EFTA00117526.pdf

1 2 APPEARANCES: OFFICE OF THE INSPECTOR GENERAL BY: BY: WITNESS: DIGITALLY RECORDED SWORN STATEMENT OF OTHER APPEARANCES: NONE OIG CASE #: 2019-010614 DEPARTMENT OF JUSTICE OFFICE OF THE INSPECTOR GENERAL OCTOBER 27, 2021 RESOLUTE DOCUMENTATION SERVICES 28632 Roadside Drive, Suite 285 Agoura Hills, CA 91301 Phone: (818) 431-5800 3 4 1 The recorder is on. 1 Thank you. 2 : My name is . I 2 : This interview will be 3 am a Special Agent with the U.S. Department of 3 recorded by me, Special Agent 4 Justice, Office of the Inspector General, New 4 Could everyone please identify themselves for 5 York Field Office, and these are my 5 the record, and spell your last name? To 6 credentials. 6 start wain I am DO] OIG Special Agent, 7 Thank you. 7 . 8 : This interview with Federal 8 Senior Special Aient 9 Bureau of Prisons employee, Captain • 9 . 10 . Did I get that right? 10 And Ca•tain 11 . 11 . 12 '. . 12 : Thank you. This is an 13 Yes. 13 official DOJ/OIG investigation into the death 14 : Is being conducted as part of 14 of inmate Jeffrey Epstein, and you are being 15 an official U.S. Department of Justice, Office 15 asked to voluntarily provide answers to our 16 of the Inspector General investigation. 16 questions. Will you agree to a voluntary 17 Today's date is October 27th. The time is 17 interview with the DOJ/OIG? 18 11:25 a.m. This interview is being conducted 18 Yes. 19 at the OIG, New York Field Office, located on 19 : Okay. I'm going to provide 20 the 29th floor of One Battery Park Plaza, New 20 you with a form. OIG form III-226/2. It 21 York, New York. Also present is: 21 states, "United States Department of Justice, 22 DO]/OIG Senior Special 22 Office of the Inspector General Warnings and 23 Agent, . And these are my 23 Assurances to Employees Requested to Provide 24 credentials. 24 Information on a Voluntary Basis. You are 25 Thank you. 25 being asked to provide information as part of EFTA00117526  6 1 an investigation being conducted by the Office 1 And signature and rint? 2 of the Inspector General. This investigation 2 Yes. This is 3 is being conducted pursuant to the Inspector 3 I'm signing on the of the Special 4 General Act of 1978, as amended. 4 Agent. Agent , can you please sign 5 This investigation pertains to job 5 as a witness? 6 performance failure and security failure. This 6 Yes. I am signing as a 7 is a voluntary interview. Accordingly, you do 7 witness. Put my name, and I will enter the 8 not have to answer questions. No disciplinary 8 date, ime and place. 9 action will be taken against you if you choose 9 1111111111: Thank you. Captain 10 not to answer questions. Any statements you 10 before starting the interview, I would like to 11 furnish may be used as evidence in any future 11 place you under oath. Can you please raise 12 criminal proceedings, or agency disciplinary 12 your ri ht hand? 13 proceeding, or both." 13 Yeah. 14 The waiver section states, "I understand 14 : Do you swear to tell the 15 the Warnings and Assurances stated above, and I 15 truth and nothing but the truth during this 16 am willing to make a statement and answer 16 interview? 17 questions. No promises or threats have been 17 Yes. 18 made to me, and no pressure or coercion of any 18 Thank you. You can put your 19 kind has been used against me." Please review 19 hand down. Please let me know if you do not 20 the form, and if you understand and agree, 20 understand any questions I ask, and I will try 21 please sign where it states, "Employee 21 to re eat it, or rephrase it for you. 22 Signature " and print your name below it. 22 Okay. 23 You said, so, print right 23 What is your current home 24 here? 24 address? 25 : Yeah. 25 7 8 1 1 : Okay. And was there a 2 2 concertation ou were following? 3 3 : No. 4 : Thank you. What is your date 4 : Okay. What did you do prior 5 of birth? S to workin for the BOP? 6 : . 6 : I worked for 7 Ma What is your social security 7 Corrections. 8 number? 8 And how long was that for? 9 10 ME 11 phone number? What is your current cell 9 10 11 : I started, it was about, I believe I started in 1993. And then, I left there in '98 and came to the BOP. 12 Area code is 12 : Okay. In '98, you came to 13 What is your highest level of 13 the BOP? 14 education? 