EFTA00117125.pdf

1 2 3 4 DIGITALLY RECORDED 5 SWORN STATEMENT 6 OF 7 8 9 OIG CASE #: 10 2019-010614 11 12 13 14 15 16 17 18 DEPARTMENT OF JUSTICE 19 OFFICE OF THE INSPECTOR GENERAL 20 AUGUST 5, 2021 21 22 23 24 25 RESOLUTE DOCUMENTATION SERVICES 28632 Roadside Drive, Suite 285 Agoura Hills, CA 91301 Phone: EFTA00117125 LIMITED OFFICIAL USE 1 APPEARANCES: 2 3 OFFICE OF THE INSPECTOR GENERAL 4 BY: 5 BY: 6 7 8 WITNESS: 9 10 11 12 OTHER APPEARANCES: 13 NONE 14 15 16 17 18 19 20 21 22 23 24 25 EFTA00117126 LIMITED OFFICIAL USE 3 1 MR. : The recorder is on. My 2 name is , and III a senior 3 special agent with the U.S. Department of 4 Justice, Office of the Inspector General, New 5 York Field Office, and these are my 6 credentials. 7 MS. : Okay. 8 MR. : And this interview with 9 Federal Bureau of Prisons employee, 10 is being conducted as part of an 11 official U.S. Department of Justice, Office of 12 the Inspector General investigation. Today's 13 date is August 5, 2021, and the time is 1:49 14 III. This interview is being conducted at the 15 Metropolitan Correctional Center, located in 16 New York, New York. Also present is DOJ/OIG 17 Special Agent . This interview 18 will be recorded by me, Special Agent - or 19 Senior Special Agent - 20 Could everyone please identify themselves for 21 the record, and spell their last name? To 22 start, again, I am DOJ/OIG Senior Special Agent 23 24 MR. : This is DOJ/OIG Special 25 Agent, . The last name is EFTA00117127 LIMITED OFFICIAL USE 1 Here is my credentials. 2 MS. : Okay. My name is officer 3 with the Federal Bureau of Prisons. 4 Last name . And these are 5 my credentials. 6 MR. : You got your credentials 7 this time. Wow. Fancy. All right. 8 MR. : Thank you. 9 MR. : Thank you. I am looking 10 at a picture, which it does match the person 11 sitting in front of me. This is an official 12 DOJ investigation into the death of inmate 13 Jeffrey Epstein and the surrounding 14 circumstances, and you are being asked to 15 voluntarily provide answers to our questions. 16 Will you agree to a voluntary interview with 17 the DOJ/OIG? 18 MS. : Sure. 19 MR. : All right. And there's a 20 form that we - and we just interviewed you, 21 just shortly, you know, a short time ago - but 22 it's the same form. It says, United States 23 Department of Justice, Office of the Inspector 24 General, Warnings and Assurances to Employee 25 Requested to Provide Information on a Voluntary EFTA00117128 LIMITED OFFICIAL USE 1 Basis. "You are being asked to provide 2 information as part of an investigation being 3 conducted by the Office of the Inspector 4 General. This investigation is being conducted 5 pursuant to the Inspector General Act of 1978, 6 as amended. This investigation pertains to job 7 performance failure and security failure. This 8 is a voluntary interview. Accordingly, you do 9 not have to answer questions. No disciplinary 10 action will be taken against you if you choose 11 not to answer questions. Any statements you 12 furnish may be used as evidence in any future 13 criminal proceedings, or agency disciplinary 14 proceedings, or both." And there's a waiver 15 section. It says, "I understand the Warnings 16 and Assurances stated above and I am willing to 17 make a statement and answer questions. No 18 promises or threats have been made to me, and 19 no pressure or coercion of any kind has been 20 used against me." You want to take a look? 21 Again, it's the same form from before, but if 22 you agree, there's an employee signature, and 23 an employee's name, where you print. 24 MS. Mm-hmm. Okay. 25 MR. : Thank you very much for EFTA00117129 LIMITED OFFICIAL USE 6 1 signing and printing your name. Today's date 2 is - again - 8/5/21, and the time is 3 MR. 1:52 III. 4 MR. -- 1:52 III. We are at 5 the MCC, New York. And III signing my name. 6 Again, this is . And 7 printing. Here you go, Special Agent 8 MR. : This is 9 signing on the signature of witness. 