First Department Expands Discovery of Social Media Accounts

Just last year, the New York Court of Appeals ruled in the case of Forman v. Henkin, that a litigant’s public posts on Facebook were subject to discovery.  The decision was based on the premise that any limitation on the discovery of social media accounts would run counter to New York’s “tradition of liberal discovery.” On January 24, 2019, the First Department expanded on that premise.
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