EFTA00114184.pdf

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: EFTA00114184  2 APPEARANCES: OFFICE OF THE INSPECTOR GENERAL BY: BY: WITNESS: OTHER APPEARANCES: NONE EFTA00114185  3 1 MR. : The recorder is on and 2 it's currently June 14, 2021 at approximately 3 9:37 a.m. 4 MR. : My name is 5 I'm a Special Agent with the U.S. Department of 6 Justice Office of the Inspector General New 7 York Field Office. And these are my 8 credentials. I'll show it to you again. 9 MS. : Thank you. 10 MR. : This interview with Federal 11 Bureau of Prisons Correctional Officer 12 . Did I get 13 that right? 14 MS. : That's correct. 15 MR. : And she is being interviewed 16 as part of an official U.S. Department of 17 Justice Office of the Inspector General 18 investigation. Today is June 14th and the time 19 is approximately 9:35 a.m. The interview is 20 being conducted on the third-floor telephone 21 monitor room of the Metropolitan Correction 22 Center. Also present is DOJ OIG Senior Special 23 Agent Can you pronounce your last name 24 please? 25 MR. . And EFTA00114186  4 1 these are my credentials. 2 MS. : Thank you. 3 MR. : And Lieutenant 4 . This interview will be 5 recorded by me, Special Agent 6 Can everyone please identify themselves for the 7 record and spell their last name. To start 8 again, I am DOJ OIG Special Agent 9 10 MR. : Senior Special Agent 11 12 MS. : Lieutenant 13 14 1. 15 MR. : This is official DOJ OIG 16 investigation into the death of inmate Jeffrey 17 Epstein and everything in response that time 18 period. And you're being asked to voluntarily 19 provide some answers to our questions. Will 20 you agree to a voluntary interview with the DOJ 21 OIG? 22 MS. : Yes. 23 MR. : I'm going to provide you with 24 a form, DOJ OIG Form 3-226-2. The title of the 25 form is Warnings and Assurances to Employee EFTA00114187  5 1 Requested to Provide Information on a Voluntary 2 Basis. I'm going to read it out to you first. 3 And then I'll let you review it also. You are 4 being asked to provide information as part of 5 an investigation being conducted by the Office 6 of the Inspector General. This investigation 7 is being conducted pursuant to the Inspector 8 General Act of 1978 as amended. This 9 investigation pertains to job performance 10 failure and security failure. This is a 11 voluntary interview. Accordingly, you do not 12 have to answer any questions. No disciplinary 13 action will be taken against you if you choose 14 not to answer any questions. Any statement you 15 furnish may be used as evidence in any future 16 criminal proceedings, or agency disciplinary 17 proceedings, and/or both. Now this is the 18 waiver part. This is for you. I understand 19 the Warnings and Assurances stated above and I 20 am willing to make a statement and answer 21 questions. No promises or threats have been 22 made to me and no pressure or coercion of any 23 kind has been used against me. Do you 24 understand? 25 MS. : I understand. EFTA00114188  6 1 MR. : Do you want to move forward 2 with the interview? 3 MS. : Yes. 4 MR. : Please sign your name and 5 print your name. 6 MR. : Let's just say thank you 7 for signing and (Indiscernible *00:03:37). 8 MR. : Thank you for signing the 9 form. I myself am signing the form. I'm going 10 to print my name on it. And Agent is 11 also going to do it. 12 MR. : Thank you SA for 13 signing and dating 6/14/2021 at 9:38 a.m. This 14 is SSA and I am now signing as the 15 witness and printing my name as a witness. 16 MR. : Again, thank you, 17 Before starting the interview, I would like to 18 place you under oath. Lieutenant , can 19 you please raise your right hand? Do you swear 20 to tell the truth and nothing but the truth 21 during this interview? 22 MS. : I do to the best of 23 my knowledge and belief. 24 MR. : Thank you. Please let me 25 know if you do not understand any questions and EFTA00114189  7 1 I will repeat it or try to rephrase it. I ask 2 that you do not try to guess answers. If you 3 don't know, just say you don't know. 4 MS. : Okay. 5 MR. : Thank you. So we'll go 6 through a little bit of your background before 7 we get in. What is your current home address? 8 MS. 9 , Brooklyn, New York 10 11209. 11 MR. : Thank you. What is your date 12 of birth? 13 MS. 14 MR. : And your Social Security 15 Number. 16 MS. 17 MR. : What is your current cell 18 phone number? 19 MS. 20 MR. : What is your highest level of 21 education? 22 MS. : I have some college. 