Case 9:08-cv-80736-KAM Document 274 Entered on FLSD Docket 11/06/2014 Page 1 of 10 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA JANE DOE #1 and JANE DOE #2, Petitioners, vs. UNITED STATES, Respondent. RESPONDENT'S REPLY TO PETITIONERS' RESPONSE TO GOVERNMENT'S MOTION FOR LEAVE TO FILE RELEVANCE OBJECTIONS TO PETITIONERS' FIRST REQUEST FOR PRODUCTION OF DOCUMENTS Respondent, by and through its undersigned counsel, files its Reply to Petitioners' Response to Government's Motion for Leave to File Relevance Objections to Petitioners' First Request for Production of Documents, and states: I. A CATEGORICAL RELVANCE OBJECTION TO SEVERAL OF PETITIONERS' REQUESTS FOR PRODUCTION IS PERMITTED Petitioners argue that the government may not raise a relevance objection to their production requests since this case is in the discovery phase. .266 at 2-3. They are incorrect since the relevance objections raised to Request for Production Nos. I, 10, 16, 18, 19, and 25 are appropriate because petitioners seek categories of documents that fall outside the permitted scope of discovery in Fed.R.Civ.P. 26(b)(1). The scope of discovery permitted in Rule 26(b)(1) is broad, however, "[t]here is no presumption in the Federal Rules of Civil Procedure that a discovery request is relevant." Presbyterian Manors. Inc. v. Simplexgrinnel L.P. 2010 WL 3880027 at *7 (D.Kan. Sep. 10, 2010)(footnote omitted). Further, discovery should ordinarily be allowed "unless it is clear that the information sought can have no possible EFTA01138760