EFTA00110002.pdf
dataset_9 pdf 6.9 MB • Feb 3, 2026 • 186 pages
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4 DIGITALLY RECORDED
5 SWORN STATEMENT
6 OF
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9 OIG CASE #:
10 2019-010614
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18 DEPARTMENT OF JUSTICE
19 OFFICE OF THE INSPECTOR GENERAL
20 DECEMBER 2, 2021
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RESOLUTE DOCUMENTATION SERVICES
28632 Roadside Drive, Suite 285
Agoura Hills, CA 91301
Phone:
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1 APPEARANCES:
2
3 OFFICE OF THE INSPECTOR GENERAL
4 BY:
5 BY:
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7
8 WITNESS:
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12 OTHER APPEARANCES:
13 NONE
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1 MR. : All right. The recorder
2 is on. There is also going to be - I'm just
3 going to go over, like, a list of - it's kind
4 of, like, an introduction, and just kind of a
5 preamble into what we are going to be
6 discussing, and who you are. It's going to
7 sound very scripted, and that's because it
8 pretty much is. But you are there still.
9 Correct?
10 MS. : Yes. Mm-hmm.
11 MR. : Perfect. All right. So,
12 my name is and I am a Senior
13 Special Agent with the U.S. Department of
14 Justice, Office of the Inspector General. New
15 York Field Office. Boston Area Office. This
16 interview with Federal Bureau of Prisons
17 Associate Warden, - did I say
18 that correctly?
19 MS. : Yes. Correct. Mm-hmm.
20 MR. : Is being conducted as
21 part of an official U.S. Department of Justice,
22 Office of the Inspector General, or DOJ/OIG,
23 investigation. Today's date is December 2nd,
24 2021, and the time is 10:34 a.m. This
25 interview is being conducted by telephone. I
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1 contacted you, Ms. by telephone number
2 . Also present
3 by telephone is DOJ/OIG Special Agent
4 This interview will be recorded by
5 me, SSA Could everyone
6 please identify themselves for the record, and
7 spell your last name? To start, again, I am
8 DOJ/OIG Senior Special Agent
9 And my last name is spelled
10 I. III, can you just state your name and spell
11 your name for the recorder?
12 MR. : Yes. I am DOJ/OIG Special
13 Agent Last name is spelled II
■
15 MR. : And Ms.
16 MS. : My name is
17 Associate warden. Last name is spelled
18
19 MR. : Great. Thank you very
20 much. This is an official DOJ/OIG
21 investigation into the death of inmate Jeffrey
22 Epstein and the surrounding circumstances, and
23 you are being asked to voluntarily provide
24 answers to our questions. Will you agree to
25 the interview with the DOJ/OIG?
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1 MS. : Yes. I do.
2 MR. : Perfect. And were you
3 able to review the voluntary interview form
4 that I sent to you via email, the DOJ/OIG form
5 11I-226/2?
6 MS. : Yes, I was. Yes, I did.
7 MR. : Perfect. And thank you
8 for sending it back to me a few minutes ago. I
9 see that you signed and dated it.
10 MS. : Mm-hmm.
11 MR. : And do you understand the
12 OIG form?
13 MS. : Yes, I do.
14 MR. : Perfect. And just, I'm
15 going to just going to read it for the record,
16 so that that's something that we have to do.
17 It says, United States Department of Justice,
18 Office of the Inspector General, Warnings and
19 Assurances to Employee Requested to Provide
20 Information on a Voluntary Basis. It says,
21 "You are being asked to provide information as
22 part of an investigation being conducted by the
23 Office of the Inspector General. This
24 investigation is being conducted pursuant to
25 the Inspector General Act of 1978, as amended.