23 MR. : What did you do prior to 24 working for the bop? 25 MS. : I was in the EFTA00114190  8 1 military. 2 MR. : Thank you for your service. 3 What branch? 4 MS. : The Navy. 5 MR. : How many years? 6 MS. : Eight. 7 MR. : Alright. And how long have 8 you served with the Federal Bureau of Prisons? 9 MS. : Twenty-six years. 10 MR. : Do you remember when you 11 started? What year you started? 12 MS. : December 11, 1994. 13 MR. : When did you graduate from 14 bop training? It was soon after? 15 MS. : No. I went to 16 Glencoe. I know it was probably six months to 17 a year after I started. 18 MR. : Okay. 19 MS. : I don't' remember the 20 exact date. But it was in `95. 21 MR. : '95? 22 MS. : Yeah, it was in 1995. 23 I don't remember the month. 24 MR. : That's fine. When and where 25 was your first office assignment with the BOP? EFTA00114191  9 1 MS. : FCI Terminal Island. 2 MR. : And after that, how long were 3 you at Terminal Island for? 4 MS. : For probably around 5 six to seven months. I resigned and took a 6 position in San 7 MR. : You resigned the position 8 altogether? Or did you get a transfer? 9 MS. : The way that they did 10 it was they had me resign and then they picked 11 me up in San 12 MR. : Okay. So -. 13 MS. : It's the way that 14 they had me do it. 15 MR. : Was there a break in 16 service? 17 MS. : No. There was no 18 break in service. No. 19 MR. : At Terminal Island, what was 20 your position? 21 MS. : I was a correctional 22 officer. 23 MR. : Okay. And then six months 24 alter you went over to San 25 MS. : As a correctional EFTA00114192  10 1 officer. 2 MR. : Okay. How long were you 3 there for? 4 MS. : A little over ten 5 years. 6 MR. : Ten years. 7 MS. : Yes. 8 MR. : San . Okay. And what 9 other positions have you held with the BOP? 10 MS. : Correctional 11 Counselor and currently as a lieutenant. 12 MR. : When did you get promoted as 13 a counselor? 14 MS. : In I believe it was - 15 I started in I believe it was July of 2005. 16 MR. : July 2005. 17 MS. : Mm-hmm. 18 MR. : Alright. And then after 19 counselor, you got promoted as -. 20 MS. : A lieutenant. 21 MR. : Lieutenant. And when was 22 that? 23 MS. : That was in 2010. I 24 believe it was December 2010 that I 25 transferred. EFTA00114193  11 1 MR. : Where did you transfer? 2 MS. : FCI Jessup. 3 MR. : Jessant? 4 MS. : Jessup. 5 MR. : Jessup. 6 MS. : Jessup. In Georgia. 7 MR. : Georgia. Okay. In 2010 you 8 transferred and that was a promotion to 9 lieutenant? 10 MS. : Yeah. Well as a 11 counselor I was already a 9. So I just I guess 12 lateral over in a sense to a GS9 lieutenant. 13 MR. : Okay. In Jessup. Okay. 14 MS. : Right. 15 MR. : And how long were you in 16 Jessup for? 17 MS. : Up until I came here 18 in November of 2014. 19 MR. : November 2014. Have you been 20 here ever since or did you have any transfers? 21 MS. : Not without trying to 22 leave. But yes, I've been here since 2014. 23 Yes. 24 MR. : And were you transferred over 25 as a lieutenant? EFTA00114194  12 1 MS. : I was a lieutenant 2 when I was at Jessup. I went there as a 9. I 3 got my 11 and I just lateral over here as an 4 11. 5 MR. : And have you been in that 6 position ever since? 7 MS. : That depends on what 8 you mean by ever since. Have I been working in 9 the position or have I held that position? 10 I've held that position. I'm currently still a 11 lieutenant. 12 MR. : Okay. And - bear with me. 13 On August 9th and 10th of 2019, what was your 14 position at the MCC? 15 MS. : I was a lieutenant. 16 MR. : Okay. And what shift did you 17 work on August 9th and 10th? 18 MS. : I believe it was the 19 morning watch shift. 20 MR. : What time does the morning 21 watch shift start? 22 MS. : At that time, we were 23 coming in I believe it was from 10:00 to 6:00. 24 I think that's it. We would leave around 10:00 25 and then we got off - we got relieved at around EFTA00114195  13 1 6:00. 2 MR. ■ So you would come in at 10:00 3 a.m. and -? 4 MS. • : 10:00 p.m. 5 MR. : 10:00 p.m. And leave at 6:00 6 a.m.? 7 MS. : Well it depends on 8 what time our relief came. But those were the 9 hours that we were working around. Around that 10 time. 11 MR. : Officially that's the 12 schedule? 13 MS. : Officially, our hours 14 were midnight to 8:00. But we would come in 15 and relieve around, you know, between the hours 16 of 10:00 and 6:00. I'll put it like that. 17 MR. : Understood. Okay. And who 18 was your supervisor when you worked at the MCC 19 on August 9th and 10th? Who did you report to? 20 MS. : Then I think it was 21 Captain . Yeah. I think it was Captain 22 We've had so many captains in and out 23 since I've been here, it's hard to keep track 24 sometimes. But yeah, it's Captain 25 MR. : As a lieutenant, where were EFTA00114196  14 1 you assigned during August 9th and 10th where 2 were you assigned? 