DOJ-OGR-00021909.pdf

Case 1:19-cr-00830-AT Document 1 Filed 11/19/19 Page 2 of 20 p.m. on August 9 until approximately 6:30 a.m. on August 10, at which time, as alleged herein, NOEL and THOMAS discovered the body of an MCC inmate, Jeffrey Epstein, who had committed suicide overnight while unobserved. RELEVANT INDIVIDUALS AND ENTITIES 2. The MCC is a federal administrative detention facility located in Manhattan that is run by the Federal Bureau of Prisons ("BOP"). The MCC is one of several facilities used to house inmates who have been charged with federal crimes in the Southern District of New York and are awaiting trial. The MCC employs correctional officers, whose primary duty is to ensure the care, custody, and control of the inmate population of the MCC. 3. TOVA NOEL, the defendant, has been employed as a correctional officer at the MCC since approximately 2016. As of August 2019, NOEL's primary assignment was the SHU. On August 9, 2019, NOEL worked a regular shift from 4 p.m. to 12 a.m. in the SHU, and then worked an overtime shift from 12 a.m. to 8 a.m. on August 10, 2019, also in the SHU. NOEL had also worked a regular shift in the SHU the day before, August 8, 2019, from 12 p.m. to 8 p.m. 4. MICHAEL THOMAS, the defendant, has been employed as a correctional officer at the MCC since approximately 2007. Beginning in approximately 2013, THOMAS was assigned to work as a 2 DOJ-OGR-00021909