Epstein Secrets

2 and 13); and Epstein’s medical records from Dr. Stephen Alexander (Request 16). Each of these categories of reques

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

from the date hereof to provide the discovery subject to these Requests. The last category of documents concern Epstein's medical records from Dr. Stephen Alexander (Request 16). Epstein raises several objections to this category of Requests from relevancy concerns to privilege claims. Because Plaintiff has fail

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

from the date hereof to provide the discovery subject to these Requests. The last category of documents concern Epstein's medical records from Dr. Stephen Alexander (Request 16). Epstein raises several objections to this category of Requests from relevancy concerns to privilege claims. Because Plaintiff has fail

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