14 : Yes. 15 Some college. 15 la Okay. Did you have any 16 17 . 18 colleiiiIIIIIIII 19 What is your college? : Just a couple of community 17 : Okay. 16 18 19 militar service? : No. : Okay. And have you been with the BOP since 1998? 20 : In my hometown. Back in 20 : Yes. 21 Indiana. 21 Okay. Do you remember your 22 : What was the name of the 22 exact enter on duty date? 23 colle e? 23 : April 26, 1998. 24 • (Phonetic Sp. 24 Mr Thank you. And what is your 25 *00:04:27) Business College. 25 current employment status? EFTA00117527  9 10 1 I'm sorry. I don't 1 : FCI III. 2 understand. 2 : As a deputy -- 3 What is your current 3 : Captain. 4 position with -- 4 : -- captain. 5 : Yeah. 5 : Mm-hmm. 6 -- the BOP? 6 : What was your position at the 7 1: I'm a captain. I'm sorry. 7 MCC in 2019? 8 : At the FCI 8 : I was a lieutenant. 9 At IIIIIi- 9 ME A lieutenant. Okay. Was 10 10 that a nine or -? 11 -- yes. At FCI 11 . No. I was an 11. 12 I'm the com lex captain. 12 An 11. 13 Oka . And prior to being 13 . Mm-hmm. 14 captain at FCI , were you employed at 14 : Okay. And as a lieutenant at 15 the MCC? 15 the MCC what were your duties there? 16 Well, I was the deputy 16 That year, I was assigned as 17 captain at . Then I got the 17 the administrative lieutenant. So, my duties 18 institution captain, but prior to that, yes, I 18 consisted of making sure the staff and the 19 was em lo ed at MCC New York. 19 correctional services department got their 20 During what time period? 20 training. I did everybody's schedules. 21 : I started in -. I 21 Sometimes, I covered shifts. If the captain 22 transferred to MCC in April of 2013, and I left 22 wasn't there, I acted in his capacity. lust 23 in Seiiiiiiiiii19. 23 varioiiiiiiiiiiow, responsibilities. 24 : And what was, in September 24 : It was not in custody, it was 25 2019, you transferred over to -? 25 more, you said administrative? 11 12 1 Well, the administrative 1 and give those to the lieutenants, and then 2 lieutenant is part of the custody department, 2 they did whatever they needed to do with them. 3 because everything I did involved officers and 3 : Okay. And who reported to 4 lieutenants. 4 you directl ? 5 : Okay. And in terms, I know 5 : The officers reported to me. 6 there is an operations lieutenant. There is an 6 And that waspretty much it. 7 activities lieutenant. 7 : Which officers? 8 Mm-hmm. 8 : All of them, because I did 9 And where would you fall 9 all of their schedules. So, they came to me if 10 under? Like, do you work side by side with 10 they had an issue, or they needed time off, 11 them, or is there a separate department that 11 they had an issue with their schedule. They 12 you are -? 12 were out on workman's comp. Or, you know, 13 : Well, we worked on the same 13 anything dealing with leave time, or anything, 14 floor. But I don't do the same duties that 14 they came to me. 15 15 : Okay. And you mentioned that 16 Okay. 16 you would coordinate training for the 17 So, I would be there with 17 employees? 18 them, but they would be covering the shift. I 18 . Mm-hmm. 19 had nothing to do with the shift itself. You 19 What kind of trainings? 20 know, the trips that went out, or the work 20 The quarterly mandatory 21 assignments or whatever. I would do the work 21 trainings that we were required to do. Our 22 assignments prior to them actually working on 22 annual trainings that we were required to do. 23 that day. So, as the administrative 23 Regular annual refresher training. Firearms 24 lieutenant, my responsibility was to generate 24 training. I had to do all of - schedule all of 25 the daily rosters, and the quarterly rosters, 25 that. EFTA00117528  13 14 1 : Okay. And did you schedule 1 sat with the union, to determine which non- 2 all of that, the quarterly training, the annual 2 custody staff member went to what post, I would 3 refresher training, all that, in 2019? 3 keep that, I would have them bid on what they 4 : Yes. Mm-hmm. 4 wanted to work. And I would keep that MI! How is it documented if 5 documentation in the administrative office with 6 emplo ees received training? 