Epstein Secrets

ot, should have it? Does it show that he was taken off the MCC count? Is so, where? If not, should have it? What does it show with regard to inmate Fernandez? Are you able to determine where he came from and if the respective unit count changed? Does the LT log help you determine of the Aug 9 counts were

1 CO : 8/9 8am to 4pm SHU #1 CO : 8/9 4pm to midnight SHU U 1 CO Michael Thomas: 8/9 midnight to 8am SHU # 2 & 8/10 Midnight to 8am SHU # 2 CO Tova Noel: 8/9 4pm to midnight SHU # 2 & 8/10 midnight to 8am SHU # 1 CO 8/9/19 6am to 2pm SHU # 3 CO 8/9/19 2pm to 10 pm SHU # 4 CO 8/9/19 6am to 2pm SH

ecause it was determined -- 6 : That he was on the outcount, 7 and on -- 8 : -- oh, yeah. 9 : -- (Indiscernible 10 *02:22:57). 11 : And so, Fernandez was 12 never removed -. So, look at -. It shows it 13 on this. "One SHU correction. Fernandez dry 14 cell." So, at 12:35 a.m., and we do have

encountered him to do anything, known him not 25 to count, do his job, you know? EFTA00059046 LIMITED OFFICIAL USE 1 2 177 : What about Ms. Tova Noel? : She was new. So, she had 3 just gotten there. You know, she got the same 4 spiel from me that everybody else does. You 5 know? You are new.

The 4:00 p.m. El shows a total of 76 11 inmates assigned to ZA." With one in attorney 12 conference, which was Epstein. "This indicates 13 that Fernandez was not keyed out of the SHU, 14 and keyed into RA. The ZA eyes on count slip 15 shows 75. Inaccurate. 16 It should have reflected 74 because,

at's near and dear to you. 25 : And that is why I asked EFTA00059151 LIMITED OFFICIAL USE 282 1 you specifically -- 2 : Right. 3 : -- with Tova Noel. Are 4 you confident that you gave her that spiel? 5 : Talk to whoever was in her 6 class, and you talk to any, any new class that 7 came thr

t accurate 8 comparing everything. 9 : Yeah, so in talking with 10 the Lieutenant, Ops Lieutenant that was on at 11 midnight, that person said, "Fernandez was 12 never keyed out," and that's why the counts 13 were off, and she keyed him out at midnight and 14 placed him over. Does that give you any m

ontrol 18 two days prior, she would have access because 19 that's what you do in Control. You 20 : When you say, "She," are 21 you talking about Tova Noel? 22 : Correct, Noel. If she 23 worked in Control before, she would have 24 access, and the reason they give us access - 25 well, all the Lieuten

ed -- 8 MR. : That he was on the outcount, 9 and on -- 10 MR. : -- oh, yeah. 11 MR. : -- (Indiscernible 12 *02:22:57). 13 MR. : And so, Fernandez was 14 never removed -. So, look at -. It shows it 15 on this. "One SHU correction. Fernandez dry 16 cell." So, at 12:35 a.m., and we do have

0119194 LIMITED OFFICIAL USE 1 7 7 1 encountered him to do anything, known him not 2 to count, do his job, you know? 3 MR. : What about Ms. Tova Noel? 4 MR. : She was new. So, she had 5 just gotten there. You know, she got the same 6 spiel from me that everybody else does. You 7 know? You

2015) 16 United States v. Edwards, 101 F.3d 17 (2d Cir. 1996) 13 United States v. Fares, 978 F.2d 52 (2d Cir. 1992) 30, 31, 33 United States v. Fernandez, 231 F.3d 1240 (9th Cir. 2000) 26 United States v. Finnerty, 411 F. Supp. 2d 428 (S.D.N.Y. 2006) 20 United States v. Floyd, No. 99 Cr. 0234 (DAB)

suicide (Mot. 6); and (iv) reports, statistics, and documents related to purported staffing issues, supervisory lapses, and the application of BOP Tova Noel did not file any pretrial motions, and has not joined in Thomas's pretrial motions. See Fed. R. Crim. P. 12(c)(3) ("If a party does not meet the dea

respects. STATEMENT OF FACTS I. The Indictment Indictment 19 Cr. 830 (AT) (the "Indictment") was filed on November 19, 2019, charging defendants Tova Noel and Michael Thomas in six counts: (i) conspiring to defraud the United States and to make or use a false writing or document, in violation of Title

2015) 16 United States v. Edwards, 101 F.3d 17 (2d Cir. 1996) 13 United States v. Fares, 978 F.2d 52 (2d Cir. 1992) 30, 31, 33 United States v. Fernandez, 231 F.3d 1240 (9th Cir. 2000) 26 United States v. Finnerty, 411 F. Supp. 2d 428 (S.D.N.Y. 2006) 20 United States v. Floyd, No. 99 Cr. 0234 (DAB)

suicide (Mot. 6); and (iv) reports, statistics, and documents related to purported staffing issues, supervisory lapses, and the application of BOP Tova Noel did not file any pretrial motions, and has not joined in Thomas's pretrial motions. See Fed. R. Crim. P. 12(c)(3) ("If a party does not meet the dea