10 MR. : Did you understand the 11 OIG form? 12 MS. : Yes. 13 MR. : Thank you. Before 14 starting the interview, I'd like to place you 15 under oath. Ms. can you please raise 16 your right hand? Do you swear to tell the truth 17 and nothing but the truth during this 18 interview? 19 MS. : Yes, I do. 20 MR. : Great. Were you 21 previously interviewed by the OIG in August ci 22 2019, and then again, by myself and SA 23 this past month, in July of 2021? 24 MS. : Yes. I was. 25 MR. : All right. And you EFTA00117130 LIMITED OFFICIAL USE 7 1 already showed me your credentials, so I don't 2 need to ask you this background stuff. Are you 3 currently employed by the BOP? 4 MS. : Yes. 5 MR. : And what is your current 6 position with the BOP? 7 MS. : Receiving and Discharge. 8 Correctional Systems Officer. 9 MR. : Is there any change since 10 the last time we spoke to you? 11 MS. : No. 12 MR. : Great. All right. So, 13 this is just a supplemental interview. When we 14 spoke last, you talked about some different 15 documentation that we could potentially obtain 16 in order to clear up some of the things we were 17 looking at. Specifically, we were looking into 18 . And when he was released, and 19 what would have been put on the court list. 20 The court transfer. So, when we last spoke, we 21 talked about this daily log. This, III going 22 to show you. It's from 8/9/2019. And on the 23 third page, where I've highlighted, it says 24 was pre-removed at 0838, when you had 25 mentioned, during our interview, that you can't EFTA00117131 LIMITED OFFICIAL USE 8 1 tell exactly why he was removed at that point, 2 just that, if he's listed as pre-removed, it 3 was highly unlikely that he would have been 4 returned, and it was assumed that he was 5 leaving the MCC, for good. Is that correct? 6 MS. : That is correct. 7 MR. : All right. Great. So, 8 there is that, in case you wanted to look at 9 it. So, we went back, and we found these 10 emails. And so, this is just the first email 11 that we found was, this was from a 12 from the U.S. Marshal Service. 13 MS. : Okay. 14 MR. : And this was to, it looks 15 like - assuming all MI, as well as 16 yourself. 17 MS. : Mm-hmm. 18 MR. : And then, it says, the 19 subject, "Transfer of Prisoners from NYM to 20 GO." What is GO? 21 MS. : It's like a private prison 22 that the Marshals transfer the inmates to when 23 they can't be housed in the BOP. 24 MR. : Okay. And it says, date, 25 Thursday, August 8, 2019 -- EFTA00117132 LIMITED OFFICIAL USE 1 MS. : Mm-hmm. 2 MR. -- at 10:33 III. And the 3 body of the email, it says, "The following 4 prisoners are to be transferred." 5 MS. : Mm-hmm. 6 MR. : And it's two people's 7 name, and the second one says 8 "Please schedule the transfer for Friday, 9 8/9/2019." 10 MS. : Mm-hmm. 11 MR. : So, there's that one. 12 MS. : Okay. 13 MR. : And then, there's another 14 email that came out the same day, that says 15 it's from another person with the U.S. Marshal 16 Service, with the last name 17 And this one was subject, "Prisoner 18 Production On 8/9/2019," and the date was 19 Thursday, August 8th, 2019 at 3:36 III., was 20 the email. And one of the attachments was NYM. 21 Is that MCC? 22 MS. : Yes. 23 MR. : All right. Great. And 24 the second, the first two people are the same 25 two people that were listed on this other EFTA00117133 LIMITED OFFICIAL USE 10 1 email. And the second person, as you'll see, is 2 It says, "Transfer within," and 3 then, right underneath, it says Judge MCC, TOT, 4 and then GO. 5 MS. : Mm-hmm. 6 MR. : What is TOT? 7 MS. : Like, when they transfer them 8 out of the prison. 9 MR. : Okay. So, by looking at 10 this stuff, does this now let you know what was 11 entered pre-removed and why? 12 MS. : Yes. That he was being 13 officially removed out of the institution, 14 going to another destination. 