6 me. As far as the quarterly training goes, 7 : So, which training are we 7 every quarter, any staff member who bid to work 8 talkin about? Just any, or -? 8 in SHU - in the Special Housing Unit, I'm 9 lust -- 9 sorry. 10 : Just -. 10 Any staff member that bid to work there, 11 -- specifically, we 11 they had to go through mandatory quarterly 12 talked about the SHU quarterly training, and 12 training. So, what I would do is, I would get 13 the annual refresher training. 13 with the SHU lieutenant to figure out a date. 14 : Okay. So, for the annual 14 It has to be completed before the new quarter 15 refresher training, Human Resources would 15 starts. And he would tell me whatever - he or 16 normally get with me. They would tell me the 16 she - would tell me whatever date they wanted 17 dates that they wanted to do annual refresher 17 to do it. Every staff member that was on the 18 training. And what I would do is go onto the 18 quarterly roster, that would be in SHU, was 19 roster program. They would let me know how 19 scheduled to attend that training. We would do 20 many staff to put in each day. I would go into 20 it in a classroom setting, for, like, a four- 21 the program. I would assign them, and then, I 21 hour block. And all I would do was schedule 22 would back fill their positions with a non- 22 the training, let the SHU lieutenant know, make 23 custody staff member. 23 sure he had the post orders, because all field 24 So, that was documented on every quarterly 24 office the staff who were going to be up there 25 roster. So, what I used to do was, because I 25 was supposed to go through the post orders, and 15 16 1 read them, and sign them. And he would the 1 Just anything dealing with SHU, period, that 2 training, and then just give me the sign in 2 lieutenant is supposed to go over it with them, 3 sheet for ever bod that attended. 3 as well as have them watch that slide show. 4 : Okay. 4 : So, are they allowed to work 5 : And prior to them actually 5 in the SHU without getting that training? 6 starting their rotation in the SHU, this 6 : Yes. However, they 7 trainin would have to be completed. 7 shouldn't because that training is documented. 8 Yes. 8 Every quarter, we have to send to the region 9 : All right. And it's a 9 that it was completed. And it also gets, I 10 mandator training? 10 believe it gets keyed into their training file 11 . Yes. 11 with Human Resources. 12 : And what topics does the 12 And who was required to 13 trainin cover? 13 ensure that the receive that training? 14 : We have a Special Housing 14 : The SHU lieutenant. 15 Unit slide down. That's the normal training. 15 Okay. And then, what 16 Mi l Yeah. 16 would your role be in that? Like, if someone 17 : But what the training should 17 didn't actually - someone would bid for that 18 cover, outside of them doing that slide show, 18 quarterly position, and actually wasn't able, 19 that SHU, normally the SHU lieutenant does the 19 for whatever reason, to attend the actual 20 training. Outside of that slide show, they 20 quarterly training, for the SHU, what is the 21 should be discussing with them how to operate 21 protocol? What should have taken place? 22 the SHU program. We have psychology come in 22 : So, if, just say for 23 and do a class on suicide prevention. Hunger 23 instance can I ive an example -- 24 strikes. They should be talking to them about 24 : Absolutely. 25 how to fill out the documentation for 292s. 25 : -- okay. So, just say for EFTA00117529  17 18 1 instance a staff member was out on a workman's 1 : So, the sign-in sheet would 2 comp. They had missed the SHU training for 2 have everybody that actually attended on the 3 that reason, or they were on annual leave. 3 scheduled day, and then the names of the people 4 When they come back to work, I would coordinate 4 who still needed to attend it. And once they 5 it with the SHU lieutenant, to have that person 5 do it, they are supposed to sign, and sign for 6 go over the training with them. And then, they 6 the date that the do it. 7 would come back and make sure that they sign 7 : Okay. 8 that they completed the training. And again, I 8 : So, my next question would 9 kept that stored in, on file in my office. In 9 have been, if any employee was not able to 10 the admin office. 