EFTA00117643.pdf

1 2 APPEARANCES: OFFICE OF THE INSPECTOR GENERAL BY: BY: WITNESS: DIGITALLY RECORDED SWORN STATEMENT OF OTHER APPEARANCES: JASON FOY, ESQ. OIG CASE #: ERIC SARRAGA, ESQ. 2019-010614 SERINE GREG DEPARTMENT OF JUSTICE OFFICE OF THE INSPECTOR GENERAL JUNE 21, 2021 RESOLUTE DOCUMENTATION SERVICES 28632 Roadside Drive, Suite 285 Agoura Hills, CA 91301 Phone: (818) 431-5800 3 4 1 MR. The recorder is on. My 1 Seplowitz, LLC; as well as union representative 2 name is . I am a Senior 2 Serine Greg of the Local 3149 with the BOP. 3 Special Agent with the U.S. Department of 3 This interview will be recorded by me, Senior 4 Justice Office of the Inspector General New 4 Special Agent . Could S York Field Office and these are my credentials. 5 everyone please identify themselves for the 6 This interview with Federal Bureau of Prisons 6 record and spell your last name. To starti_ 7 correctional officer is being 7 again, I am DO) OIG Senior Special Agent 8 conducted as part of an official U.S. 8 9 Department of Justice Office of the Inspector 9 DOJ OIG Special Agent 10 General investigation. Today's date is June 10 11 22, 2021 and the time is 10:09 a.m. This 11 MS. : I'm 12 interview is being conducted at - what is the 12 MR. FOY: Jason Foy, F-O-Y, attorney for 13 location - 15 -? 13 14 MR. FOY: 15 Bergen Street, Hackensack, 14 MR. SARRAGA: Eric Sarraga, S-A-R-R-A-G-A, 15 New JerseiiIIIIIIII 15 attorney for 16 MR. : Thank you, sir. 16 MS. GREGG: Serine Gregg, G-R-E-G-G, Local 17 MR. FOY: Bergen County Bar Association, 17 3148. 18 second floor conference room. 18 MR. : Thank you everyone. Ms. 19 MR. : Okay. 19 IIII, you are here today as a subject in this 20 MR. FOY: By the way, that was Jason Foy 20 DOJ OIG investigation. This DO) OIG 21 speaking. 21 investigation concerns your alleged misconduct 22 MR. Yes. Also present are 22 to include allegations of false statements, job 23 DO) OIG Special Agent 23 performance failure, security failure, and 24 Correctional officer ; 24 reporting false information. This is an 25 attorneys, Jason Foy, and Eric Sarraga of Foy & 25 official DOJ OIG investigation and you are EFTA00117643  S 6 1 being asked to voluntarily provide answers to 1 questions. Any statement you furnish may be 2 our questions. Will you agree to a voluntary 2 used as evidence in any future criminal 3 interview with the DO] OIG? 3 proceeding or agency disciplinary proceedings 4 MS. : Yes. 4 or both. And of course, there's the DPA 5 MR. : Alright. Great. And 5 waiver. I understand the warnings and 6 then everyone that does voluntary interviews 6 assurances stated above and I am willing to 7 with the DO] we provide them with these 7 make a statement or answer questions. No 8 voluntary interview forms. I don't know if you 8 promises or threats have been made to me and no 9 guys were sent that at the time, but it says, 9 pressure or coercion of any kind has been used 10 "United States Department of Justice Office of 10 against me. You can take a look at this and 11 the Inspector General, Warnings and Assurances 11 review it. If you agree, there's a section 12 to Employee Requested to Provide Information on 12 there for your name and signature. 13 a Voluntary Basis. You are being asked to 13 MR. FOY: So the only thing that this is 14 provide information as part of an investigation 14 actually subject to is the deferred prosecution 15 being conducted by the Office of the Inspector 15 agreement. 16 General. This investigation is being conducted 16 MR. : Well so there's the 17 pursuant to the Inspector General Act of 1978 17 agreement that you had, so that's the part 18 as amended. This investigation pertains to 18 where I'm talking about the specific part where 19 your alleged misconduct to include allegations 19 it says criminal. 20 of false statements, job performance failure, 20 MR. FOY: Mm-hmm. 21 security failure, and reporting false 21 MR. : That's something I think 22 information. This is a voluntary interview. 