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Case 1:19-cr-00830-AT Document 64 Filed 12/30/21 Page 1 of 3

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
------------- X

UNITED STATES OF AMERICA NOLLE PROSEQUI

-v. - 19 Cr. 830 (AT)

TOVA NOEL and
MICHAEL THOMAS,

Defendant s.

- - - - - X

1. The filing of this nolle prosequi will dispose of

this case with respect to TOVA NOEL and MICHAEL THOMAS, t he

defendant s.

2. On or about November 19, 2019, a grand jury sitting

in this District returned Indictmen t 19 Cr. 830 (AT), which charged

TOVA NOEL and MICHAEL THOMAS, the defendant s, with committin g

offenses against the United States, to wit, conspirin g 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 defendant s, entered into deferred prosecuti on

agreement s with the Governmen t. Under the agreement s, prosecuti on

was deferred for a period of six months during the term of NOEL's

and THOMAS's good behavior , completio n of community service , and
Case 1:19-cr-00830-AT Document 64 Filed 12/30/21 Page 2 of 3

satisfac tory complian ce with the terms of the agreeme nt. The United

States Pretria l Services Office has informed the Governm ent that

NOEL and THOMAS have complied with the terms of the agreeme nt

during the period of deferra l, which expired on Novembe r 20, 2021.

4. In light of the

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