Motion To Compel Facebook Information

MOTION TO COMPEL/PROTECT FACEBOOK INFORMATION

STATE OF ________________

IN THE _________ COURT FOR THE COUNTY OF ______________

PLAINTIFF Case No. _____________

Plaintiff,

v.

MR. DEFENDANT, MRS. DEFENDANT,

DEFENDANT INSURANCE CORPORATION,

and DEFENDANT 4,

Defendants.

PLAINTIFF’S RESPONSE TO DEFENDANT 4’S MOTION TO COMPEL FACEBOOK INFORMATION

NOW COMES Plaintiff, by and through her attorneys, the Law Offices of Michael J. Morse, P.C., and for her Response to Defendant Indemnity & Liability Company’s Motion to Compel Facebook Information, hereby states the following:

Admitted.

Admitted, but denied in its implication.

Denied as stated. Plaintiff did testify regarding the content of her Facebook page; however, providing Defendant unfettered access will invade the privacy of the Plaintiff and others.

Neither admitted nor denied.

Admitted but denied in its implication. This information is a violation of both Plaintiff and other “Friends” privacy concerns.

Neither admitted nor denied.

Denied as stated. To the extent that Plaintiff’s Facebook information is more probative than prejudicial, Plaintiff requests a limiting instruction. Defendant must not be able to conduct an extensive fishing expedition into her personal Facebook account.

Neither admitted nor denied.

Neither admitted nor denied. However, recently Judge __________ issued an order stating that a person’s Facebook information is generally deemed private and not discoverable.

WHEREFORE, Plaintiff respectfully requests that this Honorable Court DENY Defendant’s Motion in its entirety and award costs and attorney fees so wrongfully incurred for having to respond to this motion. Alternatively, if the Court agrees to allow some access to the Plaintiff’s Facebook page, this access must be limited by Order of the Court to protect the privacy of all parties and individuals posting on Plaintiff’s Facebook page.

Respectfully submitted,

LAW OFFICES OF MICHAEL J. MORSE, P.C.

Attorneys for Plaintiff

_____________________________________

[Name]

[Address]

[Phone number]

Dated:

STATE OF _____________________

IN THE _______________ COURT FOR THE COUNTY OF _____________

PLAINTIFF Case No. _____________

Plaintiff,

v.

MR. DEFENDANT, MRS. DEFENDANT,

DEFENDANT INSURANCE CORPORATION,

and DEFENDANT 4,

Defendants.

BRIEF IN SUPPORT OF PLAINTIFF’S RESPONSE TO DEFENDANT 4’S MOTION TO COMPEL FACEBOOK INFORMATION

This lawsuit for No-Fault benefits and...