22 that was worked out with the U.S. Attorney's 23 Accordingly, you do not have to answer 23 Office -- 24 questions. No disciplinary action will be 24 MR. Exactly. 25 taken against you if you choose not to answer 25 MR. : So -. 7 8 1 MR. FOY: I know there's no sort of 1 rest for signature of witness, name of witness, 2 protection with regard to the disciplinary 2 date, time and place. 3 internalliiiiiiiiiinistrative thing that -- 3 MR. : This is Agent signing 4 MR. : Correct. 4 on the siinat eof witness. 5 MR. FOY: -- will happen at some point. 5 MR. : And then do you understand 6 But I just wanted to make that clear. But go 6 the form as ou read and you review? 7 ahead, yoiliiiiiiii IIII. 7 MS. : Yes, I do. 8 MR. : Now obviously, that is 8 MR. : Great. Thank you. 9 pursuant to you answering questions truthfully. 9 Before starting the interview, I'd like to 10 MR. FOY: Right. Of course. That's the 10 place you under oath. Can you please raise 11 exception to our agreement. 11 your right hand? Do you swear to tell the 12 MR. : There's a line that says 12 truth and nothing but the truth during this 13 employee si nature. 13 interview? 14 MS. . Mm-hmm. 14 MS. : Yes, sir. 15 MR. Alright. And the rest 15 MR. Thank you, Ma'am. 16 will be filled out by the two of us. 16 Alright. Please let me know if you do not 17 MR. 17 understand any of my questions. I'll try to 18 MR. lila : Thank you, sir. 18 rephrase or ask it a different way. 19 MR. Si 19 MS. : Okay. 20 MR. : And thank you for signing 20 MR. : Alright. So this is 21 Ms. IIII. Alright. So I'm going to sign where 21 something we ask everybody. Do you - what's 22 it says signature of the Office of the 22 your current home address? 23 Ins ector General S ecial Agent. Again, this 23 MS. 24 is . I'm printing my name. 24 25 And Special Agent , can you fill out the 25 MR. Thank you. What's your EFTA00117644  9 10 1 date of birth? 1 worked at the Post Office. 2 MS. 2 MR. : Okay. What did you do 3 MR. And your last four of 3 there? 4 your Social Securit number. 4 MS. : I was a mail handler. 5 MS. 5 MR. And for how long? 6 MR. Thank you. What's your 6 MS. six months. 7 highest level of education? 7 MR. Six months? 8 MS. ,bachelor's degree. 8 MS. : Mm-hmm. 9 MR. : And what was your 9 MR. And that was in 2016, 10 bachelor's degree in? 10 2016? When did you do that? 11 MS. IIII: Criminal justice (Indiscernible 11 MS. : Yes. 12 *00:06:14) in law. 12 MR. 2015 and 2016? 13 MR. : And where did you receive 13 MS. No. At the post office, I was 14 that degree from? 14 there 2017. 15 MS. John Jay. 15 MR. . Oh 2017. 16 MR. : John Jay in New York 16 MS. : '16, '17. Mm-hmm. 17 City? 17 MR. Oh, okay. And do you 18 MS. Yes, sir. 18 have any military service? 19 MR. : And when did you 19 MS. : Yes. 20 graduate? 20 MR. And what is that? 21 MS. 1.7. 21 MS. : Military service? 22 MR. : Thank you. What did you 22 MR. Yeah. Can you tell me 23 do - just briefly - prior to working with the 23 what the service? 24 BOP? 24 MS. The Army. 25 MS. IIII: Prior to working with the BOP I 25 MR. Army. And how long were 11 12 1 you in the Army? 1 MR. FOY: So would it be 17 into 18? 2 MS. : Six years. 2 MS. : 18 yeah. 3 MR. : From when until when? 3 MR. Oh you did start with the 4 MS. 2008 to 2014. 4 BOP in '18? 5 MR. And what did you do with 5 MS. 6 the militar 6 MR. Not in '16? 7 MS. IIII: I was a patient administrative 7 MS. : No. That was an error in the 8 specialist. 8 (Indiscernible *00:07:49). 9 MR. And what is that? 9 MR. FOY: Right. So it's '18, then she 10 MS. Patient admin. 10 left the Post Office in '17, going to - so I 11 MR. Patient as in like a 11 think it's 16 -. No 17 - 18. 12 hospital? 12 MS. IIII: '18 - Mm-hmm. 13 MS. : Yes. 13 MR. FOY: Post Office. Then MCC. 14 MR. : Okay. So you worked in a 14 MR. : Okay. And did you work 15 hospital. And what was your rank when you left 15 for anybody prior or in between your military 16 the militar ? 16 service and the post office? 17 MS. : E4 Specialist. 17 MS. : No. 18 MR. : And did you leave - were 18 MR. No? Okay. 19 you honorabl , discharged? 