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bear on any issue that is or may be in the case." Oppenheimer Fund, Inc. v. Sanders, 437 U.S. 340, 352 (1978). Discovery
at 521; see also Hunter’s Ridge Golf Co. Inc. v. Georgia-Pacific Corp., 233 F.R.D. 678, 680 (M.D. Fla. 2006). Here, the
to encompass any matter that bears on, or that reasonably could lead to another matter that could bear on any issue that is or may be in the case." Oppenheimer Fund, Inc. v. Sanders, 437 U.S. 340, 352 (1978). Discovery is not limited to the issues raised by the pleadings because 'discovery itself is designed to help
en shifts to the moving party to show the information is relevant and necessary. Gober, 197 F.R.D. at 521; see also Hunter's Ridge Golf Co. Inc. v. Georgia-Pacific Corp., 233 F.R.D. 678, 680 (MD. Fla. 2006). Here, the information requested concerns Epstein's dates of travel, health care provider identification, and
to encompass any matter that bears on, or that reasonably could lead to another matter that could bear on any issue that is or may be in the case? Oppenheimer Fund, Inc. v. Sanders, 437 U.S. 340, 352 (1978). Discovery is not limited to the issues raised by the pleadings because "discovery itself is designed to help
en shifts to the moving party to show the information is relevant and necessary. Gober, 197 F.R.D. at 521; see also Hunter's Ridge Golf Co. Inc. v. Georgia-Pacific Corp., 233 F.R.D. 678, 680 (M.D. Fla. 2006). Here, the information requested concerns Epstein's dates of travel, health care provider identification, and
to encompass any matter that bears on, or that reasonably could lead to another matter that could bear on any issue that is or may be in the case." Oppenheimer Fund, Inc. v. Sanders, 437 U.S. 340, 352, 98 S. Ct. 2380, 57 L. Ed. 2d 253 (1978). Discovery is not limited to the issues raised by the pleadings because "dis
den shifts to the moving party to show the information is relevant and necessary. Gober, 197 F.R.D. at 521; see also Hunters Ridge Goff Co. Inc. v. Georgia-Pacific Corp., 233 F.R.D. 678, 680 (M.D. Fla. 2006). For internal use only For internal use only CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-00751
to encompass any matter that bears on, or that reasonably could lead to another matter that could bear on any issue that is or may be in the case." Oppenheimer Fund, Inc. v. Sanders, 437 U.S. 340, 352, 98 S. Ct. 2380, 57 L. Ed. 2d 253 (1978). Discovery is not limited to the issues raised by the pleadings because "dis
den shifts to the moving party to show the information is relevant and necessary. Gober, 197 F.R.D. at 521; see also Hunters Ridge Goff Co. Inc. v. Georgia-Pacific Corp., 233 F.R.D. 678, 680 (M.D. Fla. 2006). For internal use only For internal use only CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-00910
Entities connected to both Oppenheimer Fund, Inc. and Georgia-Pacific Corp.

Jeffrey Epstein
PERSON
Bernie Sanders
PERSON
J. Robert Oppenheimer
PERSONRossbach
PERSONEmmy Taylor
PERSONHickman
PERSONJane Doe
PERSON
Dunbar
PERSONCoker
PERSONDuke & Co.
ORGANIZATIONCanal Authority
ORGANIZATIONPanola Land Buyers
ORGANIZATION
Kenneth Marra
PERSONHubbell
PERSONF.R.D. 519
ORGANIZATIONFarnsworth v. Proctor
PERSONDonuts, Inc.
ORGANIZATIONF.R.D. 609
ORGANIZATIONGamble Co.
ORGANIZATIONDunkin Donuts
PERSON