Case 1:19-cr-00830-AT Document 65 Filed 0 ELECTRONICALLY FILED UNITED STATES DISTRICT COURT DOC #: SOUTHERN DISTRICT OF NEW YORK DATE FILED: 1/3/2022 -~- ee re ee ee ee eee HK L NS UNITED STATES OF AMERICA 2 NOLLE PROSEQUI -v.- 2 19 Cr. 830 (AT) TOVA NOEL and MICHAEL THOMAS, Defendants. - - - - - - - - — -— - - - - = x 1. The filing of this nolle prosequi will dispose of this case with respect to TOVA NOEL and MICHAEL THOMAS, the defendants. 2. On or about November 19, 2019, a grand jury sitting in this District returned Indictment 19 Cr. 830 (AT), which charged TOVA NOEL and MICHAEL THOMAS, the defendants, with committing offenses against the United States, to wit, conspiring to knowingly defraud the United States and to knowingly make and use a false writing or document, in violation of 18 U.S.C. § 371, and knowingly making and using a false writing or document, in violation of 18 U.S.C. § 1001. 3. On or about May 20, 2021, TOVA NOEL and MICHAEL THOMAS, the defendants, entered into deferred prosecution agreements with the Government. Under the agreements, prosecution was deferred for a period of six months during the term of NOEL’s and THOMAS’s good behavior, completion of community service, and EFTA00009791

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Case 1:19-cr-00830-AT Document65 Filed 01/03/22 Page 2 of 3 satisfactory compliance with the terms of the agreement. The United States Pretrial Services Office has informed the Government that NOEL and THOMAS have complied with the terms of the agreement during the period of deferral, which expired on November 20, 2021. 4. In light of the foregoing, the Government recommends that an order of nolle prosequi be filed as to TOVA NOEL and MICHAEL THOMAS, the defendants, with respect to Indictment 19 Cr. 830 (AT). Nicolas Roos Assistant United States Attorney (212) 637-2421 Dated: New York, New York December 13, 2021 EFTA00009792

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Case 1:19-cr-00830-AT Document65 Filed 01/03/22 Page 3 of 3 Upon the foregoing recommendation, I hereby direct, with leave of the Court, that an order of nolle prosequi be filed as to defendants TOVA NOEL and MICHAEL THOMAS with respect to Indictment 19 Cr. 830 (AT). ed States Attorney Southern District of New York Dated: New York, New York December 13, 2021 SO ORDERED. Go Dated: January 3, 2022 ANALISA TORRES New York, New York United States District Judge EFTA00009793