ting the Government to comply with what you believe are your disclosure obligations. As an alternative, we are willing to apply under seal to Judge Tones for a Protective Order to preclude the disclosure. Our client is not a witness, and so this is not 3500 material, nor is it Rule 16 material. We do

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 Tones: The Government submits this letter to inform the Court that the parties have entered into deferred prosecution agreements (the "Agreements"), whic