DOB#Telephone numbers:Previous Cell #Cell #Current cell #Email Address:Work Email Address:
5 Years Work Address: I don’t
remember my exact work email addresses, but theywould be some variation of my name:
INTERROGATORY NO. 2.:
Identify the user name and email address for any Facebook account maintained by you from July 2009 through the present.
Plaintiff objects to this interrogatory as seeks information thatis irrelevant, overly broad, unduly burdensome, and would likely lead a violation of theComputer Fraud and Abuse Act, 18 U.S.C. § 1030; the Store Communications Act, 18U.S.C. §§ 2701-2712; and the Wiretap Act, as amended by the Electronic PrivacyCommunications Act ("EPCA"), 18 U.S.C. §§ 2510-2522. Notwithstanding, myFacebook account is
INTERROGATORY NO. 3.:
Provide the name, address and telephonenumber of each and every person who has knowledge or information of any relevantfacts concerning any matter raised by any pleading in this action and describe in detail
the substance of that person’s knowledge.
Plaintiff objects to this interrogatory as it is overly broad andvague.
Anderson v. UPS, Inc.,
2010 U.S. Dist. LEXIS 123878 *6 (D. Kan. Nov. 22,2010);
Aikens v. Deluxe Fin. Servs., Inc.,
217 F.R.D. 533, 538 (D. Kan. 2003);
Hilt v.SFC Inc.,
170 F.R.D. 182, 186-7 (D. Kan. 1997);
Stephens v. City of Chi,
Case 5:12-cv-00019-DCB-MTP Document 68-8 Filed 02/07/13 Page 2 of 32