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lo Building One Saint Andrew's Plaza New York, New York 10007 October 13, 2020 BY USAfx Jason E. Foy Foy & Seplowitz LLC Re: United States v. Tova Noel No. 19 Cr. 830 Dear Counsel: This letter provides additional discovery pursuant to Rule 16(a) of the Federal Rules of Criminal Procedure. This let
nda SDNY_000 13258 — SDNY_000 13324 Confidential Records of evidence seizures and submissions SDNY_000 13325 — SDNY_000 13424 Confidential 1 The Bureau of Prisons ("BOP") provided to the Government the contents of 24 email accounts used by MCC employees, including an account used by each of the defendants. The
e of Epstein's death.13131 On November 19, 2019, federal prosecutors in New York charged Metropolitan Correctional Center guards Michael Thomas and Tova Noel with creating false records, and with conspiracy, after video footage obtained by prosecutors revealed that Epstein had, against regulation, been in
Al Epstein was found dead in his cell at the Metropolitan Correctional Center (MCC) in New York City at 6:3o a.m. EDT on August 10, 2019 129°12911J The Bureau of Prisons said lifesaving measures were initiated immediately upon the discovery of Epstein's body. Emergency responders were called and he was taken to a ho
attan, according to a source. As captain, Darden oversees lieutenants and correctional officers at MCC. Among those under his command were Officers Tova Noel and Michael Thomas, who are accused of sleeping on the job and falsifying records the night of Epstein's death. A source doubted that Darden was at
don't have any pictures of what happened that night because they didn't follow proper protocol," Figgins said. "And yet he gets another position." The Bureau of Prisons declined to comment on personnel decisions. Thomas and Noel have pleaded not guilty to charges including filing false records, which carries a maxim
BOP also properly withheld records under Exemption 7(A) that could reasonably be expected to interfere with the prosecutions of Michael Thomas and Tova Noel. The Capone Declarations logically and plausibly explain why these records could reasonably be expected to interfere with Noel, including because t
OIA Exemption 7(A)—records that could reasonably be expected to interfere with two pending federal criminal prosecutions, one a death penalty case. The Bureau of Prisons ("BOP") properly withheld these records, and plaintiff's arguments to the contrary ignore or mischaracterize the weighty law enforcement interests a
BOP also properly withheld records under Exemption 7(A) that could reasonably be expected to interfere with the prosecutions of Michael Thomas and Tova Noel. The Capone Declarations logically and plausibly explain why these records could reasonably be expected to interfere with Noel, including because t
OIA Exemption 7(A)—records that could reasonably be expected to interfere with two pending federal criminal prosecutions, one a death penalty case. The Bureau of Prisons ("BOP") properly withheld these records, and plaintiff's arguments to the contrary ignore or mischaracterize the weighty law enforcement interests a
BOP also properly withheld records under Exemption 7(A) that could reasonably be expected to interfere with the prosecutions of Michael Thomas and Tova Noel. The Declarations logically and plausibly explain why these records could reasonably be expected to interfere with Noel, including because they "in
OIA Exemption 7(A)—records that could reasonably be expected to interfere with two pending federal criminal prosecutions, one a death penalty case. The Bureau of Prisons ("BOP") properly withheld these records, and plaintiff's arguments to the contrary ignore or mischaracterize the weighty law enforcement interests a
Brown - NY DAILY NEWS Questions & Proposed Responses: Hello. I'm working on a story about morale at MCC in Manhattan in the wake of charges against Tova Noel and Michael Thomas. I've spoken to an AFC The thrust of the story is that morale has plummeted at the facility in the wake of the falsification of d
's office will investigate how Jeffrey Epstein died in an apparent suicide ... Jeffrey Epstein's apparent suicide is unfathomable Washington Post The Bureau of Prisons, the federal agency that runs the MCC, has said the ... If any prisoner in the federal system should have been a candidate for ... Prison experts a
attan, according to a source. As captain, Darden oversees lieutenants and correctional officers at MCC. Among those under his command were Officers Tova Noel and Michael Thomas, who are accused of sleeping on the job and falsifying records the night of Epstein's death. A source doubted that Darden was at
Page: EFTA00014245 →don't have any pictures of what happened that night because they didn't follow proper protocol," Figgins said. "And yet he gets another position." The Bureau of Prisons declined to comment on personnel decisions. Thomas and Noel have pleaded not guilty to charges including filing false records, which carries a maxim
Page: EFTA00014246 →attan, according to a source. As captain, Darden oversees lieutenants and correctional officers at MCC. Among those under his command were Officers Tova Noel and Michael Thomas, who are accused of sleeping on the job and falsifying records the night of Epstein's death. A source doubted that Darden was at
Page: EFTA00014265 →don't have any pictures of what happened that night because they didn't follow proper protocol," Figgins said. "And yet he gets another position." The Bureau of Prisons declined to comment on personnel decisions. Thomas and Noel have pleaded not guilty to charges including filing false records, which carries a maxim
Page: EFTA00014266 →Entities connected to both Tova Noel and The Bureau of Prisons

Jeffrey Epstein
PERSONMichael Thomas
PERSON
Department of Justice
ORGANIZATIONFederal Bureau of Prisons
ORGANIZATION
Metropolitan Correctional Center
ORGANIZATION
Prince Andrew
PERSONFBI
ORGANIZATION
Ghislaine Maxwell
PERSON
Julie K. Brown
PERSONLeon Black
PERSONNicholas Tartaglione
PERSON
Geoffrey S. Berman
PERSONthe Southern District
LOCATION
United States
LOCATION
Donald Trump
PERSONSouthern District
LOCATION
William Barr
PERSON
New York
LOCATION
Southern District of New York
ORGANIZATION
Stephen Hawking
PERSON