3 MS. : I was operations 4 lieutenant. 5 MR. : Okay. And as an operations 6 lieutenant, what are your daily duties? 7 MS. : We supervise staff 8 and of course the inmate population. We're 9 responsible for the safety and security of the 10 inmate staff and the institution. We do - we 11 hire overtime. We make runs throughout the 12 institution. And do various other duties. We 13 have checks and balances that we have to do 14 throughout the night. 15 MR. : Okay. As a supervisor, who 16 did you supervise? 17 MS. : I supervised the 18 inmate population and of course the staff that 19 worked for me during that shift. 20 MR. : Do you remember who you r 21 staff was during that shift? 22 MS. : Ooh, all of them? 23 No. No I do not. 24 MR. : Any key people you 25 communicated with? EFTA00114197  15 1 MS. : I mean I communicate 2 with all my staff. 3 MR. : Okay. 4 MS. : There is not one 5 person during the course of a shift that I 6 don't communicate with. Especially when I'm 7 making rounds. And especially during that 8 time, I communicated with them even more 9 because we were below the bottom of the barrel 10 then when it came to staffing. So we really 11 didn't have a lot of -. We didn't have anybody 12 back then. We didn't even have enough staff at 13 that time to even respond to body alarms. Or 14 to do uses or forces. You know. Especially on 15 morning watch. It's already tight. But we was 16 even tighter. So that was one of those nights 17 when as much as -. Well that night as like 18 every other night. As much as possible I tried 19 to talk to staff because staff were doing back- 20 to-back mandations then. And you had staff 21 that were being mandated every day of the week 22 Monday through Sunday. Or Sunday through 23 Saturday as we say in Bureau. Because that's 24 when our week officially starts - Sunday. 25 MR. : When you say mandated what do EFTA00114198  16 1 you mean by that? 2 MS. : Mandations are 3 mandatory overtime. That's when you've 4 exhausted your overtime roster. That's the 5 people that sign up for overtime. You've gone 6 through that. There's no one available. Or 7 you get everybody from that list that wants to 8 do overtime or that's available. Then you 9 announce it over the intercom system. That's 10 voluntary. Whoever wants overtime outside of 11 that, you can assign them overtime from there. 12 And then we go to mandatory overtime. That's 13 when we have nothing else left. And we have to 14 utilize the staff that we have currently on 15 duty that's not officially on a double-shift. 16 That's not officially on 16 hours. 17 MR. : So I'm going to ask a couple 18 more questions. How many hours where COs 19 working during that time period? ON average? 20 MS. : Sixteen plus because 21 -. 22 MR. : Per day? 23 MS. : Per day. Yes. 24 Because there were days when staff would be 25 late. There were days when there wasn't EFTA00114199  17 1 anybody even after we mandated everybody on the 2 shift. We didn't have anybody to fill a bunch 3 of posts. We had vacated posts. We had a lot 4 of stuff. It was grueling during that time. 5 And I think we had been doing that for at least 6 a year if not more than a year. 7 MR. : Okay. 8 MS. : Mm-hmm. 9 MR. : Did you previously meet with 10 agents regarding the Epstein investigation? 11 MS. : I did. 12 MR. : Do you recall meeting with 13 them on August 14, 2019 in regard to the 14 matter? 15 MS. : I don't remember what 16 day it was. But yes, I recall meeting with 17 them. 18 MR. : I have a summary of the 19 report. What I'm going to do is I'm going to 20 read it out to you. And once I read it out to 21 you, we're going to have some follow-up 22 questions because there's some holes in there 23 that we would like to fill. This is like the 24 summary part. informed that she 25 had been employed with the Bureau of Prisons EFTA00114200  18 1 since December 11, 1994 and promoted to 2 lieutenant around 2010 and has spent her entire 3 career working at the Metropolitan Correctional 4 Facility. During the interview, 5 described the duties -. 6 MR. : Let her correct that. 7 It's not correct. So if you hear something 8 that's not correct -- 9 MR. : Yes, please. 