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of these materials is “inherent” in the case itself. The principle that defamatory material in a defamation case cannot be sealed is recognized in Carnegie v. Tedder, 698 So.2d 1310 (2d DCA 1997). Carnegie involved a claim and counterclaim between two parties (Carnegie and Tedder), one of whom alleged t
lso containing discussion of Ms. Giuffre’s affidavit). The Court should be aware that within approximately two hours of this exchange, Ms. McCawley. (David Boies’ law partner) released a statement on his behalf, which stated that Dershowitz was misrepresenting what happened: “Because the discussions that Mr. Bo
s’ law partner) released a statement on his behalf, which stated that Dershowitz was misrepresenting what happened: “Because the discussions that Mr. Boies had with Mr. Dershowitz were expressly privileged settlement discussions, Mr. Boies will not, at least at this time, describe what was actually sai
s to -~- to conceal the scope of -- of the -- of the operation. In addition to that, when I started to compare the Dave Rogers' flight logs with the David -- excuse me. I am going to get a drink. When I started to compare the -- oh, I'm sorry. I should be looking at the camera. When I started -- when
work product enjoys a nearly absolute immunity and can be discovered only in very rare and extraordinary circumstances." Cox v. Adm'r U.S. Steel & Carnegie, 17 F.3d 1386, 1422 (11th Cir. 1994). In the context of government attorneys, the "work-product privilege applies to . . . discussions between prose
ile, attorney typed notes, relevant pieces of grand jury materials, telephone records/flight records analysis charts, victim/witness photographs, DAVID records, NCICs, and related materials for persons identified as Jane Does #15, 16, 17, 18, 19, Past Employees, Misc. Witnesses Work product 6(e)
lf. The principle that defamatory material in a defamation case cannot be sealed is recognized in Carnegie v. Tedder, 698 So.2d 1310 (2d DCA 1997). Carnegie involved a claim and counterclaim between two parties (Carnegie and Tedder), one of whom alleged that disclosure of HOUSE_OVERSIGHT_015623 --- PAG
Page: HOUSE_OVERSIGHT_015624 →of these materials is “inherent” in the case itself. The principle that defamatory material in a defamation case cannot be sealed is recognized in Carnegie v. Tedder, 698 So.2d 1310 (2d DCA 1997). Carnegie involved a claim and counterclaim between two parties (Carnegie and Tedder), one of whom alleged t
Page: HOUSE_OVERSIGHT_015624 →lso containing discussion of Ms. Giuffre’s affidavit). The Court should be aware that within approximately two hours of this exchange, Ms. McCawley. (David Boies’ law partner) released a statement on his behalf, which stated that Dershowitz was misrepresenting what happened: “Because the discussions that Mr. Bo
Page: HOUSE_OVERSIGHT_015634 →s’ law partner) released a statement on his behalf, which stated that Dershowitz was misrepresenting what happened: “Because the discussions that Mr. Boies had with Mr. Dershowitz were expressly privileged settlement discussions, Mr. Boies will not, at least at this time, describe what was actually sai
Page: HOUSE_OVERSIGHT_015634 →Entities connected to both Carnegie and David Boies

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSONSigrid McCawley
PERSON
Bradley Edwards
PERSON
Prince Andrew
PERSON
Alan Dershowitz
PERSON
Donald Trump
PERSON
Virginia Giuffre
PERSON
George Mitchell
PERSON
United States
LOCATION
Paul Cassell
PERSON
Bill Clinton
PERSONthe Southern District
LOCATIONJane Doe
PERSONLeon Black
PERSON
George W. Bush
PERSON
Marc Rich
PERSON
Department of Justice
ORGANIZATION
Julie K. Brown
PERSONMaria Farmer
PERSON