Esl FOY & SEPLOWITZ
attorneys at law

105 MAIN STREET
HACKENSACK, NJ 07601

30 WALL STREET
8TH FLOOR
NEW YORK, NY 10005
TEL: 212-709-8230

WWW.FOYSEPLOWITZ.COM

June 5, 2020

US Attorney's Office - SDNY
One Saint Andrew's Plaza
New York, NY 10007

# Re: US v. Tova Noel, et al
19 cr. 830

Dear Counsel:

Pursuant to Fed. R. 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 record.

	b. Complete Performance Log maintained in the Admin Lieutenant's Office or any other location in the MCC.

	c. Completed and signed Position Description Cover Sheet.

	d. Completed and signed yearly Employee Performance Appraisal.

	e. Completed and signed quarterly 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) training information and course outline for 2019.

2. The BOP and MCC 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 for 2018 and 2019.

5. A copy of the internal memorandums, letters, and/or emails addressing the death of Jeffrey Epstein including, but not limited to, the memorandums drafted by Employee Number 5, Employee Number 6, and Employee Number 13.

EFTA00024814

# Re: US v. Tova Noel, et al
19 cr. 830 (cont.)

FOY & SEPLOWITZ LLC
ATTORNEYS AT LAW

PAGE 2

6. The email referenced in Employee Number 7's witness statement that was sent to MCC employees regarding Jeffrey Epstein's need for a cellmate.

7. Psychology Services post-suicide watch report drafted by Employee Number 12 on July 24, 2019.

8. A copy of the memorandum sent by Employee Number 22 to the evening watch officers stating that Jeffrey Epstein needed a cellmate.

9. The BOP and MCC policy on cellmates and local Institutional Supplement on Special Housing Unit Regulations, including Institutional Supplement/Program Statement Number P.S. NYM 5270.10.

10. The BOP and MCC policy on SHU quarterly training.

11. The Inmate Accountability Institutional Supplement/Program Statement, Number I.S. NYM 5511.08, referenced in bates number SDNY_0005392.

12. The Security Inspections Institutional Supplement/Program Statement, Number I.S. NYM 5500.13, referenced in bates number SDNY_0005392.

13. An unredacted copy of SDNY_7551.

14. An unredacted copy of SDNY_883.

15. SHU Watch Call Logs from August 9, 2019 and August 10, 2019.

16. All SHU Watch Call Logs completed during Defendant Noel's assignment to the SHU post which began on June 26, 2019.

# Re: US v. Tova Noel, et al
19 cr. 830 (cont.)

17. All SHU Control Center Logs completed during Defendant Noel's assignment to the SHU post which began on June 26, 2019.

18. All SHU Operations Lieutenant Log Books completed during Defendant Noel's assignment to the SHU post which began on June 26, 2019.

19. All SHU TRUSCOPE Log Books completed during Defendant Noel's assignment to the SHU post which began on June 26, 2019.

20. All High Risk Lists reviewed during weekly SHU meetings during Defendant Noel's assignment to the SHU post which began on June 26, 2019.

21. All SHU reports and SRO reviews completed by the SHU Lieutenant during Defendant Noel's assignment to the SHU post which began on June 26, 2019.

22. A copy of the BOP Master Agreement.

23. All surveillance camera records, logs, and orders since June 26, 2019, including, but not limited to, warden, captain, lieutenant, and/or supervisory personnel records of broken or malfunctioning surveillance cameras.

24. All records and logs completed by the warden, lieutenant, and/or supervisory personnel in relation to the monitoring of counts and rounds.

25. All facility maintenance logs since June 26, 2019.

26. All incident reports (583 and 586 forms) drafted after Jeffrey Epstein's death.

EFTA00024815

# Re: US v. Tova Noel, et al
19 cr. 830 (cont.)

FOY & SEPLOWITZ LLC
ATTORNEYS AT LAW

PAGE 3

27. A copy of the After Action Internal Report completed after the death of Jeffrey Epstein and Board of Inquiry Report.

28. A copy of the Suicide Reconstruction Report

29. All MCC Correctional Services, Operational Reviews, and Program Reviews relating to the SHU and completed during Defendant Noel's employment at the MCC which began on June 24, 2018.

30. Who is the author of the 4Chan message produced as bates number SDNY_00006978?

31. All internal and external investigation records related to the suicide of Kenneth Houck at the MDC, death of inmate Jamel Floyd at the MDC, and smuggling of a firearm into the MCC.

If you have any questions or concerns about the foregoing, please give me a call. Thank you for your thoughtful consideration.

Sincerely,

FOY & SEPLOWITZ LLC

Jason E. Foy

JASON E. FOY

CC: Tova Noel

EFTA00024816