19 MS. Hm-mm. 20 MS. : Yes. 20 MR. So you were unemployed at 21 MR. : Okay. 21 that time? 22 MR. FOY: Can I - one second real quick? 22 MS. No I was going to school. 23 For the post office, you said 16 - 17 but you 23 MR. Oh that's when you went 24 started MCC in 18. 24 to John Ja 25 MS. IIII: Yeah. 25 MS. IIII: That's when I was going to John EFTA00117645  13 14 1 Jay. Yeah. 1 have you held with the BOP? 2 MR. Okay. Thank you. And 2 MS. : Correctional officer. 3 when was our Enter on Duty Date with BOP? 3 MR. • Okay. The entire time? 4 MS. : June 24, 2018. 4 MS. Yes, sir. 5 MR. Okay. And when did you 5 MR. : Alright. And when you 6 graduate from BOP training down at the Federal 6 were there last, who did you report to? Who 7 Law Enforcement Training Center? 7 was your direct supervisor? Or did you have 8 MS. IIII: Um, I want to say September of 8 one? 9 2018. 9 MS. : Lieutenant 10 MR. : Okay. But you did 10 MR. : And do you know how to 11 graduate from there? 11 spell that last name? 12 MS. Yes, I did. 12 MS. 13 MR. That was a correctional 13 MR. Thank you. What is your 14 officer training? 14 current -? Again, this is something we ask 15 MS. : Yes. 15 everybody. We won't be contacting your client. 16 MR. : Alright. And when and 16 But what is our current cell phone number? 17 where was your first office assignment with the 17 MS. 18 BOP? 18 MR. : Okay. And how long have 19 MS. Sa that again? 19 you had that number? 20 MR. When and where was your 20 MS. : Years. 21 first office assignment with the BOP? So where 21 MR. • Years. 22 did you start - did you start working in MCC 22 MS. Mm-hmm. 23 and work there the entire time? 23 MR. • So for a long time. 24 MS. : Yes, sir. 24 MS. Yes. 25 MR. Okay. And what positions 25 MR. And to include in 2019? 15 16 1 MS. 1 MR. By no other means? 2 MR. : Okay. Any other cell 2 MS. 3 phone numbers? 3 MR. Okay. And when did you 4 MS. 4 last work at the MCC? 5 MR. • Okay. And your current 5 MS. August 10, 2019. 6 email address? 6 MR. And was that the same 7 MS. 7 supervisor that you mentioned? 8 MR. . Okay. Great. And have 8 MS. : Yes. 9 you had that one also for years? 9 MR. : Okay. Briefly, what 10 MS. Yes. 10 training have you attended or conducted during 11 MR. Okay. Any others? 11 your employment with the BOP? You mentioned 12 MS. Yes. 12 the correctional officer training at FLETC. 13 MR. What are the others? 13 What other trainings have they provided for 14 MS. 14 you? 15 MR. . Same? 15 MS. IIII: Um, their two-week training 16 MS. Mm-hmm. 16 when you first start at BOP. I forget what 17 MR. You've had that for 17 it's called. IF training. Yes. 18 years? 18 MR. IF training? 19 MS. Yes. 19 MS. Mm-hmm. 20 MR. Okay. Both in 2019? 20 MR. And any other training? 21 MS. Yes. 21 MS. 22 MR. Okay. Thank you. Um, do 22 MR. Annual refresher 23 you have any current -? I should have asked 23 training? 24 this. Ar2a2u currently employed right now? 24 MS. : I have one. 25 MS. IIII: No. 25 MR. : Okay. So you've gone to EFTA00117646  17 18 1 annual. And what about like a SHU training 1 you just initial and date? And that's just a 2 course? 2 way for us to verify that that's what we showed 3 MS. 3 you. 4 MR. Okay. But you did - and 4 MS. IIII: Okay. 5 this is just - you guys can take a look at this 5 MR. FOY: Each page or just to top? 6 if you would like. This is the training that 6 MR. Nope, just the top of 7 we have for you. That we asked for your list 7 each page. 8 of training. I'm not asking you to necessarily 8 MR. FOY: Okay. Is (Indiscernible 9 verify that you've conducted all of it, but it 9 *00:12:34)? 10 shows the last time you did your annual 10 MR. No, you do have that. So 11 training was on 3/8/2019 was when you actually 11 just briefly, you don't have to like list off 12 completed that week of training. 12 the course syllabus. But what did they cover 13 MS. • Yes. 13 during that annual training? 14 MR. • Does that sound correct? 14 MS. IIII: Um they spoke about different 15 MS. Correct. 