Our client, Michael Carlsen, was sued one year ago by Lindsey Young for damages arising out of a car accident allegedly caused by Carlsen's negligent and reckless driving. Young has alleged that she has suffered great pain and injury and was unable to work for nine months.

During discovery, we requested that Young produce various documents, including all postings and photos posted by her to her Twitter and Facebook accounts relating to physical activities engaged in by Young that would be inconsistent with her claims concerning the nature and extent of her injuries.

Specifically, after another witness testified during a deposition as to the existence of photos, tweets, and posts on social media showing Young after the accident, we requested the production of any materials on Twitter or Facebook showing or discussing Young hiking in Europe, dancing, or riding a motorcycle during the nine months after the accident.

Young refused to produce the documents requested and has claimed that such would be a violation of her right to privacy and is a "fishing expedition" based on Carlsen's mere hope of discovering relevant information.

Please prepare a brief (or memorandum of law) in support of a motion to compel production of documents (under Anywhere Ct. R. Civ. P. 37) that will persuade the Anywhere Circuit Court in the Anywhere State that Young must produce the social media documents requested.

Our state has no cases or statutes regarding the issue of production of social media evidence. Therefore, do not restrict your research to the law of any one jurisdiction. By way of background, Anywhere's court rules are identical to those found in the Federal Rules of Civil Procedure.

Court rules impose an eight-page limit on all briefs. In addition, court rules require that the brief be word-processed and double-spaced and that current Bluebook or ALWD citation form be followed. There are no other court rules relating to citation form.