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Foster’s family refused to waive the deceased man’s legal privilege and Hamilton declined to testify. served as Sexton’s psychotherapist for the last years of her life. Orne had tape recorded the sessions so that Sexton, who had a history of alcohol abuse and memory problems, could listen to them as she wished. Linda Gray Sexton, the poet’s daughter and executrix of her literary estate, granted permission, and Dr. Unlike the Simpson and Foster cases, the Sexton case involved approval of release of the audio records by a family member with full legal authority to grant permission.