15 areas like dealing with inmates. They spoke 16 MR. Again, this just goes 16 about the issues on the job like dealing with 17 along with it. It shows -. It shows what the 17 shortages. They spoke about um, basically like 18 syllabus was as well as the sign-in sheet where 18 mask fitted I remember. 19 Ms. signed in. Again, it's - we're not 19 MR. • Mask fitting? 20 asking to ou 20 MS. Mm-hmm. 21 MS. : Mm-hmm. 21 MR. • Was that back in 2019? 22 MR. : For - if you want to take 22 People were wearing masks as well? 23 a look at it you can. It just shows that you 23 MS. : No like um. 24 did that training in March of 2019. And 24 MR. : It's for OC's sprays? 25 anything that I'm going to provide to you, can 25 MR. Oh, for OC spray. 19 20 1 MS. : Yes. 1 it? Polices and guidelines? 2 MR. : Okay. Did they include 2 MS. IIII: I think I signed that like you 3 things like ethics, standards of conduct? 3 receive it. 4 MS. • Yes. 4 MR. : Right. Okay. If you 5 MR. Okay. What about like 5 don't mind, just -. 6 counts and rounds? 6 MR. FOY: You want it in the lower right? 7 MS. IIII: I don't recall them talking 7 MR. : Doesn't matter. Top or 8 about counts and rounds. 8 bottom. You know wherever there's room. I 9 MR. : Okay. So did they go 9 typically do top, but bottom is totally fine. 10 over like MCC policies and guidance? 10 MR. FOY: This one, that one. 11 MS. : Yes. 11 MR. : Today's date is lune 22nd. 12 MR. : Okay. And did they ever 12 MR. FOY: That's part of the same 13 provide you with the policies and guidelines or 13 document. 14 did they ust speak to you about it? 14 MS. IIII: Hm. 15 MS. : For in this training? 15 MR. FOY: And just the top page. 16 MR. Yes. 16 MR. : And now you mentioned 17 MS. : They just spoke about it. 17 that you didn't quite remember them going over 18 MR. At another time did they 18 training when conducting counts and rounds in 19 provide you with the polices and guidelines? 19 this training. Did you - were you - did you 20 MS. IIII: Yeah. It's on like the 20 ever receive training on conducting counts and 21 computer. 21 rounds? 22 MR. Okay. 22 MS. : Yes. 23 MS. The -. 23 MR. : Okay. When would that 24 MR. Do you have to certify 24 have been? 25 that you've like received it and you reviewed 25 MS. IIII: In an IF training. EFTA00117647  21 22 1 MR. And what does IF stand 1 rounds. Just like a general - 2 for? 2 MR. Right. 3 MS. IIII: Rm. 3 MS. Like -. 4 MS. GREGG: You want some clarity? I can 4 MR. Like you know the housing 5 tell you -- 5 orders or unit policies and things like that. 6 MR. : Sure. 6 When you're supposed to conduct counts, when 7 MS. GREGG: -- just what it stands for. 7 you're supposed to do rounds, that type of 8 Institution Familiarization training. 8 thing. 9 MR. : Okay. Great. And that's 9 MS. : The post orders. 10 something that the MCC provided directly? 10 MR. : Post orders. Right. 11 MS. : Yes. 11 Okay. Great. You mentioned you didn't 12 MR. : Okay. Great. And then 12 remember ever going to quarterly SHU training. 13 you had mentioned - did you ever receive 13 This is a sign-in sheet for quarterly SHU 14 policies on counts and rounds? 14 training. I just want to -. Is this your 15 MS. : No. 15 signature on there for June 26, 2019? 16 MR. I know you said you 16 MS. IIII: You see how I'm the last one on 17 certified. Do you remember that specific 17 the bottom of all of them? 18 policy - like receiving that? 18 MR. : Correct. 19 MS. IIII: Like specifically on counts and 19 MS. : Because I wasn't at the 20 rounds? 20 training when I came -. 21 MR. : I'm not asking you to 21 MR. : Did they provide it to 22 like verbatim tell me what it was. I'm just 22 you one-on-one though? 23 saying like were you provided and you reviewed 23 MS. : No. 24 it. DO you remember? 24 MR. So how come -? 25 MS. IIII: Not specifically on counts and 25 MS. : Because when I came back from 23 24 1 an injury, the lieutenant asked me to sign 1 MS. 2 because when they had program review, they need 2 MR. And is she a lieutenant? 3 to show that I received the training. But I 3 MS. : She's a - I don't know what she 4 never did. She just asked me to sign. That's 4 is now. But she's not at MCC anymore. She's 5 why I wonder wh 5 at somewhere in Jersey. 