10 MR. : -- just say that that's 11 not correct. 12 MS. : Okay. 13 MR. : If you hear anything, please 14 interrupt me and I'll -. 15 MS. : Okay. I was a 16 lieutenant prior to coming here. I had - as a 17 matter of fact, I was promoted. I was given a 18 temporary position not to exceed a year as a 19 lieutenant back in I think it was 2000, 2001 20 when I was at MCC San in California. And 21 I did - even after that year expired, I 22 remained in the lieutenant's office for the 23 next three or four years after that until I 24 transferred. And so when I came here, when I 25 left there, I went to be a counselor. And then EFTA00114201  19 1 I picked up my lieutenant position again in 2 Jessup. When I came here, I was already a 3 lieutenant. I didn't get promoted to the 4 lieutenant rank coming here. 5 MR. : Okay. 6 MS. : And I haven't spent 7 my whole career here at MCC New York. This is 8 my fifth institution. 9 MR. : Okay. 10 MR. : You said you've been here 11 since 2014. 12 MS. : I've been here since 13 November of 2014. 14 MR. : Okay. I'm going to keep 15 going. If you hear anything wrong, please -. 16 MS. : Okay. 17 MR. : During the interview, 18 described the duties and 19 responsibilities of the position as well as the 20 guards she supervises at the MCC. 21 is assigned to the midnight shift to 8:00 22 a.m. shift, but routinely arrives at 10:00 a.m. 23 MS. : 10:00 p.m. 24 MR. : 10:00 p.m. Sorry, I read 25 that wrong. In addition to describing her EFTA00114202  20 1 administrative duties, how 2 account at the MCC works and that the 3 lieutenants are responsible for supervising one 4 count per shift. described that 5 during the count, two guards assigned to the 6 area are to unlock the main gate that separates 7 the cells from the open and common area where 8 the guards are. One guard will walk down range 9 and actually look into each cell and count the 10 number of prisoners inside. Once the count is 11 complete, the guard will return to the key and 12 exchange places with the guard that was left to 13 secure the gate. That guard will then walk 14 down range and count the number of prisoners in 15 the cells. Upon completion, the guard will 16 return to the gate, secure it from the outside, 17 and record the numbers that came from their 18 count. Those numbers will be compared to the 19 master list of prisoners on record for being 20 assigned to the south. In addition to the 21 numbers being recorded and compared to the 22 master list or the E-1 sheet, the guards will 23 call in or receive a call from internal and 24 give a verbal record of their count. And 25 internal. EFTA00114203  21 1 MS. : Wait a minute. What 2 is that again? 3 MR. : I'll repeat that back. In 4 addition to the numbers being recorded and 5 compared to the master list or E-1 sheet, the 6 guards will call in or receive a call from 7 internal. 8 MS. : That's not true. 9 MR. : Go ahead. You can tell me. 10 MS. : When the officers 11 take the count, once they have gone around to 12 each range and both of them had counted each 13 range, before they leave that range, they will 14 compare their count for that particular range. 15 And they would do that in each subsequent 16 range. When they've completed, they call the 17 control center. And they will call in their 18 unit. They will call in the count that they 19 got for that particular unit. They will give 20 them their name, who conducted the count, and 21 at that time, the control center will let them 22 know whether they have a good count or a bad 23 count. Internals position is to pick up those 24 count slips after each unit has counted and 25 place those counts slips out into their EFTA00114204  22 1 respective sally port to be picked up by 2 internal. They do not call. Internal has 3 absolutely nothing to do with their count 4 unless they get a bad count. Sometimes 5 internal, or if we have other extra staff, they 6 will go up there and they will assist them with 7 the count. You know just to see maybe if one 8 of them miscounted or something like that. 9 They would just be like an additional person. 10 A new set of eyes, basically, to assist them 11 with the count. 12 MR. : So before I continue, I had a 13 question for you. Can you sat the difference 14 between internal and control? What exactly 15 their duties are? 16 MS. : The internal officer 17 is an officer who mans the elevator. He's 18 responsible for moving inmates around in the 19 institution. He has - they have checks and 20 stuff that they do throughout their shift. But 21 mainly they're responsible for moving inmates 22 up throughout the institution. They respond to 23 body alarms. They pick up the count slips. 