DOJ-OGR-00021921.pdf

--- Page 1 --- **Document Header** * Case: 1:19-cr-00830-AT * Document 1 * Filed: 11/19/19 * Page: 14 of 20 **Text** department or agency of the United States, in violation of Title 18, United States Code, Section 1001 (a) (3). 30. In furtherance of the conspiracy and to effect the illegal objects thereof, TOVA NOEL and MICHAEL THOMAS, the defendants, committed the following overt acts, among others, in the Southern District of New York: a. On August 10, 2019, NOEL and THOMAS falsely certified, on an MCC count slip, that they had performed the 12 a.m. institutional count of the SHU, when they had not in fact done so. b. On August 10, 2019, NOEL and THOMAS falsely certified, on an MCC count slip, that they had performed the 3 a.m. institutional count of the SHU, when they had not in fact done so. c. On August 10, 2019, NOEL and THOMAS falsely certified, on an MCC count slip, that they had performed the 5 a.m. institutional count of the SHU at MCC, when they had not in fact done so. d. On August 10, 2019, NOEL falsely certified that she and THOMAS had performed a series of 30-minute rounds of the SHU between 12 a.m. and 6:30 a.m., when they had not in fact done so. (Title 18, United States Code, Section 371) **Footer** * DOJ-OGR-00021921