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eafter did perform a crime of violence to further the unlawful activity, and did • aid and abet the same, and death resulted, to wit, after Urbano Santiago accompanied Martin Luna to the Likquid Lounge, where Luna had been lured by TARTAGLIONE and others, Urbano Santiago was held captive, transported t
IONE, the defendant, intentionally and knowingly killpd, and counseled, commanded, induced, procured, and caused the intentional killing of Urbano.Santiago, in and around the vicinity of 419 Old Mountain Road in Otisville, New York, and did aid and abet the same. (Title 21, United States Code, Section
ates v. Epstein, No. 19 Cr. 490 (RMB) (S.D.N.Y.). The Prosecution of Tova Noel and Michael Thomas 9. As alleged in the Noel Indictment, Thomas and Tova Noel were correctional officers on duty at the SHU on August 9-10, 2019, the night of Epstein's death. See Noel Indictment 91 3-4. On that night, Noel a
eafter did perform a crime of violence to further the unlawful activity, and did • aid and abet the same, and death resulted, to wit, after Urbano Santiago accompanied Martin Luna to the Likquid Lounge, where Luna had been lured by TARTAGLIONE and others, Urbano Santiago was held captive, transported t
IONE, the defendant, intentionally and knowingly killpd, and counseled, commanded, induced, procured, and caused the intentional killing of Urbano.Santiago, in and around the vicinity of 419 Old Mountain Road in Otisville, New York, and did aid and abet the same. (Title 21, United States Code, Section
ates v. Epstein, No. 19 Cr. 490 (RMB) (S.D.N.Y.). The Prosecution of Tova Noel and Michael Thomas 9. As alleged in the Noel Indictment, Thomas and Tova Noel were correctional officers on duty at the SHU on August 9-10, 2019, the night of Epstein's death. See Noel Indictment 91 3-4. On that night, Noel a
r of nolle prosequi against Epstein. See Nolle Prosequi, Dkt. No. 52, United States v. Epstein, No. 19 Cr. 490 (RMB) (S.D.N.Y.). The Prosecution of Tova Noel and Michael Thomas 9. As alleged in the Noel Indictment, Thomas and Tova Noel were correctional officers on duty at the SHU on August 9-10, 2019,
Page: EFTA00015440 →paragraphs 1 through 27 of this Indictment as though fully set forth herein. 32. On or about August 9, 2019, in the Southern District of New York, TOVA NOEL, the defendant, willfully and knowingly did make and use a false writing or document knowing the same to contain a materially false, fictitious, an
Page: EFTA00015466 →IONE, the defendant, intentionally and knowingly killpd, and counseled, commanded, induced, procured, and caused the intentional killing of Urbano.Santiago, in and around the vicinity of 419 Old Mountain Road in Otisville, New York, and did aid and abet the same. (Title 21, United States Code, Section
Page: EFTA00015475 →r of nolle prosequi against Epstein. See Nolle Prosequi, Dkt. No. 52, United States v. Epstein, No. 19 Cr. 490 (RMB) (S.D.N.Y.). The Prosecution of Tova Noel and Michael Thomas 9. As alleged in the Noel Indictment, Thomas and Tova Noel were correctional officers on duty at the SHU on August 9-10, 2019,
Page: EFTA00031027 →paragraphs 1 through 27 of this Indictment as though fully set forth herein. 32. On or about August 9, 2019, in the Southern District of New York, TOVA NOEL, the defendant, willfully and knowingly did make and use a false writing or document knowing the same to contain a materially false, fictitious, an
Page: EFTA00031053 →IONE, the defendant, intentionally and knowingly killpd, and counseled, commanded, induced, procured, and caused the intentional killing of Urbano.Santiago, in and around the vicinity of 419 Old Mountain Road in Otisville, New York, and did aid and abet the same. (Title 21, United States Code, Section
Page: EFTA00031062 →Entities connected to both Santiago and Tova Noel

Jeffrey Epstein
PERSONMichael Thomas
PERSONSpecial Housing Unit
ORGANIZATIONFederal Bureau of Prisons
ORGANIZATION
Department of Justice
ORGANIZATION
Metropolitan Correctional Center
ORGANIZATION
Prince Andrew
PERSONFBI
ORGANIZATION
Julie K. Brown
PERSON
South
LOCATIONReyes
PERSON
United States
LOCATIONNicholas Tartaglione
PERSON
Geoffrey S. Berman
PERSONLeon Black
PERSON
Ghislaine Maxwell
PERSONthe Southern District
LOCATION
George W. Bush
PERSON
Donald Trump
PERSON
Southern District of New York
ORGANIZATION