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1 This investigation pertains job performance
2 failure and security failure. This is a
3 voluntary interview. Accordingly, you do not
4 have to answer questions. No disciplinary
5 action will be taken against you if you choose
6 not to answer questions. Any statements you
7 furnish may be used as evidence in any future
8 criminal proceedings, or agency disciplinary
9 proceedings, or both." And there is a waiver
10 section. It says, "I understand the Warnings
11 and Assurances stated above, and I am willing
12 to make statements and answer questions. No
13 promises or threats have been made to me, and
14 no pressure or coercion of any kind has been
15 used against me." And I see that you signed
16 your signature. You printed your name,
17 And you dated and time
18 12/02/21, at 9:00 a.m. So, I assume that is
19 the time that you reviewed the form?
20 MS. : Yes.
21 MR. : Perfect. And that is
22 your signature on this form?
23 MS. : Yes, it is.
24 MR. : Awesome. And is there
25 any questions you have with regard to the
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1 interview, or this form?
2 MS. : No. I don't.
3 MR. : Awesome. So, I will be
4 signing my name as the Special Agent. And
5 then, I will print my name under that as the
6 Special Agent. do you mind - since this
7 is a telephone interview, you're not present -
8 do you mind if I sign for you, and place that
9 it was me that signed for you, and print your
10 name as the witness?
11 MR. : I don't mind.
12 MR. : Perfect. All right. So,
13 I will sign for you, and then print your name,
14 and I will add the telephone number that we
15 are, as the place. Great. Let me get back to
16 this. Before starting the interview, I would
17 like to place you under oath. Ms. , can
18 you please raise your right hand? Do you swear
19 to tell the truth and nothing but the truth
20 during this interview?
21 MS. : Yes, I do.
22 MR. : Perfect. Thank you. And
23 then, because we are not in person, I'm just
24 going to have to ask you a couple questions to
25 verify your identity. What is your current
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1 home address?
2 MS.
. 38053.
4 MR. : Thank you. And what is
5 your date of birth?
6 MS.
7 MR. : And what is your social
8 security number?
9 MS. : Do I have to give it?
10 MR. : You can give me your last
11 four, if that's okay.
12 MS. : Okay. The last four.
13 MR. : Perfect. Thank you. And
14 how long have you worked for the BOP?
15 MS. : For 21 years.
16 MR. : Do you remember,
17 approximately, when your enter on duty date
18 was?
19 MS. : Yes. September 10 of 2000.
20 MR. : Perfect. And what is
21 your current position with the BOP?
22 MS. : I'm an Associate Warden.
23 MR. : And where is that?
24 MS. : I'm stationed at FCC Forrest
25 City in Forrest City, Arkansas.
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1 MR. : And how long have you
2 held that position?
3 MS. : I've been - well, I've been at
4 this present duty station since officially
5 September, but physically here in October. Bu-
6 I've been an associate warden for, prior to
7 that.
8 MR. : Okay. So, you've been
9 basically you were remote in September, and
10 then physically present in October of this
11 current year, 2021?
12 MS. : Correct.
13 MR. : Perfect. And you - I'm
14 sorry - you said you've been an associate
15 warden since when?
16 MS. : I've been an associate warden
17 since - we're in 2021 - I think 2017.
18 MR. : Since 2017?
19 MS. : Uh-huh.
20 MR. : Okay. Great. And what
21 are your duties and responsibilities as an
22 associate warden?
23 MS. : As an associate warden, I
24 provide advice and counsel to the warden, and I
25 have oversight of specific disciplines as
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1 decided by the warden.
2 MR. : Okay.
3 MS. : And I made decisions on policy,
4 and security (Indiscernible *00:06:34) concerns
5 of the institution.
6 MR. : Okay. And were you ever
7 interviewed by either the DOJ/OIG or FBI
8 regarding the Epstein matter?
9 MS. : No. I was not.
10 MR. : Okay. So, this is the
11 first time?
12 MS. : Yes.
13 MR. : Okay. Great. And are
14 you familiar with inmate Jeffrey Epstein, who
15 was housed within the MCC in July and August
16 2019, until his death on August 10th, 2019?
17 MS. : Yes.
18 MR. : And what was your
19 involvement with the matter?
