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Case 1:19-cr-00830-AT Document65 Filed 01/03/22 Page2of3 satisfactory compliance with the terms of the agreement. The United States Pretrial Services Office has informed the Government that NOEL and THOMAS 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 prosequi be filed as to TOVA NOEL and MICHAEL THOMAS, the defendants, with respect to Indictment LL Nicolas Roos Assistant United States Attorney (212) 637-2421 19 Cr. 830 (AT). Dated: New York, New York December 13, 2021 DOJ-OGR- 00022148