6 MR. Who asked to do that? 6 MS. GREGG: I'm sorry. Before you go, are 7 MS. : Lieutenant 7 you done with that question? 8 MR. : So that supervisor you 8 MR. : Actually, let me um, I 9 mentioned was your first line supervisor asked 9 didn't do this. 10 you sign without providing you the training? 10 MS. GREGG: Because I want to 11 MS. : Yes. 11 (Indiscernible *00:17:14) 12 MR. : And she didn't' like 12 MR. : And I did forget to do 13 provide you anything to review? 13 this. There's an advisory to the union 14 MS. : No. 14 representative. 15 MR. She didn't go over 15 MS. GREGG: Mm-hmm. 16 anything with you? 16 MR. : Can you review this? And 17 MS. : No. 17 I do apologize. But since you're speaking up a 18 MR. Did you discuss this with 18 little bit, let me hand this to you. and then 19 her - that how can you sign something without 19 you can review that. And then if you want to 20 being provided the training? 20 just take a look. After you're done reviewing, 21 MS. IIII: Well I just told her I wasn't 21 you may sign it if you agree. 22 here. I was out on an injury. She said she 22 MS. GREGG: Will you be able to give me a 23 knows but she needed me to sign it because they 23 copy of it? 24 need it for ro ram review. 24 MR. : Yes. I think it says on 25 MR. : What's her first name? 25 there that we will forward you a copy of that. EFTA00117648  25 26 1 MS. GREGG: I didn't even see that part. 1 MS. IIII: From March 2019 to - I came 2 MR. : Should I continue asking 2 back in June. So when I came back in June, 3 questions while she's reviewing that or do you 3 that's when I was told to sign this. 4 want to wait? 4 MR. Okay. 5 MR. FOY: Yeah, you can ask questions. 5 MS. Mm-hmm. 6 Absolutel 6 MR. Alright. Thank you for 7 MR. . : Sure. So there's another 7 signing the Advisory to Union Representative. 8 training that you - it says that you conducted 8 MS. GREGG: I signed it (Indiscernible 9 on also June 26, 2019 for SHU suicide 9 *00:19:02). 10 prevention training. Did you also not receive 10 MR. : I am just going to sign 11 that trainin ? 11 that form as name of OIG special agent. Again, 12 MS. Yeah. I didn't. 12 I do apologize for not providing that up front. 13 MR. You did not receive that 13 MS. GREGG: So I just -. 14 training? 14 MR. : I'm sorry, what was your 15 MS. 15 question? 16 MR. Did you receive - so 16 MS. IIII: I want to call because 17 there's slides in the back that shows the 17 (Indiscernible *00:19:15) I'm just saying that 18 training and how they conducted it. Did they 18 well I know that the dynamics are that I should 19 provide you with those slides? 19 interrupt you in the middle of a question. But 20 MS. No because I wasn't there. 20 interrupt her answering a question. So I was 21 MR. You weren't there? 21 asking were you done because I wanted to just 22 MS. I was out on an injury. 22 step out for Oust one second. 23 MR. Okay. Can you -? When 23 MR. You want to step out? 24 were you out on the injury? What are the 24 MS. Mm-hmm. 25 dates? 25 MR. Okay. We don't want to 27 28 1 interrupt the interview because we have a lot 1 somethingliiiiiiiiito what you're saying. 2 of questions to get through. 2 MR. : I'm going to give you a 3 MS. GREGG: Mm-hmm. 3 different form that says that I'm going to let 4 MR. : If the attorneys ask 4 you interrupt the interview now to talk to her 5 that, that's not really -. But if you would 5 out there. And if you do it again, I'm going 6 like to -. 6 to ask that you not be here any longer so that 7 MS. GREGG: So based on the agreement we 7 we can continue with the interview. Obviously, 8 just signiiiiiiiii 8 her attorneys would stay here. So I just want 9 MR. : Sure. 9 to make sure that we don't just continue. 10 MS. GREGG: It acknowledges the right to 10 MS. GREGG: I just need clarity then. I 11 have me representing her. And part of those 11 need clariiiiiiiiii 12 rights are the ability to assist in 12 MR. : Sure. 13 representing her. Right? And so I don't want 13 MS. GREGG: So the representing of and 14 to dispute and I don't want to hold up the 14 talking to the employee who I have the right to 15 process at all. I just want to say something 15 represent is considered by you an interruption 16 to her. 16 of the interview? 