but whether the standard for pre-trial discovery of the documents is met. “The requirement of relevancy at the discovery stage is more loosely construed than that required at trial.” Brown v. Superior Court, 137 Ariz. 327, 332, 670 P.2d 725, 730 (1983). Discovery may extend to “any matter, not privileged, which is relevant to the subject matter involved in the pending action” and “reasonably calculated to lead to the discovery of admissible evidence.” Ariz. R. Civ. P. 26(b)(1). ¶ 26 There is a substantial disparity among the jurisdictions as to whether the confidentiality required by statute is a factor in considering discoverability or whether confidentiality is to be considered only by limiting the persons to whom the discoverable material can be disclosed. See Rios, 73 F.R.D. at 599 (<HOLDING>); Zaal, 602 A.2d at 1256 (holding by Maryland
holding that in the absence of public disclosure the court need not address whether relator was original source of the information holding that where an authorized disclosure is voluntarily made to a nonfederal party whether or not that disclosure is denominated confidential the government waives any claim that the information is exempt from disclosure under the deliberative process privilege holding by federal district court that before a court orders disclosure of educational records the party seeking disclosure is required to demonstrate a genuine need for the information that outweighs the privacy interest of the students holding that the disclosure is a public disclosure within the meaning of the fca if the the prior public disclosure  contained enough information to enable the government to pursue an investigation against the defendant holding that the government must provide the party seeking disclosure with a detailed index describing the documents the government claims are exempt from disclosure under foia