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Discovery may be carried out by directly asking a person questions (oral depositions), by sending a person written questions (interrogatories and depositions on written questions), and by requesting that the person provide documents (motions for production, subpoenas duces tecum).
Write out each fact you wish the other party to admit is true. When writing these facts, be as clear and concise as possible. Each request must be for a single fact; do not include multiple facts, compound questions, or subparts.
Discovery requests typically follow a common format that you can mirror. First, list instructions detailing the request for production. Be sure to mention Rule 34 and Rule 26(b), which outline the scope of the discovery request. It's also necessary to include a section with definitions.
Evidence from social media platforms that could be admissible includes posts that the user made, shared, or liked. It could be an analysis of the friend list of that user. It could be photos or videos or a breakdown of what groups they are a member of on the platform.
A party may ?obtain discovery regarding any non-privileged matter that is relevant to any party's claim or defense?including the existence, description, nature, custody, condition, and location of any documents or other tangible things.? Social media posts by a party are discoverable in California as long as the ...