and common area where the guards are. One guard will walk down range and actually look into each cell and count the number of prisoners inside. Once the count is complete, the guard will return to the gate and exchange places with the guard that was left to secure the gate. That guard will then walk down range and count the number of prisoners in the cells. Upon completion, the guard will return to the gate, secure it from the outside, and record the numbers that came from their count. Those numbers will be compared to the master list of prisoners on record for being assigned to the cells. In addition to the numbers being recorded and compared to the master list or the E-1 sheet, the guards will call in or receive a call from internal and give a verbal record of their count. And internal. EFTA00061717 21 take the count, once they have gone around to each range and both of them had counted each range, before they leave that range, they will compare their count for that particular range. And they would do that in each subsequent range. When they’ve completed, they call the control center. And they will call in their unit. They will call in the count that they got for that particular unit. They will give them their name, who conducted the count, and at that time, the control center will let them know whether they have a good count or a bad count. Internals position is to pick up those count slips after each unit has counted and place those counts slips out into their EFTA00061718 22 respective sally port to be picked up by internal. They do not call. Internal has absolutely nothing to do with their count unless they get a bad count. Sometimes internal, or if we have other extra staff, they will go up there and they will assist them with the count. You know just to see maybe if one of them miscounted or something like that. They would just be like an additional person. A new set of eyes, basically, to assist them with the count. MR. : So before I continue, I had a question for you. Can you say the difference between internal and control? What exactly their duties are? MS. : The internal officer is an officer who mans the elevator. He’s responsible for moving inmates around in the institution. He has - they have checks and stuff that they do throughout their shift. But mainly they’re responsible for moving inmates up throughout the institution. They respond to body alarms. They pick up the count slips. And they just have general duties throughout the night. They assist with the count EFTA00061719 23 EFTA00061720 24 EFTA00061721 25 EFTA00061722 26 EFTA00061723 27 Whether that be medical - wherever we had inmates at that time, they would have been picking up those count slips. Or sometimes if unit team or somebody like that is here. And they’re on the unit at the time, you know, they’ll say if they’re on their way down they’ll say I’ll take the count slip down. So it just depends on what day it is and what we have going on during that specific time. But for the most part, when no one else has delivered the count slips down, it would be Well, on this day, Friday, August 9th. It would have been between and or both. EFTA00061724 28 EFTA00061725 29 EFTA00061726 30 EFTA00061727 31 EFTA00061728 32 MR. : So that's so yeah. Let’s say for instance the 12:00 p.m. count, the 3:00 a.m. count, and the 5:00 a.m. count. Who would have been called then on August 10th? MS. : They would have been calling control number one because I don't think they had, um -. They would have been calling -. I want to say they was calling control number one. Because at this time, it look like we had a control number two. Because there was a time when internal number two would fill in for the control number two. But it doesn’t look like this was during that time. MR. : To your best guess, who of the officers in the special housing unit, who would have been called? For the 12:00, the 3:00, and the 5:00 a.m. counts, who would have been called on those? MS. : They would have been calling the control center number one. MR. : And who was that? MS. : During the 12:00 to 8:00 shift that would have been Officer who, like I said, was on overtime. She’s non-custody. She works in the R&D department. EFTA00061729 33 EFTA00061730 34 EFTA00061731 35 MR. Because we’re probably going to have to go back to this, I wouldn’t mark them as exhibits. MR. Okay. No problem. MR. Because this is always going to be Exhibit 1. MR. I understand. Just to clarify before we move forward. How many counts take place at the MCC? Daily? MS. It depends. During the week we have the -. Let’s start with day watch. Day watch we have the 4:00 p.m. count. Evening watch we have the 10:00 p.m. count. Morning watch we have the 12:00 a.m., the 3:00 a.m., and the 5:00 a.m. So five. On weekends and holidays, we have an additional count of 10:00 a.m. which is added for weekends and holidays. MR. Okay. Thank you. So I’m going to go back and I’m going to continue reading from that spot. So I’m going to reread that line and we’ll move forward. MS. Okay. MR. In