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ODUCTION 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 subst
Page: EFTA00009747 →she and THOMAS had performed a series of 30-minute rounds of the SHU between 12 a.m. and 6:30 a.m., when they had not in fact done so. (Title 18, United States Code, Section 371) 14 EFTA00009760 --- PAGE BREAK --- Case 1:19-cr700830-AT Document 1 Filed 11/19/19 Page 15 of 20 COUNT TWO (False Records - 4 p.
Page: EFTA00009761 →w York Times Company (the "FOIA Requests") that are the subject of this case, which seek records related to the incarceration of Jeffrey Epstein at the Metropolitan Correctional Center ("MCC"). I am also familiar with the responsive records that defendant the Federal Bureau of Prisons ("BOP") has withheld pursuant to exemptions 5,
Page: EFTA00015438 →ry resulting in death, of the victim, during the commission of an offense under Title 18, United States Code, Section 1201 (kidnapping) (Title 18, United States Code, Section 3592(c)(1)); g. committed the offense in an especially .heinous, cruel, and depraved manner in that it involved torture and serious phys
Page: EFTA00015487 →ODUCTION 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 subst
Page: EFTA00017915 →S DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA TOVA NOEL and MICHAEL THOMAS, Defendants. INDICTMENT 19 Cr. Title 18, United States Code, Sections 371, 1001(a)(3), and 2. GEOFFREY S. BERMAN United States Attorney A TRUE BILL Foreperson. EFTA00017934
Page: EFTA00017934 →w York Times Company (the "FOIA Requests") that are the subject of this case, which seek records related to the incarceration of Jeffrey Epstein at the Metropolitan Correctional Center ("MCC"). I am also familiar with the responsive records that defendant the Federal Bureau of Prisons ("BOP") has withheld pursuant to exemptions 5,
Page: EFTA00031025 →ry resulting in death, of the victim, during the commission of an offense under Title 18, United States Code, Section 1201 (kidnapping) (Title 18, United States Code, Section 3592(c)(1)); g. committed the offense in an especially .heinous, cruel, and depraved manner in that it involved torture and serious phys
Page: EFTA00031074 →Entities connected to both Metropolitan Correctional Center and U.S. Congress

Jeffrey Epstein
PERSONFederal Bureau of Prisons
ORGANIZATION
Department of Justice
ORGANIZATIONSpecial Housing Unit
ORGANIZATION
Ghislaine Maxwell
PERSON
United States
LOCATION
George W. Bush
PERSON
New York
LOCATIONFBI
ORGANIZATION
Donald Trump
PERSONthe Southern District
LOCATIONLeon Black
PERSON
Julie K. Brown
PERSON
Geoffrey S. Berman
PERSON
Prince Andrew
PERSON
William Barr
PERSONNicholas Tartaglione
PERSON
South
LOCATION
Virginia Giuffre
PERSON
Bill Clinton
PERSON