24 And they just have general duties throughout 25 the night. They assist with the count EFTA00114205  23 1 throughout the night. But yes, once those 2 officers if they was to get a bad count, they 3 count again. And then if they get another bad 4 count, a subsequent bad count, then internal or 5 whoever else we have available at the time 6 that's not assigned to doing something else 7 will go in and conduct another count. But 8 internal would never just - they never report 9 to internal the results of their count. 10 MR. : I was just going to ask. 11 On this if she's able to identify during her 12 shift who was internal. 13 MR. : Do you remember who was an 14 internal that night? 15 MS. : That night? No. 16 MR. : What about control? 17 MS. : No. I don't. And I 18 don't want to guess. 19 MR. : And that's why I gave him 20 This is the official duty roster from those 21 nights. See I didn't expect you to remember. 22 That's why I was just asking if you were table 23 to look at these 24 MS. : Yeah. 25 MR. : -- things and be able to EFTA00114206  24 1 determine who it is that actually -. I think 2 this is you. you were on the 10th. So -. 3 MR. : So we're going to present you 4 with two rosters. One from August 9th, 2019. 5 MR. : Well I don't think you 6 were on August 9th. Well I guess you were at 7 the 10:00 p.m. So -. 8 MR. : The 10:00 p.m. And she 9 worked an overnight too. Right? So from 10 August 9th and then also from August 10th. So 11 I'm going to mark it Exhibit 1 on August 9th. 12 And Exhibit 2 for August 10th. 13 MS. : Okay. This is August 14 10th. 15 MR. : Can you take a look and let 16 me know who the internal was and who the 17 control was for those nights? 18 MS. : For both nights? 19 MR. : Yes, please. 20 MS. : Okay. I'm currently 21 looking at the assignment roster for Friday, 22 August 9, 2019. 23 MR. : Let's start with that 24 afternoon. And then the evening. 25 MS. : You want day watch? EFTA00114207  25 1 MR. : Yeah. Again, you can go 2 through it. 3 MS. : Okay. On Friday, 4 August 9, 2019, the day watch. You wanted the 5 control room or you wanted -? 6 MR. : Let's do control room first. 7 MS. : The control room 8 number one was Officer 9 MR. : Please spell that. I don't 10 have it. Just for the record. Can you spell 11 the name on that? 12 MS. : Yes. 13 MR. : Okay. Officer 14 MS. : Yes. And his control 15 number two officer was Officer 16 I. For the evening watch shift, 17 would have been the control number one officer. 18 It seems like it appears. Ancl 19 , would have been the control two 20 according to this roster. 21 MR. : And those were the people 22 that they would have called with the numbers. 23 Correct? 24 MS. : They generally would 25 call the control number two. EFTA00114208  26 1 MR. : Okay. Control two. 2 MS. : Control two. Yes. 3 MR. : And who was that again? 4 MS. : On day watch that 5 would have been And on evening watch 6 that would have been 7 MR. : Now as far as the counts, 8 who would have picked up the slips from 9 internal? Who was that? 10 MS. : Internal during day 11 watch was Officer who was overtime. 12 And for the evening watch shift, you had 13 Officer and they had an internal 14 number two, - Officer 15 MR. : So they would have been 16 the people that like for instance would go to 17 the SHU and pick up the count slips? 18 MS. : They would go to each 19 floor -- 20 MR. : Sure. 21 MS. : -- and pick up all 22 the count slips for the entire institution. 23 MR. : To include for the 24 special housing unit though? 25 MS. : Everywhere. EFTA00114209  27 1 MR. : Great. 2 MS. : Yes. Everywhere. 3 Whether that be medical - wherever we had 4 inmates at that time, they would have been 5 picking up those count slips. Or sometimes if 6 unit team or somebody like that is here. And 7 they're on the unit at the time, you know, 8 they'll say if they're on their way down 9 they'll say I'll take the count slip down. So 10 it just depends on what day it is and what we 11 have going on during that specific time. But 12 for the most part, when no one else has 13 delivered the count slips down, it would be 14 Well, on this day, Friday, August 15 9th. It would have been between and 16 or both. 17 MR. : Great. Do you mind just 18 - this is only so that we know what document 19 you're looking at - do you mind just initialing 20 and dating and then circling the people that 21 you just discussed? 