EFTA00087848.pdf
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From: "Kathleen E. Cassidy"
Cc: Susan Necheles
Subject: RE: Submission on behalf o'
Date: Tue, 24 Mar 2020 19:03:39 +0000
Attachments:
We share with you the attached draft submission in anticipation of our call.
Thanks,
From:
Sent: Tuesday, March 24, 2020 12:51 PM
To: Kathleen E. Cassidy
Cc: Susan Necheles
Susan Necheles
Subject: RE: Submission on behalf ofElli
That works for us, and thanks for sending the dial-in information. Talk with you then.
From: Kathleen E. Cassidy
Sent: Tuesday, March 24, 2020 10:30
To:
Cc: Susan Necheles
• Susan Necheles
Subject: Re: Submission on behalf of
Can we do 5:30?
Passcode
Sent from my iPhone
On Mar 24, 2020, at 10:14 AM,
Susan,
wrote:
We could talk anytime this afternoon between 12:00 and 2:00, if there's a time then that works? Or otherwise after
5:00. And if you're able to send a dial-in, that would be helpful, but let us know if not.
thanks,
IM•
EFTA00087848
From: Susan Necheles
Sent: Monday, March 23, 2020 21:28
To:
Cc: Susan Necheles
Kathleen E. Cassidy
Subject: Re: Submission on behalf
>
Can we talk tomorrow afternoon? I hope to get you another draft in the morning.
Susan R. Necheles
Sent from my iPhone
On Mar 23, 2020, at 4:20 PM
wrote:
Susan,
We wanted to follow up on the below —we understand these are very unusual times but we're continuing to move
ahead with our internal decision-making discussions, and it would be very helpful to be able to incorporate your
client's proposal (if anything) in that process. It will be of particular use given the civil lawsuit Ms
it is difficult for us to explain to our supervisors why she has been able to file a complaint but not
to make a submission to our office. Would it be possible to schedule a call for tomorrow to discuss status? And
separately we hope that you and your colleagues and families are weathering the current circumstances.
thanks,
From:
Sent: Tuesday, March 17, 2020 16:16
To: Susan Necheles
Cc: Susan Necheles
Kathleen E. Cassidy
Subject: Re: Submission on behalf ofil
Susan
totally understand, and we appreciate you letting us know. That's not a problem.
thanks,
On Mar 17, 2020, at 15:46, Susan Necheles
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 psychologically fragile state, and because offigLaronavirus, we cannot get her the proper
therapy which she needs. We have suggested she go back to
so at least she can be in her home and
not 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.
EFTA00087849
Susan R. Necheles
Sent from my iPhone
On Mar 12, 2020, at 8:49 PM,
wrote:
Confirming receipt, thanks.
From: Susan Necheles (via Google Docs)
Sent: Thursday, March 12, 2020 20:40
To:
Cc:
>
Subject: Submission on behalf of
has shared a link to the following document:
<-WRD178.jpg>I
Submission on behalf of
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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<-WRD178.jpgd
EFTA00087850
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Document Details
| Filename | EFTA00087848.pdf |
| File Size | 140.1 KB |
| OCR Confidence | 85.0% |
| Has Readable Text | Yes |
| Text Length | 3,829 characters |
| Indexed | 2026-02-11T10:30:53.322735 |