DOJ-OGR-00021924.pdf

Case 1:19-cr-00830-AT Document 1 Filed 11/19/19 Page 17 of 20 administration of any matter within the jurisdiction of any department or agency of the United States, and did attempt to do the same, to wit, NOEL and THOMAS created, signed, and submitted to the MCC a materially false count slip indicating that they had performed the 12 a.m. institutional count of the SHU, when they had not in fact done so. (Title 18, United States Code, Sections 1001(a)(3) and 2) COUNT FIVE (False Records - 3 a.m. Count) The Grand Jury further charges: 37. The Grand Jury incorporates the allegations contained in paragraphs 1 through 27 of this Indictment as though fully set forth herein. 38. On or about August 10, 2019, in the Southern District of New York, TOVA NOEL and MICHAEL THOMAS, the defendants, willfully and knowingly did 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 department or agency of the United States, and did attempt to do the same, to wit, NOEL and THOMAS created, signed, and submitted to the MCC a materially false count slip indicating that they had 17 DOJ-OGR-00021924