22 MS. : Do you want me to 23 date each one? 24 MR. : No-no. I'm sorry. Just 25 on the top of the form, just an initial and a EFTA00114210  28 1 date. And then you can just circle the name of 2 the people that you just said. Just for the 3 purposes of the documents that we discussed 4 will be attached to the transcript of this. 5 And it's just to make sure that we have the 6 right document. Thank you. We'll come back. 7 MR. : So I'm going to also present 8 you with the roster for August 10, 2019. Can 9 you do the same for us again? Identify the 10 internal and the control officers? 11 MS. : Okay. 12 MR. : Do you want her to be 13 specific though between the hours of 6:00 and 14 8:00 a.m.? 15 MR. : Yes. So specifically, 10 16 p.m. 17 MR. : So between 10 p.m. and 18 6:00 a.m. 19 MR. : I think the roster -. What's 20 the time that starts on the roster for August 21 10th? Midnight? 22 MS. : Midnight. Yeah. 23 MR. : So let's identify from 24 midnight to let's say 25 MR. : 8:00 a.m. The same shift EFTA00114211  29 1 that you were on. 2 MR. : Yeah. 3 MS. : Okay. So I'm looking 4 at the assignment roster for Saturday, August 5 10, 2019. The control number one officer was 6 Ms. who is non-custody. She works in 7 the R&D - Receiving and Discharge department 8 for - she was on overtime. For day watch, 9 control number one is Officer . Control 10 number two is Officer (Phonetic Sp. 11 *00:27:07) who was on overtime. For evening 12 watch, in the control one position there was 13 Officer and control two was Officer 14 who was also non-custody. 15 MR. : Now when they - when the 16 SHU officers would call control for the counts 17 during that shift, who is it that they would 18 have called? And which counts would have been 19 called? For that shift? I think you said that 20 typically, actually it -- 21 MS. : Typically 22 MR. : -- works from 10:00 p.m. 23 to 6:00 a.m. but it shows on their schedule 24 it's 12:00 to 8:00. 25 MS. : Well the officers EFTA00114212  30 1 were working those hours. 2 MR. : Okay. 3 MS. : The officers were 4 working -- 5 MR. : So just the lieutenants 6 were different? 7 MS. : -- 12:00 to 8:00. 8 Yes. It was just the lieutenants. 9 MR. : Okay. So if they 10 actually worked 12:00 to 8:00. 11 MS. : To 8:00, 8:00 to 12 4:00, and 4:00 to midnight. That's correct. 13 MR. : Okay. So who on the 14 schedule then when the special housing unit 15 officers would call in, who was it that they 16 would call into? 17 MS. : They would normally 18 call control two. Now this is not all- 19 inclusive because if control two is busy, 20 sometimes they would call control one. Because 21 control two would be you know sometimes 22 handling back-to-back calls. And plus, they're 23 responsible for answering outside calls and 24 stuff to that nature as well. I mean when 25 people are calling in from eh outside, they EFTA00114213  31 1 don't care if they miss count time or not. But 2 the control number two officers work from 6:00 3 to 2:00 to 2:00 to 10:00. Those were their 4 hours. 5 MR. : Okay. 6 MS. : Okay? And um. 7 MR. : So 6:00 a.m. or 6:00 8 p.m.? 9 MS. : The day watch would 10 work - or the a.m. shift as we call it. They 11 would work from 6:00 a.m. to 2:00 p.m. 12 MR. : Okay. 13 MS. : And the p.m. shift 14 would work 2:00 p.m. to 10:00 p.m. 15 MR. : Okay. So specifically in 16 the hours that you were working there, who 17 would have been called by the special housing 18 unit? 19 MS. : Well like I said, 20 they would have been calling because I worked 21 morning watch. They would have been calling 22 There wouldn't have been a control two -. 23 MR. : So that's -. 24 MS. : Wait a minute. 25 MR. : So that's so yeah. Let's EFTA00114214  32 1 say for instance the 12:00 p.m. count, the 3:00 2 a.m. count, and the 5:00 a.m. count. Who would 3 have been called then on August 10th? 4 MS. : They would have been 5 calling control number one because I don't 6 think they had, um They would have been 7 calling -. I want to say they was calling 8 control number one. Because at this time, it 9 look like we had a control number two. Because 10 there was a time when internal number two would 11 fill in for the control number two. But it 12 doesn't look like this was during that time. 13 MR. : To your best guess, who 14 of the officers in the special housing unit, 15 who would have been called? For the 12:00, the 16 3:00, and the 5:00 a.m. counts, who would have 17 been called on those? 