addition to the numbers being recorded and compared to the master list EFTA00061732 36 or E-1 sheet, the guards will call in or receive a call from internal and give a verbal record of the account and internal will compare that number to the number that they have on file and advise the count matches and is good or does not match and a count needs to be conducted again. You clarified that. You explained how the control and the internal works. The count slips prepared by the guards are then placed in the area for pickup by another guard assigned in the MCC and brought to control for review. In addition to the official counts that are to be conducted at specific times during each shift, informed that the guards are also responsible for conducing rounds every 30 to 40 minutes. During the rounds, the guards simply walk the range and view that the prisoners are alive and in their cells with no issues. The number of prisoners is not recorded, but simply the fact that a round was conducted. And the officers who conducted it is. When asked, stated that she has no knowledge of rounds or counts not being conducted and that no one would tell her if that were the EFTA00061733 37 EFTA00061734 38 MS. : -- so that the rounds can be irregular if you get tied up. Because when you’re making rounds, inmates will stop you. They will hold conversations with you and ask questions. You know and so it’s hard to keep those rounds within those guidelines because there’s always something to trip you up. When you’re making rounds you may notice something out of place, so that would stop you. But as far as those rounds getting conducted, those rounds are supposed to be conducted on an irregular basis. But do understand that there are things that will trip you up. So sometimes you may be on time. Sometimes you -. It’s hard to fall within those guidelines because you’re - it’s live time. Everything is live. So you can’t predict what’s going to happen while you’re making your rounds. MR. : Understood. And that was a summary of your interview. So as you can see, we have a few questions we want to follow -. MS. : Right. MR. : And we’ve got -. EFTA00061735 39 MS. : You have medical emergencies. You have inmates that are complaining, wait until you start making your rounds to complain about being in pain or something that’s hurting them. Or a lot of general stuff. They’ll ask you questions just about anything when you’re making rounds. MR. : Understood. MS. : Mm-hmm. MR. : I’m going to go back to my interview now and I have a few questions for you. If there were instructions of guidance from upper management, how would you receive them? MS. : It depends. During that time, they made -. Whoever was in the office may come and say something to the person in the office. And it was left up to everybody else to get that information from that individual. MR. : Who was in the office at that point? I mean is a certain person assigned to the office or it could be anybody in the office? MS. : Like the lieutenant. EFTA00061736 40 EFTA00061737 41 subordinates or COs, correctional officers, who report to you, how would you communicate those instructions to them? MS. : I usually did it when I made my rounds. And I would tell them. But you could also do a thing such as 3-3-3s. And that way, that’s when everybody come on the line and you could do it that way. But you really didn’t have time. It was easier to just tell everybody individually because that way you’re with them in person. And it’s just easier for you to do it at that time because if they had questions, then they could ask you questions. And when you’re doing over the phone at the hole, you’re sitting in the office. So you’re really not getting anything done, you know. At least if I’m making my rounds, I’m getting my rounds done and I’m doing my - passing down information to my staff at the same time. And also it lets me know that you got it. I’m telling you. it’s just you and me. There’s no distractions in the background. There’s nothing else going on. But it just depends on the person. MR. : Okay. EFTA00061738 42 MS. : How they got that information to each individual staff. MR. : Would you communicate that directly with your COs or would you tell another CO to pass on the message? MS. : It depends on what the information was. I mean things that you want them to know and definitely. If it was something that was a new policy or procedure or something like that, you would definitely want to tell them yourselves because at that time, like I said, there wasn’t anything coming out in writing. That’s generally how new policy and procedure is put in place. You know you either receive a memorandum saying starting with this memorandum or starting with effective today or some other date, this is what we’re going to be doing. That’s generally how that information is put out. Or some type of manual or something like that is updated. Those are the ways that it’s generally put out. That way you have the information there and you can refer back to it