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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
f Justice, M8 F.3d 1188 (10th Cir. 2 011) 9, 10, 21, 22 Judicial Watch, Inc. v. U.S. Dept of Commerce, 337 F. Supp. 2d 146 (D.D.C. 2004) 20, 21 Kansi v. U.S. Depst of Justice, 11 F. Supp. 2d 42 (D.D.C. 1998) 8 Kay v. F.C.C., 976 F. Supp. 23 (D.D.C. 199 7) 7 Kidder v. FBI, 517 F. Supp. 2d 17
released, could interfere with post-trial criminal proceedings, such as an appeaL See, e.g.,Kidder v. FBI, 517 F. Supp. 2d 17, 27-28 (D.D.C. 2007); Kansi v. U.S. Dep 't of Justice, 11 F. Supp. 2d 42, 44 (D.D.C. 1998). 8 EFTA00071567 Case 1:20-cv-00833-PAE Document 25 Filed 08/05/20 Page 15 of 30 (
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
f Justice, M8 F.3d 1188 (10th Cir. 2 011) 9, 10, 21, 22 Judicial Watch, Inc. v. U.S. Dept of Commerce, 337 F. Supp. 2d 146 (D.D.C. 2004) 20, 21 Kansi v. U.S. Depst of Justice, 11 F. Supp. 2d 42 (D.D.C. 1998) 8 Kay v. F.C.C., 976 F. Supp. 23 (D.D.C. 199 7) 7 Kidder v. FBI, 517 F. Supp. 2d 17
released, could interfere with post-trial criminal proceedings, such as an appeaL See, e.g.,Kidder v. FBI, 517 F. Supp. 2d 17, 27-28 (D.D.C. 2007); Kansi v. U.S. Dep 't of Justice, 11 F. Supp. 2d 42, 44 (D.D.C. 1998). 8 EFTA00075450 Case 1:20-cv-00833-PAE Document 25 Filed 08/05/20 Page 15 of 30 (
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
f Justice, M8 F.3d 1188 (10th Cir. 2 011) 9, 10, 21, 22 Judicial Watch, Inc. v. U.S. Dept of Commerce, 337 F. Supp. 2d 146 (D.D.C. 2004) 20, 21 Kansi v. U.S. Depst of Justice, 11 F. Supp. 2d 42 (D.D.C. 1998) 8 Kay v. F.C.C., 976 F. Supp. 23 (D.D.C. 199 7) 7 Kidder v. FBI, 517 F. Supp. 2d 17
released, could interfere with post-trial criminal proceedings, such as an appeaL See, e.g.,Kidder v. FBI, 517 F. Supp. 2d 17, 27-28 (D.D.C. 2007); Kansi v. U.S. Dep 't of Justice, 11 F. Supp. 2d 42, 44 (D.D.C. 1998). 8 EFTA00088684 Case 1:20-cv-00833-PAE Document 25 Filed 08/05/20 Page 15 of 30 (
Entities connected to both Special Housing Unit and Kansi

Jeffrey Epstein
PERSON
Metropolitan Correctional Center
ORGANIZATIONNicholas Tartaglione
PERSONTova Noel
PERSONMichael Thomas
PERSON
United States
LOCATIONthe Southern District
LOCATION
George W. Bush
PERSON
THE NEW YORK TIMES COMPANY
ORGANIZATION
Alberto Gonzales
PERSON
Audrey Strauss
PERSONAnalisa Torres
PERSON
Sarah Ferguson
PERSONGarcia
PERSON
The Washington Post
ORGANIZATIONthe Acting United States
ORGANIZATION
Andrew Cuomo
PERSON
Supreme Court
ORGANIZATION
Human Rights Watch
ORGANIZATION
Urbano Santiago
PERSON