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Case 1:19-cr-00830-AT Document1 Filed 11/19/19 Page 16 of 20 34. On or about August 9, 2019, in the Southern District of New York, TOVA NOEL, the defendant, willfully and knowingly did make and use a false writing or document knowing the same to contain a materially false, fictitious, and fraudulent statement and entry with the intent to impede, obstruct, or influence the investigation or proper administration of any matter within the jurisdiction of any department or agency of the United States, and did attempt to do the same, to wit, NOEL created, signed, and submitted to the MCC a materially false count slip indicating that she had performed the 10 p.m. institutional count of the SHU, when she had not in fact done so. (Title 18, United States Code, Sections 1001(a) (3) and 2) COUNT FOUR (False Records ~ 12 a.m. Count) The Grand Jury further charges: 35. The Grand Jury incorporates the allegations contained in paragraphs 1 through 27 of this Indictment as though fully set forth herein. 36. on or about August 10, 2019, in the Southern District of New York, TOVA NOFL and MICHAEL THOMAS, the defendants, willfully and knowingly did make and use a false writing or document knowing the same to contain a materially false, fictitious, and fraudulent statement and entry with the intent to impede, obstruct, or influence the investigation or proper 16 DOJ-OGR-00021923