| From: |
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| Subject: Re: Submission on behalf a Date: The, 17 Mar 2020 20:16:20 +0000 |
| a— totally understand, and we appreciate you letting us know. That’s not a problem. |
| thanks, |
| On Mar 17, 2020, at 15:46 > wrote: |
| I am working on the new draft of this submission but it is going slower than I expected. has been in an emotionally and sychologically fragile state and because of the Coronavirus, we cannot get 1M the proper needs. We have suggestedM go back to Florida, so at leash can be in =home and not therapy which shut up in a stranger’s apartment here in NYC. Additionally, we attorneys have all shut our offices and are working at home, leading to a great loss in productivity. |
| So, realistically I am hoping to get you the new draft tomorrow afternoon. |
| Sent from my iPhone |
| On Mar 12, 2020, at 8:49 PM, > wrote: |
| Confirming receipt, thanks. |
| From: Sent: Thursday, March 12, 2020 20:40 To: |
| Cc: |
| Subject: Submission on behalf of |
| has shared a link to the following document: Submission on behalf of a’Unk nown nizaa |
Attached is a draft of the factual statement, just so that you can better understand the facts that we are presenting.¶
We feel that given 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.¶
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