20 MS. : Well, I have limited
21 involvement. I arrived at MCC New York July
22 4th, I believe, of 2019. And Epstein expired
23 August 10th, I believe. So, I actually, I saw
24 him, like, when he was in the visiting room.
25 And I was part of - there has been some
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1 meetings, exec staff meetings. But as far as
2 extensive contact, or extensive involvement,
3 really nothing extensive due to my short time
4 being at the institution.
5 MR. : Okay. So, you didn't
6 arrive on July 4th? So, I guess you were
7 there, then, the entire time during his stay,
8 though. Correct?
9 MS. : Well, not the entire -. I
10 don't know when he arrived. So, I believe it
11 wasn't the entire time. But it was -. I think
12 he arrived some time in June, if I'm not
13 mistaken. I don't recall.
14 MR. : He arrived in July.
15 Right around the same time. So --
16 MS. : In July?
17 MR. : -- there might be, like,
18 a day or two difference, but yeah, it was --
19 MS. : Okay.
20 MR. : -- it was July and August
21 was when he was there.
22 MS. : Okay. Yeah.
23 MR. : Awesome. So, if you were
24 there in July, I'm just going to briefly touch
25 on the July 23rd, 2019 incident. Do you recall
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1 an incident involving Jeffrey Epstein and
2 inmate Tartaglione on July 23rd, 2019?
3 MS. : When you say an incident, what
4 do you mean?
5 MR. : So, there was an incident
6 that happened in the SHU, where Tartaglione was
7 Epstein's celimate, and Epstein was removed
8 from the SHU and placed on suicide watch, and
9 then psychological observation. Are you
10 familiar with that?
11 MS. : Oh, yes. I'm familiar with it.
12 MR. : And what is your
13 understanding of what transpired?
14 MS. : My understanding is that
15 Tartaglione, I believe he requested, or he
16 called somehow for assistance because I believe
17 he indicated that Epstein was trying to commit
18 suicide.
19 MR. : Okay. And do you know by
20 what manner Epstein was attempting to commit
21 suicide?
22 MS. : I believe he was trying to, by
23 use of either strings, or some kind of
24 clothing, or something as a ligature.
25 MR. : Okay. And is it your
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1 understanding that Epstein attempted to harm
2 himself?
3 MS. : Yes. That was my
4 understanding.
5 MR. : And did you hear anything
6 with regard to Tartaglione attempting to harm
7 Epstein?
8 MS. : I know there was, there was
9 speculation, not from Epstein, but there was
10 speculation that, perhaps, you know, there
11 could have been something involved, but
12 Epstein, I believe, made statements that his
13 cellmate did not try to harm him, as well as
14 Tartaglione himself indicated that he did not
15 try to harm him.
16 MR. : Okay. So, your belief is
17 that they are, they were not correct
18 statements, and then the fact it was Epstein
19 that attempted to harm himself, and not
20 Tartaglione?
21 MS. : That is correct.
22 MR. : Okay. And did you have
23 any involvement with selecting Tartaglione as
24 Epstein's cellmate?
25 MS. : No. I did not.
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1 MR. : And do you know how
2 Tartaglione was selected to be Epstein's
3 cellmate?
4 MS. : I don't know. I don't, I don't
5 know exactly how he was selected. I do know,
6 after the fact, it was indicated that, because
7 he was former law enforcement, and he didn't
8 seem like he, I guess he didn't - he didn't
9 have anything that, it didn't appear that he
10 would hurt Epstein, that he was suitable to be
11 Epstein's cellmate. But I don't know exactly
12 what the vetting process was for that decision.
13 MR. : Okay. And do you believe
14 that Tartaglione was an appropriate choice for
15 a cellmate?
16 MS. : I'm not going to speculate
17 about that. I do know, at the time that he was
18 a cellmate, that he did not try to harm him.
19 Epstein never voiced any concerns about - that
20 I am aware of - about Tartaglione being his
21 cellmate. But as far as looking at
22 Tartaglione's charges, or anything to see if he
23 had any risk factors that would indicate that
24 he would harm Epstein, that would be
25 speculation after the fact. So, that, I don't
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1 believe I'm in a position to make that decision
2 at this time.
