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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 a
performed the 5 a.m. institutional count of the SHU, when they had not in fact done so. (Title 18, United States Code, Sections 1001(a)(3) and 2) GEOFFREY BERMAN United States Attorney 19 EFTA00126165 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA TOVA NOEL
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 a
5 a.m. institutional count of the SHU, when they had not in fact done so. (Title 18, United States Code, Sections 1001(a)(3) and 2) 5.1&arfrss,-. GEOFFREY BERMAN United States Attorney 19 EFTA00164395 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA TOVA NOEL
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 a
5 a.m. institutional count of the SHU, when they had not in fact done so. (Title 18, United States Code, Sections 1001(a)(3) and 2) 5.1&arfrss,-. GEOFFREY BERMAN United States Attorney 19 EFTA00164478 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA TOVA NOEL
Entities connected to both Special Housing Unit and GEOFFREY

Jeffrey Epstein
PERSON
Metropolitan Correctional Center
ORGANIZATION
Geoffrey S. Berman
PERSONFBI
ORGANIZATION
United States
LOCATIONthe Southern District
LOCATION
Prince Andrew
PERSON
New York
LOCATIONControl Center
ORGANIZATIONthe Upper East Side
LOCATION
Prince Charles
PERSON
FedEx
ORGANIZATIONThe Office of the Chief
ORGANIZATIONTOVA NOEL
PERSON
Michael Cohen
PERSON
Stephen Hawking
PERSONthe "Control Center
ORGANIZATION
the United States District Court
ORGANIZATION
NEW YORK NY
LOCATION
Wilbur Ross
PERSON