EFTA00009747.pdf

"TOVA NOEL, the defendant, has been employed as a correctional officer at the MCC since approximately 2016"

"MICHAEL THOMAS, the defendant, has been employed as a correctional officer at the MCC since approximately 2007"

"Jeffrey Epstein was incarcerated at the MCC between his arrest on July 6, 2019, and his suicide on August 10, 2019"

"The MCC is a federal administrative detention facility located in Manhattan that is run by the Federal Bureau of Prisons (BOP)"

"Epstein was detained pending trial in the Southern District of New York on sex trafficking charges"

"TOVA NOEL and MICHAEL THOMAS, Defendants"

"TOVA NOEL and MICHAEL THOMAS, Defendants"

"MICHAEL THOMAS, the defendant, was one of the MCC officers who responded to the incident"

"On July 10, 2019, Epstein was assigned to the SHU due to, among other things, risk factors for suicidality"

"Epstein remained on suicide watch for approximately twenty-four hours... until July 30, 2019."

"On July 30, 2019, Epstein was transferred back to the SHU"

"TOVA NOEL, the defendant, was one of the assigned officers on duty in the SHU"

"MICHAEL THOMAS, the defendant, started his shift in the SHU at 12 a.m. on August 10."

"Epstein returned to the SHU from his attorney visit and was escorted into his cell by TOVA NOEL... at approximately 7:49 p.m."

"TOVA NOEL, the defendant, and Officer-1 were responsible for conducting the 4 p.m. institutional count in the SHU."

"From 12 a.m. until 8 a.m. on August 10, NOEL and THOMAS were the only two officers on duty in the SHU."

"At approximately 4 a.m., the overnight supervisor briefly visited NOEL and THOMAS in the SHU, and conferred with NOEL and THOMAS"

"entered the tier in which Epstein was housed"

"TOVA NOEL and MICHAEL THOMAS, the defendants, knowingly conspired with each other... (Title 18, United States Code, Section 371)"

"TOVA NOEL and MICHAEL THOMAS, the defendants, knowingly conspired with each other... (Title 18, United States Code, Section 371)"

"TOVA NOEL, the defendant, willfully and knowingly did make and use a false writing or document... Section 1001(a)(3)"

"NOEL and THOMAS created, signed, and submitted to the MCC a materially false count slip... Section 1001(a)(3)"

"NOEL told Supervisor-1 that "Epstein hung himself.""

"Medical Examiner of the City of New York conducted an autopsy and determined that Epstein had committed suicide"

"TOVA NOEL and MICHAEL THOMAS, the defendants... Case 1:19-cr-00830-AT"

"TOVA NOEL and MICHAEL THOMAS, the defendants... Case 1:19-cr-00830-AT"

"TOVA NOEL... willfully and knowingly did make and use a false writing... (Title 18, United States Code, Sections 1001(a)(3) and 2)"

"MICHAEL THOMAS... willfully and knowingly did make and use a false writing... (Title 18, United States Code, Sections 1001(a)(3) and 2)"

"NOEL and THOMAS created, signed, and submitted to the MCC a materially false count slip"

"NOEL and THOMAS created, signed, and submitted to the MCC a materially false count slip"

"GEOFFREY S. BERMAN United States Attorney... Case 1:19-cr-00830-AT"

"NOEL and THOMAS walked up to and entered the tier... to serve breakfast... submitted to the MCC a materially false count slip"

"NOEL and THOMAS walked up to and entered the tier... to serve breakfast... submitted to the MCC a materially false count slip"

"performed the 5 a.m. institutional count of the SHU... NOEL and THOMAS created, signed, and submitted to the MCC"

"performed the 5 a.m. institutional count of the SHU... NOEL and THOMAS created, signed, and submitted to the MCC"

"NOEL and THOMAS walked up to and entered the tier in which Epstein was housed to serve breakfast."

"TOVA NOEL and MICHAEL THOMAS, the defendants, knowingly conspired with each other"

"repeatedly failed to perform mandated counts of prisoners under their watch... as a result of the defendants' conduct, no correctional officer conduct"

"repeatedly failed to perform mandated counts of prisoners under their watch... as a result of the defendants' conduct, no correctional officer conduct"