10 attend training, was there a makeup training 11 : All right. So, it sounds 11 session involved? 12 like you were the one who kind of keeps records 12 : Yes. 13 of who has done it, and who has not. You then 13 And that would be not by you, 14 coordinate it with the SHU lieutenant, and say 14 that would be b the SHU lieutenant? 15 if this person needs to take it. And then, 15 : Yes. 16 after they take it, they are supposed to come 16 : Okay. And do they normally 17 to you and si n it? 17 get training? How long is the SHU training? 18 : No. Not -. After they take 18 How long does it normally take? The quarterly 19 it, I would give the SHU lieutenant the sign-in 19 trainin . 20 sheet. 20 : We usually schedule it for a 21 Okay. 21 four-hour block. 22 WBecause that person should 22 : For how many days? 23 sign for the date that they actually completed 23 : One. Just one day. 24 the trainin . 24 : So, one day, four hours? 25 : Okay. 25 : Mm-hmm. I would schedule 19 20 1 everyiiiiiiiiiihat one day, for four hours. 1 lieutenant ive them a training? 2 : And let's say if somebody 2 : Right away, if they are 3 missed it, and they came back, they would have 3 going to have them in SHU. I would -. I tried 4 to sit throw h that four hours? 4 my best - because I was the admin lieutenant 5 : Well, once I would tell the 5 there for a long time - so, I tried my best to 6 SHU lieutenant this person is back, you got to 6 keep up with that, to make sure, as soon as 7 make sure that they complete the training. I'm 7 this person came back, they did whatever they 8 not sure how he went about doing it with them. 8 needed to do. 9 Because I didn't attend the training. I never 9 : Okay. I 10 attended the training. I just scheduled it. 10 : But I can I -- 11 : Who schedules the trainers? 11 : Yeah. Sure. 12 Who picks the trainers and schedules them to 12 : -- say something? 13 teach the class? 13 : Yeah. 14 : Well, any lieutenant can 14 : Absolutely. 15 teach training for the Special Housing Unit. 15 : Because you had asked me, 16 During annual refresher training, every year 16 can a person work in the Special Housing Unit 17 when we do it, it's a lieutenant assigned to do 17 without the training, and like I said, yes, but 18 it. 18 they shouldn't. However, you had a lot of non- 19 : So, normally, it's a 19 custody staff who weren't required to take this 20 lieutenant. So, in this case, if a C.O. missed 20 training. Because they weren't in correctional 21 the training, they come back, the lieutenant 21 services. 22 can technical) give the full training? 22 But the quarterly bidded 23 : They can. 23 people -- 24 : Okay. And how soon after 24 : The quarterly bidded people 25 they come back from training should the 25 EFTA00117530  21 22 1 : -- were required. 1 : Once she came back, the SHU 2 : -- had to do it. 2 lieutenant would have gotten with her to get 3 : Right. 3 with her to have her take care of it, and have 4 : That was it. 4 her sign. 5 : Okay. 5 Okay. Go ahead. 6 : Yes. 6 Okay. Is this the mandatory 7 : Do you recall a C.O. by the 7 quarterly SHU training for 2019? 8 name of Tova Noel? 8 Yes. 9 : Yes. 9 The dates shows 6/6/2019? 10 Do you know if in that 10 Mm-hmm. 11 quarter that - this would be June, July, August 11 Is that the -? 12 of 2019 - if she was one of those C.O.s that 12 Yeah. I'm sorry. Yes. 13 bidded for the SHU? 13 Okay. And that is the sign- 14 : I don't remember. I think 14 in sheet? 15 she got a relief post in SHU, if I'm not 15 t Yes. 16 mistaken, and I do remember, she was out for a 16 : Okay. 17 while because she had injured, I don't know if 17 : So, on the sign-in sheet, 18 it was her ankle or something. She was out on 18 it shows different dates on it. Do you know 19 workman's comp. So, around that time, when we 19 what the would represent? 20 did the training, she wasn't there. 20 : So, as I said, the 21 : She wasn't there. 21 difference dates would be because, when we 22 : Hmm-mm. 22 actually had this training, these people 23 : Now -. 