EFTA00117030.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: (818) 431-5800 EFTA00117030 LIMITED OFFICIAL USE 1 APPEARANCES: 2 3 OFFICE OF THE INSPECTOR GENERAL 4 5 6 7 8 WITNESS: 9 10 11 12 OTHER APPEARANCES: 13 NONE 14 15 16 17 18 19 20 21 22 23 24 25 EFTA00117031 LIMITED OFFICIAL USE 3 1 MR. The recorder is on. My 2 name is , and I'm 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 Okay. 8 And this interview with 9 Federal Bureau of Prisons employeer 10 s 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 p.m. 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 EFTA00117032 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 EFTA00117033 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 EFTA00117034 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 p.m. 4 MR. -- 1:52 p.m. We are at 5 the MCC, New York. And I'm signing my name. 6 Again, this is And I'm 7 printing. Here you go, Special Agent 8 MR. This is I'm 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.M Yes, I do. 20 MR. Great. Were you 21 previously interviewed by the OIG in August of 22 2019, and then again, by myself and 23 this past month, in July of 2021? 24 MS Yes. I was. 25 MR. All right. And you EFTA00117035 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 Efrain Reyes. 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, I'm going 22 to show you. It's from 8/9/2019. And on the 23 third page, where I've highlighted, it says 24 Reyes was pre-removed at 0838, when you had 25 mentioned, during our interview, that you can't EFTA00117036 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 al 12 from the U.S. Marshal Service. 13 MS : Okay. 14 MR. : And this was to, it looks 15 like - I'm assuming all of R&D, 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 GEO." What is GEO? 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 -- EFTA00117037 LIMITED OFFICIAL USE 9 1 MS. Mm-hmm. 2 MR. MATULEWICZ: -- at 10:33 a.m. And the 3 body of the email, it says, "The following 4 prisoners are to be transferred." 5 MS. 'I'll": Mm-hmm. 6 MR. : And it's two people's 7 name, and the second one says Efrain Reyes. 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 p.m., was 20 the email. And one of the attachments was NYM. 21 Is that MCC? 22 MS. IM 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 EFTA00117038 LIMITED OFFICIAL USE 10 1 email. And the second person, as you'll see, is 2 Efrain Reyes. It says, "Transfer within," and 3 then, right underneath, it says Judge, MCC, 4 TOT, and then GEO. 5 MS. Mm-hmm. 6 MR. MATULEWICZ: 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. EFTA00117039 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 Yeah. We were told by 11 your supervisor that you would be the person 12 that would have created that. 13 MS. • (Indioccrniblc *00:07:37)8/9 14 worked 2:00 to 10:00 for Semall. 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 EFTA00117040 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. MATULEWICZ: 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 EFTA00117041 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 Efrain 5 Reyes' 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 Efrain Reyes 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. I'm 24 not sure if they know what those acronyms 25 stands for. They just know that he's on a call EFTA00117042 LIMITED OFFICIAL USE 1 out, and that -- 2 MR. If they know it means -- 3 MS. he has to go down to R&D. 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. IIIIIII We don't keep those. 18 MR. MATULEWICZ: They don't keep them? 19 Is 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, EFTA00117043 LIMITED OFFICIAL USE 15 1 and then, you said it's actually created in 2 Sentry, though? 3 MS. M: 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. a I'm 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. I'm 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 EFTA00117044 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 EFTA00117045 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 Efrain Reyes. The next 21 one is going to be with regard to inmate 22 Fernandez. Do you recall us talking to you 23 about an inmate Fernandez? I know you worked in 24 control. 