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Case 1:19-cr-00830-AT Document 59 Filed 05/2 5 26sdecraW UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK United States of America v. Tova Noel, Defendant. TO: TOVA NOEL DOCUMENT ELECTRONICALLY FILED DOC #: DATE FILED: 5/25/2021 Deferred Prosecution Agreement 19 Cr. 830 (AT) On Nove
Page: EFTA00023087 →ent, in violation of 18 U.S.C. § 1001. However, after a thorough investigation, and based on the facts of this case and your personal circumstances, the U.S. Attorney's Office for the Southern District of New York ("USAO-SDNY") has determined that the interests of justice will best be served by deferring prosecution in thi
Page: EFTA00023087 →suicide (Mot. 6); and (iv) reports, statistics, and documents related to purported staffing issues, supervisory lapses, and the application of BOP Tova Noel did not file any pretrial motions, and has not joined in Thomas's pretrial motions. See Fed. R. Crim. P. 12(c)(3) ("If a party does not meet the dea
Page: EFTA00031268 →respects. STATEMENT OF FACTS I. The Indictment Indictment 19 Cr. 830 (AT) (the "Indictment") was filed on November 19, 2019, charging defendants Tova Noel and Michael Thomas in six counts: (i) conspiring to defraud the United States and to make or use a false writing or document, in violation of Title
Page: EFTA00031269 →Discussion As described above, the Government has produced Brady, Giglio, and Rule 16 material in the possession of the prosecutors and agents at the United States Attorney's Office, the FBI, and the DOJ-OIG who have worked on this investigation and prosecution. Thomas seeks materials that are not in the possession of the Unite
Page: EFTA00031286 →Field Office of the Federal Bureau of Investigation ("FBI"), announced today the unsealing of an indictment charging federal correctional officers TOVA NOEL and MICHAEL THOMAS with making false records and conspiring to make false records and to defraud the United States by impairing the lawful functions
Page: EFTA00017935 →ollow us on Twitter I SDNY website I YouTube Nicholas Biase EFTA00017937 --- PAGE BREAK --- Public Affairs United States Department of Justice U.S. Attorney's Office 'Southern District of New York 'Mobile: I Press Office: [ 1 ] As the introductory phrase signifies, the entirety of the text of the Indictment, an
Page: EFTA00017938 →suicide (Mot. 6); and (iv) reports, statistics, and documents related to purported staffing issues, supervisory lapses, and the application of BOP Tova Noel did not file any pretrial motions, and has not joined in Thomas's pretrial motions. See Fed. R. Crim. P. 12(c)(3) ("If a party does not meet the dea
Page: EFTA00027312 →Discussion As described above, the Government has produced Brady, Giglio, and Rule 16 material in the possession of the prosecutors and agents at the United States Attorney's Office, the FBI, and the DOJ-OIG who have worked on this investigation and prosecution. Thomas seeks materials that are not in the possession of the Unite
Page: EFTA00027330 →ly that the two prison officers responsible for the SHU area during the night of August 9 and early morning hours of August 10 — Michael Thomas and Tova Noel — did not conduct any of the required institutional "counts" at 12 a.m., 3 a.m., and 5 a.m., nor did they conduct most of the "rounds" they were re
Page: EFTA00029992 →eing handled by the Office's Public Corruption Unit, led by Co-Chiefs EFTA00029992 --- PAGE BREAK --- Visit of Attorney General William P. Barr United States Attorney's Office for the Southern District of New York October 10, 2019 Nine Trev Prosecution will be presenting on this important gang-violence prosecution, whic
Page: EFTA00029993 →Entities connected to both Tova Noel and U.S. Attorney's Office

Jeffrey Epstein
PERSONMichael Thomas
PERSON
Department of Justice
ORGANIZATION
Ghislaine Maxwell
PERSON
Prince Andrew
PERSONFederal Bureau of Prisons
ORGANIZATIONSpecial Housing Unit
ORGANIZATIONDistrict Court for the Southern District of New York
ORGANIZATION
Metropolitan Correctional Center
ORGANIZATIONFBI
ORGANIZATION
United States
LOCATION
Geoffrey S. Berman
PERSON
Julie K. Brown
PERSONJane Doe
PERSON
Donald Trump
PERSON
Bradley Edwards
PERSONSecond Circuit
ORGANIZATIONNicholas Tartaglione
PERSON
Michael Cohen
PERSONMartin Weinberg
PERSON