• accident scene investigation, video surveillance...
TRANSCRIPT
Investigation
Interrogatories
Depositions
Preservation Issues
Social Media Discovery
INVESTIGATION
Discovery of Video Surveillance
Obviously, it is important to have as many details as possible concerning
the accident. While eyewitness accounts are helpful, as we all know
people can view the same event in many different ways. Video of the
accident can clear this up.
Dash Cam Footage
With the growing popularity of dashboard cameras, you may find dashcam
footage of the accident. If a police car is involved in the accident, you may
wish to obtain a copy of the dash cam video footage. Often, the police
officer’s dash camera has video and audio recordings of events that
occurred both in front of the squad car, as well as within the vehicle itself.
Note: police dash cameras are not always recording. Most police dash
cameras will only save a recording if lights or sirens are activated..
Police dash cam footage is often a public record, so accident victims have
a right to submit a Freedom of Information Act request in order to obtain
the footage from the police department. Notify the police department
immediately if you wish for the footage to be preserved. The request
should be submitted in writing.
Local Businesses
More and more often, the accident is caught on video by a local business’
surveillance camera. Many businesses now have surveillance cameras in
their parking lots, and outside their businesses. Don’t wait too long, as the
video is often erased over after a few days or 1 week.
Highway Traffic Cameras
One can to use the freedom of information act to obtain the footage from
highway traffic cameras. The process can be difficult, as these cameras
can be owned by the state, private companies, or even news outlets.
Red Light Cameras
If a driver may have run a red light, a red light camera may provide video
evidence. Keep in mind that red light camera footage is usually not kept
for long.
Discovery of Accident/Police Reports
First, send for all police reports, ambulance reports and lifeflight records
Send for 911 records to locate additional witnesses, or admissions by
drivers, or even the sounds of the accident scene
Check for supplemental records that are made
Get police photos and videos from the scene
Find out where the vehicles were taken and any parts of vehicles
Go to the courthouse and get the records for any citations;
Get the complaint
Get the court Order
Get the transcript of any plea or plea deal
See if there are additional witnesses that are not listed on original
report
Show up at the sentencing if needed
Accident Scene Evidence Preservation Tips; Preservation Letter
Auto Parts; lose them at your peril
Spoliation
Keeping vehicles: do you need to keep the car;
Pay for storage?
Black box issues
Video preservation
INTERROGATORIES
STATE OF MINNESOTA IN DISTRICT COURT
COUNTY OF BLUE EARTH FIFTH JUDICIAL DISTRICT
,
Plaintiff,
vs.
,
Defendant.
Court File No.:
PLAINTIFF’S
INTERROGATORIES TO
DEFENDANT
TO: DEFENDANT ABOVE NAMED AND HER ATTORNEY,:
In accordance with Rules 26 and 33 of the Rules of Civil Procedure,
plaintiff requests and requires you to furnish answers to the following
interrogatories (questions) to plaintiff’s attorney within thirty (30) days
from the date of service. These questions are to be answered in writing
and under oath in accordance with the following instructions:
INSTRUCTIONS
In answering these questions, you should use your best efforts to provide
all the information you can to the full extent known or ascertainable by
you. This includes all information obtained by anyone working on your
behalf, including your lawyers and their associates, investigators, legal
assistants and any others, either obtained during investigation, during
preparation for trial, or otherwise.
If any of the questions, or any parts of any questions, are not answered in
full after you use your best efforts to secure all information, then you
should state your specific objection and the reasons for not fully
answering. If you do not answer a question because you allege the
information sought is privileged, you should fully IDENTIFY the
information, including documents, for which the privilege is asserted, and
specify the privilege (for example: work product, attorney/client, etc.)
If any of your answers to these questions comes from your records, or if
the question asks you to IDENTIFY a document or other item, you can
answer the question by attaching a copy of the record, document or other
item, provided the copy contains all the information which will fully
answer the question. Whenever any of these questions asks you to
IDENTIFY a person, you should give the full name, age, current or most
recent address and phone number, and current or most recent employer
and their job with that employer.
Lastly, whenever any one of these questions asks you to IDENTIFY a
document or other item, unless you attach a copy of the document or item,
you should give the name of the person who has it, a complete description
of its subject matter, its date, who created it, and who, if anyone, signed it.
PLAINTIFF’S INTERROGATORIES
1. Identify the person or persons signing your answers to these
questions and identify every other person assisting in the preparation of
the answers, and their address and relationship to Defendant.