18 MS. : They would have been 19 calling the control center number one. 20 MR. : And who was that? 21 MS. : During the 12:00 to 22 8:00 shift that would have been Officer 23 who, like I said, was on overtime. She's non- 24 custody. She works in the R&D department. 25 MR. : Okay. EFTA00114215  33 1 MS. : That's where she's 2 assigned. 3 MR. : Okay. And then for those 4 same counts, 12:00 a.m., 3:00 a.m., and 5:00 5 a.m., who from internal would have collected 6 those slips? 7 MS. : It could have been 8 either one of them. 9 MR. : Okay. 10 MS. : Because on morning 11 watch, it look like there was two. But I'm 12 trying to remember at that time if um -. 13 Because sometimes the internal two would assist 14 control because there were other things that 15 needed to be done. But you have for internal 16 there on morning watch there was Officer 17 and Officer (Phonetic Sp. *00:31:14) who 18 was on overtime. Officer was on overtime 19 for midnight to 8:00. So between those two, 20 they would have been picking up the count 21 slips. 22 MR. : Just can you repeat those 23 two again? 24 MS. : That's internal would 25 have been Officer . And internal number EFTA00114216  34 1 two was Officer . And he was on overtime. 2 MR. : Great. Thank you very 3 much. 4 MR. : Can you do the same with 5 that? Just circle. 6 MR. : Just circle the names 7 that you just mentioned and then just initial 8 and date on the top. 9 MS. : Oh, you know what I'm 10 doing? 11 MR. : It's -. 12 MS. : I'm putting the date 13 of the roster on here. 14 MR. : Yeah, I know. You want 15 to date it today. I'm sorry. So today is 16 6/14/21. Sorry. And I'm handing you back the 17 other roster so you can fix that. 18 MR. : So the August 10th roster I'm 19 going to mark as Exhibit 2. And August 9th 20 will be Exhibit 1. 21 MR. : I wouldn't. this is -. 22 If you're doing exhibits, this is Exhibit 1. 23 MR. : Alright. 24 MR. : If you want to do that. 25 MR. : Okay. EFTA00114217  35 1 MR. : Because we're probably 2 going to have to go back to this, I wouldn't 3 mark them as exhibits. 4 MR. : Okay. No problem. 5 MR. : Because this is always 6 going to be Exhibit 1. 7 MR. : I understand. Just to 8 clarify before we move forward. How many 9 counts take place at the MCC? Daily? 10 MS. : It depends. During 11 the week we have the Let's start with day 12 watch. Day watch we have the 4:00 p.m. count. 13 Evening watch we have the 10:00 p.m. count. 14 Morning watch we have the 12:00 a.m., the 3:00 15 a.m., and the 5:00 a.m. So five. On weekends 16 and holidays, we have an additional count of 17 10:00 a.m. which is added for weekends and 18 holidays. 19 MR. : Okay. Thank you. So I'm 20 going to go back and I'm going to continue 21 reading from that spot. So I'm going to reread 22 that line and we'll move forward. 23 MS. : Okay. 24 MR. : In addition to the numbers 25 being recorded and compared to the master list EFTA00114218  36 1 or E-1 sheet, the guards will call in or 2 receive a call from internal and give a verbal 3 record of the account and internal will compare 4 that number to the number that they have on 5 file and advise the count matches and is good 6 or does not match and a count needs to be 7 conducted again. You clarified that. You 8 explained how the control and the internal 9 works. The count slips prepared by the guards 10 are then placed in the area for pickup by 11 another guard assigned in the MCC and brought 12 to control for review. In addition to the 13 official counts that are to be conducted at 14 specific times during each shift, 15 informed that the guards are also 16 responsible for conducing rounds every 30 to 40 17 minutes. During the rounds, the guards simply 18 walk the range and view that the prisoners are 19 alive and in their cells with no issues. The 20 number of prisoners is not recorded, but simply 21 the fact that a round was conducted. And the 22 officers who conducted it is. When asked, 23 stated that she has no knowledge 24 of rounds or counts not being conducted and 25 that no one would tell her if that were the EFTA00114219  37 1 case. 2 MS. : As far as the rounds 3 go, the rounds are irregular. So they're not 4 supposed to be done at the same time and 5 there's a reason for that. You know. So the 6 rounds are supposed to be conducted - are 7 usually conducted every hour and they're done 8 on an irregular basis. So that's how the 9 rounds are supposed to be done. 10 MR. : So you say every hour, 11 it's not every 30 minutes? 