Falsely stated that the 4 p.m. institutional count had been performed.
This document is page 8 of a legal filing (likely a criminal complaint) against correctional officers Tova Noel and Michael Thomas. It alleges that between August 9 and August 10, the officers failed to perform any of the five required institutional counts in the SHU, despite completing paperwork claiming they had done so. Specifically, video evidence shows Noel and 'Officer-1' falsified the 4 p.m. count slip on August 9.
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