as needed. MR. : What if it involved an inmate? Like certain instructions for certain EFTA00061739 43 EFTA00061740 4 4 EFTA00061741 45 EFTA00061742 46 EFTA00061743 47 EFTA00061744 48 EFTA00061745 49 EFTA00061746 50 EFTA00061747 51 EFTA00061748 52 EFTA00061749 53 EFTA00061750 54 | EFTA00061751 | | :--- | :--- | This is a simple Markdown document with no headings or paragraphs. It contains just one line of text. 55 EFTA00061752 56 EFTA00061753 57 EFTA00061754 58 EFTA00061755 59 EFTA00061756 60 That should be an all staff email to be honest with you. Because that way everybody in the institution knows that there’s an important reason why that inmate needs a cellmate. And that way if at some point in time it’s not happening or there’s a lapse in that, everybody knows. So you’ve got - because you have staff making rounds around the institution on the housing units and all of that stuff all the time. You know. different members of the institution staff. So that would be an all staff email just to alert everybody in the institution that, you know, if you’re ever in that area and you come across this inmate and he doesn’t have a cellie, then you need to follow-up, ask why, make sure somebody knows that that inmate don't have a cellie. MR. : I’m going to clarify. Based on the fact that based on what we - our investigation. Inmate was assigned as a cellmate for Jeffrey Epstein. MS. : Okay. MR. : And he was required - according to psychology - he was required to have a cellmate. Now Inmate was EFTA00061757 61 EFTA00061758 62 EFTA00061759 63 EFTA00061760 64 to the MCC, Epstein should have been placed on 10 South. That’s our - what they consider the maximum-security unit here. He never should have been placed on 10 South anyway because you’re not guaranteed that anybody in this building is going to maintain a cellie because it’s an administrative institution. Inmates come and go all the time. So there’s - they don't have a sentence date. And with that said, that means that at any point and time while we’re sitting here, the courts can release somebody and that inmate is gone right now. So to put out an email to certain individuals and not make that an all-staff email so that it would -. And I guess we have to go back and say what was the intentions of that? If it’s something that you feel is concerning and that absolutely needs to happen because you still feel that this inmate is at risk, then you say to yourself, well why is he being released from suicide watch? Or psych ops. Why, you know? If you feel that this inmate still needs this type of supervision. And if the answer to that is yes, he still needs that type of supervision, then you would EFTA00061761 65 recommend that, you know, why don't you keep him?? Why aren't you maintaining him? You know. On watch? If he requires that type of supervision? Or why - since you didn't do it to begin with - which they should have done. Considering he was high-profile, he was an at-risk inmate, just the fact that he was a high-profile inmate, he should have been placed on 10 South. After he attempted suicide and they determined that they was going to remove him from that and required him to have a cellie. Then they should have either made it an all-staff email, made sure everybody was aware - everybody. Not just -. And it's difficult because people are on days off, people are on vacation, people are on sick leave, you see what I'm saying? MR. : Okay. Assuming that the CO-. Let’s start with the COs. Assuming the COs in the SHU knew that this was a requirement. EFTA00061762 66 EFTA00061763 67 EFTA00061764 68 EFTA00061765 69 EFTA00061766 70 EFTA00061767 71 EFTA00061768 72 EFTA00061769 73 EFTA00061770 74 EFTA00061771 75 EFTA00061772 76 EFTA00061773 77 MS. : But they were for some reason -. I want to say. I don't know if he was on dry cell or what his status was. MR. : Was -? MS. : I don't think he was on suicide watch. I can't remember. MR. : You said dry cell. Now dry cell. Is that in R&D? MS. : No. That's not in R&D. Usually dry cell is done in the special housing unit. So I can't remember what his status was but he was -. I can't remember if he was on dry cell or if he was on - if that was an extension of the suicide watch. I can't remember, but there was an inmate down there. And he was being housed down there with the watch on that particular night. And they were counting him on the unit because they hadn't received any guidance as to how he was going to be counted. Because R&D, mind you, is the intake unit. It's not a housing unit. MR. : Okay. MS. : So inmates are theoretically are not supposed to be staying - spending the night down there. EFTA00061774 78 EFTA00061775 79 EFTA00061776 80 EFTA00061777 81 this count was done, they were counting this inmate that was in R&D on that count because no one had told them that the inmate was actually somewhere else. And he was being counted in that area. So they were logging -. So what I understand - and that’s how they understood it. That that inmate was being carried on to their