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a determination on who we were going to 25 house with Epstein. EFTA00059004 LIMITED OFFICIAL USE 1 2 : Now, if the operations , his name is Perez. 135 3 : Right. 4 : Carlos 5 : Right. 6 : -- Perez. 7 : Right. 8 : If he says, yes, I know 9 Epstein was gone, but I believe that he w
encountered him to do anything, known him not 25 to count, do his job, you know? EFTA00059046 LIMITED OFFICIAL USE 1 2 177 : What about Ms. Tova Noel? : She was new. So, she had 3 just gotten there. You know, she got the same 4 spiel from me that everybody else does. You 5 know? You are new.
12/23/2019 15:10 (U) Interview o EFTA01730710 178 12/20/2019 12:49 (U) Proffer of Jason Mojica 177 12/20/2019 12:48 (U) Proffer of Christian Perez 176 12/20/2019 11:22 (U) Proffer of Freddy Caraballo 1.75 12/20/2019 11:22 (U) Proffer of Carlos Sanchez-Galan 174 12/19/2019 14:58 (U) Inte
14:48 (U nterview 170 12/19/2019 14:48 (U nterview 169 12/19/2019 14:47 (U) Interview o 168 12/13/2019 14:25 (U) Daily Assignment Log for Tova Noel 167 12/13/2019 14:25 (U) Work Schedules fo 166 12/13/2019 14:24 (U) Letter to the Office of the Chief Medical Examiner Regarding the Autopsy o
king sure everything is conducted 23 according to BOP policy. 24 MR. Okay. And who was your 25 supervisor? EFTA00116071 13 1 MR. ieutenant Perez. 2 MR. Lieutenant Perez? It 3 wasn't Lieutenant Rice? 4 MR. Well, actually yes, yes, 5 Lieutenant Rice, I'm sorry, yes. 6 MR. And he was t
nible 25 *01:06:57). EFTA00116152 94 1 MR. I don't know if it's T or 2 a J. 3 MR. J or a -. 4 MR. It's T. 5 MR. T? 6 MR. T and so Tova Noel? 7 MR. Yes. 8 MR. But you believe is 9 the one that should have certified the 2:00 to 10 4:00? 11 MR. Yeah. 12 MR. Do you believe 13
66 --- PAGE BREAK --- United States v. Payne, 63 F.3d 1200 (2d Cir. 1995) United States v. Pelullo, 399 F.3d 197 (3d Cir. 2005) United States v. Perez, 940 F. Supp. 540 (S.D.N.Y. 1996) United States v. Persico, 645 F.3d 85 (2d Cir. 2011) 8 21 10 8 United States v. Reese, 933 F. Supp. 2d 579 (S
Page: EFTA00031267 →suicide (Mot. 6); and (iv) reports, statistics, and documents related to purported staffing issues, supervisory lapses, and the application of BOP Tova Noel did not file any pretrial motions, and has not joined in Thomas's pretrial motions. See Fed. R. Crim. P. 12(c)(3) ("If a party does not meet the dea
Page: EFTA00031268 →respects. STATEMENT OF FACTS I. The Indictment Indictment 19 Cr. 830 (AT) (the "Indictment") was filed on November 19, 2019, charging defendants Tova Noel and Michael Thomas in six counts: (i) conspiring to defraud the United States and to make or use a false writing or document, in violation of Title
Page: EFTA00031269 →d 04/24/20 Page 5 of 34 United States v. Payne, 63 F.3d 1200 (2d Cir. 1995) United States v. Pelull°, 399 F.3d 197 (3d Cir. 2005) United States v. Perez, 940 F. Supp. 540 (S.D.N.Y. 1996) United States v. Persico, 645 F.3d 85 (2d Cir. 2011) 8 21 10 8 United States v. Reese, 933 F. Supp. 2d 579 (S
Page: EFTA00027311 →suicide (Mot. 6); and (iv) reports, statistics, and documents related to purported staffing issues, supervisory lapses, and the application of BOP Tova Noel did not file any pretrial motions, and has not joined in Thomas's pretrial motions. See Fed. R. Crim. P. 12(c)(3) ("If a party does not meet the dea
Page: EFTA00027312 →Entities connected to both Perez and Tova Noel

Jeffrey Epstein
PERSON
Department of Justice
ORGANIZATION
Prince Andrew
PERSONFederal Bureau of Prisons
ORGANIZATION
Donald Trump
PERSON
Julie K. Brown
PERSON
United States
LOCATIONLeon Black
PERSONSpecial Housing Unit
ORGANIZATION
Ghislaine Maxwell
PERSONFBI
ORGANIZATION
Virginia Giuffre
PERSON
Metropolitan Correctional Center
ORGANIZATION
Joe Biden
PERSON
George W. Bush
PERSON
Scarlett Johansson
PERSON
South
LOCATION
Bloomberg L.P.
ORGANIZATIONReyes
PERSONthe Southern District
LOCATION