15 MR. : Okay. So, was he ever 16 going to court, based on that? 17 MS. : No. He was going to be 18 transferred to another prison. 19 MR. : Okay. So then, we here 20 at the MCC, then, did know that he was going to 21 another prison, and not coming back to the MCC? 22 MS. : That is correct. 23 MR. : And would you be the 24 person -? So, here's your work schedule. 25 MS. : Mm-hmm. EFTA00117134 LIMITED OFFICIAL USE 1 MR. : I think you couldn't 2 remember at the time. So, on the 8th and the 3 9th, it shows that you were working regular 4 time. 5 MS. : Mm-hmm. 6 MR. : Eight hours. And would 7 you be the one that would have created that 8 court list for the SHU? 9 MS. : For SHU? 10 MR. : Yeah. We were told by 11 your supervisor that you would be the person 12 that would have created that. 13 MS. : (Indiscernible *00:07:37) 14 worked 2:00 to 10:00 for small. 15 Probably. So, I don't recall, but if that was 16 my position that day, then I probably would 17 have created it for the SHU. 18 MR. : Okay. 19 MS. : So, we do it the night 20 before, and send it out the housing units the 21 night before, and they take it up to their 22 units for the next day, for production. 23 MR. : Okay. And then, what is 24 sent and how is it sent? 25 MS. : We just type it in the Sentry EFTA00117135 LIMITED OFFICIAL USE 12 1 system. We print out call outs. And the 2 internal officer will disseminate it, and pass 3 it around to the unit officers. 4 MR. : So, the way that the SHU 5 would - you would give it to internal, and then 6 internal would bring it to the SHU? 7 MS. : That is correct. 8 MR. : Okay. And what would the 9 SHU, what would they receive? 10 MS. : They receive a print out of 11 the call out, of whatever this is. This here 12 is people's report (Indiscernible *00:08:22), 13 they print out (Indiscernible *00:08:23) from 14 Sentry. 15 MR. : So, they get a print out 16 of the actual document? 17 MS. : Not this document. A Sentry 18 devised document. 19 MR. : Okay. 20 MS. : We put their names in the 21 Sentry computer system. It prints out a call 22 out receipt, with all the names, the times, and 23 the internal officer would then take it to the 24 housing unit. 25 MR. : Okay. So, based upon EFTA00117136 LIMITED OFFICIAL USE 1 this information that I just showed you 2 MS. : Mm-hmm. 3 MR. : -- what would have you 4 created? What would have it said next to 5 ' name? 6 MS. : It would say WAB. 7 MR. : Is that it? 8 MS. : That was it. 9 MR. : Okay. So -- 10 MS. : It would say WAB. 11 MR. : -- by it saying WAB, does 12 that mean that he's leaving and he's not 13 returning? 14 MS. : That is correct. 15 MR. : Okay. So, the people 16 that received this in the SHU, in the housing 17 unit that was staying in, they 18 would know this guy is leaving and not coming 19 back? 20 MS. : Yes. 21 MR. : Okay. 22 MS. : Well, let me not say they 23 would know. They just know it says WAB. III 24 not sure if they know what those acronyms 25 stands for. They just know that he's on a call EFTA00117137 LIMITED OFFICIAL USE 1 out, and that -- 2 MR. : If they know it means -- 3 MS. he has to go down to 4 MR. : -- if the people, let's 5 say that we know WAB means With All Belongings, 6 and we're supposed to give them everything that 7 they have, and send them on their way. 8 MS. Mm-hmm. That is correct. 9 MR. : Shouldn't they know, at 10 that point, that they're leaving and not coming 11 back? 12 MS. : They should know, yes. 13 MR. : Okay. Great. And since 14 we spoke, were you ever able to find that list 15 that you would have created to provide to the 16 SHU? 17 MS. : We don't keep those. 18 MR. : They don't keep them. Is 19 it ever emailed? 20 MS. : No. 21 MR. : No. So -- 22 MS. : We didn't email those. 23 MR. : -- it's only -- 24 MS. : No. 25 MR. : -- created, printed out, EFTA00117138 LIMITED OFFICIAL USE 15 1 and then, you said it's actually created in 2 Sentry, though? 