count. MR. : Even though they didn't get eyes on the inmate? Even though they don't know physically. If they physically cannot see the inmate, they're allowed to put it in their count? MS. Because the inmate is being ghosted. They could call R&D and ask and say he is the inmate there. Because there was a staff member on the inmate. The problem was not how many inmates they had or what’s counted. The problem was the status of this inmate that was in R&D. EFTA00061778 82 indicate him on their count slip. They didn’t know any of that. That wasn’t until they brought this to my attention. And this was the original count slip. There was another count slip that they supposed to have been completing. And place that in the Sally port, but apparently nobody picked it up. So this was the original count slip that was submitted. MR. : Okay. MS. : But they were EFTA00061779 83 EFTA00061780 84 | EFTA00061781 | | :--- | :--- 85 EFTA00061782 86 EFTA00061783 87 EFTA00061784 88 EFTA00061785 89 EFTA00061786 90 inmates. When we make rounds, we get with the officers. We make sure that -. I mean if we choose to do that we can. But -. MR. : But there’s no requirement? For your requirement, that one per shift of round. That’s to do rounds with your officer - or with your staff - as opposed to conducting a round with them? MS. : No. There was nothing here said to us or in policy telling us that we needed to go around -- MR. : Sure. MS. : -- on each housing unit to each individual cell and check on the inmates. If we chose to do that based upon something that we knew wasn’t right or something that we had heard or something like that during the course of our shift. Then that - and we felt as though we needed to double check on it. Because our officers are our eyes and ears. And during that time, we didn’t have a whole lot of time. We would spend half of our shift just trying to fill overtime. At that time. MR. : So are you supposed to EFTA00061787 91 EFTA00061788 92 EFTA00061789 93 EFTA00061790 94 | EFTA00061791 | | :--- | :--- | This is a simple Markdown document with no headings or paragraphs. It contains just one line of text. 95 EFTA00061792 96 EFTA00061793 97 EFTA00061794 98 EFTA00061795 99 EFTA00061796 100 EFTA00061797 101 EFTA00061798 102 EFTA00061799 103 EFTA00061800 104 EFTA00061801 105 EFTA00061802 106 EFTA00061803 107 EFTA00061804 108 EFTA00061805 109 EFTA00061806 110 EFTA00061807 111 EFTA00061808 112 EFTA00061809 113 EFTA00061810 114 of shanks, cell phones, drugs. Inmates were going out of their mind on drugs and all this other stuff. We had inmates fighting, inmates getting stabbed, inmates getting slashed. There were -. In addition to everything else that we had to take care of. We were doing uses of forces. We didn’t have adequate staff to even do a use of force or even to respond to a body alarm a lot of times. There were incidents where we as lieutenants were the only people here and had to do things. So -. MR. : So there’s just overwhelming -. You guys were just completely overwhelmed. In the weeds. MS. : We -. At that time, there was just so much going on. MR. : Right. MS. : You would be hell-bent to stay abreast of every little thing that was going on. You just -. When your relief came, you know, you was like let me get some fresh air. MR. : Just let me -. In this circumstance. We’re going to try to reign it in specifically to -. EFTA00061811 115 EFTA00061812 116 EFTA00061813 117 EFTA00061814 118 EFTA00061815 119 MR. : What the difference between -- MS. : -- that’s how -- MR. : -- 10 South -? MS. : -- important it is. MR. : So what’s the difference between 10 South and the SHU? MS. : The difference between SHU is that SHU is for general population inmates. MR. : Okay. MS. : You know. You’re not guaranteed to have a cellie there. You know. So you may have a cellie and you may not. Epstein was a high-profile inmate. All high-profile inmates they usually assign to 10 South. Epstein had just-. Even before he committed suicide. Everybody knew and that’s not just here. That’s people in the region. You know all the way up to Donald Trump knew Epstein was here. You know. And when you look at Donald Trump all the way down the line, you know, to the regional director, the correctional services administrator. All those people should have been involved in where EFTA00061816 120 EFTA00061817 121 been put up there from day one. Most especially after he attempted suicide. So if you didn’t place him up there from day one. When he attempted suicide with a cellmate. Okay? Let’s not forget that because when he attempted suicide, he had a cellmate. EFTA00061818 122 EFTA00061819 123 EFTA00061820 124 EFTA00061821 125 EFTA00061822 126 staff here that were dead on their feet. MR. : Sure. MS. : You know. Trying to watch an inmate. And when all those circumstances that was going on, there was a lot of things that we should have been doing that wasn’t done. So it’s not just about what happened to Epstein. It’s about everything else surrounding his death that occurred that didn’t happen. MR. : That’s