17 MR. : Sure. We'll let that - 17 MR. : We haven't even gotten 18 we'll do that this time, but if this continues 18 into the questions yet. So -. 19 to happen, I'm going to have to give you a 19 MS. GREGG: Well -. 20 different form that says you can stay here 20 MR. : -- yes, we need to 21 voluntarily if you want, but we're going to ask 21 continue with the interview. But we're now -. 22 you not to interrupt the interview. And if you 22 I can allow you to do that now. I'm just not 23 do, then we're going to ask her if she wants to 23 going to be able to allow you to continue to 24 continue with the interview without you. 24 stop the interview and leave the room. 25 MS. GREGG: So but that form says 25 MS. GREGG: I'm just asking for clarity EFTA00117649  29 30 1 right. So it was kind of -. 1 I would be informing her of anything. 2 MR. : Sure. Absolutely. 2 MR. : Okay. But so yes. To 3 MS. GREGG: And I don't mean to be 3 answer your question, you can be here to 4 difficult. It kind of was a yes or no. So 4 represent here if she's asking you for the 5 you're saying to me based on the document that 5 information. I don't want you stopping our 6 I signed -. 6 interview. 7 MR. I'm saying that you can 7 MS. GREGG: Mm-hmm. 8 assist her. 8 MR. : And then asking to leave 9 MS. GREGG: I didn't get to -. 9 the room. I'm going to allow that this time. 10 MR. : Sure. Go ahead. 10 After that, I will consider that an 11 MS. GREGG: Okay. So you're saying based 11 interruption of the interview. 12 on the document that I signed, in my right to 12 MS. GREGG: Mm-hmm. 13 represent the employee, which is asking to 13 MR. : And then we'll have to 14 caucus and say something to Ms. is 14 proceed from there. And then there's a 15 interrupting the interview even though I have 15 different form to provide you. So does that 16 the right to do so based on the document I 16 make sense? 17 signed? 17 MS. GREGG: No it doesn't. 18 MR. : It's more for her to be 18 MR. : Okay. So I'm asking you 19 able to ask you for a question. 19 not to interrupt -. 20 MS. GREGG: So it's just a yes or no. 20 MS. GREGG: Wait. It doesn't make sense 21 MR. : Oh, no-no. I'm the one 21 but I'm not - that was -. 22 that's leading the interview here. So if she 22 MR. : So I'm asking you not to 23 stops and asks you for clarity, absolutely. 23 interrupt the interview. She may defer to you 24 You stopping to inform her? No. 24 and ask you for questions. 25 MS. GREGG: I never identified to you that 25 MS. GREGG: Mm-hmm. 31 32 1 MR. I'm asking you not to 1 MR. They're directed at Mrs. 2 interrupt my questions. 2 3 MS. GREGG: Okay. It doesn't make sense 3 MS. GREGG: I'm not answering questions. 4 to me. What I'm interpreting is my ability to 4 I was just trying to -. I'm representing her. 5 represent is only if the employee asks a 5 But I understand that there has been a 6 question that's what you're saying to me. 6 determination of how I'm able to represent. 7 MR. : Correct. So her 7 And so I'll deal with that in a different 8 attorneys are here. 8 venue. You can move forward. 9 MS. GREGG: I got it. I got it. 9 MR. : Alright. Let me read 10 MR. : Her attorneys are here. 10 this real quick in this paperwork so that we're 11 I'm asking if she has a question for her union 11 not going to have any disputes. 12 representative -- 12 MS. GREGG: We don't have to. You don't 13 MS. GREGG: Mm-hmm. 13 have to continue. Right. Because I don't want 14 MR. -- she may at any time 14 to interrupt. So you can go on ahead and move 15 ask you. 15 forward. 16 MS. GREGG: I got it. 16 MR. Okay. So it just says 17 MR. I'm asking you not to 17 that you may not attempt to answer the 18 interrupt. 18 questions. 19 MS. GREGG: I got it. 19 MS. GREGG: Mm-hmm. 20 MR. These questions are not 20 MR. Or dictate the employee's 21 for you. 21 actions to question or otherwise take charge of 22 MS. GREGG: Mm-hmm. 22 proceedings. 