EFTA00089488Set 9
2021-04-0116p5,409w
Deferred Prosecution/Misdemeanor Request Memorandum
United States v. Tova Noel, 19 Cr. 830 (AD'
AUSAs:
— Federal Bureau of Investigation
Agent:
— Department of Justice, Office of the Inspector
General
Defendant: Tova Noel ... Noel graduated from high school in 2005 at the age of 16. At age
18, she began taking classes at the Borough of Manhattan
Education: Community College. She enlisted ... Kuwait for active duty in support
of Operation Enduring Freedom. During her military service,
Noel took courses at ASA College in New York City and earned an
Prior to charging
https://www.justice.gov/epstein/files/DataSet%209/EFTA00089488.pdf
EFTA00075382Set 9
2019-11-1955p11,931w
Assistant United States Attorney
from January 2011. I supervised the Noel prosecution directly in my prior role as Chief of the
Public Corruption Unit, and I play a supervisory role ... over both the Noel and Tartaglione
prosecutions in my current role as Counsel to the Acting United States Attorney.
2. I am familiar with the Freedom of Information Act requests ... Document 22 Filed 08/05/20 Page 2 of 13
America v. Noel, 19-CR-830 (Al), and United States of America v. Tartaglione, 16-CR-832
(KMK). True and correct copies
https://www.justice.gov/epstein/files/DataSet%209/EFTA00075382.pdf
EFTA00031025Set 8
2019-11-1955p11,904w
Assistant United States Attorney
from January 2011. I supervised the Noel prosecution directly in my prior role as Chief of the
Public Corruption Unit, and I play a supervisory role ... over both the Noel and Tartaglione
prosecutions in my current role as Counsel to the Acting United States Attorney.
2. I am familiar with the Freedom of Information Act requests ... Document 22 Filed 08/05/20 Page 2 of 13
America v. Noel, 19-CR-830 (Al), and United States of America v. Tartaglione, 16-CR-832
(KMK). True and correct copies
https://www.justice.gov/epstein/files/DataSet%208/EFTA00031025.pdf
EFTA00039908Set 9
2019-11-1955p11,794w
Document 22 Filed 08/05/20 Page 2 of 13
America v. Noel, 19-CR-830 (Al), and United States of America v. Tartaglione, 16-CR-832
(KMK). True and correct copies ... Indictment filed in Noel on November 19, 2019 (the
"Noel Indictment"), and the Superseding Indictment filed in Tartaglione on April 16, 2019 (the
"Tartaglione Indictment"), are attached hereto as Exhibits ... documents maintained in the
files of the USAO-SDNY, conversations with members of the Noel and Tartaglione prosecution
teams at the USAO-SDNY, public court filings, and conclusions made
https://www.justice.gov/epstein/files/DataSet%209/EFTA00039908.pdf
EFTA00089923Set 9
2019-08-1020p4,164w
STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
INDICTMENT
UNITED STATES OF AMERICA
TOVA NOEL and
109CRIM 830
MICHAEL THOMAS,
Defendants.
X
INTRODUCTION
1. On or about August ... TOVA NOEL and MICHAEL
THOMAS, the defendants, in dereliction of their duties as
correctional officers at the Metropolitan Correctional Center
("MCC"), repeatedly failed to perform mandated counts of prisoners
under ... Special Housing Unit ("SHU").
Instead, for substantial portions of their shifts, NOEL and THOMAS
sat at their desk, browsed the Internet, and moved around the
common area
https://www.justice.gov/epstein/files/DataSet%209/EFTA00089923.pdf
EFTA00126147Set 9
2019-08-1020p3,992w
COURT
SOUTHERN DISTRICT OF NEW YORK
INDICTMENT
UNITED STATES OF AMERICA
19 Cr.
TOVA NOEL and
MICHAEL THOMAS,
19 CRIM
Defendants.
X
INTRODUCTION
1. On or about August ... TOVA NOEL and MICHAEL
THOMAS, the defendants, in dereliction of their duties as
correctional officers at the Metropolitan Correctional Center
("MCC"), repeatedly failed to perform mandated counts of prisoners
under ... Special Housing Unit ("SHU").
