Case 1:19-u-00830-AT Document 1 Filed 11/19/19 Page 1 of 20

Case 1:19-u-00830-AT Document 1 Filed 11/19/19 Page 1 of 20 Junetrowifits UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA TOVA NOEL and MICHAEL THOMAS, Defendants. X INDICTMENT 109CRIM 830 INTRODUCTION 1. On or about August 10, 2019, 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 their watch in the MCC's 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 of the SHU. To conceal their failure to perform their duties, NOEL and THOMAS repeatedly signed false certifications attesting to having conducted multiple counts of inmates when, in truth and in fact, they never conducted such counts. As a result of those false statements, the MCC believed pri