1.24.2019

Privately Posted Dispositive Social Media Posts


Privately Posted Dispositive Social Media Posts are Discoverable 

pursuant to today’s order issued by 
SUPREME COURT, APPELLATE DIVISION, FIRST DEPARTMENT (a personal injury suit)

Genaro Vasquez-Santos, Plaintiff-Respondent, 

v

Leena Mathew, Defendant-Appellant:



If it turns out that such dispositive posts exist, should the plaintiff’s attorney be subject to Rule 11 sanctions?
How will this ruling affect how diligence regarding clients is conducted? Or will this be overturned?
#storedcommunications #electroniccommunications #privacy #liberaldiscovery #relevance #ESI 


How is today’s order similar to or distinct from 
“In The Matter of the Search Of A Residence in Oakland, California” 
(Order Denying Application for Search Warrant) issued January 10, 2019 in United States District Court, Northern District of California? 



h/t NY Law Journal, Naked Security