Instead, for substantial portions of their shifts, NOEL and THOMAS
sat at their desk, browsed the internet, and moved around the
common area
https://www.justice.gov/epstein/files/DataSet%209/EFTA00126147.pdf
EFTA00126127Set 9
2019-08-1020p3,994w
COURT
SOUTHERN DISTRICT OF NEW YORK
INDICTMENT
UNITED STATES OF AMERICA
19 Cr.
TOVA NOEL and
MICHAEL THOMAS,
19 CRIM
Defendants.
X
INTRODUCTION
1. On or about August ... TOVA NOEL and MICHAEL
THOMAS, the defendants, in dereliction of their duties as
correctional officers at the Metropolitan Correctional Center
("MCC"), repeatedly failed to perform mandated counts of prisoners
under ... Special Housing Unit ("SHU").
Instead, for substantial portions of their shifts, NOEL and THOMAS
sat at their desk, browsed the internet, and moved around the
common area
https://www.justice.gov/epstein/files/DataSet%209/EFTA00126127.pdf
EFTA00164460Set 9
2019-08-1020p3,996w
COURT
SOUTHERN DISTRICT OF NEW YORK
INDICTMENT
UNITED STATES OF AMERICA
19 Cr.
TOVA NOEL and
MICHAEL THOMAS,
19 CRIM
Defendants.
X
INTRODUCTION
1. On or about August ... TOVA NOEL and MICHAEL
THOMAS, the defendants, in dereliction of their duties as
correctional officers at the Metropolitan Correctional Center
("MCC"), repeatedly failed to perform mandated counts of prisoners
under ... Special Housing Unit ("SHU").
Instead, for substantial portions of their shifts, NOEL and THOMAS
sat at their desk, browsed the internet, and moved around the
common area
https://www.justice.gov/epstein/files/DataSet%209/EFTA00164460.pdf
EFTA00164377Set 9
2019-08-1020p3,996w
COURT
SOUTHERN DISTRICT OF NEW YORK
INDICTMENT
UNITED STATES OF AMERICA
19 Cr.
TOVA NOEL and
MICHAEL THOMAS,
19 CRIM
Defendants.
X
INTRODUCTION
1. On or about August ... TOVA NOEL and MICHAEL
THOMAS, the defendants, in dereliction of their duties as
correctional officers at the Metropolitan Correctional Center
("MCC"), repeatedly failed to perform mandated counts of prisoners
under ... Special Housing Unit ("SHU").
Instead, for substantial portions of their shifts, NOEL and THOMAS
sat at their desk, browsed the internet, and moved around the
common area
https://www.justice.gov/epstein/files/DataSet%209/EFTA00164377.pdf
EFTA00009747Set 8
2019-08-1020p4,218w
STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
INDICTMENT
UNITED STATES OF AMERICA
TOVA NOEL and
MICHAEL THOMAS,
.096um 830
Defendants.
X
INTRODUCTION
1. On or about August ... TOVA NOEL and MICHAEL
THOMAS, the defendants, in dereliction of their duties as
correctional officers at the Metropolitan Correctional Center
("MCC"), repeatedly failed to perform mandated counts of prisoners
under ... Special Housing Unit ("SHU").
Instead, for substantial portions of their shifts, NOEL and THOMAS
sat at their desk, browsed the internet, and moved around the
common area
https://www.justice.gov/epstein/files/DataSet%208/EFTA00009747.pdf
EFTA00010968Set 8
2019-08-1020p3,994w
STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
INDICTMENT
UNITED STATES OF AMERICA
TOVA NOEL and
MICHAEL THOMAS,
Defendants.
X
The Grand Jury charges:
INTRODUCTION
1. On or about August ... TOVA NOEL and MICHAEL
THOMAS, the defendants, in dereliction of their duties as
correctional officers at the Metropolitan Correctional Center
("MCC"), repeatedly failed to perform mandated counts of prisoners
under ... Special Housing Unit ("SHU").
Instead, for substantial portions of their shifts, NOEL and THOMAS
sat at their desk, browsed the internet, and moved around the
common area
https://www.justice.gov/epstein/files/DataSet%208/EFTA00010968.pdf
EFTA00073596Set 9
2019-08-1020p4,198w
STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
INDICTMENT
UNITED STATES OF AMERICA
TOVA NOEL and
109CRIM 830
MICHAEL THOMAS,
Defendants.
