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& SEPLOWITZ LLc ATTORNEYS AT LAW PAGE 2 6. The email referenced in Employee Number 7's witness statement that was sent to MCC employees regarding Jeffrey Epstein's need for a cellmate. 7. Psychology Services post-suicide watch report drafted by Employee Number 12 on July 24, 2019. 8. A copy of the memorandum
s, and/or emails addressing the death of Jeffrey Epstein including, but not limited to, the memorandums d
, letters, and/or emails addressing the death of Jeffrey Epstein including, but not limited to, the memora
s: 1. Defendant Noel's complete personnel and training file including, but not limited to, the following: a. Individual employee training record. b. Complete Performance Log maintained in the Admin Lieutenant's Office or any other location in the MCC. c. Completed and signed Position Description Cover Sheet. d. Complet
& SEPLOWITZ LLc ATTORNEYS AT LAW PAGE 2 6. The email referenced in Employee Number 7's witness statement that was sent to MCC employees regarding Jeffrey Epstein's need for a cellmate. 7. Psychology Services post-suicide watch report drafted by Employee Number 12 on July 24, 2019. 8. A copy of the memorandum
s, and/or emails addressing the death of Jeffrey Epstein including, but not limited to, the memorandums d
, letters, and/or emails addressing the death of Jeffrey Epstein including, but not limited to, the memora
s: 1. Defendant Noel's complete personnel and training file including, but not limited to, the following: a. Individual employee training record. b. Complete Performance Log maintained in the Admin Lieutenant's Office or any other location in the MCC. c. Completed and signed Position Description Cover Sheet. d. Complet
& SEPLOWITZ LLc ATTORNEYS AT LAW PAGE 2 6. The email referenced in Employee Number 7's witness statement that was sent to MCC employees regarding Jeffrey Epstein's need for a cellmate. 7. Psychology Services post-suicide watch report drafted by Employee Number 12 on July 24, 2019. 8. A copy of the memorandum
s, and/or emails addressing the death of Jeffrey Epstein including, but not limited to, the memorandums d
, letters, and/or emails addressing the death of Jeffrey Epstein including, but not limited to, the memora
s: 1. Defendant Noel's complete personnel and training file including, but not limited to, the following: a. Individual employee training record. b. Complete Performance Log maintained in the Admin Lieutenant's Office or any other location in the MCC. c. Completed and signed Position Description Cover Sheet. d. Complet
Entities connected to both Jeffrey Epstein and b. Complete Performance Log

Prince Andrew
PERSONTova Noel
PERSONHACKENSACK
LOCATIONFLETC
ORGANIZATIONFOY & SEPLOWITZ LLC
ORGANIZATIONJASON E. FOY
PERSONSHU Watch
ORGANIZATIONJamel Floyd
PERSONSHU Watch Call Logs
ORGANIZATION
Kenneth Houck
PERSONthe Suicide Reconstruction Report
ORGANIZATIONSHU Operations Lieutenant
ORGANIZATIONBoard of Inquiry Report
ORGANIZATIONMCC Correctional Services
ORGANIZATIONInstitutional Supplement
ORGANIZATIONProgram Reviews
ORGANIZATIONOperational Reviews
ORGANIZATIONa. Individual
ORGANIZATIONThe Inmate Accountability Institutional Supplement/Program Statement
ORGANIZATIONSecurity Inspections Institutional Supplement/Program Statement
ORGANIZATION