23 probably weren't here. So, once they came 24 : Whoa, whoa. So, what 24 back, they had to do the training, and sign 25 happened if she wasn't there? 25 that they completed it on the date that they 23 24 1 completed it. 1 injury, and I told her she had to do the 2 And for any of these 2 trains ir m 3 people, did you review the training with me, or 3 Okay. 4 was it always the SHU lieutenant that was 4 : But I didn't have her sign 5 supposed to review the training with them? 5 this. 6 : No. I never did the 6 : Do you remember her 7 training with them. It was always the SHU 7 saying -. So, she returned to work on or 8 lieutenant, or whoever was assigned to SHU at 8 around June 24th of 2021. 9 10 11 that time. So, with this sign-in sheet, would you, did you give that sign-in 9 10 11 n Mm-hrrim. : The SHU was her quarterly 12 sheet to the lieutenant to have them sign, or 12 2019. Sorry. 13 would you go to the employee themselves and 13 -- sorry. 2019. The SHU 14 have them si n it? 14 was her quarterly bidded post. And she says 15 : No. I gave this to the 15 that, on the 26th, is when she signed, that you 16 lieutenant. 16 came to her directly and said, you have to sign 17 : All right. So, in this 17 this, and she said she didn't get it from the 18 instance, we spoke with Tova Noel. She is 18 lieutenant. She got it directly from you. 19 claiming that you went directly to her with 19 Does that -- 20 this, and asked her to sign it. Do you recall 20 No. 21 that? 21 -- ring a bell at all? 22 MiNo. 22 No. 23 : No? 23 : All right. We just want 24 : No. I remember speaking to 24 to read you some quotes from her transcript. 25 her, and she returned back to work, from her 25 Just to see, you know, what your response is to EFTA00117531  25 26 1 this. We asked her, "Who was your direct 1 : I'm assuming. 2 su ervisor?" And she said, "Lieutenant 2 : Okay. 3 ." Would that be accurate? 3 : But once she returned to 4 No. 4 work, whoever that shift lieutenant was, would 5 : So, you didn't believe 5 be who she would deal with. 6 that ou were her direct supervisor? 6 : Okay. So then, we asked, 7 : Well, the operations 7 it says - and this is me speaking - "You 8 lieutenant on her shift, or the activities 8 mentioned you didn't remember ever going to 9 lieutenant on her shift was her direct 9 quarterly SHU training. This is a sign-in 10 supervisor. 10 sheet for quarterly SHU training. I just want 11 Okay. So, that changes 11 you to, is this your signature on there for 12 every day, but I guess if we had one specific 12 June 26th, 2019?" And she responds, "You see 13 that was a constant, would that be you? 13 how I'm the last one on the bottom of all of 14 : No. She was dealing with me 14 them?" I say, "Correct." She says, "Because I 15 while she was out on workman's comp, because 15 wasn't at the training when I came in," she 16 while she was out, I was the one getting her 16 responded. "Did they provide it to you one on 17 doctor's notes, and calling to check on her, or 17 one, though?" She said, "No." I said, "So, 18 if she had, like, a CA-7 that needed to be 18 how come?" She said, "Because when I came back 19 filled out, so she can keep getting paid, I had 19 from an injury, the lieutenant asked me to sign 20 to fill that out. 20 because when they had program review, they need 21 : Okay. So, while she was 21 to show that I received the training. But I 22 out, up until at least the 24th of - lune - 22 never did. She just asked me to sign." 23 2019, that's why she considered you her 23 "That's why I wonder why, who asked you to do 24 supervisor, because you were the one dealing 24 that?" I said. And she said, "Lieutenant 25 directly with her? 25 27 28 1 MMm-hrml. 1 I did explain to her that 2 : I said, "So, that 2 she needed to complete the training because we 3 supervisor you mentioned was your first line 3 had to have it done for our program review. 4 supervisor, asked you to sign without providing 4 However, I had her do that training with the 5 you the training?" She said, "Yes." I said, 5 SHU lieutenant. I would have never had her 6 "And she didn't, like, provide you anything to 6 sign something that she didn't review. And the 7 review?" She said, "No." And I said, "She 7 reason why her name is last on that list is 8 didn't go over anything with you?" She said, 8 because she came back to work at that time. 9 "No." I said, "Did you discuss this with her, 9 Okay. So -. 