fred&edna
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That's because it's likely she has no history. But as discussed earlier on the thread, if she is convicted in this case she will then have a history of use of violence towards children under 12 and that will justify the DP. Sounds very legally iffy to me but I'm not an attorney.
MOO
Asking for the DP asserting as fact that she has prior convictions definitely seems "iffy". I'm not a lawyer, either, so maybe that's why it doesn't make sense to me.