3 MS. : Mm-hmm. 4 MR. : And how long is it 5 maintained in Sentry? 6 MS. : I believe 45 days. 7 MR. : 45 days. So, there is no 8 There would be no way to actually obtain 9 that court list? 10 MS. -: III not sure. 11 MR. : Okay. But it is called 12 the -. 13 MS. : I don't want to say yeah, and 14 I don't want to say no. III not sure. 15 MR. : Okay. But there's no 16 way, that you know of, to obtain that court 17 list? 18 MS. : Right. 19 MR. : And that's what it's 20 called? A court list? Or is it called 21 MS. : A call out. 22 MR. : -- it's called a call out 23 list? 24 MS. : Mm-hmm. 25 MR. : Okay. So, it's not EFTA00117139 LIMITED OFFICIAL USE 1 actually called a court list. 2 MS. : Right. 3 MR. : Okay. Call out list. 4 MS. : Because normally, what we do 5 is, we go back in the night, like, if I have to 6 do a new call list for the next day, I delete 7 the previous call list, because then you'll 8 keep having call lists. So, we go in, we 9 delete it, and we do the next one for the next 10 day. 11 MR. : Okay. Gotcha. 12 MS. : So, I don't even know if 13 they're maintained, how they're maintained in 14 the system. If they're even stored in the 15 system. 16 MR. : Okay. 17 MS. : After that. I don't know. 18 MR. : All right. So, they may 19 only be stored for that 24-hour period, until 20 you do your next list. 21 MS. : Right. 22 MR. : Okay. 23 MS. : Because we're supposed to go 24 in and delete the call out. And then, for the 25 next day, like say, for example, tonight, I EFTA00117140 LIMITED OFFICIAL USE 17 1 will be deleting today's call out, and I will 2 be entering tomorrow's call out. 3 MR. : Okay. 4 MS. : So, that's how it's supposed 5 to be done. 6 MR. : Perfect. All right. 7 Great. Do you mind just initialing and dating 8 those -- 9 MS. : Mm-hmm. 10 MR. : -- just so we have them? 11 It's not certifying the accuracy. It's simply 12 saying that that's what you reviewed. 13 MS. : Mm-hmm. 14 MR. : And you can go on, and 15 the date is 8/5/21. 16 MS. : Okay. Okay. Okay. 17 MR. : Thank you. 18 MS. : That's everything. Right? 19 MR. : Thank you so much. All 20 right. So, that covers . The next 21 one is going to be with regard to inmate 22 Do you recall us talking to you 23 about an inmate ? I know you worked in 24 control. 25 MS. : No. EFTA00117141 LIMITED OFFICIAL USE 1 MR. : Oh, that's fine. 2 MS. : We probably talked about it. 3 MR. : We talked about a lot. 4 So, this is just to refresh your memory. It 5 shows that you worked at the MCC on Saturday, 6 August 10th, 2019. This is the daily 7 assignment roster. 8 MS. : Mm-hmm. 9 MR. : It shows that you were 10 control number one. 11 MS. : Mm-hmm. 12 MR. : Working overtime from 13 midnight to 8:00 III.? 14 MS. : That is correct. 15 MR. : Is that -? Okay. Great. 16 And then, when you were in control one, are you 17 the only person in control, at that time? 18 MS. : No. 19 MR. : Okay. 20 MS. : I have a control two. Okay. 21 Wait a minute. 22 MR. : And I'll -. 23 MS. : I know was there with 24 me. 25 MR. : So, internal would be EFTA00117142 LIMITED OFFICIAL USE 1 actually with you? 2 MS. : That number two was - would 3 be in control with me. 4 MR. : Okay. So, that's how it 5 went. Okay. 6 MS. : At that time, the number two. 7 They normally they didn't have an internal 8 number two, but that person is the person that 9 was in there with me because, at that time, 10 when they would put the internal number two on 11 the roster, they would be the person that would 12 assist the control center officer, in the 13 control. And they would do the counts, and 14 assignments, and do the - yeah - the counts. 15 The call outs. If somebody was on suicide 16 watch, and they had a companion swap out to 17 come out to a work detail, they would take that 18 companion off, put that new companion on, while 19 food service came and they would key in the 20 food service workers that would be off the 21 housing unit, but at that time, we only have -. 