10 that how can you sign something without being 10 rid you ask her to sign the 11 provided the training?" 11 document for the program review, prior to the 12 She said, "Well, I just told her I wasn't 12 program review, without her actually taking the 13 here. I was out on an injury. She said she 13 trainin ? 14 knows, but she needed me to sign it because 14 : No. I explained to her that 15 they need it for a program review." I said, 15 she had to complete the training because when 16 "What's her first name?" And she responded, 16 we had our program review, they review these 17 ." I said, "And is she a 17 documents, and that is part of what they call 18 lieutenant?" And Noel said, "She's a - I don't 18 our working papers. And if one person has - or 19 know what she is now - but she is not at MCC 19 whoever - has it missed, we get a write-up for 20 anymore. She's at somewhere in Jersey." So, 20 that. 21 with all that being said, what is your response 21 : Did you speak with Lieutenant 22 to Ms. Noel with her statements to us? 22 IIII, and instruct him that, hey, listen, he 23 • Her statement is partially 23 needs to ive Tova Noel the training? 24 true. 24 : Yes. 25 Okay. 25 : And did he ever confirm with EFTA00117532  29 30 1 you that he did provide it to her? 1 not saying that what she said was accurate. 2 : No. I just got the sign-in 2 That's wh we're asking you -- 3 sheet back with her name signed. 3 Mm-hmm. 4 : Oh, so, you didn't give it to 4 -- to just clarify all of 5 her. You ave it to the lieutenant. And -- 5 this, of what exactly happened. 6 Yeah. 6 : No. The only conversation 7 -- the lieutenant got her to 7 that she and I had, and if I remember 8 sign in, and rovide it back to you? 8 correctly, it was on her first day back, if I 9 Yes. 9 am not mistaken. Her first day back to work, 10 : So, she is saying you 10 because she came to me to find out where she 11 came directly to her. She didn't_ggt any 11 was working. And when we had that 12 training from either Lieutenant IIII, who was 12 conversation, I did say to her that she had to 13 the SHU lieutenant at the time, or provided any 13 complete the training, you know, because we got 14 kind of sheets to review. She said - and we 14 to make sure we are in line with everything for 15 can go into reater detail of what she said -- 15 program review. But I never gave her anything 16 : Mm-hmm. 16 to si n. At all. 17 : -- but she said that you 17 : So, when she says you 18 didn't, when she said this to you, you said, I 18 specifically gave her this sign-in sheet, you 19 just need it for the program review, and you 19 are sa in ou did not? 20 asked her not to date it, and she said that she 20 : No. I did not. And I 21 intentionally wanted to date it, to show what 21 definitel didn't tell her not to date it. 22 date that she did this on. 22 : All right. So, when she 23 : That's not accurate at all. 23 says that, you know, let's go back and read it. 24 : Okay. So, please, 24 She specifically says, "Because when I came 25 explain to us. And just for the record, we are 25 back from an injury, the lieutenant asked me to 31 32 1 sign because when they had program review, they 1 that, after she did the training, she was going 2 need to show that I received the training, but 2 to have to sign the sheet. And I told her she 3 I never did. She just asked me to sign." So, 3 had to complete it because of program review. 4 her saying that you asked her to sign that, is 4 I did do that. 5 inaccurate? 5 Okay. Do you recognize - 6 : Yes, it is. 6 hold on - this stuff that we are giving you 7 : Okay. And are you 7 here. Can you just let us know what this 8 confident with that? Because this is, like, an 8 information is? And what the sign-in sheet is? 9 under oath. She was under oath, and you are 9 Okay. So, this is another 10 now under oath. So, now -- 10 sign-in sheet for training. This one would be 11 aMm-hrrim. 