12 MS. : That would be in SHU. 13 MR. : Okay. 14 MS. : Special housing has 15 its own set of rules as far as the count goes 16 but on the other units, and even in SHU the 17 rounds are supposed to be irregular. 18 MR. : Sure. 19 MS. : They're not supposed 20 to be like every half hour or something like 21 that. 22 MR. : Is it correct that it's 23 every 30 minutes but it's supposed to be 24 between 30 and 40 minutes? 25 MS. : There's a little EFTA00114220  38 1 hangover just for that -- 2 MR. : Sure. 3 MS. : -- so that the rounds 4 can be irregular if you get tied up. Because 5 when you're making rounds, inmates will stop 6 you. They will hold conversations with you and 7 ask questions. You know and so it's hard to 8 keep those rounds within those guidelines 9 because there's always something to trip you 10 up. When you're making rounds you may notice 11 something out of place, so that would stop you. 12 But as far as those rounds getting conducted, 13 those rounds are supposed to be conducted on an 14 irregular basis. But do understand that there 15 are things that will trip you up. So sometimes 16 you may be on time. Sometimes you -. It's 17 hard to fall within those guidelines because 18 you're - it's live time. Everything is alive. 19 So you can't predict what's going to happen 20 while you're making your rounds. 21 MR. : Understood. And that was a 22 summary of your interview. So as you can see, 23 we have a few questions we want to follow 24 MS. : Right. 25 MR. : And we've got -. EFTA00114221  39 1 MS. : You have medical 2 emergencies. You have inmates that are 3 complaining, wait until you start making your 4 rounds to complain about being in pain or 5 something that's hurting them. Or a lot of 6 general stuff. They'll ask you questions just 7 about anything when you're making rounds. 8 MR. : Understood. 9 MS. : Mm-hmm. 10 MR. : I'm going to go back to my 11 interview now and I have a few questions for 12 you. If there were instructions of guidance 13 from upper management, how would you receive 14 them? 15 MS. : It depends. During 16 that time, they made -. Whoever was in the 17 office may come and say something to the person 18 in the office. And it was left up to everybody 19 else to get that information from that 20 individual. 21 MR. : Who was in the office at that 22 point? I mean is a certain person assigned to 23 the office or it could be anybody in the 24 office? 25 MS. : Like the lieutenant. EFTA00114222  40 1 Like a - when I say the office, I'm talking 2 about like the lieutenants' office. So 3 sometimes they would just - and more often than 4 not - they would just say something to whoever 5 is in the office. And that's how everybody is 6 supposed to get that information. 7 MR. : If there were instructions 8 from the lieutenants, who would give it? 9 MS. : We would expect the 10 captain to give it. 11 MR. : Did the instructions that 12 would come from above the captain? Or was it 13 always from the captain? 14 MS. : Um.... I don't -. I 15 mean, from time to time, some of the AWs would 16 put things out. But the normal chain would be 17 through the captain because that was our 18 immediate supervisor. 19 MR. : Okay. If you had important 20 details to discuss with your subordinates or 21 COs who report to you, how would you 22 communicate that to them? 23 MS. : One more time. 24 MR. : If you had important details 25 or instructions you wanted to discuss with your EFTA00114223  41 1 subordinates or COs, correctional officers, who 2 report to you, how would you communicate those 3 instructions to them? 4 MS. : I usually did it when 5 I made my rounds. And I would tell them. But 6 you could also do a thing such as 3-3-3s. And 7 that way, that's when everybody come on the 8 line and you could do it that way. But you 9 really didn't have time. It was easier to just 10 tell everybody individually because that way 11 you're with them in person. and it's just 12 easier for you to do it at that time because if 13 they had questions, then they could ask you 14 questions. And when you're doing over the 15 phone at the hole, you're sitting in the 16 office. So you're really not getting anything 17 done, you know. At least if I'm making my 18 rounds, I'm getting my rounds done and I'm 19 doing my - passing down information to my staff 20 at the same time. And also it lets me know 21 that you got it. I'm telling you. it's just 22 you and me. There's