EFTA00099413Set 9
2020-06-053p764w
Crim. P. 16, please provide the following information and
materials:
1. Defendant Noel's complete personnel and training file including, but not
limited to, the following:
a. Individual employee training ... performance logs completed at the end
of the 3", 6th, and 9th month of Defendant Noel's employment.
f. Completed and signed 6th month progress review.
g. BOP GLYNCO (FLETC ... Employee Code of Conduct, Code of Ethics, and
corresponding employee acknowledgement forms for Defendant Noel.
3. The MCC institutional familiarization training outline.
4. The MCC annual training outline
https://www.justice.gov/epstein/files/DataSet%209/EFTA00099413.pdf
EFTA00091641Set 9
2019-07-243p758w
Crim. P. 16, please provide the following information and
materials:
1. Defendant Noel's complete personnel and training file including, but not
limited to, the following:
a. Individual employee training ... performance logs completed at the end
of the 3rd, 6th, and 9th month of Defendant Noel's employment.
f. Completed and signed 6th month progress review.
g. BOP GLYNCO (FLETC ... Employee Code of Conduct, Code of Ethics, and
corresponding employee acknowledgement forms for Defendant Noel.
3. The MCC institutional familiarization training outline.
4. The MCC annual training outline
https://www.justice.gov/epstein/files/DataSet%209/EFTA00091641.pdf
EFTA00091633Set 9
2019-07-243p751w
Crim. P. 16, please provide the following information and
materials:
1. Defendant Noel's complete personnel and training file including, but not
limited to, the following:
a. Individual employee training ... performance logs completed at the end
of the 3", 6th, and 9th month of Defendant Noel's employment.
f. Completed and signed 6th month progress review.
g. BOP GLYNCO (FLETC ... Employee Code of Conduct, Code of Ethics, and
corresponding employee acknowledgement forms for Defendant Noel.
3. The MCC institutional familiarization training outline.
4. The MCC annual training outline
https://www.justice.gov/epstein/files/DataSet%209/EFTA00091633.pdf
EFTA00023768Set 8
2019-07-243p758w
Crim. P. 16, please provide the following information and
materials:
1. Defendant Noel's complete personnel and training file including, but not
limited to, the following:
a. Individual employee training ... performance logs completed at the end
of the 3", 6th, and 9th month of Defendant Noel's employment.
f. Completed and signed 6th month progress review.
g. BOP GLYNCO (FLETC ... Employee Code of Conduct, Code of Ethics, and
corresponding employee acknowledgement forms for Defendant Noel.
3. The MCC institutional familiarization training outline.
4. The MCC annual training outline
https://www.justice.gov/epstein/files/DataSet%208/EFTA00023768.pdf
EFTA00023756Set 8
2020-07-207p2,604w
discuss the basis for any such request at your convenience.
Request No. I. Defendant Noel's complete personnel and training file.
The Government has already produced the entirety ... Employee Code of Conduct, Code of Ethics, and
corresponding employee acknowledgement forms for Defendant Noel.
On or about June 24, 2020, the Government received from the BOP copies ... responsive to this request.
