EFTA00023768

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g in FOY& SEPLOW I TZE attorne ys at law 105 MAIN STREET HACKENSACK. NJ 07601 WWW.FOYSEPLOWITZ.COM June 5, 2020 US Attorney's Office - SDNY One Saint Andrew's Plaza New York, NY 10007 30 WALL STREET 8TH FLOOR NEW YORK. NY 10005 TEL 212-709-8230 Re: US v. Tova Noel, et al 19 cr. 830 Dear Counsel: Pursuant to Fed. R. Crim. P. 16, please provide the following information and materials: 1. Defendant Noel's complete personnel and training file including, but not limited to, the following: a. Individual employee training record. b. Complete Performance Log maintained in the Admin Lieutenant's Office or any other location in the MCC. c. Completed and signed Position Description Cover Sheet. d. Completed and signed yearly Employee Performance Appraisal. e. Completed and signed quarterly performance logs completed at the end of the 3", 6th, and 9th month of Defendant Noel's employment. f. Completed and signed 6th month progress review. g. BOP GLYNCO (FLETC) training information and course outline for 2019. 2. The BOP and MCC Employee Code of Conduct, Code of Ethics, and corresponding employee acknowledgement forms for Defendant Noel. 3. The MCC institutional familiarization training outline. 4. The MCC annual training outline for 2018 and 2019. 5. A copy of the internal memorandums, letters, and/or emails addressing the death of Jeffrey Epstein including, but not limited to, the memorandums drafted by Employee Number 5, Employee Numb