EFTA00017915

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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