25 MS. No. EFTA00117046 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 a.m.? 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 EFTA00117047 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 EFTA00117048 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 ensuring 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 Fernandez, and we've since 21 learned, through our reviews, that Fernandez 22 was gone from the SHU around 1:40 p.m., and 23 definitely moved to R&D at least by 3:15. 24 MS. Oh, I recall that. 25 MR. Yeah. EFTA00117049 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 Fernandez. 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 R&D? 15 MS. Mm-hmm. 16 MR. Okay. Until 8/10/2019, 17 at 12:35 a.m., 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 keyep people in and out of the housing units. EFTA00117050 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 R&D 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. ANDREA: 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 a.m., who would 25 have been the one, then -- EFTA00117051 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 -- EFTA00117052 LIMITED OFFICIAL USE 1 MS.I 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 area within SHU, like say one SHU bed to 14 another SHU bed, the SHU OIC would be making 15 the changes in the system, but this is one 16 location to another location. Like, physically 17 out of that unit. That probably, most likely, 18 at that time, and it might have been the 19 control. 20 MR. : Well, so, in this case, 21 that's not when he was moved. That's just when 22 it was caught. So, we believe that actually -- 23 MS. Right. 24 MR. : -- the Ops Lieutenant did 25 that, because she's the one who figured it out. EFTA00117053 LIMITED OFFICIAL USE 25 1 However, it sounds like, when he was moved at 2 approximately 3:00 p.m. the day before, August 3 9th, 2019, control should have been the one 4 MS. Mm-hmm. 5 MR. -- to do it. Is that 6 correct? 7 MS. Wait a minute. 8 MR. So, if he -- 9 MS. Repeat that again. 10 MR. -- if he went from - at 11 about 3:00 p.m., he was moved from the SHU, 12 that was his housing unit, and placed into R&D 13 as his new housing unit -- 14 MS. Right. 15 MR. : -- and placed on dry 16 cell, what with staff assigned to him, who 17 should have -? 18 MS. Control should have. The SHU 19 officer should have notified control, or 20 whoever was moving him, and put him there, 21 should have notified control this inmate moved 22 from so and so place, and is now placed here, 23 and the control center officer should have been 24 keying him at that location. 25 MR. So, the control should EFTA00117054 LIMITED OFFICIAL USE 1 have done it? 2 MS. Mm-hmm. 3 MR. Perfect. Thank you. 4 MR. If the officer who actually 5 moved him actually wrote up a shot, also, for 6 moving him? Because if -- 7 MS. : Say that again. 8 MR. : DO you know what a shot 9 is? 10 MS. Mm-hmm. An incident report. 11 MR. Incident report. Does that 12 mean that the officer was responsible for - o - 13 to make sure that the control was aware that 14 inmate was being moved? 15 MS. Well, whenever an inmate is 16 leaving your housing unit, going off your unit 17 completely, you should be notifying control, 18 and verifying your base count and your unit 19 count. So, that's what you should be doing. 20 MR. Well, what about in this 21 case? If the person was actually in visiting, 22 and the reason why he got the shot was because 23 the person that was visiting him provided him 24 contraband. From there, they took him 25 MS. Well, the unit officer might EFTA00117055 LIMITED OFFICIAL USE 27 1 not necessarily know that, because somebody 2 would have to tell that unit officer this 3 person is being removed, going to SHU, because 4 they got drugs on the visiting floor. So, the 5 unit officer might not necessarily know that, 6 but -. 7 MR. : Well, let's say, in this 8 case, for instance, it was. It was actually 9 the person who found him, was the OIC of the 10 SHU, he's the one who saw what happened, and -- 11 MS. Mm-hmm. 12 MR. -- actually is the one 13 who placed him onto the dry cell, and is the 14 one that wrote up the shot. 15 MS. I Oh, okay. Well then, he 16 should have just ben notifying control he's 17 going to dry cell. If it was dry cell within 18 the SHU, then he doesn't 19 MR. It was dry cell in R&D. 20 MS. right, but if it was in 21 SHU, he wouldn't have to notify nobody because 22 it's in SHU. 23 MR. Right. 