RE: Submission on behalf of (Redacted)
Attached is a draft of the factual statement, just so that you can better understand the facts that we are presenting.
We feel that giver abuse, and given the fact that we see her basically as a cog in Epstein's wheel, acting entirely at his direction and doing what she did at a time that she herself was a very vulnerable victim, a non-pros would be the appropriate disposition. But we want to discuss this with you before we finalize this and make a submission.
Thanks Susan
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Can we talk tomorrow afternoon? I hope to get you another draft in the morning.
Susan R. Necheles
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We share with you the attached draft submission in anticipation of our call.
Thanks,