11 for the -. was the chief 12 : -- we have two 12 psychologist. So, that would be discussing 13 discre ancies of what happened. 13 suicide trainin. 14 : Yes. I am confident with 14 • Just -. 15 that. 15 This is -. 16 : Do you recall, 16 • So, that one was suicide 17 specifically? Can you place yourself back into 17 prevention training? 18 that conversation? Do you remember 18 This one was. Yes. 19 specificall this happening or not happening? 19 20 : I remember specifically 20 M I : Okay. This is , again, 21 speaking to her about it. And I told her she 21 but this is a different training. This was in 22 had to complete the training, but I did not 22 2018. 23 have her si n an thing. 23 : Okay. So, the one that 24 : Okay. 24 we are on top, though, that is the sign-in for, 25 : I didn't. I did tell her 25 it says June 6, 2019. And then, again, on the EFTA00117533  33 34 1 bottom, it sa s T. Noel. 1 Okay. So, if this was 2 Yes. 2 all completed, if the training was done on June 3 And then, does it have a 3 6, 2019 when you get the sign-in sheets? 4 date next to that one, too? 4 MEM: Whenever the SHU lieutenant 5 nJune 26. 5 brought them to me. Brought them back to me. 6 : Okay. So, that was also 6 : Okay. So, in this case, 7 the June 26, 2019. So, it looks like she had 7 do you believe it would have been some time 8 the quarterly, the quarterly post training, or 8 shortl after June 6, 2019? 9 quarterl , what do you call it -- 9 : Well, I don't remember that. 10 : SHU training. 10 But I do remember, because these other people 11 : SHU training. And 11 who weren't there, they had to do the exact 12 then, the suicide prevention training, both 12 same thing, and the SHU lieutenant got with all 13 signed on the same date. 13 of all them, and had them all do their 14 aMm-hTm. 14 training, and sign for their days. I didn't do 15 : Did you give that - 15 any of these eo le's. 16 either one of those - sign-in sheets directly 16 : Okay. So, and the fact 17 to Ms. Noel? 17 that, when was the - prior to T. Noel - when 18 Mi No. 18 was the last date on that? 19 : No. 19 • June, it looks the 23rd, and 20 : Because would 20 then, June 20th. 21 keep her own sheet. And also, the SHU 21 Okay. So, the two prior 22 lieutenant, who completed the training, that 22 were both in the 20s. And you don't believe 23 person would get a copy of this, as well. And 23 you went direct to either of those two, either? 24 then, when everything was completed, they would 24 MI.No. I didn't. 25 give me back the sign-in sheets. 25 : So, do you -- 35 36 1 I didn't. 1 these same forms. 2 : -- do you believe that 2 : Okay. So, on this 3 Lieutenant - would it have been Lieutenant 3 specific training, this is, these were the 4 that would have provided this to you, when it 4 statements that were made, I said, "So, there 5 was all done? 5 is another training that you - it says that you 6 : Yes. 6 conducted on also June 26th, 2019, for SHU 7 : Okay. So, he wouldn't 7 suicide prevention training. Did you also not 8 have provided that back to you until after June 8 receive that training?" Ms. Noel responded, 9 26, 2019 after Noel signed? 9 "Yeah. I didn't." I responded, "You did not 10 IIIIIIIIIII: No. Because at the time, if 10 receive that training?" She said, "No." I 11 I had this, then the last person before her was 11 said, "Did you receive -. 12 June 23rd. So, took care of all of these 12 So, there's slides in the back that show 13 people, and then, he gave it back to me. I 13 that the training, shows the training and how 14 can't remember if he just came back after the 14 they conducted it. Did they provide you with 15 6th, when everybody was done, and got it. Or 15 those slides?" And she responded, "No because 16 if he came back. Because I kept them in a 16 I wasn't there." I said, "You weren't there?" 