Format must be : Introduction / Factual Background / Legal Standard / Argument / ConclusionBrief-Writing AssignmentOur client, Michael Carlsen, was sued oneyear ago by Lindsey Young for damagesarising

Format must be : Introduction / Factual Background / Legal Standard / Argument / Conclusion
Brief-Writing Assignment
Our client, Michael Carlsen, was sued one
year ago by Lindsey Young for damages
arising out of a car accident al
legedly caused by Carlsen’s neg
ligent and reckless driving. Young
has alleged that she has suffered great pain and in
jury and was unable to work for nine months.
During discovery, we request
ed 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 w
ith her allegations concerning the
nature and extent of her injuri
es. Specifically, after another w
itness 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 (memora
ndum 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 brie
fs. In addition, court ru
les require that the
brief be word-processed and double-spaced and that current
Bluebook
citation form be followed.







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