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or may be in the case." Oppenheimer Fund, Inc. v. Sanders, 437 U.S. 340, 352 (1978). Discovery is not limi
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
hat 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
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
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
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
at 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 "discovery itse
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
at 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 "discovery itse
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 Bernie Sanders and Georgia-Pacific Corp.

Jeffrey Epstein
PERSON
Donald Trump
PERSON
George W. Bush
PERSON
United States
LOCATIONEmmy Taylor
PERSON
Scarlett Johansson
PERSON
Hunter Biden
PERSONJane Doe
PERSON
Kenneth Marra
PERSON
Palm Beach
LOCATIONFisher
PERSON
Jay Lefkowitz
PERSON
J. Robert Oppenheimer
PERSONOppenheimer Fund, Inc.
ORGANIZATIONChambers
PERSON
Rhodes
PERSONGoodwin
PERSON
Dunbar
PERSONHickman
PERSONRossbach
PERSON