2. Identify all known witnesses to the accident involved in this
litigation.
3. Identify all other persons who have any knowledge relating to the
accident which is the subject of this litigation and state the knowledge
possessed by each person.
4. Identify all persons who have knowledge or information relating to
the personal, social, vocational, recreational, educational or other
background as it relates to the claims made by plaintiff.
5. State which of the persons referred to in your answers to
Interrogatories 1, 2, 3, and 4 you have interviewed, giving the date, time
and location of each interview, and identifying each person conducting, or
otherwise present at, each interview.
6. Have you taken or received any statements from any of the persons
whose names are listed in the answers to Interrogatories 1, 2, 3, and 4? If
so:
a. Give the name of the person whose statement was taken,
indicating whether the statement was oral, written, before a
court reporter, tape-recorded or otherwise preserved.
b. State the date, time and location of each statement.
c. Identify each person taking the statement and any other
person present during the taking of the statement.
d. State whether the person from whom the statement was
taken has been provided with a copy thereof, specifying the
date and place of delivery.
7. Identify any photographs, slides, motion pictures, videotapes, plats,
drawings, models, charts or other physical, demonstrative or illustrative
evidence of any type or nature whatsoever, relating to this case. Indicate
for each, such time whether you will make the evidence available to
plaintiff’s attorney for inspection, or supply copies thereof without the
necessity of a motion to produce.
8. Excluding matters already referred to in your answer to
Interrogatory 7, identify other physical evidence of any type or nature
whatsoever relating in any manner to this case.
9. Fully relate any information you have of conversations regarding
the accident which is the subject of this litigation which took place at the
time of, prior to, or following the accident. Identify each person involved
in each such conversation, and also identify all persons who overheard or
may have overheard such conversations.
10. If you have knowledge that any party to the accident which is the
subject of this litigation consumed any liquor, beer or other alcoholic
beverage(s) of any sort whatsoever, or any drug, narcotic, pill, or any
medication of any sort whatsoever, within the twenty-four (24) hour
period preceding the accident which is the subject of this litigation, state:
a. The precise substance(s) consumed.
b. The quantity of each consumed.
c. The time and place of each consumption.
d. Identify each person observing or having the opportunity to
observe each instance or period of consumption.
11. If you claim plaintiff’s injuries and damages were caused in whole
or in part by the fault of plaintiff, including negligence or assumption of
risk, state in detail each and every fact which supports your claim.
12. If you claim plaintiff’s injuries and damages were caused in whole
or in part by the fault (including but not limited to negligence, breach of
warranty or conduct giving rise to strict liability) of any person or
organization other than the defendants, state in as much detail as you can
all facts which support your claim.
13. Do you have any knowledge of plaintiff having sustained any
injuries or suffered any illness, disease, disability or condition at any time
prior or subsequent to the accident which is the subject of this litigation?
If so:
a. Describe in detail the nature of each injury, illness, disease,
disability or condition, including the date, time, duration
and place of the injury or onset of the illness, disease,
disability or condition.
b. Identify all persons having information relating to each
such injury, illness, disease, disability or condition,
including each person or entity rendering medical care or
treatment.
c. Identify all statements, documents, and physical evidence
of any type or nature whatsoever known to you to exist
relating to each such injury, illness, disease, disability or
condition.
14. Identify any medical reports, medical records, employment, payroll,
personnel, or tax records or documents of any type whatsoever relating to
plaintiff which you have examined or which is in your possession or
control. Specifically, please identify all facilities from which you have
obtained medical records, and all employers from which you have
obtained employment records.
15. Identify all persons whom you may call at trial to give testimony in
the form of expert opinions or conclusions and, for each such person, state
the following:
a. The subject matter on which he or she may be asked to give
expert testimony.
b. His or her qualifications to give expert testimony on that
subject or subjects.
c. All facts to which the expert will testify.
d. All opinions or conclusions to which the expert will testify.
e. The grounds for those opinions or conclusions.
16. Please identify all motor vehicle accidents you have been involved
in prior to the occurrence referred to in Plaintiff’s Complaint, specifically
stating when, where, and how each accident occurred.
17. Please identify all traffic citations, tickets or tab charges you have
received as a motor vehicle driver.
18. If you have ever been charged, convicted of, or pleaded guilty to a
felony or misdemeanor, state the date of each conviction or plea, the court
in which the conviction or plea was rendered, the nature of the charge, and
any sentence you received.
