Seems decent. The on cast trigger is pretty good. I need to think a bit more about this one.
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Playing since 1994: Currently MAGS (HomeBrew), Pioneer, Pauper and Modern
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I think she is good. You can look into the 3 top card and take the best for the situation. Is better than just drawing a card. You are filling your graveyard and she has lifelink. I wouldn't play her as commander but she is quite good in the 99. If your play her in a tribal deck (angel or cleric) than the mana cost will most likely be reduced. She is quite good in limited, too. I don't think you want to play her in standard, tho.
Power level is pretty good, but most importantly she's not a gimmick Commander: she has lots of different nodes off of which to build, which is important when you're building for a singleton format with a constrained cardlist. Since Pauper EDH is currently my format, I really like this one.