22 If we had anybody, it would be him. 23 MR. : Okay. 24 MS. : Yes. Yes. 25 MR. : So - and you probably EFTA00117143 LIMITED OFFICIAL USE 20 1 told me this before, then - so, would be 2 the one responsible for doing the counts, as 3 MS. : Yes. 4 MR. : -- as the second. And 5 what would your responsibility be? 6 MS. : My responsibility was 7 insuring all the equipment was in the control 8 center, doing a body alarm testing. What else? 9 Tracking all the equipment. Doing the 10 paperwork as far as the security forms, 11 (Indiscernible *00:13:37) security forms. And 12 looking up at cameras periodically. Popping 13 the doors. 14 MR. : Okay. But nothing to do 15 with counts? 16 MS. : No. 17 MR. : Okay. Then this might 18 not be too relevant. All right. As far as the 19 last person we talked about during our last 20 interview was and we've since 21 learned, through our reviews, that 22 was gone from the SHU around 1:40 III., and 23 definitely moved to III at least by 3:15. 24 MS. : Oh, I recall that. 25 MR. : Yeah. EFTA00117144 LIMITED OFFICIAL USE 1 MS. : Okay. 2 MR. : Okay. 3 MS. : I recall. Yes. 4 MR. : So, were you able to -? 5 MS. : I didn't recall his name. 6 MR. : I think you may have led 7 us onto this. I can't exactly remember. But 8 there's the inmate history quarters for inmate 9 10 MS. : Mm-hmm. 11 MR. : And it shows that he was 12 in the SHU, put to the SHU on August 2nd, 2019, 13 and then, he was not keyed out of the SHU, and 14 put into his RO1. Does that stand for III? 15 MS. : Mm-hmm. 16 MR. : Okay. Until 8/10/2019, 17 at 12:35 III., on August 10th, 2019. Would 18 that have -. Would you be involved in that at 19 all? 20 MS. : No. 21 MR. : No? So, not with what you 22 were doing? 23 MS. : Hmm-mm. 24 MR. : Who has the ability to 25 keep people in and out of the housing units. EFTA00117145 LIMITED OFFICIAL USE 1 Does -? 2 MS. : I mean, the control center 3 officers have the ability to do it. The 4 lieutenants, if they know. They have the 5 ability to do it. The SHU officers have the 6 ability to do it. And III has the ability to 7 do to it. 8 MR. : Okay. So, there's 9 actually a number of people that could have 10 done that. 11 MS. : Yeah. 12 MR. : Okay. But that's not 13 something you would have done in your role? 14 MS. : No. Hmm-mm. 15 MR. : And you don't recall 16 doing that? 17 MS. : No. 18 MR. : Okay. Great. Do you 19 mind just -. And you're there -. Actually, 20 just initial and date these (Indiscernible 21 *00:15:19). 22 MS. : Mm-hmm. 23 MR. : So, in your expert 24 opinion, at that time, 12:35 M.1 who would 25 have been the one, then -- EFTA00117146 LIMITED OFFICIAL USE 1 MS. : Well -- 2 MR. : -- do you think, who 3 would have -? 4 MS. : -- that would be the number 5 two person because he's -- 6 MR. : If they did it from 7 control. 8 MS. right. Right. But if he 9 did it from control, because he would be 10 preparing the counts. Or it could have been 11 the SHU officer. I don't know. 12 MR. : Okay. 13 MS. : It could have been a number 14 of people. 15 MR. : Or it could have b been 16 the Ops Lieutenant. Correct? 17 MS. : Right. 18 MR. : Okay. But it wasn't you? 19 MS. : But normally, the Ops 20 Lieutenants, they don't do that. It's normally 21 the control, or the SHU officer. What is 22 today? The fifth? 23 MR. : And that's who would 24 normally do it? When an inmate is moved, it 25 would typically be control -- EFTA00117147 LIMITED OFFICIAL USE 1 MS. : Control. 2 MR. : -- or the housing unit 3 officers? 4 MS. : No. Not the housing unit 5 officer. 6 MR. : Just the SHU? 7 MS. : It would be the control. 8 MR. : Oh, so, typically, it's 9 control? 10 MS. : Control. 11 MR. : So, if -. 