19. Please identify and describe the status of your license at the time of
the accident.
20. Please give a complete description of the accident including, but
not limited to, the date, time, place, your direction of travel, your speed,
position of turn signals, breaks, horn, and other instruments, the actions
you took to avoid the accident, and a description of the point of impact.
21. Please identify any tests, experiments, or accident re-creations/re-
construction from which, or the results of which, you may attempt to
introduce into evidence in a trial of this case.
22. Please identify all things you did on the day of the accident, in the
time leading up to the accident, including all jobs attended, places
travelled, and where you were coming from and going to at the time of the
accident.
23. Describe any umbrella or excess liability insurance coverage, over
and above the basic or primary coverage, that may be responsible for
paying any part of a judgment against you in this case.
24. If the insurance policy you have described in the previous
Interrogatory answer is a single limit policy, state what amounts have been
paid to any other claimant that would serve to reduce the amount of
available coverage under such policy.
25. Do you contend that the Plaintiff has done anything, or failed to do
anything, that constitutes a failure to mitigate damages? If so, please
describe what your contention is based on and what evidence exists to
support the same.
26. Has any settlement of any character been made between you and
other person, party or entity whatsoever concerning or in connection with
the occurrence made the basis of this suit? If so, give the date, person or
entity with whom you have entered into such settlement, and attach to
your answers to these Interrogatories a copy of such settlement.
27. Do you admit or deny that you were at fault for the accident in
question, and do you admit or deny that Plaintiff was not at fault for the
accident in question?
28. Have you ever told any other person(s), since the date of the
accident, that you were at fault for the accident in questions?
29. Please identify and produce all photographs or copies of
photographs in your possession, or that you know to exist, from the
accident scene or of any vehicles involved in said accident. If the
documents are not in your possession, please identify all knowledge of
their whereabouts.
30. Please identify and produce all repairs estimates or repair invoices
for vehicles involved in this accident that are in your possession, or are
known to exist. If the documents are not in your possession, please
identify all knowledge of their whereabouts.
31. Please identify whether the Defendant had a cell phone at the time
of the accident and whether he/she was using it in any fashion just prior to
or at the time of the accident.
32. Please identify if you were employed on the day of the accident,
listing your employer, the address of your employer, and the hours of
work on the day of the accident, and the day before the accident.
These interrogatories are continuing in nature and it is specifically
requested and demanded that all information coming to your attention
subsequent to the completion of your answers to these questions which is
in any manner relevant to such questions be promptly made available to
plaintiff’s attorneys. You should take notice that plaintiff will object at
trial to the introduction of evidence regarding any matters inquired of in
these interrogatories which are not revealed in a timely manner.
The undersigned counsel has read the above discovery requests and
certifies that, to the best of his or her knowledge, information and belief,
formed after reasonable inquiry, they meet the standards of Rule 26.07 of
the Rules of Civil Procedure.
KNUTSON + CASEY LAW FIRM
Dated: _______________________________
Randall G. Knutson
Knutson + Casey Law Firm
Attorneys for Plaintiff
196 St. Andrews Drive
Mankato, MN 56001
Telephone: 507-344-8888
Fax: 507-344-8616
Attorney License No. 0229891
DEFENDANT’S INTERROGATORIES
STATE OF MINNESOTA
COUNTY OF BLUE EARTH
DISTRICT COURT
FIFTH JUDICIAL DISTRICT
xxxxxxxx,
Plaintiff,
vs.
xxxxxxx,
Defendant.
Case Type: Personal Injury
Court File No.:
PLANTIFF’S ANSWERS TO
INTERROGATORIES
TO : DEFENDANT, AND HER ATTORNEY, XXXXX
Question 1:
What is your full name, date of birth, weight, height, present
residential address, marital status, social security number, and what
are, if any, other names you have used or by which you have been
known?
Answer:
XX
Question 2:
What are your residential addresses for the preceding five years and the
dates during which you so resided?
Answer:
XX
Question 3:
Describe in detail the manner in which the accident occurred.
Answer:
I was coming home from work going down XXXX Street in North
Mankato when a car came out fast through a Yield sign on XXXX
Ave. and hit me on the passenger side.
Question 4:
Where were you coming from and where were you going to at the time of
the accident?
Answer:
Coming from work and on my way home.
