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704 KB
Extraction Summary
2
People
4
Organizations
2
Locations
5
Events
2
Relationships
4
Quotes
Document Information
Type:
Court filing / legal memorandum
File Size:
704 KB
Summary
This document is page 8 of a court filing (Document 35) from April 2020 regarding the criminal case against correctional officers Noel and Thomas. It details the charges related to their failure to perform prisoner counts at the MCC SHU between August 9 and 10, 2019 (the night of Jeffrey Epstein's death) and their falsification of records. It also outlines the timeline of pretrial discovery, noting that the Government provided surveillance video, computer analysis, and interview reports to the defense.
People (2)
Organizations (4)
| Name | Type | Context |
|---|---|---|
| MCC |
Metropolitan Correctional Center; location where defendants worked.
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| Federal Bureau of Investigation |
Prepared reports and notes of witness interviews.
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| DOJ-OIG |
Department of Justice Office of the Inspector General; participated in the investigation.
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| The Government |
Provided discovery production to defendants.
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Timeline (5 events)
2019-12-31
Discovery deadline and date of substantial discovery production by the Government.
N/A
Relationships (2)
Referenced as 'Both defendants' and 'Noel and Thomas' working as correctional officers.
Government providing discovery materials to defendants.
Key Quotes (4)
"the defendants failed to perform mandated counts of prisoners housed in MCC’s Special Housing Unit (“SHU”), but nevertheless signed false certifications attesting to having conducted those counts"Source
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Quote #1
"no counts or rounds of the SHU were conducted from approximately 10:30 p.m. on August 9 to 6:30 a.m. on August 10."Source
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Quote #2
"surveillance video for the common area of the SHU; analysis of the computers used by Noel and Thomas"Source
DOJ-OGR-00022070.jpg
Quote #3
"The Government does not concede that production of all of the materials was required under Rule 16"Source
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Quote #4
Full Extracted Text
Complete text extracted from the document (2,051 characters)
Case 1:19-cr-00830-AT Document 35 Filed 04/24/20 Page 8 of 34
Both defendants are charged in Counts One, Four, Five, and Six; defendant Noel only is charged in Counts Two and Three. The charges in the Indictment stem from a fourteen-hour time period, from approximately 4:00 p.m. on August 9, 2019 to approximately 6:30 a.m. the following day, August 10, 2019, when the defendants were working as correctional officers at the MCC. As charged in the Indictment, during that time period, the defendants failed to perform mandated counts of prisoners housed in MCC’s Special Housing Unit (“SHU”), but nevertheless signed false certifications attesting to having conducted those counts, when, in fact, no counts or rounds of the SHU were conducted from approximately 10:30 p.m. on August 9 to 6:30 a.m. on August 10.
II. Pretrial Discovery and the Defendants’ Request for Additional Materials
A. The Government’s Discovery Production
At the initial pretrial conference on November 25, 2019, the Court set a discovery deadline of December 31, 2019. On that date, pursuant to a protective order entered by the Court, the Government made a substantial discovery production to both defendants, consisting in part of the following: surveillance video for the common area of the SHU; analysis of the computers used by Noel and Thomas from August 9 to 10, 2019; count slips and thirty-minute round reports; MCC phone records; personnel records and prior work schedules; and reports and notes of witness interviews prepared by agents from the Federal Bureau of Investigation (“FBI”) and the DOJ-OIG who were participating in the investigation.2
Subsequently, the Government made three additional discovery productions, much more limited in scope. On January 23, 2020, the Government produced additional interview reports and
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2 The Government does not concede that production of all of the materials was required under Rule 16, but nonetheless produced the materials in its possession out of an abundance of caution.
2 The Government does not concede that production of all of the materials was required under Rule 16, but nonetheless produced the materials in its possession out of an abundance of caution.
3
DOJ-OGR-00022070
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