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ted such counts. See id. II 15-24. On November 19, 2019, Noel and Thomas were charged in the Noel Indictment with one count of conspiring to defraud the United States and to make or use a false writing or document, in violation of Title 18, United States Code, Section 371; and five counts as to Noel and three coun
ps, 1O EFTA00039931 Caeale2DIS, 003C3E13BAPEI OThrica.uneint 22 -F act IMEE/2 OP age gel. 12 3021 at approximately 3:24 a.m. and 5:30 a.m., the Control Center cleared the 3 a.m. and 5 a.m. counts, respectively. 23. Moreover, despite the requirement that officers on duty in the SHU conduct and document re
Southern District of New York, TOVA NOEL and MICHAEL THOMAS, the defendants, knowingly conspired with each other to: a. Knowingly defraud the United States by impairing, obstructing, and defeating the lawful functions of a department or agency of the United States, to wit, the MCC's function to ensur
a.m. and 5 a.m. institutional counts. In reliance on those falsified count slips, 10 EFTA00126156 at approximately 3:24 a.m. and 5:30 a.m., the Control Center cleared the 3 a.m. and 5 a.m. counts, respectively. 23. Moreover, despite the requirement that officers on duty in the SHU conduct and document re
Southern District of New York, TOVA NOEL and MICHAEL THOMAS, the defendants, knowingly conspired with each other to: a. Knowingly defraud the United States by impairing, obstructing, and defeating the lawful functions of a department or agency of the United States, to wit, the MCC's function to ensur
a.m. and 5 a.m. institutional counts. In reliance on those falsified count slips, 10 EFTA00126136 at approximately 3:24 a.m. and 5:30 a.m., the Control Center cleared the 3 a.m. and 5 a.m. counts, respectively. 23. Moreover, despite the requirement that officers on duty in the SHU conduct and document re
Southern District of New York, TOVA NOEL and MICHAEL THOMAS, the defendants, knowingly conspired with each other to: a. Knowingly defraud the United States by impairing, obstructing, and defeating the lawful functions of a department or agency of the United States, to wit, the MCC's function to ensur
a.m. and 5 a.m. institutional counts. In reliance on those falsified count slips, 10 EFTA00164386 at approximately 3:24 a.m. and 5:30 a.m., the Control Center cleared the 3 a.m. and 5 a.m. counts, respectively. 23. Moreover, despite the requirement that officers on duty in the SHU conduct and document re
Southern District of New York, TOVA NOEL and MICHAEL THOMAS, the defendants, knowingly conspired with each other to: a. Knowingly defraud the United States by impairing, obstructing, and defeating the lawful functions of a department or agency of the United States, to wit, the MCC's function to ensur
a.m. and 5 a.m. institutional counts. In reliance on those falsified count slips, 10 EFTA00164469 at approximately 3:24 a.m. and 5:30 a.m., the Control Center cleared the 3 a.m. and 5 a.m. counts, respectively. 23. Moreover, despite the requirement that officers on duty in the SHU conduct and document re
ted such counts. See id. II 15-24. On November 19, 2019, Noel and Thomas were charged in the Noel Indictment with one count of conspiring to defraud the United States and to make or use a false writing or document, in violation of Title 18, United States Code, Section 371; and five counts as to Noel and three coun
ps, 1O EFTA00075405 Caeale2DIS, 003C3E13BAPEI OThrica.uneint 22 -F act IMEE/2 OP age gel. 12 3021 at approximately 3:24 a.m. and 5:30 a.m., the Control Center cleared the 3 a.m. and 5 a.m. counts, respectively. 23. Moreover, despite the requirement that officers on duty in the SHU conduct and document re
Entities connected to both United States and Control Center

Jeffrey Epstein
PERSON
George W. Bush
PERSON
Ghislaine Maxwell
PERSON
Department of Justice
ORGANIZATIONthe Southern District
LOCATIONLeon Black
PERSONFBI
ORGANIZATION
New York
LOCATIONDarren Indyke
PERSON
Julie K. Brown
PERSONSouthern District
LOCATION
New York City
LOCATION
Richard Kahn
PERSON
the United States District Court
ORGANIZATION
Alfredo Rodriguez
PERSON
Bloomberg L.P.
ORGANIZATION
Vicky Ward
PERSON
Geoffrey S. Berman
PERSON
South
LOCATIONFederal Bureau of Prisons
ORGANIZATION