This document is page 10 of a federal indictment against correctional officers Tova Noel and Michael Thomas. It details allegations that on the night of August 9-10 (the night of Jeffrey Epstein's death), the officers failed to perform mandatory institutional counts at 12 a.m., 3 a.m., and 5 a.m. in the Special Housing Unit (SHU). Instead, they allegedly falsified count slips stating the checks had been performed, which the Control Center relied upon.
| Name | Role | Context |
|---|---|---|
| Jeffrey Epstein | Inmate |
Housed in the tier mentioned; subject of the custody supervision.
|
| Michael Thomas | Defendant / Correctional Officer |
Replaced Officer-2 at 12 a.m.; accused of falsifying count slips and failing to perform counts.
|
| Tova Noel | Defendant / Correctional Officer |
On duty in the SHU; accused of falsifying count slips and failing to perform counts.
|
| Officer-1 | Correctional Officer |
Shift ended at approximately 10 p.m.
|
| Officer-2 | Correctional Officer |
Replaced by Michael Thomas at approximately 12 a.m.
|
| Name | Type | Context |
|---|---|---|
| MCC |
Metropolitan Correctional Center (implied); source of internal video surveillance.
|
|
| SHU |
Special Housing Unit; location where defendants were on duty.
|
|
| Control Center |
Facility operations center that cleared the counts based on falsified slips.
|
|
| DOJ |
Department of Justice (indicated by Bates stamp DOJ-OGR).
|
| Location | Context |
|---|---|
|
Specific unit within the correctional facility where Epstein was housed.
|
|
|
Correctional facility housing the SHU.
|
"NOEL and THOMAS did not perform the 12 a.m. count."Source
"NOEL and THOMAS completed and signed a count slip for the 12 a.m. count that falsely stated that the institutional count had been performed."Source
"As confirmed by video from the MCC's internal video surveillance system, NOEL and THOMAS did not perform either the 3 a.m. or the 5 a.m. counts."Source
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