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 3", 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. ## 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. - 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. ## 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 cc: Tova Noel