Deferred Prosecution/Misdemeanor Request Memorandum

Deferred Prosecution/Misdemeanor Request Memorandum United States v. Tova Noel, 19 Cr. 830 (AD' AUSAs: - Federal Bureau of Investigation Agent: - Department of Justice, Office of the Inspector General Defendant: Tova Noel Age: • al Noel graduated from high school in 2005 at the age of 16. At age 18, she began taking classes at the Borough of Manhattan Education: Community College. She enlisted in the Army National Guard in 2008 and in 2012 was deployed to Kuwait for active duty in support of Operation Enduring Freedom. During her military service, Noel took courses at ASA College in New York City and earned an Prior to charging this case, we gave defense counsel for Noel an opportunity to meet with the case team, unit supervisors, and the United States Attorney. During the meeting, defense counsel urged a declination or deferred prosecution, but did not raise the majority of the arguments set forth in the deferred prosecution request (the "Request"). The defendant di