one point. MS. : That should have been occurring that didn’t happen. MR. : Okay. Now let’s - I’m going to take it out. Let’s say you’re on shift. Inmate attempted to commit suicide. You know there’s an issue with the inmate. You’re leaving the shift. Do you have a conversation with the person you’re relieving - I mean whoever’s relieving you? Do you have a conversation with that person and advise them what happened during your shift? MS. : Yes. I would -. MR. : Why? Why would you do it? Just to, what reason -. EFTA00061823 127 MS. : Because look. Let me explain something to you. MR. : No-no-no. I just need an explanation. MS. : No-no-no. I’m going to give you an explanation. But I’m going to give you the explanation that best suits the question that you’re -- MR. : Okay. MS. : -- asking me. When we do these pass downs, everybody is different. Some people tell you verbatim everything that happened. Some people don’t. That’s just the nature of the beast. You know. I could sit here all day and say somebody should have told me something. Or you know if they had the information. But when you’ve got so many things on your mind and you’ve dealt with so many things during the course of the day, you know, people don't want to continue to stand there and do it. People forget. I mean they could have been standing there talking to me for five minutes with all the things that go on during the course of the day. You know. That’s not just here. That’s every place I've EFTA00061824 128 EFTA00061825 129 EFTA00061826 130 EFTA00061827 131 EFTA00061828 132 EFTA00061829 133 EFTA00061830 134 captain and he should have made sure a cellmate was put in there. If knew, same thing. He should have notified the captain, he should have put someone there. If you knew, you should have notified the caption, you should have put someone there. That’s just the kind of what the ops lieutenant does. Would it be basically the ops lieutenant if it came up to that person? They notify the captain. They make sure it’s done. Is that a fair assessment? MS. : Yeah. That’s a fair assessment. And you’re just notifying - and the only reason why we’re letting the captain know is to let him know. Hey, you know you guys, we keep telling you this guy should be on 10 South, but you keep him on SHU. And we keep running into these close - really, really, close calls. MR. : So the staff -. MS. : So that’s one reason why -- MR. : Is the staff ever -? MS. : -- you notify them. MR. : Did you ever have any EFTA00061831 135 MS. : Let me tell you something. If we as lieutenants are responsible for knowing everything that we’re supposed to know. And we’re running this institution off the cuff, we don't know what’s going to happen here at any given time of the day or night. If we’re required to know that, you think that these cats in the region and in the central office and at the executive staff level don't know the same thing that or more than we know? EFTA00061832 136 EFTA00061833 137 EFTA00061834 138 EFTA00061835 139 EFTA00061836 140 EFTA00061837 141 EFTA00061838 142 EFTA00061839 143 EFTA00061840 144 EFTA00061841 145 EFTA00061842 146 EFTA00061843 147 EFTA00061844 148 EFTA00061845 149 EFTA00061846 150 EFTA00061847 151 EFTA00061848 152 EFTA00061849 153 EFTA00061850 154 EFTA00061851 155 EFTA00061852 156 EFTA00061853 157 EFTA00061854 158 EFTA00061855 159 EFTA00061856 160 EFTA00061857 161 EFTA00061858 162 EFTA00061859 163 EFTA00061860 164 EFTA00061861 165 EFTA00061862 166 EFTA00061863 167 MR. : Okay. Point being, like if he’s claiming someone tried to kill him, but also at the same time is saying that he’s trying to commit suicide. He didn’t have anything around his neck. Is there any reason for you to believe that his cellmate was actually trying to kill him? MS. : No. I mean I had no proof that his cellmate tried to do anything to him. And I'm trying to remember what the officer said. I don't even remember offhand what the officers were telling me. I don't know if they saw him with something around his neck or what they observed. But I can't remember. I would have to refer back to my notes. Because that was a long time ago. MR. : Sure. So if counts are not conducted. And I'm assuming -. Are counts more important than rounds? Or are they both just as equally as important? MS. : I mean they're both important. They are both independently important. MR. : Okay. So let's go first with counts. If counts are not conducted, who EFTA00061864 168 is -. So if counts are signed off on. You’re given a count slip. If those counts actually weren’t conducted. So if let’s say for instance that during your shift, the 12:00 a.m., the 3:00 a.m., and the 5:00 a.m. If they were not conducted - those counts- who is responsible for that? For them being signed and certified? Who - so I’m assuming the people? Noel and Thomas are the ones assigned to that shift. And they are the ones who certify that those counts were conducted and then provided to you. Are they the only ones that are responsible for providing false information? MR. Correct. So