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ates v. Epstein, No. 19 Cr. 490 (RMB) (S.D.N.Y.). The Prosecution of Tova Noel and Michael Thomas 9. As alleged in the Noel Indictment, Thomas and Tova Noel were correctional officers on duty at the SHU on August 9-10, 2019, the night of Epstein's death. See Noel Indictment 11 3-4. On that night, Noel a
ence in violation of Title 18, United States Code, Sections 1952 and 2. These charges arise from the April 2016 murders of Martin Luna, Miguel Luna, Urbano Santiago, and Hector Gutierrez. On April 19, 2019, USAO-SDNY filed a Notice of Intent to Seek the Death Penalty against Tartaglione. The Tartaglione case is
ates v. Epstein, No. 19 Cr. 490 (RMB) (S.D.N.Y.). The Prosecution of Tova Noel and Michael Thomas 9. As alleged in the Noel Indictment, Thomas and Tova Noel were correctional officers on duty at the SHU on August 9-10, 2019, the night of Epstein's death. See Noel Indictment 91 3-4. On that night, Noel a
ence in violation of Title 18, United States Code, Sections 1952 and 2. These charges arise from the April 2016 murders of Martin Luna, Miguel Luna, Urbano Santiago, and Hector Gutierrez. On April 19, 2019, USAO-SDNY filed a Notice of Intent to Seek the Death Penalty against Tartaglione. The Tartaglione case is
of 30 TABLE OF CONTENTS PRELIMINARY STATEMENT BACKGROUND 2 I. Criminal Proceedings Against Jeffrey Epstein 2 II. Criminal Proceedings Against Tova Noel and Michael Thomas 2 III. Criminal Proceedings Against Nicholas Tartaglione 3 IV. The Times's FOIA Requests and This Action 3 ARGUMENT 4 I.
olas Tartaglio nc Nicholas Tartaglione has been charged with fifteen criminal violations arising from the murders of Hector Gutierrez, Martin Luna, Urbano Santiago, and Miguel Luna. Id. ¶ 10; see Superseding Indictment, Dkt. No. 120, United States of America v. Tartaglione, No. 16-CR-832 (KMK) (S.D.N.Y.). On A
of 30 TABLE OF CONTENTS PRELIMINARY STATEMENT BACKGROUND 2 I. Criminal Proceedings Against Jeffrey Epstein 2 II. Criminal Proceedings Against Tova Noel and Michael Thomas 2 III. Criminal Proceedings Against Nicholas Tartaglione 3 IV. The Times's FOIA Requests and This Action 3 ARGUMENT 4 I.
olas Tartaglio nc Nicholas Tartaglione has been charged with fifteen criminal violations arising from the murders of Hector Gutierrez, Martin Luna, Urbano Santiago, and Miguel Luna. Id. ¶ 10; see Superseding Indictment, Dkt. No. 120, United States of America v. Tartaglione, No. 16-CR-832 (KMK) (S.D.N.Y.). On A
ates v. Epstein, No. 19 Cr. 490 (RMB) (S.D.N.Y.). The Prosecution of Tova Noel and Michael Thomas 9. As alleged in the Noel Indictment, Thomas and Tova Noel were correctional officers on duty at the SHU on August 9-10, 2019, the night of Epstein's death. See Noel Indictment 91 3-4. On that night, Noel a
ence in violation of Title 18, United States Code, Sections 1952 and 2. These charges arise from the April 2016 murders of Martin Luna, Miguel Luna, Urbano Santiago, and Hector Gutierrez. On April 19, 2019, USAO-SDNY filed a Notice of Intent to Seek the Death Penalty against Tartaglione. The Tartaglione case is
of 30 TABLE OF CONTENTS PRELIMINARY STATEMENT BACKGROUND 2 I. Criminal Proceedings Against Jeffrey Epstein 2 II. Criminal Proceedings Against Tova Noel and Michael Thomas 2 III. Criminal Proceedings Against Nicholas Tartaglione 3 IV. The Times's FOIA Requests and This Action 3 ARGUMENT 4 I.
olas Tartaglio nc Nicholas Tartaglione has been charged with fifteen criminal violations arising from the murders of Hector Gutierrez, Martin Luna, Urbano Santiago, and Miguel Luna. Id. ¶ 10; see Superseding Indictment, Dkt. No. 120, United States of America v. Tartaglione, No. 16-CR-832 (KMK) (S.D.N.Y.). On A
r of nolle prosequi against Epstein. See Nolle Prosequi, Dkt. No. 52, United States v. Epstein, No. 19 Cr. 490 (RMB) (S.D.N.Y.). The Prosecution of Tova Noel and Michael Thomas 9. As alleged in the Noel Indictment, Thomas and Tova Noel were correctional officers on duty at the SHU on August 9-10, 2019,
Page: EFTA00015440 →ence in violation of Title 18, United States Code, Sections 1952 and 2. These charges arise from the April 2016 murders of Martin Luna, Miguel Luna, Urbano Santiago, and Hector Gutierrez. On April 19, 2019, USAO-SDNY filed a Notice of Intent to Seek the Death Penalty against Tartaglione. The Tartaglione case is
Page: EFTA00015441 →paragraphs 1 through 27 of this Indictment as though fully set forth herein. 32. On or about August 9, 2019, in the Southern District of New York, TOVA NOEL, the defendant, willfully and knowingly did make and use a false writing or document knowing the same to contain a materially false, fictitious, an
Page: EFTA00015466 →r of nolle prosequi against Epstein. See Nolle Prosequi, Dkt. No. 52, United States v. Epstein, No. 19 Cr. 490 (RMB) (S.D.N.Y.). The Prosecution of Tova Noel and Michael Thomas 9. As alleged in the Noel Indictment, Thomas and Tova Noel were correctional officers on duty at the SHU on August 9-10, 2019,
Page: EFTA00031027 →ence in violation of Title 18, United States Code, Sections 1952 and 2. These charges arise from the April 2016 murders of Martin Luna, Miguel Luna, Urbano Santiago, and Hector Gutierrez. On April 19, 2019, USAO-SDNY filed a Notice of Intent to Seek the Death Penalty against Tartaglione. The Tartaglione case is
Page: EFTA00031028 →paragraphs 1 through 27 of this Indictment as though fully set forth herein. 32. On or about August 9, 2019, in the Southern District of New York, TOVA NOEL, the defendant, willfully and knowingly did make and use a false writing or document knowing the same to contain a materially false, fictitious, an
Page: EFTA00031053 →Entities connected to both Tova Noel and Urbano Santiago

Jeffrey Epstein
PERSONMichael Thomas
PERSONSpecial Housing Unit
ORGANIZATIONFederal Bureau of Prisons
ORGANIZATION
Metropolitan Correctional Center
ORGANIZATIONNicholas Tartaglione
PERSON
Geoffrey S. Berman
PERSONthe Southern District
LOCATION
United States
LOCATION
Richard M. Berman
PERSON
Southern District of New York
ORGANIZATION
New York
LOCATION
George W. Bush
PERSONAnalisa Torres
PERSONChristenson
PERSON
THE NEW YORK TIMES COMPANY
ORGANIZATION
Audrey Strauss
PERSONDistrict Court for the Southern District of New York
ORGANIZATIONMartin Luna
PERSONMiguel Luna
PERSON