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This legal document provides background on the criminal case against correctional officers Mr. Thomas and Noel, who are charged with conspiracy and creating false records. The charges stem from an investigation that began after the alleged suicide of Jeffrey Epstein on August 10, 2019, at the Metropolitan Correctional Center, where the defendants allegedly failed to conduct required prisoner counts and falsified logs to cover it up. The document also outlines the procedural history of discovery requests made by defendant Thomas, which were denied by the government.