3 MR. : Sure. Okay. And then,
4 what is your understanding of, after this
5 incident occurred, where was Epstein placed?
6 MS. : He was placed on suicide watch,
7 is my understanding.
8 MR. : Okay. Great. And that
9 was immediately following, or on July 23rd,
10 2019. Do you have any involvement with Epstein
11 while he was on suicide watch? And then,
12 psychological observation?
13 MS. : No.
14 MR. : And where is that
15 conducted? Or where was that conducted?
16 MS. : Where, in the suicide watch
17 cells, you mean?
18 MR. : Correct. Where would
19 have he been housed at the time?
20 MS. : Oh, yeah. The suicide watch
21 cells are on the, they are on the second -.
22 They are on the second floor. On the same
23 floor as the health services department. So,
24 around the corner, and it's down the hall from
25 psychology. From the psychology department
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1 themselves.
2 MR. : Great. And where was the
3 SHU located in the MCC?
4 MS. : The Special Housing Unit is
5 located on the ninth floor.
6 MR. : Great. And while Epstein
7 was on suicide watch, and then psychological
8 observation, do you know if he was allowed any
9 visits, specifically any attorney visits, or
10 anything like that?
11 MS. : I do believe that he was
12 allowed to see his attorney.
13 MR. : And do you know if he did
14 see his attorney while he was on psychological
15 observation?
16 MS. : I don't know for certain if,
17 like, watch was - if it was the same day, but
18 am not for certain, 100 percent certain, but I
19 do believe that it did occur. It did occur. I
20 know he was He saw his attorneys very
21 often. Almost daily. And I don't believe that
22 there was any break in visits. So, I would,
23 would say that it probably did happen on the
24 same day that he was on suicide watch.
25 MR. : And how would that work?
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1 If someone is on suicide watch, and then
2 psychological observation, how would they meet
3 with their attorneys?
4 MS. : Typically, if someone is on
5 suicide watch, they do not have visits, and
6 they don't - because they're on watch - they
7 would be under constant, whether it was an
8 inmate companion, or a staff watch. So,
9 typically, a person on suicide watch would not
10 have visits. So, if a visit did happen during
11 suicide watch, I would gather that that person
12 will still be under the same observation
13 protocol. Obviously, another inmate would not
14 be able to watch them because of the privacy
15 factor with the visit, but I would, I would
16 assume that a staff member would be present.
17 MR. : Okay. Now, would they be
18 present on that second floor suicide watch
19 area, psychological observation area? Or would
20 that be conducted in the attorney visit rooms
21 of the MCC?
22 MS. : So, again, typically, visits
23 don't happen when a person is on suicide watch.
24 And because of the placement where suicide
25 watch is, there is no visits that happen in
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1 that area. So, all of the attorney conference
2 visits, they happen in the attorney conference
3 area, which is on the third floor. So, any
4 visit, attorney related, would happen on the
5 third floor, in the attorney conference area.
6 MR. : And to make sure I'm
7 understanding you correctly. So, that means
8 you believe that when Epstein was on
9 psychological observation or suicide watch, he
10 would have been, then, transported to that
11 third floor visiting area where he would
12 conduct his visits with his attorney? His
13 attorneys.
14 MS. : That is correct.
15 MR. : Okay. Now, were there
16 any specific - and oh, sorry, before I move on,
17 I guess I should say. So, that is not typical,
18 though? That would have been, like, a kind of
19 something that was a special circumstance for
20 Epstein?
21 MS. : Yeah. Yeah. That is not
22 typical.
23 MR. : Okay. And do you know if
24 there is any prohibition up against that, or
25 not?
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1 MS. : I know There are
2 guidelines, I believe, that when a person is on
3 suicide watch, that is where they would remain
4 under constant supervision, and there would be
5 no visits.
