UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK

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UNITED STATES OF AMERICA NOLLE PROSEQUI

19 Cr. 830 (AT)

TOVA NOEL and MICHAELIIIIIII,

Defendants.

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1. The filing of this nolle prosequ{sup}`i` will dispose of this case with respect to TOVA NOEL and MICHAEL Ill.., 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 , 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 afalse writing or document, in violation of {sup}`18` U.S.C. § 1001.

3. On or about May 20, 2021, TOVA NOEL and MICHAEL , 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 good behavior, completion of community service, and

satisfactory compliance with the terms of the agreement. The United States Pretrial Services Office has informed the Government that NOEL and 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 prosequ{sup}`i` be filed as to TOVA NOEL and MICHAEL , 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

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 with respect to Indictment 19 Cr. 830 (AT).

Dated: New York, New York December 13, 2021

SO ORDERED:

Dated: New York, New York , 2021

illiams ed States Attorney Southern District of New York

HONORABLE ANALISA United States District Judge Southern District of New York