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d supporting Zinoview's Motion for Protective Order. The court found that an order completely prohibiting the deposition from going forward is rare, Salter v. Upiohn co., 593 F.2d 649, 651 (5th Cir. 1979), and that Zinoview's conclusory affidavit in which he denies knowledge of the facts giving rise to
2 F.R.D. 685 (S.D. Fla. 2007). See Hickman v. Taylor, 329 U.S. 495, 507-08 (1947); Oppenheimer Fund, Inc. v. Sanders, 437 U.S. 340, 351 (1978). In Oppenheimer, the Supreme Court discussed the concept of relevance in relation to Fed. R. Civ. P. 26(b) and noted that: The key phrase in this definition - "rel
oke, with the benefit of hindsight, about Jeffrey 4 Epstein and others like him from her office in Madison, Wisconsin. | _ “Consider a car,” says Dr. Salter. “There’s a motor, and there "are brakes. We all have sexual impulses we don’t think it would bea good idea to act on. Most of us have good control o
Page: HOUSE_OVERSIGHT_022035 →cording to Mark Oppenhe _ and followed his career for fi ; by selling rare books and p: Academic connections. A number of these trans. “Wwsuits,” Oppenheimer wor =a HOUSE_OVERSIGHT_022039 --- PAGE BREAK --- 2ATTERSON ., artificial intelligence, systems of d other topics. get-togethers like this for y
Page: HOUSE_OVERSIGHT_022040 →vered dozens of lawsuits he'd been involved in. In 2007, Seckel settled a libel lawsuit against a man who'd edited his Wiki- pedia page. Years later, Oppenheimer spoke with Seckel’s lawyer, Nicholas Hornberger. “Hornberger confirmed that he'd reached a settlement for the case, a favorable one,” the journalist
Page: HOUSE_OVERSIGHT_022042 →e spoke, with the benefit of hindsight, about Jeffrey _ Epstein and others like him from her office in Madison, Wisconsin. “Consider a car,” says Dr. Salter. “There’s a motor, and there "are brakes. We all have sexual impulses we don’t think it would be a good idea to act on. Most of us have good control
Page: HOUSE_OVERSIGHT_022124 →rming, erudite, humorous,” one of Seckel’s marks told the reporter. “I lent him $75,000. When the time came to pay it back he didn’t want to do it.” Oppenheimer found several people whom Seckel had stiffed and uncovered dozens of lawsuits he’d been involved in. In 2007, Seckel settled a libel lawsuit against
Page: HOUSE_OVERSIGHT_022131 →s. aves of the ocean. : ymantic, generous gestures that Jee o ‘A . q number of these transactions resulted in accusations and aw Ui ” . . 4 ts," Oppenheimer would write. “In speaking to former HOUSE_OVERSIGHT_022130 --- PAGE BREAK --- JAMES PATTERSON Seckel acquaintances, I kept hearing variations on
Page: HOUSE_OVERSIGHT_022131 →Entities connected to both Salter and J. Robert Oppenheimer

Jeffrey Epstein
PERSON
George W. Bush
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Justin Trudeau
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Julie K. Brown
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Donald Trump
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Prince Andrew
PERSONLeon Black
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Marc Rich
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Bill Clinton
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Barack Obama
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Michael Cohen
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William Barr
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Alexander Acosta
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Colorado
LOCATIONRubin
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Hillary Clinton
PERSONColeman
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Steven Mnuchin
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Aguilar
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Audrey Strauss
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