Request No. 16. All SHU Watch Call Logs completed during Defendant Noel's
assignment to the SHU post which began on June
https://www.justice.gov/epstein/files/DataSet%208/EFTA00023756.pdf
EFTA00079566Set 9
2019-08-103p846w
paragraph #17 of the indictment, which specific video and time stamp
makes clear that defendant Noel and Officer -1 did not perform the 4pm count;
18.As per paragraph ... indictment, which specific video and time stamp
shows that defendant Noel did not perform the 10pm count;
EFTA00079567
FOY & SEPLOWITZ LLC
ATTORNEYS AT LAW
PAGE 3
19.As per paragraph ... indictment, which video surveillance file contains
defendant Noel briefly walk up to and then walk back from the tier where
Epstein was housed;
20.As per paragraph #21 of the indictment
https://www.justice.gov/epstein/files/DataSet%209/EFTA00079566.pdf
EFTA00105918Set 9
2019-08-103p846w
paragraph #17 of the indictment, which specific video and time stamp
makes clear that defendant Noel and Officer -1 did not perform the 4pm count;
18.As per paragraph ... indictment, which specific video and time stamp
shows that defendant Noel did not perform the 10pm count;
EFTA00105919
FOY & SEPLOWITZ LLC
ATTORNEYS AT LAW
PAGE 3
19.As per paragraph ... indictment, which video surveillance file contains
defendant Noel briefly walk up to and then walk back from the tier where
Epstein was housed;
20.As per paragraph #21 of the indictment
https://www.justice.gov/epstein/files/DataSet%209/EFTA00105918.pdf
EFTA00087564Set 9
2019-08-103p839w
paragraph #17 of the indictment, which specific video and time stamp
makes clear that defendant Noel and Officer -1 did not perform the 4pm count;
18.As per paragraph ... indictment, which specific video and time stamp
shows that defendant Noel did not perform the 10pm count;
EFTA00087565
FOY & SEPLOWITZ LLC
ATTORNEYS AT LAW
PAGE 3
19. As per paragraph ... indictment, which video surveillance file contains
defendant Noel briefly walk up to and then walk back from the tier where
Epstein was housed;
20.As per paragraph #21 of the indictment
https://www.justice.gov/epstein/files/DataSet%209/EFTA00087564.pdf
EFTA00075609Set 9
2019-08-103p819w
paragraph #17 of the indictment, which specific video and time stamp
makes clear that defendant Noel and Officer -1 did not perform the 4pm count;
18.As per paragraph ... indictment, which specific video and time stamp
shows that defendant Noel did not perform the 10pm count;
EFTA00075610
FOY & SEPLOWITZ LLC
ATTORNEYS AT LAW
PAGE 3
19. As per paragraph ... indictment, which video surveillance file contains
defendant Noel briefly walk up to and then walk back from the tier where
Epstein was housed;
20.As per paragraph #21 of the indictment
https://www.justice.gov/epstein/files/DataSet%209/EFTA00075609.pdf
EFTA00076885Set 9
2019-08-103p845w
paragraph #17 of the indictment, which specific video and time stamp
makes clear that defendant Noel and Officer -1 did not perform the 4pm count;
18.As per paragraph ... indictment, which specific video and time stamp
shows that defendant Noel did not perform the 10pm count;
EFTA00076886
FOY & SEPLOWITZ LLC
ATTORNEYS AT LAW
PAGE 3
19. As per paragraph ... indictment, which video surveillance file contains
defendant Noel briefly walk up to and then walk back from the tier where
Epstein was housed;
20.As per paragraph #21 of the indictment
https://www.justice.gov/epstein/files/DataSet%209/EFTA00076885.pdf
EFTA01123882Set 9
2016-01-2016p3,865w
with an address of 13 &I4 Estate Gift &
Regenback, St. John. V.1.00830.
I I. Defendant Noel U. Boynes, Sr., at all times mentioned herein, was an individual
U.S. Virgin Islands
https://www.justice.gov/epstein/files/DataSet%209/EFTA01123882.pdf
EFTA00039416Set 9
2019-11-253p898w
Government refers you to the forensic examination of the
computers used by defendants Noel and Thomas during August 9 to 10, 2019, which were
previously produced in discovery (SDNY ... 8/10) 05:10:00 —
06:20:00 as to defendant Noel, and approximately (8/10) 00:35:00 — 01:15:00 and (8/10
https://www.justice.gov/epstein/files/DataSet%209/EFTA00039416.pdf
EFTA00021988Set 8
2019-11-253p896w
Government refers you to the forensic examination of the
computers used by defendants Noel and Thomas during August 9 to 10, 2019, which were
previously produced in discovery (SDNY ... 8/10) 05:10:00 —
06:20:00 as to defendant Noel, and approximately (8/10) 00:35:00 - 01:15:00 and (8/10
https://www.justice.gov/epstein/files/DataSet%208/EFTA00021988.pdf
EFTA00018948Set 8
2019-11-253p894w
Government refers you to the forensic examination of the
computers used by defendants Noel and Thomas during August 9 to 10, 2019, which were
previously produced in discovery (SDNY ... 8/10) 05:10:00 —
06:20:00 as to defendant Noel, and approximately (8/10) 00:35:00 — 01:15:00 and (8/10
https://www.justice.gov/epstein/files/DataSet%208/EFTA00018948.pdf