EFTA00117565.pdf

34 1 Alright. DO you know where we left off 2 What was the last question that we asked? 3 : It was what we asked for 4 (Indiscernible *00:24:53) about the injuries. 5 : Okay. So you were 6 telling us you said March through June you were 7 injured? 8 MS. NOEL: Yes. 9 : And you were not actually 10 working during that time? 11 MS. NOEL: No. 12 : Do you remember around 13 when in March and when did it end? Was it the 14 beginning of March, end of March, middle? 15 MS. NOEL: Um I'm not sure. I just know 16 it was March. 17 : Sometime in March? 18 MS. NOEL: Yes. 19 : But when you came back, 20 was it around the 26th when they asked you to 21 sign those? 22 MS. NOEL: I came back in June. I don't 23 recall the date exactly. 24 : Okay. 25 MS. NOEL: But I remember the day I came EFTA00117565  35 1 into work and the lieutenant asked me to go see 2 Lieutenant And she asked me to sign 3 and I said but I wasn't here. I was out on an 4 injury. And she said she's aware but they need 5 me to sign it for program review. 6 Okay. 7 MS. NOEL: So I signed. 8 So both trainings when 9 you signed, they didn't actually even provide 10 you anything? 11 MS. NOEL: No. 12 Verbally? 13 Electronically? Nothing? 14 MS. NOEL: No. 15 : Okay. And that was on 16 the date that was signed that that happened? 17 MS. NOEL: Actually she told me not to 18 date it. I remember when I was signing, she 19 said don't date it. 20 But you dated it anyway? 21 Did you have a conversation about that? 22 MS. NOEL: No. 23 : After you dated it, she 24 didn't say why did you date it or anything like 25 that? EFTA00117566  36 1 MS. NOEL: No. 2 : Okay. Did you receive 3 that training though in the annual training 4 courses as well? Like the suicide prevention 5 or the - you know how to operate in the SHU 6 during MCC annual? Or the - I think you call 7 it the IF training? Or during the correctional 8 officer training at FLETC? 9 MS. NOEL: Those trainings are like 10 general overall training. It's not 11 specifically speaking about SHU. Like SHU may 12 come up in the conversations, but it's not 13 specific to SHU or how to operate or run the 14 SHU. 15 Okay. 16 MS. NOEL: Mm-hmm. 17 Do you know if they were 18 doing this with other employees as well? 19 Having them sign training that they weren't 20 actually conducting? 21 MS. NOEL: I don't know. 22 : Okay. But did you do 23 this per the direction of your supervisor? 24 MS. NOEL: Supervisor. Yes. 25 : So she - did she EFTA00117567  37 1 specifically you must sign this? 2 MS. NOEL: Yes. 3 : Okay. And again, that 4 was 5 MS. NOEL: 6 And you said 7 and I apologize. I don't know if we were 8 interrupted when Where did you say she is 9 currently? 10 MS. NOEL: She is in Jersey I know. I'm 11 trying to -. 12 : At the FCI Fort Dix? 13 MS. NOEL: Yes. 14 : Okay. 15 MR. FOY: Question real quick. 16 : Absolutely. Do you want 17 a more precise answer to when she was out and 18 when she came back? 19 : Uh, so far -. 20 MR. FOY: Because I happen to know -- 21 : Oh sure. If you'd like. 22 MR. FOY: -- the approximate dates. 23 : Sure. You can provide 24 that. 25 MR. FOY: And this is based on my review EFTA00117568  38 1 of discovery and conversations with Ms. Noel. 2 We're looking at about March 15 to June 24-ish. 3 : Okay. 4 MR. FOY: And I note that the execution 5 was on the 26th. But I think there was some 6 time, you know, it's not like the first minute 7 she was there they had her sign the document. 8 Okay. 9 MS. NOEL: Right. 10 MR. FOY: So those are the estimated 11 times. I could be off by a day or two, but 12 Perfect. 13 MR. FOY: The 15th of March to June 24th. 14 And thank you attorney 15 Foy. 16 MR. FOY: No problem. 17 : During your time at the 18 MCC, how often were you assigned to the special 19 housing unit also known as the SHU? 20 MS. NOEL: Mm. 21 : And this is an 22 approximate. I'm not asking you for like exact 23 amount. 24 MS. NOEL: When I came back from the 25 injury, my assignment was the SHU. So from EFTA00117569  39 1 June 20-whatever to August 10th, I worked the 2 SHU. 3 : Okay. And that was your 4 quarterly assignment was in the SHU from - for 5 that whole summer 6 MS. NOEL: Yes. 7 : -- in 2019? 8 MS. NOEL: Yes. 9 : Okay. Thank you. So I 10 know that you said that you didn't - they 11 didn't provide you with the SHU training. Did 12 they provide you with the policies of the SHU? 13 MS. NOEL: No. 14 : So you never received 15 those policies? Would it have been when you 16 received and you said you had to initial and 17 date something electronically? I think you 18 said when you provided -? 19 MS. NOEL: That's the employee code of 20 conduct. 21 : Okay. 22 MS. NOEL: That's the - like the handbook 23 that's online. 24 : Should have they provided 25 you with the polices and post orders in the EFTA00117570  40 1 SHU? 2 MS. NOEL: In the SHU there is post 3 orders. 4 : Oh, okay. So in the SHU 5 there's the post orders. 6 MS. NOEL: Yes. 7 : And were you provided a 8 copy of that to review? 9 MS. NOEL: Yes. 10 : And had you reviewed 11 that? 12 MS. NOEL: Yes. 13 : Okay. And when did you 14 review that? 15 MS. NOEL: When I came back. 16 : So sometime in that June 17 -- 18 MS. NOEL: So in June. 19 : -- or July timeframe? 20 MS. NOEL: Yes. 21 : Okay. So aside from hose 22 post orders, did you receive any other SHU 23 training? 24 MS. NOEL: No. 25 : No. And who was EFTA00117571