6 MR. : Okay. So, I am assuming
7 that answer would be, then, yes, there are
8 prohibitions?
9 MS. : When you say prohibitions, you
10 mean that the agency has guidelines in place
11 that says absolutely not?
12 MR. : Yeah. So, I guess what
13 I'm asking is, should Epstein have been
14 visiting with his attorneys while he was on
15 suicide watch, or psychological observation?
16 MS. : If there was a determination,
17 which I am not aware of, that deemed that it
18 would be okay or appropriate, as far as a
19 psychologist, or someone from the psychology
20 department, indicating that it would be okay,
21 then that would be, you know, that would be a
22 consent.
23 MR. : Sure.
24 MS. : But other than that, I don't
25 believe anyone else would make that
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1 determination to say that he would then be
2 taken off of suicide watch, and then placed in
3 the attorney conference area.
4 MR. : Okay. Great. So, I take
5 it, then, is it that MCC psychology department,
6 are they the ones who determined that Epstein
7 should be on suicide watch, and then
8 psychological observation?
9 MS. : Well, anyone can actually place
10 someone on suicide watch, if that person voices
11 - and when I say "anyone," for instance, if I
12 call a psychologist is not there after hours,
13 someone voices an intent to harm themselves,
14 the lieutenant can make that decision to place
15 the person on suicide watch. But psychology
16 typically is the one that would determine
17 whether someone is taken off of suicide watch
18 because they would have to do a suicide risk
19 assessment, and any other clinical assessment.
20 So, placing someone on suicide watch
21 again - depending on the time, it can be
22 psychology, or it can be a correctional
23 services staff member. And then, the removal
24 would be someone from psychology, to say that
25 this person is not deemed suicide, or, you
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1 know, they are safe to be in general
2 population.
3 MR. : Okay. And then, but it
4 would also - and correct me if I'm wrong - but
5 it did sound like you said that it would have
6 been psychology's decision to allow Epstein to
7 visit with his attorneys while he was on
8 suicide watch or psychological observation?
9 MS. : No. I don't know if that was
10 what actually occurred. But to remove someone
11 from suicide watch, that would be a psychology
12 decision.
13 MR. : So, when you say "remove
14 someone," do you mean, like, just for those
15 hours that he was visiting, or are you talking
16 about when he was removed and placed back in
17 the SHU?
18 MS. : Typically, when you remove
19 someone, it's not for an hour or two. It's
20 typically, you are saying that that person
21 poses no more risk to themselves, so they are
22 off. Basically, they are going back to general
23 population. So, I am not aware of any
24 situation where you remove a person for an hour
25 or two, or for a short timeframe, and then
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1 place them back.
2 MR. : Sure. So, that is kind
3 of I guess what I'm asking is, who makes the
4 determinations? Because you said that your
5 understanding was that he did conduct his
6 attorney visits during that time period that he
7 was on suicide watch.
8 MS. : Mm-hmm.
9 MR. : Or psychological
10 observation. So, who made the, you know, who
11 had the authority to allow him to conduct those
12 attorney visits?
13 MS. : Yes. I don't know. Again, I
14 don't know who made the ultimate decision for
15 that to happen. But I know the process for
16 removal of suicide watch ,and what that process
17 entails. And that is why I'm saying, to remove
18 someone off of suicide watch, it would have to
19 be someone in psychology, to say that that is
20 appropriate. But in this instance, I don't
21 know, I don't know if that was communicated.
22 If that actually occurred. So, I hope,
23 hopefully that answers the question.
24 MR. : Sure. Yeah.
25 MS. : But (Indiscernible *00:19:29).
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1 MR. : We can move on to the
2 SHU, then, when he got removed. So, do you
3 know if there were any specific instructions,
4 by either you, the warden, or other MCC
5 executive staff, with regard to Epstein being
6 placed back in the SHU from psychological
7 observation?
8 MS. : When he was - you are saying
9 when he was removed?
10 MR. : So, when a determination
11 was made that he - for Epstein to be removed,
12 which was on or about July 30th, 2019.
