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ea Johnson noted in her October 28, 2009 Omnibus Order (DE #377), "[w]hile the scope of discovery is broad, it is not without limits. Washington v. Brown & Williamson Tobacco, 959 F.2d 1566, 1570 (11th Cir. 1992). . .. Cou1is have long held that ' [ w]hile the standard of relevancy [in discovery] is a liberal one, it is
the information requested is neither relevant F to any pending claim or defense nor will it lead to the discovery of admissible evidence," citing Tanchel v. Shoemaker, 928 So. 2d 440, 442 (Fla. 5th DCA 2006)). 13. As illustrated above, the questions are simply not germane to any pending '--.. claim
mited the scope of disclosure or discovery to certain matters." 9. While the scope of discovery is broad, it is not without limits. Washington v. Brown & Williamson Tobacco, 959 F.2d 1566, 1570 (11th Cir. 1992). Courts have long held that while the standard of relevancy in discovery is a liberal one, it is not so libera
7 of 11 infonnation requested is neither relevant to any pending claim or defense nor will it lead to the discovery of admissible evidence," citing Tanchel v. Shoemaker, 928 So. 2d 440, 442 (Fla. 5th DCA 2006)). 10. Accordingly, consistent with counsels' agreement noted above, a protective order shou
imited the scope of disclosure or discovery to certain matters." :_While the scope of discovery is broad, it is not without limits. Washington v. Brown & Williamson Tobacco, 959 F.2d 1566, 1570 (11th Cir. 1992). Courts have long held that while the standard of relevancy in discovery is a liberal one, it is not so libera
that the information requested is neither relevant to any pending claim or defense nor will it lead to the discovery of admissible evidence " chin Tanchel v. Shoemaker, 928 So. 2d 440, 442 (Fla. 5th DCA 2006)). 940. Accordingly, consistent with counsels' agreement noted above, a protective order shou
Entities connected to both Brown & Williamson Tobacco and Tanchel

Jeffrey Epstein
PERSONJane Doe
PERSONJack Goldberger
PERSONIsidro Manuel Garcia
PERSON
Paul Cassell
PERSON
Adam D. Horowitz
PERSONMichael J. Pike
PERSONMermelstein & Horowitz
ORGANIZATION
Bradley Edwards
PERSONRobert D. Critton
PERSON
Salt Lake City
LOCATIONStuart S. Mermelstein
PERSONShoemaker
PERSONSaini
PERSONBertine
PERSONJardines
PERSONZolin
PERSONScott Lewis'
PERSONStandard Brands, Inc.
ORGANIZATIONZumpe
ORGANIZATION