if they’re saying they conducted counts but they didn’t. So they were providing you with something saying either 72 or 73, but those counts were not conducted. EFTA00061865 169 EFTA00061866 170 EFTA00061867 171 EFTA00061868 172 EFTA00061869 173 EFTA00061870 174 EFTA00061871 175 EFTA00061872 176 EFTA00061873 177 aware of that, and especially if control is taking the count. Then control will call them back and tell them I need a new count slip because this one is not right. And usually the only time that that would happen is would be like in the incidents where we may have moved a staff member during that time. And we need to go back and update that count slip that we were originally getting. Or like in this case with the inmate being in R&D. We needed to go back and get another count slip that reflected the new count which was 72. Once we put the inmate in R&D. MR. : Okay. On that same topic, if the count was wrong, and you told them that they needed to go back and do another count. MS. : Not that the count was wrong. That the count slip was wrong. The EFTA00061874 178 number that was reflected on the count slip was wrong. MR. : Did you see them do the count? MS. : No. MR. : So the number they reported was wrong. The count should have been -. MS. : They said that they had -. They said that they had their count was 73 but that they had there was an inmate that was in R&D. So that was the problem. They never did a count slip saying - they never said my count is 73 and left it at that. They were clear to say that the count is - SHU has 73 but there is an inmate that is down on the third floor in R&D. Or something to that effect. They notified me that there was an inmate that was off their housing unit. MR. : So you’re saying the count wasn’t wrong. MS. : What was on the count slip was wrong. MR. : The count slip was wrong but she said that they explained it when they delivered it. EFTA00061875 179 MR. : But you just stated a little bit before that the count wasn’t wrong, the count slip was wrong. MS. : The count slip was wrong. MR. : Why did you ask them to go back and do the count? MS. : Because I needed to find out what was going on with this dude in R&D so that, you know, if they in fact -. If we made changes to whatever the status was to this guy in R&D. If he was in fact going to be there overnight or whatever the case may be, then we needed to get him off of their count. So while I was verifying that, I said, you know what, just go back and do it again just to make sure. While I’m looking into this thing with this dude. I didn’t say that to them. I’m thinking to myself. I’ll have them go back and do another count while I check on this inmate that was -. MR. : There’s a possibility the count was wrong then. MS. : What do you mean? MR. : You said go back and verify EFTA00061876 180 EFTA00061877 181 EFTA00061878 182 EFTA00061879 183 EFTA00061880 184 EFTA00061881 185 EFTA00061882 186 EFTA00061883 187 thousand times. I’m not here to cover for nobody. I’m not here to provide false answers for something that somebody had done, but at the same time, you all are throwing these questions at me about what somebody would have done. I don't know what's in somebody’s mind - MR. : We’re saying did you see it. So that’s what we’re trying to get you to answer more like yes, no, hey I don't know on that front. So we’re trying to keep it consolidated and ask you direct questions. What did you know? Did you know if they did another count slip? EFTA00061884 188 EFTA00061885 189 EFTA00061886 190 EFTA00061887 191 EFTA00061888 192 EFTA00061889 193 time to read at that time because of everything that was going on during our shift and in this building. MR. : And is that just a constant issue of just trying to keep up with emails as well as do your job? MS. : That was a constant issue. Yes. Because there was so much going on in this building at the time. So much chaos. That you didn’t have time to read. MR. : Okay. MS. : You didn’t have time to read a lot of the emails that you’d gotten. But most importantly, if when you’re talking about information that’s that important, you know. Whoever is sending out the information. Whoever got the information should always be trying to make sure that everybody knows that this is important. We have to make sure that he has a cellie because like I said, the officers are the main ones who come in contact. MR. : And that goes back to our original question. MS. : With the inmates. MR. : If the chain of command EFTA00061890 194 EFTA00061891 195 EFTA00061892 196 EFTA00061893 197 EFTA00061894 198 reported, hey he's supposed to have an inmate - he's supposed to have a cellmate in here. He doesn't. MS. : That’s if they knew. There is no reason for me to believe that those guys that was there on SHU that if they knew that, whether or not before they left, I’m sure they would have questioned that again as to what you want me to do about this particular situation. MR. : Okay. So should have each -. So then let’s say if Thomas and Noel did know. And they