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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
0119-KAM Document 242 Entered on FLSD Docket 08/04/2009 Page 14 of 22 unreasonable or otherwise unduly burdensome."); Dunkin Donuts, Inc. v. Mary's Donuts, Inc., 2001 WL 34079319 (S.D. Fla. 2001)("the burden of showing that the requested information is not relevant to the issues in the case is on the party
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
9-KAM Document 242 Entered on FLSD Docket 08/04/2009 Page 14 of 22 unreasonable or otherwise unduly burdensome."); Dunkin Donuts, Inc. v. Mary's Donuts, Inc., 2001 WL 34079319 (S.D. Fla. 2001)("the burden of showing that the requested information is not relevant to the issues in the case is on the party
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
onstrate specifically how the objected-to information is unnecessary, unreasonable or otherwise unduly burdensome."); Dunkin Donuts, Inc. v. Mary's Donuts, Inc., 2001 U.S. Dist. LEXIS 25205, 2001 WL 34079319 (S.D. Fla. 2001)("the burden of showing that the requested information is not relevant to the issues
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
onstrate specifically how the objected-to information is unnecessary, unreasonable or otherwise unduly burdensome."); Dunkin Donuts, Inc. v. Mary's Donuts, Inc., 2001 U.S. Dist. LEXIS 25205, 2001 WL 34079319 (S.D. Fla. 2001)("the burden of showing that the requested information is not relevant to the issues
Entities connected to both Oppenheimer Fund, Inc. and Donuts, Inc.

Jeffrey Epstein
PERSONJane Doe
PERSON
Bernie Sanders
PERSON
J. Robert Oppenheimer
PERSONHickman
PERSONEmmy Taylor
PERSON
Kenneth Marra
PERSONRossbach
PERSON
Dunbar
PERSON
United States
LOCATIONCoker
PERSONHubbell
PERSONDuke & Co.
ORGANIZATIONCanal Authority
ORGANIZATIONJack Goldberger
PERSONPanola Land Buyers
ORGANIZATIONDunkin Donuts
PERSONGeorgia-Pacific Corp.
ORGANIZATION
Jay Lefkowitz
PERSONFarnsworth v. Proctor
PERSON