23 MR. They're not directed at 23 MS. GREGG: Mm-hmm. 24 you. 24 MR. : But affin, please feel 25 MS. GREGG: Mm-hmm. 25 free to go confer with Ms. EFTA00117650  33 34 1 MS. GREGG: I appreciate it. Thank you. 1 Alright. DO you know where we left off I=? 2 MR. : I am going to pause the 2 What was the last question that we asked? 3 recording. It is currently 10:32 a.m. 3 MR. : It was what we asked for 4 [Whereupon, the above-entitled matter went off 4 (Indiscernible *00:24:53) about the injuries. 5 the record and went back on the record.] Okay. 5 MR. : Okay. So you were 6 The recorder is back on. It is 10:38 a.m. 6 telling us you said March through June you were 7 Tuesda lune 22 2021. This is Senior Special 7 injured? 8 Agent . We're resuming the 8 MS. : Yes. 9 interview. Ms. I just remind you that you 9 MR. : And you were not actually 10 are under oath and this is a voluntary 10 working during that time? 11 interview. I'm sorry. What was your question? 11 MS. : No. 12 MS. GREGG: You need me to initial 12 MR. : Do you remember around 13 (Indiscernible *00:24:24)? 13 when in March and when did it end? Was it the 14 MR. If you don't mind. And 14 beginning of March, end of March, middle? 15 again, it's just to show that you know, what we 15 MS. IIII: Um I'm not sure. I just know 16 are looking at. 16 it was March. 17 MS. GREGG: Okay. 17 MR. Sometime in March? 18 MR. Now since we took that 18 MS. 19 break, is there anything else we want to 19 MR. But when you came back, 20 discuss or -? 20 was it around the 26th when they asked you to 21 MS. FOY: No, we can move forward. 21 sign those? 22 MS. : No thank you. 22 MS. IIII: I came back in June. I don't 23 MR. : Thank you again very much 23 recall the date exactly. 24 for your cooperation with this matter. Is 24 MR. Okay. 25 there anything else you wanted to -? No? 25 MS. : But I remember the day I came 35 36 1 into work and the lieutenant asked me to go see 1 MS. : No. 2 Lieutenant . And she asked me to sign 2 MR. : Okay. Did you receive 3 and I said but I wasn't here. I was out on an 3 that training though in the annual training 4 injury. And she said she's aware but they need 4 courses as well? Like the suicide prevention 5 me to sign it for rogram review. 5 or the - you know how to operate in the SHU 6 MR. Okay. 6 during MCC annual? Or the - I think you call 7 MS. I signed. 7 it the IF training? Or during the correctional 8 MR. : So both trainings when 8 officer training at FLETC? 9 you signed, they didn't actually even provide 9 MS. IIII: Those trainings are like 10 you anythin 10 general overall training. It's not 11 MS. : N 11 specifically speaking about SHU. Like SHU may 12 MR. : Verbally? 12 come up in the conversations, but it's not 13 Electronically? Nothing? 13 specific to SHU or how to operate or run the 14 MS. : No. 14 SHU. 15 MR. : Okay. And that was on 15 MR. Okay. 16 the date that was signed that that happened? 16 MS. Mm-hmm. 17 MS. IIII: Actually she told me not to 17 MR. Do you know if they were 18 date it. I remember when I was signing, she 18 doing this with other employees as well? 19 said don't date it. 19 Having them sign training that they weren't 20 MR. : But you dated it anyway? 20 actually conducting? 21 Did you have a conversation about that? 21 MS. : I don't know. 22 MS. : No. 22 MR. : Okay. But did you do 23 MR. : After you dated it, she 23 this per the direction of your supervisor? 24 didn't say why did you date it or anything like 24 MS. : Su ervisor. Yes. 25 that? 25 MR. So she - did she EFTA00117651  37 38 1 specificall you must sign this? 1 of discovery and conversations with Ms. IIII. 2 MS. : Yes. 2 We're looEilg_2l_gout March 15 to June 24-ish. 3 MR. : Okay. And again, that 3 MR. IIIIIIIIII: Okay. 4 was 4 MR. FOY: And I note that the execution 5 MS. 5 was on the 26th. But I think there was some 6 MR. • . And you said - 6 time, you know, it's not like the first minute 7 and I apologize. I don't know if we were 7 she was there the had her sign the document. 