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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
pond to them. "Governmental decisions and policies can include the formulation of an agency's statements to the public and other outside entities." Leopold v. Office ofDirector ofNational Intelligence, No. 16-2517 15 EFTA00071574 Case 1:20-cv-00833-PAE Document 25 Filed 08/05/20 Page 22 of 30 (CKK), 2020 WL 8
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
pond to them. "Governmental decisions and policies can include the formulation of an agency's statements to the public and other outside entities." Leopold v. Office ofDirector ofNational Intelligence, No. 16-2517 15 EFTA00075457 Case 1:20-cv-00833-PAE Document 25 Filed 08/05/20 Page 22 of 30 (CKK), 2020 WL 8
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
pond to them. "Governmental decisions and policies can include the formulation of an agency's statements to the public and other outside entities." Leopold v. Office ofDirector ofNational Intelligence, No. 16-2517 15 EFTA00088691 Case 1:20-cv-00833-PAE Document 25 Filed 08/05/20 Page 22 of 30 (CKK), 2020 WL 8
Entities connected to both Special Housing Unit and Leopold v. Office

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
PERSONAnalisa Torres
PERSONthe Acting United States
ORGANIZATION
Audrey Strauss
PERSON
Supreme Court
ORGANIZATION
Sarah Ferguson
PERSONGarcia
PERSON
Urbano Santiago
PERSON
Andrew Cuomo
PERSON
The Washington Post
ORGANIZATIONChristenson
PERSON