EFTA00028582.pdf

Type: pdf
Source set: data-set-8
Extracted text

U.S. Department of Justice 
United States Attorney 
Southern District of New York 
The SilWoJ. Mollo Building 
One Saint Andrew's Plaza 
New York New York 10007 
May 21, 2021 
BY ECF 
The Honorable Analisa Tones 
United States District 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"), which have been approved by Pretrial 
Services and are included for the Court's consideration.' After a thorough investigation, and based 
on the facts of this case and the personal circumstances of the defendants, the Government has 
determined that the interests of justice will best be served by deferring prosecution in this District. 
The proposed Agreements contemplate an additional six-month term of supervision by Pretrial 
Services and, in addition to the standard terms of pretrial supervision, the proposed Agreements 
include the additional salient terms: 
• 
The defendants will cooperate with a pending Department of Justice Office of Inspector 
General review by providing truthful information related to their employment by the 
Bureau of Prisons, including about the events and circumstances described in the 
Indictment; and 
• 
The defendants will complete 100 hours of community service, preferably in an area related 
to the criminal justice system. 
The defendants have consented to the entry of the Agreements and have also admitted that 
they "willfully and knowingly completed materially false count and round slips regarding required 
counts and rounds in the Special Housing Unit of the Metropolitan Correctional Center on August 
9, 2019 and August 10, 2019." 
The Government respectfully requests, with the consent of the defendants, through counsel, 
that the Court schedule a hearing date for entry of the Agreements. Having conferr…
Open in the interactive archive →