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Case 1:19-cr-00830-AT Document 53 Filed 05/21/21 Page 1 of 2
U.S. Department of Justice
[Type text]
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew’s Plaza
New York, New York 10007
May 21, 2021
BY ECF
The Honorable Analisa Torres
United States District Judge
Southern District of New York
500 Pearl Street
New York, New York 10007
Re: United States v. Noel and Thomas, 19 Cr. 830 (AT)
Dear Judge Torres:
The Government submits this letter to inform the Court that the parties have entered into
deferred prosecution agreements (the “Agreements”), which have been approved by Pretrial
Services and are included for the Court’s consideration. 1 After a thorough investigation, and based
on the facts of this case and the personal circumstances of the defendants, the Government has
determined that the interests of justice will best be served by deferring prosecution in this District.
The proposed Agreements contemplate an additional six-month term of supervision by Pretrial
Services and, in addition to the standard terms of pretrial supervision, the proposed Agreements
include the additional salient terms:
• The defendants will cooperate with a pending Department of Justice Office of Inspector
General review by providing truthful information related to their employment by the
Bureau of Prisons, including about the events and circumstances described in the
Indictment; and
• The defendants will complete 100 hours of community service, preferably in an area related
to the
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