Question 5:
If you have any information indicating there was any alcohol or drugs
consumed by you or any of the parties or witnesses within twelve hours
preceding the accident, what is the name and address of the person
consuming; the time, place, type, and amount of alcohol or drugs
consumed; and the name and address of each person having such
information?
Answer:
None to my knowledge.
Question 6:
What are the names and addresses of all witnesses to the accident, either
eyewitnesses, bystanders, or those who arrived after the accident, or any
other person who may know something about the facts of the accident?
Answer:
XXXXX, North Mankato PD
Investigation is continuing
Question 7:
If you have talked to Defendant at any time, up to the present day, give the
substance of the conversation, telling who said what, and when and where
the conversation took place.
Answer:
No.
Question 8:
Please state the names and addresses of all persons or witnesses, including
expert witnesses, that you have interviewed or consulted in this matter.
Answer:
Objection, seeks to invade attorney work product. Discovery is
continuing.
Question 9:
If you expect to call any person as an expert witness at trial, please state
for each such person:
a. Name, address, occupation, and employer;
b. Subject matter concerning which the expert is expected to
testify;
c. The substance of the facts and opinions to which the expert
is expected to testify and the facts that have been
determined or assumed by the expert and that have become
the basis for the expert's opinions; and
d. A summary of the grounds for each opinion.
Answer:
No experts have been retained at this time. Discovery is ongoing. It is
expected that Ms. XXXX’s treating physicians will testify that
Plaintiff suffered injuries in the accident including but not limited to
headaches, neck, back, chest and thumb injuries; that the treatment
and bills for the treatment have been reasonable and necessary; that
Plaintiff suffered a disability that kept her from work for periods of
time; that she has suffered from pain up to the present; that she is
expected to incur medical treatment in the future; that some future
wage loss is expected; and that Plaintiff will have pain in the future
from her disability. This answer will be supplemented as information
is obtained.
Question 10:
If you have secured any photographs, slides, motion pictures, videotapes,
plats, drawings, or other photographic or non-photographic visual
representations relating in any manner to the subject matter of the
Complaint, please state:
a. The type of visual representation secured;
b. The subject matter of each such visual representation
(specifying such in detail);
c. The date each was taken or made;
d. By whom each was taken or made (providing name,
address, occupation, and employer); and
e. Who currently is in possession of the negatives or prints or
other representations (providing name, address, occupation,
and employer).
Answer:
See the Accident Report, 6 photographs of the accident scene and 20
photographs from xxxxx Insurance of XX’s car damage on the
enclosed CD. Discovery is continuing.
Question 11:
Excluding matters already referred to in the previous answer to
interrogatory, do you have knowledge of any other physical and/or
documentary evidence of any type or nature whatsoever relating in any
manner to the subject matter of this litigation? If so:
a. Describe in detail the nature of all such evidence; and
b. State the name, address, occupation, and employer of the
person currently in possession or control of such evidence.
Answer:
None. Discovery is continuing.
Question 12:
What is the nature and extent of each and every injury you claim to have
sustained as a result of the accident?
Answer:
As I understand it, I sustained cervical strain, thoracic strain, lumbar
strain, chest contusion, thumb sprain and headaches.
See the medical record on the attached CD. Discovery is continuing.
Question 13:
What symptoms do you now have that you attribute to any injuries that
you sustained in the accident?
Answer:
Pain in my neck and down my shoulders, arms, elbows to my thumb
and contributes to headaches and stiffness.
Question 14:
What, if any, permanent injury do you claim you sustained as a result of
the accident?
Answer:
Unknown at this time.
Question 15:
What are the names and addresses of each and every hospital, doctor,
clinic, chiropractor, osteopath, or other medical person or health care
professional who examined or treated you for the injuries you claim to
have sustained, the dates of each examination or treatment, and the
inclusive dates of hospitalizations?
Answer:
XX
XX
XX
XX
The medical records in our possession are on the enclosed CD.
Discovery is continuing.
Question 16:
Please itemize the medical, hospital, and health care expenses that you
claim to have sustained as a result of this accident.
Answer:
XX
XX
XX
TOTAL: $11,586.19
Copies of the medical bills in our possession are on the enclosed CD.
Discovery is continuing.
Question 17:
What, if any, condition are you claiming was aggravated as a result of this
accident?
Answer:
I am uncertain, and would have to ask the doctors for their opinion.