X
INTRODUCTION
1. On or about August ... TOVA NOEL and MICHAEL
THOMAS, the defendants, in dereliction of their duties as
correctional officers at the Metropolitan Correctional Center
("MCC"), repeatedly failed to perform mandated counts of prisoners
under ... Special Housing Unit ("SHU").
Instead, for substantial portions of their shifts, NOEL and THOMAS
sat at their desk, browsed the Internet, and moved around the
common area
https://www.justice.gov/epstein/files/DataSet%209/EFTA00073596.pdf
EFTA00014985Set 8
2019-08-1018p3,574w
STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
INDICTMENT
UNITED STATES OF AMERICA
TOVA NOEL, and
MICHAEL THOMAS,
Defendants.
X
The Grand Jury charges:
INTRODUCTION
1. On or about August ... TOVA NOEL and MICHAEL
THOMAS, the defendants, while on duty as correctional officers at
the Manhattan Correctional Center ("MCC"), repeatedly chose not to
do mandated counts of prisoners under their ... special housing unit ("SHU"). Instead, for substantial portions
of their shifts, NOEL and THOMAS sat at their desk, slept, and
browsed the internet. To conceal the deliberate dereliction of
their
https://www.justice.gov/epstein/files/DataSet%208/EFTA00014985.pdf
EFTA00141250Set 9
2019-07-308p3,117w
walked off the tier.
said that he had a brief conversation with and
Noel before he departed the SHU. The video footage shows, at
approximately 6:53 p.m., escorted Epstein ... ended at 7:19 p.m. At
7:19 p.m., the video shows that Noel walked onto G tier and returned back to
the SHU desk area with what appeared ... phone in her hand.
o The OIG's interviews and investigation revealed that and Noel
did not conduct the 10 p.m. count inside the SHU on August
https://www.justice.gov/epstein/files/DataSet%209/EFTA00141250.pdf
EFTA00592858Set 9
2016-05-1141p13,275w
Narrows TURNER. JOSEPH WILLIAM Kilgarren Castle, Pembrokeshire 700,000 1.200,000 500.000
(Collateral) MALLORD
Noel Calb COROT, JEAN-BAPTISTE- Portrait of Mlle. Jeanne Farochon 1.000,000 1.500,000 500.000
CAMILLE ... Noel Calb MARDEN. BRICE Long Letter 1 1.000,000 1.500.000 500.000
AP Narrows GOYA. FRANCISCO DE The Bulls of Bordeaux: the set of four 715.000 1.200.000 485.000
Narrows DELACROIX. EUGENE ... Grand Canal with the 1.025,000 1.500,000 475.000
(Collateral) Rialto Bridge (verso)
Noel Calb SERRA, RICHARD Conrad 540,000 1.000.000 460.000
Narrows GRIS. JUAN Nature mode
https://www.justice.gov/epstein/files/DataSet%209/EFTA00592858.pdf
EFTA02731790Set 12
2019-11-140p2,890w
United States v. Tova Noel and
Michael Thomas
November 14, 2019
EFTA02731790
Overview ofInvestigation
• Interviewed more than 27 MCC employees and 16 inmates at MCC
• Reviewed hundreds of hours ... ensure the care, custody, and control of the inmate population of the MCC.
• TOVA NOEL, the defendant, has been employed as a correctional officer at the MCC since approximately ... 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
https://www.justice.gov/epstein/files/DataSet%2012/EFTA02731790.pdf
EFTA00039895Set 9
2019-11-1913p3,715w
Document 21 Filed 08/05/20 Page 2 of 13
America v. Noel, 19-CR-830 (Al), and United States of America v. Tartaglione, 16-CR-832
(KMK). True and correct copies ... Indictment filed in Noel on November 19, 2019 (the
"Noel Indictment"), and the Superseding Indictment filed in Tartaglione on April 16, 2019 (the
"Tartaglione Indictment"), are attached hereto as Exhibits ... documents maintained in the
files of the USAO-SDNY, conversations with members of the Noel and Tartaglione prosecution
teams at the USAO-SDNY, public court filings, and conclusions made
https://www.justice.gov/epstein/files/DataSet%209/EFTA00039895.pdf