24 MS. He would just make the bed 25 assignment change, but because he actually EFTA00117056 LIMITED OFFICIAL USE 28 1 physically left the unit, he should have been 2 notifying the control center, I got one being 3 moved from SHU down to R&D for dry cell. 4 MR. Okay. So, he should have 5 notified control and said, key this person into 6 7 MS. Mm-hmm. 8 MR. : -- to R&D? Okay. 9 MS. Not just phyoically 10 specifically him, but anybody that was in the 11 SHU working that day should have just notified. 12 It's not, you know, because we all share the 13 same responsibility. 14 MR. : Okay. Perfect. Do you 15 mind just initialing and dating that -- 16 MS. Mm-hmm. 17 MR. : -- then, the last -- 18 MR. I'm sorry. I have a quick 19 question on the same thing. 20 MR. : Sure. 21 MR. How soon after you move an 22 inmate should that update be done? 23 MS. Immediately. 24 MR. Why? 25 MS. Because if you got to do an EFTA00117057 LIMITED OFFICIAL USE 1 emergency count, you've got to account for 2 where that person is. 3 MR. Now, let's say, if it wasn't 4 done immediately, what could happen to the 5 count? 6 MS. We have a bad count. 7 MR. =MI : Here you go. Keep those 8 together. Keep it in order. And then, the 9 last thing, I think -. Well, no, because 10 there's, like, two more. This one was the - 11 and you just said, would have been the one 12 responsible for the -- 13 MS. Mm-hmm. 14 MR. -- the count. Correct? 15 MS. Mm-hmm. 16 MR. So, and I think we talked 17 about this already. 18 MS. Mm-hmm. 19 MR. But if you see, this ir 20 the count from 8/10/2019, it says it was 21 printed at 12:35, I guess, and then, it shows 22 _and I think this is 23 signature, as well. Right above It 24 says, "Good verbal" at 12:36 a.m. Count 25 cleared at 12:49 p.m. ZA, it says 72. RA, it EFTA00117058 LIMITED OFFICIAL USE 30 1 says one. However, and again, I think - which 2 we already discussed in our last one - and 3 according to the ZA count slips, on the very 4 last page, it says 73. 5 MS. Mm-hmm. 6 MR. And it shows, M. Thomas 7 and Noel are the ones that signed it. 8 MS. Mm-hmm. 9 MR. : And it shows they signed 10 it at 12:01 a.m. And do you have any knowledge 11 or recollection of this being a bad count? 12 Being that the El says 72, and the count slip 13 said that, it said 73. And you don't -- 14 MS. : No. 15 MR. -- no? 16 MS. Because normally, when 17 they're take - that's, like, the beginning of 18 the shift. So, normally, while they're taking 19 count, I'm in there, verifying keys, making 20 sure equipment is there, radios is there, 21 checking all - everything else. So, while 22 they're taking the count. So, I'm not 23 necessarily sitting right there, alongside 24 them, listening to what's going on. 25 MR. : Okay. EFTA00117059 LIMITED OFFICIAL USE 31 1 MS. You know? So, no. 2 MR. And if the Ops Lieutenant 3 was t this time, I believe 4 that's her signature on top of Cale. If she's 5 taking that official count, where would that 6 count be -? Where would she be taking the 7 count? 8 MS. In the control center, 9 alongside the counting assignment Office, 10 alongside Cale. 11 MR. : Okay. And do you recall 12 that taking place that night, by chance? 13 MS. If the roster said she was 14 there, then she probably was there, but I don't 15 recall. I don't. 16 MR. Okay. But in order for 17 her to sign it, and for him to -- 18 MS. She would have to be there. 19 MR. -- all right. And do you 20 know - this is pretty nice handwriting - do you 21 know if that would be handwriting, or 22 hers? Can you really tell by that? 23 MS. IIIIIII I know this is 24 don't know whose writing this is. 25 MR. : Okay. But that is EFTA00117060 LIMITED OFFICIAL USE 32 1 2 MS. : This is his right here, yeah. 3 MR. Okay. Perfect. And you 4 don't -. And do you recall ever 5 getting on the phone, though, with the SHU, 6 regarding this count? 