Question 18:
What other expenses have you incurred because of this accident that have
not been specified in answers to previous interrogatories?
Answer:
None, other than ongoing medical bills and mileage to doctors.
Question 19:
If you claim that you lost any time from work as a result of your injuries
and if you claim that you suffered any wage loss or income loss because of
your injuries, please state:
a. The name and address of your employer at the time of the
accident;
b. All dates you were off work;
c. Your wage rate at the time of the accident;
d. The total amount of wages or income loss claimed by you;
and
e. The total amount of workers' compensation benefits, if any,
that you received and the name of the company that has
paid such benefits.
Answer:
XX
XX
XX
Question 20:
If you have ever been hospitalized or treated before or subsequent to the
accident in question, please state:
a. The type of disease, illness, or injury you sustained;
b. The date of said disease, illness, or injury;
c. Where said disease, illness, or injury occurred;
d. The name and address of the treating physician or medical
professional and dates of treatment; and
e. The occurrence, incident, or causes of said disease, illness,
or other injury.
Answer:
Objection, overly broad and unduly burdensome. Notwithstanding
that objection:
I treated at:
XX
XX
XX
Question 21:
Have you ever been treated or counseled by any physician or professional
person for any mental or emotional condition? If so, state with
particularity the names and current addresses of each such physician or
professional, and the dates of each such treatment and/or counseling
session.
Answer:
Objection, overly broad and unduly burdensome, beyond the scope of
the rules of civil procedure.
Question 22:
What activities have been affected by the injuries you claim to have
sustained in the accident and how have they been affected?
Answer:
Objection, overly broad. Notwithstanding that objection, ones that
come to mind are any activities that require lifting such as
lifting/carrying groceries, garbage and housework. Also, gardening,
bike riding and sitting at a computer. Discovery is continuing.
Question 23:
If you have been paid any sums by any no-fault insurer, please state:
a. The name and address of the insurance company;
b. The name of the policyholder;
c. The amount of medical expense(s) that has been paid by
said company; and
d. The amount of wage loss, if any, that has been paid to you
by said company.
Answer:
XX
XX
XX
Question 24:
Do you carry underinsured motorist coverage applicable to this accident?
If so, state the name of the underinsurance carrier, applicable policy
number, and amount of coverage issued by the underinsurance carrier.
Answer:
XX
Question 25:
Upon what facts or acts of this party, in detail with particularity, do you
base your claim of this party's negligence or other liability?
Answer:
Defendant failed to yield at the yield sign, failed to keep a proper
lookout for my vehicle, and failed to keep their vehicle under control.
Question 26:
What is the name, age, address, and occupation and place of employment
of each person having knowledge of the information contained in the
previous interrogatory?
Answer:
Objection, overly broad and unduly burdensome. See the attached
police report.
Question 27:
What are the names and addresses of your present employer and previous
employers for the past ten years, and what, in detail, is the type of work
that you do and did for each of your employers?
Answer:
XX
Question 28:
With respect to each and every medical bill that you claim was incurred as
a result of the accident sued upon, identify:
a. The amount of each such bill;
b. Whether each such bill has been paid; and
c. For each such bill that has been paid, the identity of the
person, entity, corporation, insurer, or governmental entity
making such payment and the amount of each such
payment.
Answer:
a. See answer to question #16.
As to subsections b and c. - Objection, calls for collateral source
information not relevant until post trial proceedings.
Question 29:
With respect to any payment or payments made to you or that you have
received for lost wages, lost income, disability, or to compensate you for
any permanent injuries or impairments resulting from the accident sued
upon, as to each such payment identify:
a. The amount of each such payment; and
b. The identity of the person, entity, corporation, insurer, or
governmental entity making such payment.
Answer:
None, other than no-fault benefits.
Question 30:
In the event you had a workers' compensation claim within the last ten
(10) years, state the following:
a. The name and address of all employers;
b. The date or dates of the accident or incident giving rise to
the claim or claims;
c. The names and addresses of all doctors, chiropractors, or
medical specialists that have treated you for each and every
workers' compensation claim within the period described;
and
d. Identify all persons that are medical experts or otherwise
that have testified either by hearing, trial, or deposition in
connection with any workers' compensation claim or claims.
Answer:
None.
Question 31:
Did you collect unemployment compensation prior to the date of the
accident? If so, identify all periods collected.
Answer:
No.
Question 32:
Have you applied for unemployment compensation subsequent to the date
of the accident? If so, for what periods of time and where did you apply?