12 MS. : But if he's moving from an 13 rea within SHU, like say one SHU bed to another 14 SHU bed, the SHU OTC would be making the 15 changes in the system, but this is one location 16 to another location. Like, physically out of 17 that unit. That probably, most likely, at that 18 time, and it might have been the control. 19 MR. : Well, so, in this case, 20 that's not when he was moved. That's just when 21 it was caught. So, we believe that actually -- 22 MS. : Right. 23 MR. : -- the Ops Lieutenant did 24 that, because she's the one who figured it out. 25 However, it sounds like, when he was moved at EFTA00117148 LIMITED OFFICIAL USE 25 1 approximately 3:00 III. the day before, August 2 9th, 2019, control should have been the one -- 3 MS. : Mm-hmm. 4 MR. : -- to do it. Is that 5 correct? 6 MS. : Wait a minute. 7 MR. : So, if he -- 8 MS. : Repeat that again. 9 MR. : -- if he went from - at 10 about 3:00 III., he was moved from the SHU, 11 that was his housing unit, and placed into III 12 as his new housing unit -- 13 MS. : Right. 14 MR. : -- and placed on dry 15 cell, what staff assigned to him, who should 16 have -? 17 MS. : Control should have. The SHU 18 officer should have notified control, or 19 whoever was moving him, and put him there, 20 should have notified control this inmate moved 21 from so and so place, and is now placed here, 22 and the control center officer should have been 23 keying him at that location. 24 MR. : So, the control should 25 have done it? EFTA00117149 LIMITED OFFICIAL USE 1 MS. : Mm-hmm. 2 MR. : Perfect. Thank you. 3 MR. : If the officer who actually 4 moved him actually wrote up a shot, also, for 5 moving him? Because if -- 6 MS. : Say that again. 7 MR. : -- you know what a shot is? 8 MS. : Mm-hmm. An incident report. 9 MR. : Incident report. Does that 10 mean that the officer was responsible for - 11 to make sure that the control was aware that 12 inmate was being moved? 13 MS. : Well, whenever an inmate is 14 leaving your housing unit, going off your unit 15 completely, you should be notifying control, 16 and verifying your base count and your unit 17 count. So, that's what you should be doing. 18 MR. : Well, what about in this 19 case? If the person was actually in visiting, 20 and the reason why he got the shot was because 21 the person that was visiting him provided him 22 contraband. From there, they took him 23 MS. : Well, the unit officer might 24 necessarily know that, because somebody would 25 have to tell that unit officer this person is EFTA00117150 LIMITED OFFICIAL USE 27 1 being removed, going to SHU, because they got 2 drugs on the visiting floor. So, the unit 3 officer might not necessarily know that, but -. 4 MR. : Well, let's say, in this 5 case, for instance, it was. It was actually 6 the person who found him was the OIC of the 7 SHU, he's the one who saw what happened, and 8 MS. : Mm-hmm. 9 MR. : -- actually is the one 10 who placed him onto the dry cell, and is the 11 one that wrote up the shot. 12 MS. : Oh, okay. Well then, he 13 should have just ben notifying control he's 14 going to dry cell. If it was dry cell within 15 the SHU, then he doesn't 16 MR. : It was dry cell in III. 17 MS. right, but if it was in 18 SHU, he wouldn't have to notify nobody because 19 it's in SHU. 20 MR. : Right. 21 MS. : He would just make the bed 22 assignment change, but because he actually 23 physically left the unit, he should have been 24 notifying the control center, I got one being 25 moved from SHU down to III for dry cell. EFTA00117151 LIMITED OFFICIAL USE 28 1 MR. : Okay. So, he should have 2 notified control and said, key this person into 3 4 MS. : Mm-hmm. 5 MR. -- to III? Okay. 6 MS. : Not just physically him, but 7 anybody that was in the SHU working that day 8 should have just notified. It's not, you know, 9 because we all share the same responsibility. 