Must be in crreac method on pleading paper

Must be in CREAC method and use RELEVANT case law and Bluebook citation

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 allegations 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 (memorandum of points and authorities) in support of a motion to

compel production of documents (under Fed. R. Civ. P. 37) that will persuade the U.S. District

Court for the Central District of California that Young must produce the social media documents

requested.

Court rules impose a five-page limit on all briefs. In addition, court rules require that the

brief be word-processed and double-spaced and that current Bluebook citation form be followed.