where he helped craft one of the most successful and
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called ""carried interest."" These profits are currently treated as capital gains and
including Mr. Rubenstein and founders of other large buyout firms
the defendant came out and said she was lying
and some of that abuse did occur when she was
and we say that that's not what's at issue
just that she was there. And they are seeking to
and reputation to show the truthfulness of that
and we have a few points there to raise. I mean
Clinton and whether or not he was on an island
' when we never got to examine him under oath and
hearsay statements and newspaper articles about
so we can get through argument and then have them
and neither does it tend to prove or disprove that
is inadmissible and a defamation action where the