8 interrupted when -. Where did you say she is 8 MR. : Okay. 9 currently? 9 MS. : Right. 10 MS. IIII: She is in Jersey I know. I'm 10 MR. FOY: So those are the estimated 11 trying to_ 11 times. I could be off by a day or two, but -. 12 MR. • At the FCI Fort Dix? 12 MR. : Perfect. 13 MS. Yes. 13 MR. FOY: The 15th of March to June 24th. 14 MR. Okay. 14 MR. And thank you attorney 15 MR. 10.iestion real quick. 15 Foy. 16 MR. : Absolutely. Do you want 16 MR. iiiiiiiiiiroblem. 17 a more precise answer to when she was out and 17 MR. : During your time at the 18 when she came back? 18 MCC, how often were you assigned to the special 19 MR. Uh, so far -. 19 housing unit also known as the SHU? 20 MR. FOY: Because I happen to know -- 20 MS. : Mm. 21 MR. Oh sure. If you'd like. 21 MR. And this is an 22 MR. FOY: -- the approximate dates. 22 approximate. I'm not asking you for like exact 23 MR. Sure. You can provide 23 amount. 24 that. 24 MS. IIII: When I came back from the 25 MR. FOY: And this is based on my review 25 injury, my assignment was the SHU. So from 39 40 1 June 20-whatever to August 10th, I worked the 1 SHU? 2 SHU. 2 MS. IIII: In the SHU there is post 3 MR. : Okay. And that was your 3 orders. 4 quarterly assignment was in the SHU from - for 4 MR. Oh, okay. So in the SHU 5 that whole summer -- 5 there's the ost orders. 6 MS. : Yes. 6 MS. : Yes. 7 MR. -- in 2019? 7 MR. And were you provided a 8 MS. Yes. 8 copy of that to review? 9 MR. Okay. Thank you. So I 9 MS. : Yes. 10 know that you said that you didn't - they 10 MR. And had you reviewed 11 didn't provide you with the SHU training. Did 11 that? 12 they provide you with the policies of the SHU? 12 MS. 13 MS. : No. 13 MR. : Okay. And when did you 14 MR. : So you never received 14 review that? 15 those policies? Would it have been when you 15 MS. : When I came back. 16 received and you said you had to initial and 16 MR. So sometime in that June 17 date something electronically? I think you 17 18 said when_ysT provided -? 18 MS. So in June. 19 MS. IIII: That's the employee code of 19 MR. -- or July timeframe? 20 conduct. 20 MS. 21 MR. : Okay. 21 MR. Okay. So aside from hose 22 MS. : That's the - like the handbook 22 post orders, did you receive any other SHU 23 that's online. 23 training? 24 MR. Should have they provided 24 MS. 25 you with the polices and post orders in the 25 MR. : No. And who was EFTA00117652  41 42 1 responsible for making sure that you actually 1 MR. But if you need to like, 2 did receive SHU training? 2 yeah, that's fine. 3 MS. : I don't know. 3 MS. : Mm-hmm. Yeah. 4 MR. : You don't know was that a 4 MR. : And if you don't know, 5 lieutenant issue -- 5 that's totally acceptable. 6 MS. : I assumed -. 6 MS. : Yeah because I don't know. 7 MR. • -- or your first line 7 MR. • Okay. No-no, that's a 8 supervisor? 8 totally acce table answer. 9 MS. IIII: I would assume the lieutenant. 9 MS. : Mm-hmm. 10 My supervisor. I don't know. 10 MR. • So yeah, if you know - if 11 MR. And when you say the 11 you don't know something or you do know 12 lieutenant, who was the lieutenant in the SHU 12 something, that's great. You don't really want 13 at the time? 13 to ask other people for the answers. 14 MS. : Lieutenant IIII. 14 MS. : Ri ht. 15 MR. : IIII. Do you know his 15 MR. : You know, obviously if 16 first name? 16 you need to confer, and you know with your 17 MS. 17 attorneys or your union representative, 18 MR. . Okay. And would he be 18 absolutely fine. But we just want to try to 19 responsible for making sure that you were 19 get away from them answering for you. 20 training when you were in the SHU? 20 MS. : Okay. 21 MS. IIII: I mean, I'm going to direct 21 MR. : Alright. And then from 22 that question to her. I don't know. 22 your recollection though, you don't remember 23 MR. : I don't want you to 23 receiving SHU training during the annual 24 direct a 222tion to her. 24 refresher training? 25 MS. fl: Okay. 25 MS. IIII: No. 43 44 1 MR. No. Okay. Did you 1 know, is suicidal or placed on suicide watch? 2 receive training on how to conduct rounds? 2 Wh