Epstein Secrets

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 define and c

in the shadow zones of relevancy and to explore matter which does not presently appear germane on the theory that it might conceivably become so.’ ” Food Lion, Inc. v. United Food & Commercial Workers Intern. Union, 103 F.3d 1007, 1012-13 (C.A. D.C. 1997)(quoting Broadway and Ninety Sixth Street Realty Co. v. Loe

nt discovery stage. See Oppenheimer Fund, Inc. v. Sanders, 437 U.S. 340, 352 (1978). Accordingly, Epstein

e theory that it might conceivably become so.’ ” Food Lion, Inc. v. United Food & Commercial Workers Intern. Union

t discovery stage. See Oppenheimer Fund, Inc. I. Sanders, 437 U.S. 340, 352 (1978). Accordingly, Epstein

in the shadow zones of relevancy and to explore matter which does not presently appear germane on the theory that it might conceivably become so.'" Food Lion, Inc. I. United Food & Commercial Workers Intern. Union, 103 F.3d 1007, 1012-13 (C.A. D.C. 1997)(quoting Broadway and Ninety Sixth Street Realty Cot Loew

t discovery stage. See Oppenheimer Fund, Inc. v. Sanders, 437 U.S. 340. 352 (1978). Accordingly, Epstein

n the shadow zones of relevancy and to explore matter which does not presently appear germane on the theory that it might conceivably become so.' " Food Lion, Inc. v. United Food & Commercial Workers Intern. Union. 103 F.3d 1007, 1012-13 (C.A. D.C. 1997)(quoting Broadway and Ninety Sixth Street Realty Co. v. L