EFTA00017915.pdf

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Source set: data-set-8
Extracted text

UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF NEW YORK 
INDICTMENT 
UNITED STATES OF AMERICA 
19 Cr. 
TOVA NOEL and 
MICHAEL THOMAS, 
Defendants. 
X 
19 GRIM 830 
INTRODUCTION 
1. 
On or about August 10, 2019, TOVA NOEL and MICHAEL 
THOMAS, the defendants, in dereliction of their duties as 
correctional officers at the Metropolitan Correctional Center 
("MCC"), repeatedly failed to perform mandated counts of prisoners 
under their watch in the MCC's Special Housing Unit ("SHU"). 
Instead, for substantial portions of their shifts, NOEL and THOMAS 
sat at their desk, browsed the internet, and moved around the 
common area of the SHU. To conceal their failure to perform their 
duties, NOEL and THOMAS repeatedly signed false certifications 
attesting to having conducted multiple counts of inmates when, in 
truth and in fact, they never conducted such counts. As a result 
of those false statements, the MCC believed prisoners in the SHU 
were being regularly monitored'and accounted for when in fact, as 
a result of the defendants' conduct, no correctional officer 
conducted any count or round of the SHU from approximately 10:30 
1 
EFTA00017915


p.m. on August 9 until approximately 6:30 a.m. on August 10, at 
which time, as alleged herein, NOEL and THOMAS discovered the body 
of an MCC inmate, Jeffrey Epstein, who had committed suicide 
overnight while unobserved. 
RELEVANT INDIVIDUALS AND ENTITIES 
2. 
The MCC is a federal administrative detention 
facility located in Manhattan that is run by the Federal Bureau of 
Prisons ("BOP"). The MCC is one of several facilities used to 
house inmates who have been charged with federal crimes in the 
Southern District of New York and are awaiting trial. 
The MCC 
employs correctional officers, whose primary duty is to ensure the 
care, custody, and control of the inmate population of the MCC. 
3. 
TOVA NOEL, the defendant, has been employed as a 
correctional officer at the MCC since approximately 2016. As of 
August 2019, NO…
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