Epstein Secrets

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

16 145 1 : Just Senior Officer? 2 Okay. So do you recall what conversations you 3 had with SHU staff who worked on August 9, 4 2019, including Michael Thomas and Tova Noel 5 about making entries related to counts and 6 rounds? So, specifically what I'm asking here 7 is that you're the OIC. Do you rememb

where is the dry cell? 8 MS. : I thought it was in SHU. 9 MR. : Okay. So let's look at the 10 statement up here. On top it says, "Inmate 11 Fernandez on dry cell with staff watch and 12 R&D." 13 MS. : Okay. 14 MR. : Does that clarify it for you? 15 MS. : Okay, okay. 16 MR. : Okay. 17

. 5 MR. : No, no, no. So what I'm 6 saying, and I'm not talking about - I think 7 you're probably specifically talking about like 8 Tova and Michael Thomas. I'm talking about in 9 the morning at 8:38 a.m., prior to that time -- 10 MS. : Uh-huh. 11 MR. : -- they get a court list, 12 WAB, the OIC

s is removed. Epstein is 8 sitting in attorney conference? 9 MS. : Uh-huh. Yes, that's right 10 here. 11 MR. : Right here? And inmate 12 Fernandez is removed. 13 MS. : Uh-huh. 14 MR. : But it still shows 75. It 15 should have been 74. 16 MS. : Uh-huh. This is - they got 17 76. Thi

. 2 MR. : No, no, no. So what I'm 3 saying, and I'm not talking about - I think 4 you're probably specifically talking about like 5 Tova and Michael Thomas. I'm talking about in 6 the morning at 8:38 a.m., prior to that time -- 7 MS. : Uh-huh. 8 MR. : -- they get a court list, 9 WAB, the OIC say

kay. 8 MR. : Does that clarify it for you? 9 MS. : Okay, okay. 10 MR. : Okay. 11 MS. : Uh-huh. 12 MR. : So at this point, inmate 13 Fernandez is removed and the count comes down 14 to -- 15 MS. : Uh-huh. 16 MR. -- 75. 17 MS. : Uh-huh. 18 MR. : Okay. Now we're looking at 19 t

saying, and I'm not talking about - I think EFTA00115229 LIMITED OFFICIAL USE 72 1 you're probably specifically talking about like 2 Tova and Michael Thomas. I'm talking about in 3 the morning at 8:38 a.m., prior to that time -- 4 MS. : Uh-huh. 5 MR. : -- they get a court list, 6 WAB, the OIC say

led 04/24/20 Page 1 of 34 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA 19 Cr. 830 (AT) TOVA NOEL and MICHAEL THOMAS, : Defendants. x MEMORANDUM OF LAW OF THE UNITED STATES OF AMERICA IN OPPOSITION TO DEFENDANT MICHAEL THOMAS'S MOTION TO COMPEL GEOFFREY S. BER

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)