17 binder. I keep all of these in a binder, in 17 And she responds, "I was out on injury." I 18 the admin lieutenant's office. So, all he had 18 said, "Okay. Can you - when were you out on 19 to do was just come get the binder. You see 19 injury? What were the dates?" And she 20 what I'm saying? So, he could have came and 20 responded, "From March 2019 to I came back in 21 got it, had them do whatever they needed to do. 21 June. So, when I came back in lune, that's 22 And the sheet would have already been in the 22 when I was told to sign this." Ltgain, is this 23 binder. And then, he keeps the copy from III 23 - you believe it's Lieutenant that 24 as well. They are supposed to keep a 24 actuall y told her to sign it? 25 binder in the SHU lieutenant's office, with 25 : It should have been. Yes. EFTA00117534  37 38 1 : Did you -- 1 happened?" Ms. Noel said, "Actually, she told 2 ies. 2 me not to date it. 3 -- but it was not you? 3 I remember when I was signing. She said, 4 No. 4 don't date it." And I said, "But you dated it 5 : And are you confident it 5 anyway? Did you have a conversation about 6 wasn't ou? 6 that?" And she said, "No." I said, "After you 7 To my recollection, yes. 7 dated it, she didn't say, why did you date it? 8 . Okay. Shortly there 8 Or anything like that?" She responded, "No." 9 later, I said, "But when you came back, was it 9 So, she is saying all of this time, that 10 around the 26th when they asked you to sign 10 specifically, that the lieutenant said to go 11 those?" And she responded, "I came back in 11 see you, and that you had her sign this 12 June. I don't recall the date exactly." I 12 information. 13 said, "Okay." She said, "But I remember the 13 : That is not true. 14 day I came back into work, and the lieutenant 14 : It's not accurate? 15 asked me to go see Lieutenant . And she 15 : No. It's not. And if the 16 asked me to sign, and I said, but I wasn't 16 lieutenant that was on shift would have told 17 here. I was out on injury. 17 her to come to see me, it was her first day 18 And she said she's aware, but they need me 18 back. So, when they returned to work for a 19 to sign for program review." I said, "Okay." 19 work-related injury, they are supposed to bring 20 She said, "So, I signed." And I said, "So, 20 in a note from the doctor, clearing them to be 21 both trainings, when you signed, they didn't 21 back at work. So, she would have came to see 22 actually ever provide you anything?" She said, 22 me, to give me a copy of that note. Because in 23 "No." I said, "Verbally? Electronically? 23 order for her to work, she had to have that 24 Nothing?" She said, "No." I said, "Okay. And 24 note from her doctor. 25 that was on the date that was signed that that 25 Okay. 39 40 1 That, and also, too, 1 "But did you do this per the direction of your 2 probably to find out about what her schedule 2 supervisor?" She said, "Supervisor, yes." And 3 would be, or where she is supposed to be 3 I said, "So, did she specifically say you must 4 working at. That's the only thing that I could 4 sign this?" Ms. Noel said, "Yes." And I said, 5 think of. But we did have the conversation 5 "Okay. And iiiiiiithat was ?" And Ms. 6 about the training. But at no time did I ask 6 Noel said, " ." So, she is claiming, 7 her to sin an thing. 7 under oath, under penalty of, you know, you 8 : Okay. So, what 8 know, of perjury, which is a criminal offense, 9 conversation did you have about the training? 9 which is - a ain - you are under oath. 10 : I just told her that she 10 : Mm-hmm. 11 needed to complete the training. Because part 11 That you specifically 12 of her post - if I remember right - it was a 12 told her to sign this. That's where I just 13 relief post. So, I don't think she was 13 wanted -. I don't want to trip up, because 14 assigned to SHU every day. 14 this right now is more of an administrative 15 : Now, did you maybe tell 15 thing. 16 her sign this training, sign this form, because 16 17 I have a program review up. Co do your 17 a 18 training. Don't date it because you didn't do 18 to a criminal. Mm-hrrim. : I don't want to bring it 19 the trainin et? 20 : No. I would have never told 20 21 her to sign it, because she hadn't completed 19 n Mm-hrrim. : If, you know, under oath, 21 under the penalties of perjury, which is 22 it. And I definitely would not have told her 22 statute 18 USC 1001, false statements, are you 23 not to date it. 23 confident that you did not ask her to sign 24 Okay. Because again, she 24 this? 25 is saying - and this is a question I asked - 25 Yes. I am. EFT