knew he was without a cellmate. Should have they then told you? When you did your rounds? Like when they’re calling control. And you’re stopping by at 4:00 a.m. Would have it been their responsibility to say hey, just so you know, he’s required to have a cellmate and he doesn’t. MS. : I’m not going to say that that’s what they should have done because there’s no rules and regulations regarding that. But they - I would have - if it was me, I would have mentioned it. EFTA00061895 199 EFTA00061896 200 EFTA00061897 201 that off on other people. But there’s a -. There’s no clear and defined form of policy and procedure here. There’s no consistency that goes on here. Everything is hodge-podge. A lot of times, people are required to make decisions off the cuff or to do -. Because when you come here, if you don't have or while you’re here - or working here. There is no formal guidance that teaches and guides staff to know what they’re supposed to be doing. There’s nothing written in stone regarding what you’re supposed to be doing and what you’re supposed to be doing on a daily basis. There are post orders and stuff like that. But they’re not in depth enough to let staff know this is what you’re supposed to be doing. There are a lot of things that - decisions that people make off the cuff that's not ever put in writing. And that they would tell whoever's here at the time. And I guess expect that information to get disseminated throughout the institution. And it's not. That's not being done. That’s not being done. So you have a lot of - we have a lot of new staff here. And a lot of them are falling between the cracks EFTA00061898 202 because they just aren't getting information to them in a manner in which they should. MR. : On what you just mentioned. So you're saying that there's orders or decisions coming down from up above? And it's not being properly communicated out. MS. : This is how. This is how this place has always been. You -. People in-in-in-in um positions will require the people up under them to carry their load rather than them carrying their own load. When if -if I'm a lieutenant, my duties and responsibilities and authority end at a certain level. At that point, the captain and above takes over. A lot of times, you don't see that. They expect you to do your job and their job as well. We can't -. There are certain decisions that we can't make. If it was up to me, Epstein would have been up on 10 South. So those are the type of decisions where you tell people that these things are wrong. You give them intel about certain things. And here we are. We done found a loaded gun in the institution. That - those type things should never happen. Never happen. EFTA00061899 203 EFTA00061900 204 EFTA00061901 205 into the Bureau, you didn’t even have email. So how was - and you still now is no different than back then. You still have inmates who was with in potential danger. The same situations that existed in the institutions then. It’s the same instances that exist now. So if back then they were able to make sure everybody was on the same page and that information was disseminated and it got to everybody. Why should it be any different here? You can’t rely on an inmate because first of all, in order to know, you don't just send out. That’s the whole purpose of walking and talking. To disseminate information that way. Because you’re never guaranteed that when you send out an email that somebody is going to read it. I have a ton of emails on my computer at home that I don’t read. So nothing is guaranteed. You have to know. When you’re in charge and you’re running something, you-you-you-you need to know that whatever you put out there, that if it's that important, if it's that important, why are you sending it through an email anyway. Why aren’t you calling somebody on the phone? Back it up. Call people on the phone. Make EFTA00061902 206 sure everybody knows. MR. : I think the purpose is to put it in writing. But yeah, so email but also verify verbally. MS. : You need to verify that if you’re sending those emails to pertinent people who should have access to that information that everybody knows about it. MR. : Do you all have all staff like where lieutenants are all present where they can verbalize something to you? Is that done here? MS. : Do we have what? MR. : So you’re saying that not only an email but people should verbalize it. But there’s a ton of people that need to know things. So is there a process in place where someone like the captain, say? If the warden tells the captain make sure he has a cellmate, is there a process in place where the captain can get in front of all the lieutenants and tell them this? Or is that - is there -? MS. : The captain has access to every lieutenant here. The captain’s office is -. EFTA00061903 207 EFTA00061904 208 EFTA00061905 209 EFTA00061906 210 EFTA00061907 211 EFTA00061908 212 EFTA00061909 213 EFTA00061910 214 EFTA00061911 215 EFTA00061912 216 EFTA00061913 217 ## 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