DOJ-OGR-00021920.pdf

Case 1:19-cr-00830-AT Document 1 Filed 11/19/19 Page 13 of 20 27. Epstein was transferred to a local hospital where he was declared dead shortly thereafter. The Office of the Chief Medical Examiner of the City of New York conducted an autopsy and determined that Epstein had committed suicide by hanging himself. STATUTORY ALLEGATIONS COUNT ONE (Conspiracy) The Grand Jury charges: 28. The Grand Jury incorporates the allegations contained in paragraphs 1 through 27 of this Indictment as though fully set forth herein. 29. In or about August 2019, in the Southern District of New York, TOVA NOEL and MICHAEL THOMAS, the defendants, knowingly conspired with each other to: a. Knowingly defraud the United States by impairing, obstructing, and defeating the lawful functions of a department or agency of the United States, to wit, the MCC's function to ensure the care, custody, and control of its inmate population. b. Knowingly make and use a false writing or document knowing the same to contain a materially false, fictitious, and fraudulent statement and entry with the intent to impede, obstruct, or influence the investigation or proper administration of any matter within the jurisdiction of any 13 DOJ-OGR-00021920