t ----

t ---- ol FOY& SEPLOWITZE HI -Ima t t o r n e y s a t l aw 105 MAIN STREET HACKENSACK. NJ 07601 US Attorney's Office- SDNY One St. Andrew's Plaza New York, New York 10007 WWW.FOYSEPLOWITZCOM February 26, 2021 Re: USA v. Tova Noel Indictment 19 cr 830 (AT) Application for Deferred Prosecution Dear Counsel: INTRODUCTION 30 WALL STREET 8TH FLOOR NEW YORK. NY 10005 Please accept this submission as Ms. Tova Noel's formal application in support of her request for a deferred prosecution agreement. For the reasons set forth herein, I submit that a deferred prosecution agreement is appropriate and consistent with the principles of federal prosecution as set forth in Title 9 of the Department of Justice Manual. DOJ Manual, Title 9: Criminal, 9-27.000, et al. Deferred prosecution is a fair and just resolution of this matter and will satisfy the relevant goals of the criminal justice system. After your review and the review of the U.S. Attorney's committee considering th