Answer:
No.
Question 33:
Are you presently entitled to receive Medicare benefits? If so, state your
Medicare Health Insurance Claim Number (HICN) and the date of
enrollment.
Answer:
No.
Dated:
XXXXXX
Subscribed and sworn to before me
this day of , 201.
Notary Public
Date: ____________________ _____________________________________
Randall G. Knutson (0229891)
Attorney for Plaintiff
196 St. Andrews Drive, Suite 100
Mankato, Minnesota 56001
Phone: 507-344-8888
Fax: 507-344-8616
PRESERVATION ISSUES December 10, 2014 Re: Accident on xx/xx/xxxx involving XXXXXX This office is representing (client) regarding the accident of xx/xx/xxxx. Please do no contact our client, but contact this office instead. This is a formal request that you preserve and not alter any and all equipment that was involved in the collision, along with photographs, video recordings, recorded audio or computer media, measurements, real evidence, documents, materials and all other evidence and things related to the collision which are presently in your possession or the possession of your employee or agent. This includes, but is certainly not limited to all documents, whether paper, electronic or otherwise stored, relative to the driver (our client) and (defendant). We request that you preserve all documentary evidence involved in this matter, including the following:
1. Any and all driver’s logs or records of driving of any kind, for six months prior to the accident;
2. All trip receipts; 3. Any and all 70-hour and other log audits, if they exist;
4. All statements, notes, audio or video recordings and other materials or things obtained from any person having information respecting this incident or who has knowledge of the circumstances;
5. Any GPS records; 6. All Maintenance records for the vehicle involved in the
accident; 7. Any and all communications via CB radio, mobile or
satellite communication system, e-mail, cellular telephone, text message, pager, or other in-cab communication device;
8. Any and all electronic control module data, as well as the ECM, EDM, or black box from the vehicle;
9. The vehicle involved in the accident, until such time as Plaintiff can inspect said vehicle;
Page Two
10. Any and all cell phone, or other phone records, showing phone or cell phone information for the day of the accident, as well as 30 days prior to the accident; and
11. All other information that may be relevant to the crash. Please retain all of this evidence. Many court decisions have permitted court sanctions or “destruction of evidence” or spoliation jury instructions where a party destroys evidence or does not preserve evidence. If you have any questions or comments about this request and notice, please give call us at (507) 344-8888. Thank you. Very truly yours, Randall Knutson Attorney at Law Civil Trial Specialist RGK/jlp
Bad Faith Letter requesting preservation of Metadata Dear : We have made a separate and additional claim for bad faith in this matter. Therefore, this is a formal request that you preserve and not alter any and all electronically stored data, information, and metadata regarding XXXXXXX’s (client’s) claim with XXXXXX Insurance Company, as well as all photographs, video recordings, recorded audio or computer media, measurements, real evidence, documents, materials and all other evidence and things related to the claims made by XXXXXXXX (client). In addition to the above, we request that you preserve:
1. All records, correspondence, emails, receipts, and electronically stored information including all Metadata, that exists regarding (client’s) claims.
2. All statements, notes, audio or video recordings and other materials or
electronically stored information from any person having information regarding (client’s) claims.
We also request that you inform our office of any changes in servers, or case management software at XXXXXX Insurance. Please retain all of this evidence. Minnesota courts have permitted court sanctions, and “destruction of evidence” or spoliation jury instructions where a party destroys evidence or does not preserve evidence. If you have any questions or comments about this request and notice, please give call us at (507) 344-8888. Thank you. Very truly yours, Randall Knutson Attorney at Law Civil Trial Specialist /jlp
SOCIAL MEDIA
-Interrogatories
QUESTION:
31. Please identify any and all “networking” online or Internet services in
which you have participated or visited in the past 5 years, including but not limited to
Twitter, Myspace, Facebook, Friendster, Classmates, Graduates, LinkedIn, Livejournal,
Reunion, Myyearbook, Hi5,and Yahoo360. For each, please include the name with or by
which you identified or identify yourself (including your display name) and with which
you registered for your account, how long you have been a participant or member. Please
refrain from deleting or changing any information currently contained or displayed on
your pages as of the date of these Interrogatories.
MY ANSWER:
Objection, overly broad and unduly burdensome; seeks private information posted
by other individuals, the release of which has not been authorized, and which could
expose Plaintiff to privacy violations and personal liability.