EFTA00014985.pdf

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

"MICHAEL THOMAS, the defendant, has been employed as a correctional officer at the MCC by the BOP 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."

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

"TOVA NOEL, and MICHAEL THOMAS, Defendants."

"TOVA NOEL, and MICHAEL THOMAS, Defendants."

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

"As of August 2019, NOEL's primary assignment was the SHU. On August 9, 2019, NOEL worked a regular shift from 4 p.m. to 12 a.m. in the SHU"

"officers on duty in the SHU, including TOVA NOEL and MICHAEL THOMAS, the defendants, were responsible for conducting five institutional counts"

"officers on duty in the SHU, including TOVA NOEL and MICHAEL THOMAS, the defendants, were responsible for conducting five institutional counts"

"the door to the tier in which Epstein was housed"

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

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

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

"Knowingly make and use a false writing or document... in violation of Title 18, United States Code, Section 1001 (a)(3)."

"Knowingly make and use a false writing or document... in violation of Title 18, United States Code, Section 1001 (a)(3)."

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

"MICHAEL THOMAS, the defendants, willfully and knowingly did make and use a false writing or document"

"GEOFFREY S. BERMAN United States Attorney"

"On or about August 9, 2019... TOVA NOEL... did make and use a false writing... (Title 18, United States Code, Sections 1001(a)(3) and 2)"

"On or about August 10, 2019... NOEL and THOMAS created, signed, and submitted... a materially false count slip... (Title 18, United States Code, Secti"

"NOEL and THOMAS falsely certified that they had completed 30-minute rounds of the SHU"

"NOEL and THOMAS falsely certified that they had completed 30-minute rounds of the SHU"

"NOEL and THOMAS discovered the body of an MCC inmate, Jeffrey Epstein, who had committed suicide while unobserved earlier that morning."

"completed the 4 p.m. institutional count of the SHU... NOEL created, signed, and submitted to the MCC a materially false count slip"

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

"TOVA NOEL and MICHAEL THOMAS, the defendants, did not perform any of the required 30-minute rounds during their shift between approximately 12 a.m. an"

"TOVA NOEL and MICHAEL THOMAS, the defendants, did not perform any of the required 30-minute rounds during their shift between approximately 12 a.m. an"