EFTA00014985

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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK INDICTMENT UNITED STATES OF AMERICA TOVA NOEL, and MICHAEL THOMAS, Defendants. X The Grand Jury charges: INTRODUCTION 1. On or about August 10, 2019, TOVA NOEL and MICHAEL THOMAS, the defendants, while on duty as correctional officers at the Manhattan Correctional Center ("MCC"), repeatedly chose not to do 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, slept, and browsed the internet. To conceal the deliberate dereliction of their responsibilities, NOEL and THOMAS repeatedly signed false certifications attesting to counts of inmates they never did. 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 p.m. on August 9 until approximately 6:30 a.m. on August 10, EFTA00014985 at which time, as alleged herein, NOEL and THOMAS discovered the body of an MCC inmate, Jeffrey Epstein, who had committed suicide while unobserved earlier that morning. RELEVANT INDIVIDUALS AND ENTITIES 2. The MCC is federal administrative detention facility located in Manhattan that is run by the Bureau of Prisons ("BOP"). The MCC is one of several facili