In your view is the so-called “Kovel Agreement” discoverable insofar as it establishes an indispensable element of the privilege claim under the Kovel Rule, a claim the proponent has the burden of proving?

Thanks.

The evidence contradicting Zionist claims concerning the reasons for Palestinian flight comes from a Zionist document outlining the result of their expulsion plans. The document is a report dated 30 June 1948, written by the Israeli Defense Forces Intelligence Branch for the Israeli prime minister. The document was uncovered in the Hashomer Hatza'ir Archive by an Israeli researcher Benny Morris. The report states that the Palestinian exodus was the result, primarily of three reasons:
-Direct, hostile Jewish operations against Arab settlements.
-The effect of hostile operations on nearby Arab settlements.
-Operations of Zionist terrorist groups such as Irgun

In 1961 the Irish journalist Erskine Childers examined the American and the British radio-monitoring records for all of 1948 after Israel failed to provide any evidence to support their claims. Childers found that: " there was not a single order or appeal, oor suggestion about evacuation from any Arab radio station inside or outside Palestine in 1948. There is repeated monitored record of Arab appeals, even flat orders, to the civilians of Palestine to stay put" Childers also found considerable evidence that Zionist radio stations had been broadcasting in Arabic in 1948 urging Palestinians to leave their homes.

According to Harry Levin, a British Zionist: "Haganah broadcasting to civilian Arabs urging them to leave the district before 5:15 A.M. “Take pity on you wives and children and get out of this blood bath. . . . Get out by the Jericho road, that is still open to you. If you stay you invite disaster.”
(Palestine and Israel: a challenge to justice – John B. Quigley p 82)

Contrary to the Zionist claim, the Arab Higher committee did not issue orders for the Palestinians to leave "to make room for Arab armies". On record is a letter dated 8 March 1948 from the Arab Higher Committee which specifically asks the Arab governments to cooperate in preventing Palestinians from leaving the country.
(Robert John and Sami Hadawi, the Palestine Diary, PLO Research center – 1970)