Epstein Secrets

and Michael Thomas On August 9-10, 2019, the night of Epstein's death, Tova Noel and Michael Thomas were correctional officers on duty at the MCC's Special Housing Unit, where Epstein was then housed. Capone DecL ¶ 9. As alleged in the November 19, 2019, indictment against Noel and Thomas, they repeatedly failed to

, 2 00 7) 15 National Archives & Records Administration v. Favish, 541 U.S. 157 (200 4) 19 Nat 7 Assoc. of Homebuilders v. Norton, 309 F.3d 26 (D.C. Cir. 2 002) 17 iii EFTA00071557 Case 1:20-cv-00833-PAE Document 25 Filed 08/05/20 Page 5 of 30 New York Tunes Co. v. Dep't o/•.Justice, No. 14 Ch,

6, 2019, he was arrested and charged by federal prosecutors and thereafter incarcerated at the MCC. (Id.) On July 10, 2019, Epstein was assigned to the Special Housing Unit ("SHU'), at least in part because of the risk of suicidal ideation. (Id. 1 5.) Nonetheless, on July 23, 2019, Epstein was found on the floor of his

the Air Force, 566 F.2d 242 (1977) 6 Meyer v. Bush, 1991 U.S. Dist. LEXIS 13626 (D.D.C. Sept. 30, 1991), rev'd on other grounds, 981 F.2d 1288 (D.C. Cir. 1993) 7 Morley v. C.I.A., 508 F.3d 1108 (D.C. Cir. 2007) 14 Multi Ag Media LLC v. Dep't ofAgric., 515 F.3d 1224 (D.C. Cir. 2008) 14 N.Y. Tim

and Michael Thomas On August 9-10, 2019, the night of Epstein's death, Tova Noel and Michael Thomas were correctional officers on duty at the MCC's Special Housing Unit, where Epstein was then housed. Capone DecL ¶ 9. As alleged in the November 19, 2019, indictment against Noel and Thomas, they repeatedly failed to

, 2 00 7) 15 National Archives & Records Administration v. Favish, 541 U.S. 157 (200 4) 19 Nat 7 Assoc. of Homebuilders v. Norton, 309 F.3d 26 (D.C. Cir. 2 002) 17 iii EFTA00075440 Case 1:20-cv-00833-PAE Document 25 Filed 08/05/20 Page 5 of 30 New York Tunes Co. v. Dep't o/•.Justice, No. 14 Ch,

6, 2019, he was arrested and charged by federal prosecutors and thereafter incarcerated at the MCC. (Id.) On July 10, 2019, Epstein was assigned to the Special Housing Unit ("SHU'), at least in part because of the risk of suicidal ideation. (Id. 1 5.) Nonetheless, on July 23, 2019, Epstein was found on the floor of his

the Air Force, 566 F.2d 242 (1977) 6 Meyer v. Bush, 1991 U.S. Dist. LEXIS 13626 (D.D.C. Sept. 30, 1991), rev'd on other grounds, 981 F.2d 1288 (D.C. Cir. 1993) 7 Morley v. C.I.A., 508 F.3d 1108 (D.C. Cir. 2007) 14 Multi Ag Media LLC v. Dep't ofAgric., 515 F.3d 1224 (D.C. Cir. 2008) 14 N.Y. Tim

and Michael Thomas On August 9-10, 2019, the night of Epstein's death, Tova Noel and Michael Thomas were correctional officers on duty at the MCC's Special Housing Unit, where Epstein was then housed. Capone DecL ¶ 9. As alleged in the November 19, 2019, indictment against Noel and Thomas, they repeatedly failed to

, 2 00 7) 15 National Archives & Records Administration v. Favish, 541 U.S. 157 (200 4) 19 Nat 7 Assoc. of Homebuilders v. Norton, 309 F.3d 26 (D.C. Cir. 2 002) 17 iii EFTA00088674 Case 1:20-cv-00833-PAE Document 25 Filed 08/05/20 Page 5 of 30 New York Tunes Co. v. Dep't o/•.Justice, No. 14 Ch,