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te process because the litigants and the courts assume that the sole purpose of discovery is to assist trial preparation") (quoting United States v. Anderson, 799 F.2d 1438, 1441 (11'h Cir. 1986; emphasis in original). See also Anderson, 799 F.2d at 1441 ("Historically, discovery materials were not avail
es may be discoverable, negotiations are rarely admissible as evidence at trial. See, e.g., hi re MSTG, Inc., 675 F.3d 1337, 1348 (Fed. Cir. 2012); LaserDynamics, Inc. v. Quanta Computes; Inc., 694 F.3d 51, 78 (Fed. Cir. 2012) (reversing district court for admitting settlement agreement at trial); Apple, Inc. v. Sa
process because the litigants and the courts assume that the sole purpose of discovery is to assist trial preparation.") (quoting United States v. Anderson, 799 F.2d 1438, 1441 (1 1 th Cir. 1986; emphasis in original). See also Anderson, 799 F.2d at 1441 ("Historically, discovery materials were not ava
Inc., No. 2:05cvl W.D. ( N.C. Sept. 12, 2006), 2006 U.S. Dist. (continued...) -5- EFTA00605755 rarely admissible as evidence at trial, see, e.g, LaserDynamics, Inc. v. Quanta Computes; Inc., 694 F.3d 51, 78 (Fed. Cir. 2012) (reversing district court for admitting settlement agreement at trial); Apple, Inc. v. S
e process because the litigants and the courts assume that the sole purpose of discovery is to assist trial preparation@) (quoting United States v. Anderson, 799 F.2d 1438, 1441 (11t1 Cir. 1986; emphasis in original). See also Anderson, 799 F.2d at 1441 (AHistorically, discovery materials were not avail
mes may be discoverable, negotiations are rarely admissible as evidence at trial. See, e.g., In re MSTG, Inc, 675 F.3d 1337, 1348 (Fed. Cir. 2012); LaserDynamics, Inc. v. Quanta Computer, Inc, 694 F.3d 51, 78 (Fed. Cir. 2012) (reversing district court for admitting settlement agreement at trial); Apple, Inc. v. Sa
Entities connected to both Anderson and LaserDynamics, Inc.

Jeffrey Epstein
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Julie K. Brown
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Scarlett Johansson
PERSONLeon Black
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Prince Charles
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Bradley Edwards
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Kenneth Marra
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Alan Dershowitz
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Bradley Cooper
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Cynthia Nixon
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Wagner
PERSONHerman
PERSONRoy Black
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Apple
ORGANIZATIONthe Federal Rules of Civil
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Tillman
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