Case 1:19-cr-00830-AT Document 1 Filed 11/19/19 Page 1 of 20 aroseItIPAIS ORIGINAL UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x INDICTMENT UNITED STATES OF AMERICA §ORBI 830 TOVA NOEL and MICHAEL Defendants. X INTRODUCTION , 1. On or about August 10, 2019, TOVA NOEL and MICHAEL the defendants, in dereliction officers the Metropolitan correctional at of their duties as 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 sat at their desk, browsed the internet, and moved around the common area of the SHU. duties, NOEL and To conceal their failure to perform their 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 prisoners in the SHU were being regularly monitored and accounted for when, in fact, as a result of the defendants' conduct, no correctional officer conducted any count or round of the SHU from approximately 10:30 EFTA02845736