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Case 1:19-cr-00830-AT Document1 Filed 11/19/19 Page 7 of 20 observation, until July 30, 2019. Psychological observation is less restrictive than suicide watch, but inmates are still housed in the hospital wing of the MCC and watched twenty-four hours a day. 13. On July 30, 2019, Epstein was transferred back to the SHU, and, at the direction of the MCC’s psychological staff, was required to have an assigned cellmate. Rpstein was also assigned to the cell closest to the correctional officers’ desk in the common area of the SHU, which was approximately fifteen feet from the cell. Conducting the required institutional counts and thirty-minute rounds in the SHU were also part of the MCC’ s procedures for ensuring the safety of inmates, including Epstein. EVENTS OF AUGUST 9-10, 2019 14. On August 9, 2019, Epstein’s cellmate was transferred out of the MCC in a routine, pre-arranged transfer at approximately 8 a.m. Despite the MCC’s psychological staff's direction that Epstein have a ceilmate, no new cellmate was assigned to Epstein’s cell. 15. TOVA NOEL, the defendant, was one of the assigned officers on duty in the SHU from 4 p.m. on August 9, 2019 to 8 a.m. on August 10. From 4 p.m. to 12 a.m., two other officers were on duty with NOFL in the SHU: one officer was assigned to work from 2 p.m. to 10 p.m. (“Officer-1”), and one officer was DOJ-OGR-00021914