10 MR. : Okay. Perfect. Do you 11 mind just initialing and dating that -- 12 MS. : Mm-hmm. 13 MR. : -- then, the last -- 14 MR. sorry. I have a quick 15 question on the same thing. 16 MR. : Sure. 17 MR. : How soon after you move an 18 inmate should that update be done? 19 MS. : Immediately. 20 MR. : Why? 21 MS. : Because if you got to do an 22 emergency count, you've got to account for 23 where that person is. 24 MR. : Now, let's say, if it wasn't 25 done immediately, what could happen to the EFTA00117152 LIMITED OFFICIAL USE 1 count? 2 MS. : We have a bad count. 3 MR. : Here you go. Keep those 4 together. Keep it in order. And then, the 5 last thing, I think -. Well, no, because 6 there's, like, two more. This one was the - 7 and you just said, would have been the one 8 responsible for the -- 9 MS. : Mm-hmm. 10 MR. : -- the count. Correct? 11 MS. : Mm-hmm. 12 MR. : So, and I think we talked 13 about this already. 14 MS. : Mm-hmm. 15 MR. : But if you see, this is 16 the count from 8/10/2019, it says it was 17 printed at 12:35, I guess, and then, it shows 18 , and I think this is 19 signature, as well. Right above . It 20 says, "Good verbal" at 12:36 III. Count 21 cleared at 12:49 III. ZA, it says 72. RA, it 22 says one. However, and again, I think - which 23 we already discussed in our last one - and 24 according to the ZA count slips, on the very 25 last page, it says 73. EFTA00117153 LIMITED OFFICIAL USE 1 MS. : Mm-hmm. 2 MR. : And it shows, I. Thomas 3 and Noel are the ones that signed it. 4 MS. : Mm-hmm. 5 MR. : And it shows they signed 6 it at 12:01 III. And do you have any knowledge 7 or recollection of this being a bad count? 8 Being that the El says 72, and the count slip 9 said that, it said 73. And you don't -- 10 MS. : No. 11 MR. : -- no? 12 MS. : Because normally, when 13 they're take - that's, like, the beginning of 14 the shift. So, normally, while they're taking 15 count, III in there, verifying keys, making 16 sure equipment is there, radios is there, 17 checking all - everything else. So, while 18 they're taking the count. So, MI not 19 necessarily sitting right there, alongside 20 them, listening to what's going on. 21 MR. : Okay. 22 MS. : You know? So, no. 23 MR. : And if the Ops Lieutenant 24 was at this time, I believe 25 that's her signature on top of . If she's EFTA00117154 LIMITED OFFICIAL USE 31 1 taking that official count, where would that 2 count be -? Where would she be taking the 3 count? 4 MS. : In the control center, 5 alongside the counting assignment Office, 6 alongside 7 MR. : Okay. And do you recall 8 that taking place that night, by chance? 9 MS. : If the roster said she was 10 there, then she probably was there, but I don't 11 recall. I don't. 12 MR. : Okay. But in order for 13 her to sign it, and for him to -- 14 MS. : She would have to be there. 15 MR. : -- all right. And do you 16 know - this is pretty nice handwriting - do you 17 know if that would be handwriting, or 18 hers? Can you really tell by that? 19 MS. : I know this is . I 20 don't know whose writing this is. 21 MR. : Okay. But that is 22 23 MS. : This is his right here, yeah. 24 MR. : Okay. Perfect. And you 25 don't -. And do you recall ever EFTA00117155 LIMITED OFFICIAL USE 32 1 getting on the phone, though, with the SHU, 2 regarding this count? 3 MS. : No. 4 MR. : No. That's fine. Do you 5 mind just initialing -- 6 MS. : Mm-hmm. 7 MR. : -- and dating it. 8 MS. : Now, that, I don't. Are you 9 taking this? Okay. 10 MR. : And then, this. Can you 11 just explain to us what we're looking at here? 12 What is this document? 13 MS. : Okay. This is an 14 (Indiscernible *00:22:20) evening watch shift. 