13 MS. : Mm-hmm.
14 MR. : Were there any specific
15 instructions provided by you, the warden, or
16 other MCC executive staff, with regard to
17 Epstein being placed back in the SHU?
18 MS. : Well, I didn't, I didn't have
19 any specific direction, or instructions to a
20 particular staff member. But I do, I do know
21 that there was a determination made, and who
22 exactly made that determination, typically,
23 when you - high-profile individuals, and you
24 are saying to place them in Special Housing for
25 their care, it is typically the CEO, the
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1 warden, in consultation with correctional
2 services, because it falls under custody care
3 and control. And so, that decision was made to
4 place him in Special Housing.
5 MR. : Okay. Do you know, did
6 you, MCC executive staff, or anyone, including
7 the warden, receive any calls, or was any
8 contacted by lawyers, or a judge, asking for
9 Epstein to be removed from suicide watch or
10 psychological observation?
11 MS. : That, I am not aware of any
12 communication about that.
13 MR. : Okay. And just to circle
14 back. Were you, or executive staff, involved
15 with any decisions to have Epstein removed from
16 suicide watch or psychological observation?
17 MS. : Say that one more time. Say
18 that one more time.
19 MR. : So, that actually having
20 him removed. So, back on July, you know, 30th,
21 when he was removed. Would yourself or
22 executive staff, would you have been a part of
23 the process of actually taking him off of
24 suicide watch or psychological observation?
25 MS. : No.
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1 MR. : So, that is solely a
2 psychology decision?
3 MS. : Yeah. Because they are the
4 subject matter experts, and again, and whether
5 someone is off of suicide, or displaying
6 suicide risk factors, typically, it is a
7 psychology thing, to remove the individual.
8 MR. : Okay. And that that's
9 not in consultation with MCC executive staff?
10 MS. : No. To remove someone from
11 suicide watch? No.
12 MR. : Okay. Now, it is our
13 understanding that, after Epstein was placed
14 back in the SHU, or the Special Housing Unit,
15 psychology recommended that Epstein be housed
16 with a cellmate. Do you know if that is
17 accurate?
18 MS. : That, I do know that is
19 accurate.
20 MR. : You do know that it is
21 accurate?
22 MS. : Yes. That, I do believe that
23 that was - Mm-hmm - that is accurate. That it
24 was indicated that he should have a cellmate.
25 MR. : Okay. And do you know
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1 how that information was disseminated within
2 MCC?
3 MS. : And again, there was several,
4 you know, there was meetings, and I don't know
5 what particular meeting it occurred, but I do
6 recall, during one of the meetings, that it was
7 indicated. I don't know if it was during close
8 out, or open up, that it was important that he
9 did have a cellmate.
10 MR. : Okay. So, it was an
11 actual requirement that Epstein have a cellmate
12 while he was assigned to the SHU?
13 MS. : Yes.
14 MR. : Okay. And do you know
15 who made -? Do you know who he was celled
16 with? Do you know what the name of his
17 cellmate was when he came back off of suicide
18 watch, on July 30th, 2019?
19 MS. : Oh, who was his cellmate? i
20 don't know if it was -. I don't know what the
21 (Indiscernible *00:23:19). But I do know, at
22 one point, he had a cellmate named - the last
23 name was . And the first name was
24 I -F-R-A-I-N. But I don't recall if that was
25 his consistent cellmate. But I do recall,
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1 besides Tartaglione, was another
2 cellmate.
3 MR. : And thank you. I have
4 actually been saying So, it's
5 MS. : That's what I think you
6 pronounce it as. It could be my New York
7 accent, but I'm saying
8 MR. : Okay. Hey. That's - _
9 guess -. Yeah. I'm looking at it, and it's -.
10 I'm going to start saying now.
11 MS. : Mm-hmm.
12 MR. : Do you know who made the
13 decision that would be Epstein's
14 cellmate?
