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AT Document 1 Filed 11/19/19 Page 1 of 20 Ye 'UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA TOVA NOEL and MICHAEL THOMAS, Defendants. X INDICTMENT .096um 830 INTRODUCTION 1. On or about August 10, 2019, TOVA NOEL and MICHAEL THOMAS, the defendants, in derelictio
Page: EFTA00009747 →the SHU, when she had not in fact done so. (Title 18, United States Code, Sections 1001(a)(3) and 2) COUNT THREE (False Records - 10 p.m. Count) The Grand Jury further charges: 33. The Grand Jury incorporates the allegations contained in paragraphs 1 through 27 of this Indictment as though fully set fort
Page: EFTA00009762 →UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK INDICTMENT UNITED STATES OF AMERICA TOVA NOEL and MICHAEL THOMAS, Defendants. X The Grand Jury charges: INTRODUCTION 1. On or about August 10, 2019, TOVA NOEL and MICHAEL THOMAS, the defendants, in derelicti
Page: EFTA00010968 →the SHU, when she had not in fact done so. (Title 18, United States Code, Sections 1001(a) (3) and 2) COUNT FOUR (False Records - 12 a.m. Count) The Grand Jury further charges: 35. The Grand Jury incorporates the allegations contained in paragraphs 1 through 27 of this Indictment as though fully set
Page: EFTA00010983 →UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK INDICTMENT UNITED STATES OF AMERICA TOVA NOEL, and MICHAEL THOMAS, Defendants. X The Grand Jury charges: INTRODUCTION 1. On or about August 10, 2019, TOVA NOEL and MICHAEL THOMAS, the defendants, while on dut
Page: EFTA00014985 →so. (Title 18, United States Code, Sections 1001(a) (3) and 2) 14 EFTA00014998 --- PAGE BREAK --- COUNT FOUR (False Records - 12 a.m. Count) The Grand Jury further charges: 34. The Grand Jury incorporates the allegations contained in paragraphs 1 through X of this Indictment as though fully set f
Page: EFTA00014999 →icers responded to an emergency call and found Epstein on the floor of his cell with a strip of bedsheet around his neck. See Noel Indictment 1 11. Michael Thomas, a correctional officer at the MCC and one of the defendants in the Noel case, was one of the MCC officials who responded to this incident. See id.
Page: EFTA00015439 →the SHU, when they had not in fact done so. (Title 18, United States Code, Sections 1001(a)(3) and 2) COUNT FIVE (False Records - 3 a.m. Count) The Grand Jury further charges: 37. The Grand Jury incorporates the allegations contained in paragraphs 1 through 27 of this Indictment as though fully set fort
Page: EFTA00015468 →UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK INDICTMENT UNITED STATES OF AMERICA 19 Cr. TOVA NOEL and MICHAEL THOMAS, Defendants. X 19 GRIM 830 INTRODUCTION 1. On or about August 10, 2019, TOVA NOEL and MICHAEL THOMAS, the defendants, in dereliction of their
Page: EFTA00017915 →the SHU, when she had not in fact done so. (Title 18, United States Code, Sections 1001(a)(3) and 2) COUNT THREE (False Records - 10 p.m. Count) The Grand Jury further charges: 33. The Grand Jury incorporates the allegations contained in paragraphs 1 through 27 of this Indictment as though fully set
Page: EFTA00017930 →icers responded to an emergency call and found Epstein on the floor of his cell with a strip of bedsheet around his neck. See Noel Indictment 1 11. Michael Thomas, a correctional officer at the MCC and one of the defendants in the Noel case, was one of the MCC officials who responded to this incident. See id.
Page: EFTA00031026 →the SHU, when they had not in fact done so. (Title 18, United States Code, Sections 1001(a)(3) and 2) COUNT FIVE (False Records - 3 a.m. Count) The Grand Jury further charges: 37. The Grand Jury incorporates the allegations contained in paragraphs 1 through 27 of this Indictment as though fully set fort
Page: EFTA00031055 →Entities connected to both Michael Thomas and The Grand Jury

Jeffrey Epstein
PERSONTova Noel
PERSONFederal Bureau of Prisons
ORGANIZATIONSpecial Housing Unit
ORGANIZATION
Metropolitan Correctional Center
ORGANIZATION
Geoffrey S. Berman
PERSONNicholas Tartaglione
PERSON
United States
LOCATIONthe Southern District
LOCATIONDistrict Court for the Southern District of New York
ORGANIZATIONAnalisa Torres
PERSON
Southern District of New York
ORGANIZATION
Richard M. Berman
PERSON
U.S. Congress
LOCATIONChristenson
PERSONthe USAO-SDNY
ORGANIZATION
Urbano Santiago
PERSONMartin Luna
PERSONMiguel Luna
PERSONHector Gutierrez
PERSON