15 The control center, the control number one 16 person is responsible for accounting for all 17 the keys. So, you go through every key, count 18 the keys, make sure Al has 17 keys. And that's 19 what this is. So, each key, you're accounting 20 for the amount of keys on the keyring. So, 21 that's what this is. 22 MR. : Okay. So, when people go 23 in and out of the institution, they get keys. 24 Is that what it is? 25 MS. : No. At the end of the night, EFTA00117156 LIMITED OFFICIAL USE 33 1 at the end of the night, on the evening shift, 2 you got to account for all the equipment, and 3 that's the - to make sure those keys are there, 4 and that those keys have this many -. Let me 5 not say that, like that. Account for all the 6 keys on the keyring. The keyring might say Al, 7 five keys. So, there's a chit on the keyring 8 that says five. So, you have to make sure five 9 keys is on that keyring. 10 MR. : Okay. So, it's kind of, 11 like, it's for equipment, though? Not for 12 people? 13 MS. : No. That's for equipment. 14 MR. : Okay. And is there also 15 one, though, for people? 16 MS. : There's one for people. To 17 make sure who's on duty? 18 MR. : Yeah. So, like, I've 19 been in other institutions where they have 20 these, you know, the little rings that, if they 21 go in or out of the institution, they grab 22 their chip, or they put it back on -- 23 MS. : It's a chit board. We have a 24 chit board here. 25 MR. : -- okay. So, that's not EFTA00117157 LIMITED OFFICIAL USE 1 this, though? 2 MS. : No. 3 MR. : This has to do 4 specifically with equipment, if you take a 5 piece of equipment, then you take the chip to 6 go with it? 7 MS. : No. That has to do 8 specifically, with accountability for keys. 9 Meaning, Al has 18 keys. So, if the chit on 10 the keyring says 18, you're supposed to have 18 11 keys. So, if lock shop came and changed the 12 keys, and took one key off or added a key, that 13 key count would be different. It would be 14 another number for that key. So, you're 15 verifying. That's basically just verification 16 and accountability that this is how ever many 17 we have on that keyring. 18 MR. : Okay. So, this is just 19 showing what keys, and if they're actual keys, 20 and the accountability of those keys. 21 MS. : Right. And how many keys is 22 on that ring. 23 MR. : All right. That was your 24 question. Did you want anything more on that? 25 MR. : With the SHU, any keys EFTA00117158 LIMITED OFFICIAL USE 1 belonging to the SHU? And let's say if the 2 count was off, would it be reflected was off, 3 would it be reflected in there? 4 MS. : No. 5 MR. : (Indiscernible *00:24:40) 6 manner? 7 MR. : Would this have anything 8 to do with the count? 9 MS. : This doesn't have anything to 10 do with the count. This is just equipment. 11 MR. : No, no. I mean, the count 12 for the keys, the number of keys. And let's 13 say the number of keys on that ring, and 14 (Indiscernible *00:24:51) -. 15 MS. : No, because what the control 16 center officer does is, on the evening watch 17 shift, whatever keys is not in the control 18 center, he'll call up to the unit as he's doing 19 - as he's testing body alarms, he'll say, what 20 keys do you have? You'll say, oh, I have 21 Charlie nine, and with what. And he'll tell 22 you, you'll say, I have Charlie nine with five 23 or whatever amount of keys you have, and he'll 24 write that down. And then, the lieutenant will 25 go over this at night, and verify the key count EFTA00117159 LIMITED OFFICIAL USE 1 is accurate. 2 MR. : Is there a count in there for 3 the SHU keys? 4 MR. : Well, this isn't the 5 count. It's not 8/10. 6 MR. : Yeah. 7 MS. : Mm-hmm. 8 MR. : I just want to know if there 9 is specifically addressed issue keys, that's 10 all. 11 MR. : Okay. 12 MS. : This is the whole 13 institution's keys. So, yeah. SHU keys would 14 be here, too. Yes. 15 MR. : What would they be listed 16 under? 17 MS. : The Charlie keys. 18 MR. : Do you know which Charlies? 19 MS. : Hmm. 20 MR. : So, the C's? 21 MS. : The C keys. So, I think, 22 starting, if I don't If I recall. I think 23 they start at -- 24 MR. : If you don't know -- 25