📧 Communication

This document is page 14 of a legal defense filing (Case 1:19-cr-00830-AT) dated April 9, 2020, regarding charges against prison guards Michael Thomas and Tova Noel. The defense argues that while Thomas is charged with falsifying logs, other supervisors who approved these logs were not charged, and points to severe staffing shortages in the SHU. The filing seeks disclosure of the Inspector General's report, arguing it is material to the defense to prove systemic failures beyond the defendants' actions.