EFTA00031025.pdf

"Epstein was arrested and thereafter incarcerated at the MCC until his death."

"Epstein was assigned to the Special Housing Unit (SHU) at the MCC"

"Tartaglione was housed in the same SHU cell as Jeffrey Epstein."

"I am Counsel to the Acting United States Attorney in the United States Attorney's Office for the Southern District of New York (USAO-SDNY)."

"Michael Thomas ... was one of the MCC officials who responded to this incident [Epstein on the floor with a strip of bedsheet around his neck]."

"Judge Berman entered an order of nolle prosequi against Epstein."

"Thomas and Tova Noel were correctional officers on duty at the SHU on August 9-10, 2019"

"Michael Thomas, a correctional officer at the MCC"

"Epstein's incarceration prior to his suicide"

"reports, memoranda, and letters concerning Epstein's August 10, 2019 suicide and surrounding events; documents in BOP's possession"

"prejudice potential jurors for or against the defendants in the Noel action"

"The risks of interference with the Noel proceedings are heightened by the media coverage of speculation and theories about Epstein's death."

"documents in BOP's possession from the New York City Office of Chief Medical Examiner"

"the period of time during which Tartaglione was Epstein's cellmate at the MCC, which includes the date of Epstein's apparent suicide attempt on July 2"

"correctional officers at the Metropolitan Correctional Center (MCC)"

"correctional officers at the Metropolitan Correctional Center (MCC)"

"United States v. Tartaglione, No. 16 Cr. 832 (KMK)"

"TOVA NOEL and MICHAEL THOMAS, Defendants."

"TOVA NOEL and MICHAEL THOMAS, Defendants."

"prosecutors in the Criminal Division of the USAO-SDNY determined that certain of the records refer to or discuss Tartaglione"

"the Government's trial strategy in Noel"

"Russell Capone Counsel to the Acting United States Attorney United States Attorney's Office for the Southern District of New York"

"medical and psychological records of Epstein prepared by BOP"

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

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

"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"

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

"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"

"NOEL and THOMAS repeatedly signed false certifications attesting to having conducted multiple counts of inmates"

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

"The SHU is a housing unit within the MCC"

"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."

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

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

"TOVA NOEL and MICHAEL THOMAS, the defendants, knowingly conspired with each other to: a. Knowingly defraud the United States"

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

"The Grand Jury charges: ... 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."

"After arriving in the SHU, Supervisor-1 spoke with THOMAS and NOEL. ... NOEL told Supervisor-1 that Epstein hung himself."

"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"

"NOEL falsely certified that she and THOMAS had performed a series of 30-minute rounds of the SHU between 12 a.m. and 6:30 a.m., when they had not in f"

"NOEL and THOMAS falsely certified, on an MCC count slip, that they had performed the 12 a.m. institutional count of the SHU, when they had not in fact"

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

"UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK... TOVA NOEL... Defendants."

"UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK... MICHAEL THOMAS, Defendants."

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