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

TABLE OF AUTHORITIES Cases ACLU v. DOD, Page(s) 389 F. Supp. 2d 547 (S.D.N.Y. 2005) 21, 22 ACLU v. DOI, 844 F.3d 126 (2d Cir. 2016) 15, 16 Adamowitz v. I.R.S., 552 F. Supp. 2d 355 (S.D.N.Y. 2008) 5 Allard K. Lowenstein Intl Human Rights Project v. Dep't of Homeland Sec., 626 F.3d 678 (2d Cir.

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

TABLE OF AUTHORITIES Cases ACLU v. DOD, Page(s) 389 F. Supp. 2d 547 (S.D.N.Y. 2005) 21, 22 ACLU v. DOI, 844 F.3d 126 (2d Cir. 2016) 15, 16 Adamowitz v. I.R.S., 552 F. Supp. 2d 355 (S.D.N.Y. 2008) 5 Allard K. Lowenstein Intl Human Rights Project v. Dep't of Homeland Sec., 626 F.3d 678 (2d Cir.

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

TABLE OF AUTHORITIES Cases ACLU v. DOD, Page(s) 389 F. Supp. 2d 547 (S.D.N.Y. 2005) 21, 22 ACLU v. DOI, 844 F.3d 126 (2d Cir. 2016) 15, 16 Adamowitz v. I.R.S., 552 F. Supp. 2d 355 (S.D.N.Y. 2008) 5 Allard K. Lowenstein Intl Human Rights Project v. Dep't of Homeland Sec., 626 F.3d 678 (2d Cir.