EFTA00010968.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."

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

"NOEL and THOMAS repeatedly signed false certifications attesting to having conducted multiple counts of inmates when, in truth and in fact, they never"

"NOEL and THOMAS repeatedly signed false certifications attesting to having conducted multiple counts of inmates when, in truth and in fact, they never"

"found Epstein on the floor of his cell with a strip of bedsheet around his neck. MICHAEL THOMAS, the defendant, was one of the MCC officers who respon"

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

"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 was transferred back to the SHU, and, at the direction of the MCC's psychological staff, was required to have an assigned cellmate."

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

"Epstein returned to the SHU from his attorney visit and was escorted into his cell by TOVA NOEL, the defendant, and another officer at approximately 7"

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

"After arriving in the SHU, Supervisor-1 spoke with THOMAS and NOEL. ... THOMAS stated, 'we'"

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

"NOEL and Officer-1 completed and signed a count slip that falsely stated that the 4 p.m. institutional count had been performed."

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

"the MCC's function to ensure the care, custody, and control of its inmate population."

"The Office of the Chief Medical Examiner of the City of New York conducted an autopsy and determined that Epstein had committed suicide by hanging him"

"The Grand Jury further charges... TOVA NOEL and MICHAEL THOMAS, the defendants, knowingly conspired with each other"

"The Grand Jury further charges... TOVA NOEL and MICHAEL THOMAS, the defendants, knowingly conspired with each other"

"TOVA NOEL, the defendant, willfully and knowingly did make and use a false writing or document"

"Supervisor-1 spoke with THOMAS and NOEL. NOEL told Supervisor-1 "we did not complete the 3am nor 5 am rounds.""

"TOVA NOEL and MICHAEL THOMAS, Defendants."

"TOVA NOEL and MICHAEL THOMAS, Defendants."

"GEOFFREY S. BERMAN United States Attorney"

"UNITED STATES OF AMERICA v. TOVA NOEL and MICHAEL THOMAS"

"Title 18, United States Code, Sections 371, 1001(a)(3), and 2."

"Title 18, United States Code, Sections 371, 1001(a)(3), and 2."

"institutional count of the SHU"

"NOEL and THOMAS... repeatedly failed to perform mandated counts of prisoners under their watch... Jeffrey Epstein, who had committed suicide overnight"

"NOEL and THOMAS... repeatedly failed to perform mandated counts of prisoners under their watch... Jeffrey Epstein, who had committed suicide overnight"

"NOEL created, signed, and submitted to the MCC a materially false count slip indicating that she had performed the 4 p.m. institutional count of the S"

"NOEL and THOMAS created, signed, and submitted to the MCC a materially false count slip indicating that they had performed the 12 a.m. institutional c"

"GEOFFREY S. BERMAN United States Attorney... UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK"

"performed the 5 a.m. institutional count of the SHU, when they had not in fact done so"

"performed the 5 a.m. institutional count of the SHU, when they had not in fact done so"