7 MS. No. 8 MR. : No. That's fine. Do you 9 mind just initialing -- 10 MS. Mm-hmm. 11 MR. -- and dating it. 12 MS. Now, that, I don't. Are you 13 taking this? Okay. 14 MR. : And then, this. Can you 15 just explain to us what we're looking at here? 16 What is this document? 17 MS. Okay. This is an, 18 (Indizecrnible +00:22:20)on the evening watch 19 shift, t. The control center, the control 20 number one person is responsible for accounting 21 for all the keys. So, you go through every 22 key, count the keys, make sure Al has 17 keys. 23 And that's what this is. So, each key, you're 24 accounting for the amount of keys on the 25 keyring. So, that's what this is. EFTA00117061 LIMITED OFFICIAL USE 33 1 MR. : Okay. So, when people go 2 in and out of the institution, they get keys. 3 Is that what it is? 4 MS. No. At the end of the night, 5 at the end of the night, on the evening shift, 6 you got to account for all the equipment, and 7 that's the - to make sure those keys are there, 8 and that those keys have this many -. Let me 9 not say that, like that. Account for all the 10 keys on the keyring. The keyring might say Al, 11 five keys. So, there's a chit on the keyring 12 that says five. So, you have to make sure five 13 keys is on that keyring. 14 MR. : Okay. So, it's kind of, 15 like, it's for equipment, though? Not for 16 people? 17 MS No. That's for equipment. 18 MR. Okay. And is there also 19 one, though, for people? 20 MS. There's one for people. To 21 make sure who's on duty? 22 MR. Yeah. So, like, I've 23 been in other institutions where they have 24 these, you know, the little rings that, if they 25 go in or out of the institution, they grab EFTA00117062 LIMITED OFFICIAL USE 1 their chip, or they put it back on 2 MS. It's a chit board. We have a 3 chit board here. 4 MR. : -- okay. So, that's not 5 this, though? 6 MS. No. 7 MR. This has to do 8 specifically with equipment, if you take a 9 piece of equipment, then you take the chip to 10 go with it? 11 MS.: No. That has to do 12 specifically, with accountability for keys. 13 Meaning, Al has 18 keys. So, if the chit on 14 the keyring says 18, you're supposed to have 18 15 keys. So, if lock shop came and changed the 16 keys, and took one key off or added a key, that 17 key count would be different. It would be 18 another number for that key. So, you're 19 verifying. That's basically just verification 20 and accountability that this is how ever many 21 keys we have on that keyring. 22 MR. : Okay. So, this is just 23 showing what keys, and if they're actual keys, 24 and the accountability of those keys. 25 MS. Right. And how many keys is EFTA00117063 LIMITED OFFICIAL USE 35 1 on that ring. 2 MR. All right. That was your 3 question. Did you want anything more on that? 4 MR. With this showc SHU, any keys 5 belonging to the SHU? And let's say if the 6 count was off, would it be reflected was off, 7 would it be reflected in there? 8 MS. No. 9 MR. (Indiscernible *00:24:40) 10 manner? 11 MR. Would this have anything 12 to do with the count? 13 MS. This doesn't have anything to 14 do with the count. This is just equipment. 15 MR. No, no. I mean, the count 16 for the keys, the number of keys. And let's 17 say the number of keys on that ring, and 18 (Indiscernible *00:24:51) -. 19 MS. No, because what the control 20 center officer does is, on the evening watch 21 shift, whatever keys is not in the control 22 center, he'll call up to the unit as he's doing 23 - as he's testing body alarms, he'll say, what 24 keys do you have? You'll say, oh, I have 25 Charlie nine, and with what. And he'll tell EFTA00117064 LIMITED OFFICIAL USE 36 1 you, you'll say, I have Charlie nine with five 2 or whatever amount of keys you have, and he'll 3 write that down. And then, the lieutenant will 4 go over this at night, and verify the key count 5 is accurate. 6 MR. Is there a count in there for 7 the SHU keys? 8 MR. : Well, this isn't the 9 count. It's not 8/10. 10 MR. Yeah. 11 MS. Mm-hmm. 12 MR. I just want to know if there 13 is specifically addressesd iscuc SHU keys, 14 that's all. 15 MR. : Okay. 16 MS. : This is the whole 17 institution's keys. So, yeah. SHU keys would 18 be here, too. Yes. 19 MR. What would they be listed 20 under? 21 MS. The Charlie keys. 22 MR. Do you know which Charlies? 23 MS. Hmm. 24 MR. So, the C's? 25 MS.