15 MS. : That, I am not aware of. I
16 don't know if it was an actual, like, meeting,
17 as far as a placement decision. So, I don't
18 know if it was actually a vetting process, to
19 determine who should be the cellmate. I know
20 itw as indicated that he should have a
21 cellmate. But what that process was, to get to
22 I am not aware of it.
23 MR. : Okay. So, that means
24 that you were not involved with that decision?
25 MS. : No.
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1 MR. : Okay. And did you work
2 at the MCC on August 9th - which was a Friday -
3 or August 10th - which was a Saturday - that he
4 was found in 2019?
5 MS. : Well, I worked on Friday. My
6 work hours, because of my position, I work
7 Monday through Friday, 7:30 to 4:00. But I did
8 report to the institution the morning of, when
9 I received the call indicating that I needed to
10 report to the institution on that day that
11 Epstein was found.
12 MR. : Okay. So, on Friday,
13 August 9th, you worked from 7:30 a.m. to 4:00
14 p.m.?
15 MS. : Correct.
16 MR. : And then, on August 10th
17 - so, you did depart at 4:00 p.m. - and then
18 you returned after Epstein was found on August
19 10th?
20 MS. : And then, I returned back to
21 the institution -. Okay. I'm trying to
22 remember what -. I received a call around
23 maybe 8:00 or something. I received a call,
24 and then, I arrived at the institution maybe
25 around 9:00 or so.
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1 MR. : Okay. 9:00 a.m.?
2 MS. : Mm-hmm.
3 MR. : Okay. So, since Epstein
4 was required to have a cellmate, who was
5 ultimately responsible to make sure that all
6 SHU staff were aware of his cellmate
7 requirement?
8 MS. : Oh. Okay. And because - I'm
9 just going to say this - because it's Special
10 Housing, Special Housing is governed under
11 correctional services. It would be the captain
12 is typically in charge of correctional
13 services. And there is a SHU lieutenant that
14 is assigned to the Special Housing on a daily
15 basis. That that is that person's daily
16 assignment. And they are responsible for
17 ensuring that everything is in compliance in
18 Special Housing. And so, there should be some
19 communication, if then, like I said, psychology
20 made a decision that he had to have a cellmate.
21 Everyone was aware of it, but that, like,
22 verbal communication, or insurance, it should
23 have happen in the correctional services. The
24 captain. The lieutenant. And then, that
25 information communicated down to the staff that
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1 actually work in the Special Housing Unit.
2 MR. : Okay. And do you know,
3 at the time, in August 9th and 10th, who the
4 captain at the MCC was?
5 MS. : It was
6 MR. : Okay. And do you know
7 who the SHU lieutenant at the time was?
8 MS. : That, I am not aware of. That,
9 I am not aware of.
10 MR. : Does Lieutenant
11 sound familiar to you?
12 MS. : I know Lieutenant . But I
13 don't know if that was his post at that
14 quarter.
15 MR. : Okay.
16 MS. : I am not sure.
17 MR. : Okay. So, that was his
18 post for the quarter. So, ultimately, the
19 information should have come from Captain
20 and SHU Lieutenant They should
21 have provided to the SHU staff that Epstein was
22 required to have a cellmate at all times?
23 MS. : Mm-hmm.
24 MR. : Okay. And that is a yes?
25 MS. : Yes. That is a yes.
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1 MR. : Okay. Great. And how
2 should have they communicated that? Should
3 have that been verbally, in writing? How
4 should have they made sure everyone knew?
5 MS. : Now, to ensure that, you could
6 have a record of it if you put it in an email.
7 That's blatant, and that can never be
8 contradicted. You could also have verbal
9 notification, in addition to written
10 notification. So, that it could be both.
11 Honestly. It could be both. But if you have
12 it in - you have something that, a bulletin or
13 some kind of an email that went out, that's
14 definitely, you know, something that - that's a
15 record. That's a permanent record.
16 MR. : So, it sounds --
17 MS. (Indiscernible *00:28:24)
18 MR. : -- you're saying, it
19 really should have been both verbal and in
20 writing, but writing would basically make sure
21 that you are, it's documented/
22 MS. : Correct.
23 MR. : Is that a correct
24 understanding?
