EPSTEIN
page 5 / 84 . OCR, unverified
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)
Case 1:19-cr-00830-AT Document 1 Filed 11/19/19 Page 15 of 20
COUNT TWO
(False Records -
p.m. Count)
The Grand Jury further charges:
31. The
Grand
Jury
incorporates
the
allegations
contained in paragraphs 1 through 27 of this Indictment as though
fully set forth herein.
32. On or about August 9, 2019, in the Southern District
of New York, TOVA NOEL, the defendant, willfully and knowingly did
make and use a false writing or document knowing the same to
c.ontain 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 created, signed, and
submitted to the MCC a materially false count slip indicating that
she had performed the 4 p.m. institutional count of the SHU, when
she had not in fact done so.
(Title 18, United States Code, Sections 1001 (a) (3) and 2)
COUNT THREE
(False Records -
p.m. Count)
The Grand Jury further charges:
33. The
Grand
Jury
incorporates
the
allegations
contained in paragraphs 1 through 27 of this Indictment as though
fully set forth herein.
Case 1:19-cr-00830-AT Document 1 Filed 11/19/19 Page 16 of 20
34. On or about August 9, 2019, in the Southern District
of New York, TOVA NOEL, the defendant, 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 created, signed, and
submitted to the MCC a materially false count slip indicating that
she had performed the 10 p.m. institutional count of the SHU, when
she had not in fact done so.
(Title 18, United States Code, Sections 1001 (a) (3) and 2)
COUNT FOUR
(False Records -
a.m. Count)
The Grand Jury further charges:
35. The
Grand
Jury
incorporates
the
allegations
contained in paragraphs 1 through 27 of this Indictment as though
fully set forth herein.
36. 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
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 l00l(a) (3) and 2)
COUNT FIVE
(False Records -
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
Case 1:19-cr-00830-AT Document 1 Filed 11/19/19 Page 18 of 20
performed the 3 a.m. institutional count of the SHU, when they had
not in fact done so.
(Title 18, United States Code, Sections l00l(a) (3) and 2)
COUNT SIX
(False Records -
a.m. Count)
The Grand Jury further charges:
39. The
Grand
Jury
incorporates
the
allegations
contained in paragraphs 1 through 27 of this Indictment as though
fully set forth herein.
40. 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