25 MS. : That is a correct
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1 understanding.
2 MR. : Okay.
3 MS. : And in addition to that, I do
4 know that the SHU staff did know that he should
5 have had a cellmate.
6 MR. : You do know that they
7 knew that?
8 MS. : I do know that the SHU staff
9 knew that. Mm-hmm.
10 MR. : And how do you know that?
11 MS. : Because the staff are required
12 to make weekly rounds, and I don't -. Now,
13 because of, after the - excuse me - after the
14 fact, you know, he was kind of, like, you are
15 playing a - I'm just trying to recall the facts
16 - but I do recall instances of making rounds in
17 the Special Housing, where staff, it was said,
18 make sure that he had a cellmate, and when we
19 make rounds, that that was - I can - I verbally
20 heard folks say it myself.
21 MR. : And do you remember who
22 was engaged in those conversations, or who you
23 know specifically that knew?
24 MS. : That, I can't recall, because
25 in Special Housing, there is, like, four -.
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1 There is -. You have the SHU number one, SHU
2 number two, the three, and the four. So, you
3 at least have four staff, and you have staff
4 that are SHU (Indiscernible *00:29:46). So,
5 there is several staff assigned to the Special
6 Housing Unit. So, and at that -. So, I can'
7 say with certainty who was engaging in a
8 conversation. And then, like I said, and then
9 you have the SHU lieutenant. So, it was
10 several folks that were assigned to the Special
11 Housing. And again, I don't know specifically
12 who said what, but I do know that it was known
13 because I verbally, I heard it, it was audible.
14 I heard it.
15 MR. : While you were in the
16 SHU?
17 MS. : While I was in the SHU.
18 MR. : And do you know around
19 what time of day that would have been?
20 MS. : No.
21 MR. : No?
22 MS. : Hmm-mm.
23 MR. : And did you hear it more
24 than one time?
25 MS. : Yes. Mm-hmm.
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1 MR. : So, it was something that
2 you had heard on multiple occasions?
3 MS. : Mm-hmm.
4 MR. : Okay.
5 MS. : Mm-hmm.
6 MR. : And is that something
7 that, because you were engaged in a
8 conversation, or you just overheard because
9 saying it?
10 MS. : I wasn't engaging in the
11 conversation about Epstein per se, but just in
12 a conversation about what was going on in SHU,
13 while making rounds.
14 MR. : Okay.
15 MS. : So, you discuss -. So,
16 typically, when you make SHU rounds, you can do
17 both. You can have, like, a SHU roster that
18 kind of lists all of the inmates that are
19 housed in the SHU. You can, like, look at the
20 board to see who has cellmates. So, sometimes,
21 the conversation is prompted from multiple
22 things, or sometimes inmates stop you at the
23 door, and ask questions, and then you talk
24 about who it is that asked you questions. So,
25 I'm just saying, because of all those
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1 instances, I don't know why it was said about
2 that particular thing, but that was, that was
3 just one of some comments during that day.
4 MR. : But it was a comment
5 specific --
6 MS. : Yeah.
7 MR. : -- to Epstein's cellmate.
8 Correct?
9 MS. : Yes. Exactly.
10 MR. : Okay. And do you know if
11 there were any plan -. Or sorry. Before I
12 move on, I guess I should specifically ask you.
13 So, you mentioned there was SHU one, two,
14 three, four, but Epstein was found when, you
15 know, during the overnight, I guess the morning
16 watch, which is, you know, I think midnight to
17 8:00 a.m.
18 MS. : Mm-hmm.
19 MR. : He was found at
20 approximately 6:33 a.m. on August 10th, and
21 then, at that time, there were only two SHU
22 staff in there.
23 MS. : Mm-hmm.
24 MR. : Specifically, a Tova Noel
25 and a Michael Thomas. Do you know those two
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1 staff members?
2 MS. : I know of them.
3
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