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Filing # E-Filed 08/31/2021 03:50:30 PM
IN THE CIRCUIT COURT OF THE SEVENTH JUDICIAL CIRCUIT
IN AND FOR VOLUSIA COUNTY, FLORIDA
ANNA YURKO, CASE NO.:
Plaintiff,
v.
SKYLA SOLLOWEN,
Defendants.
PLAINTIFF'S SOCIAL MEDIA REQUEST FOR PRODUCTION TO
DEFENDANT, SKYLA SOLLOWEN
Plaintiff, ANNA YURKO, by and through his undersigned counsel and pursuant to Rule 1.350 of
the Florida Rules of Civil Procedure, and hereby requests the Defendant, SKYLA SOLLOWEN,
to produce and permit the Plaintiff to inspect and copy each of the following documents on or
before thirty {30) days after service hereof at the offices of the undersigned counsel:
REQUEST FOR PRODUCTION
1. A copy of Defendant's Facebook "activity log" for the past three (3) years to include About Me,
all status updates, posts by you, shares and videos; and not to include connections, events,
following (a list of people you follow), last location, likes on others' posts, likes on your posts
from others, likes on other sites, notes, posts to others, recent activities, registration date, removed
friends, searches {this information should be redacted.)
2. A copy of Defendant's Facebook "downloaded info" for the past three (3) years, to include About
Me, Address, Alternate Name, Check-Ins, Current City, Date of Birth, Education, Name, Name
Changes, Photos, Photos Metadata, Status Updates, Work and Videos; not to include account
status history, active sessions, ads clicked, ad topics, apps, birthday visibility, chat, connections,
deleted friends, currency, emails, events, facial recognition data, family, favorite quotes,
followers, friend requests, friends, gender, groups, hidden from news feed, hometown, IP
Addresses, locale, logins, logouts, messages, notification settings, pages you admin, pending
friend requests, phone numbers, physical tokens, pokes, political views, recent activities,
2021 11271 CIDL
registration date, removed friends, screen names, spoken languages (this information should be
redacted).
3. A color copy of any and all photographs Defendant has uploaded to Instagram in the last five
years including the date the photographs were uploaded as well as any comments thereon.
4. A complete copy of Defendant's LinkedIn profile and photographs uploaded in the last three (3)
years.
5. A complete copy of Defendant's Twitter profile, including any and all tweets, photographs and
video uploaded, as well as any and all comments thereon.
6. A complete copy of Defendant's Tumblr page and any and all posts and photographs uploaded by
Plaintiff as well as any comments thereon.
7. A complete copy of Defendant's Vine profile and any and all videos uploaded as well as the
comments thereon.
8. Color copies of all photographs and videos of Defendant which have been uploaded to any other
social media/networking website in the last three (3) years including the date the photographs and
videos were uploaded as well as any comments thereon.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished via
service of process simultaneously with the Summons and Complaint.
Craig I \Ly , Esquire
Florid'd B`arNo.: 122210
Jeffrey S. Kaufman, Esquire
Florida Bar No.: 99538
Christopher H. Hunt, Esquire
Florida Bar No.: 21705
Primary: craiglynd@kaufmanlynd.com
Secondary: rrosso@kaufinanlynd.com
Alternate: litigation@kaufmanlynd.com
KAUFMAN & LYND, PLLC
Counsel for Plaintiff
200 E. Robinson Street,
Orlando, Florida 32801
Phone: (407) 706-3535
Fax: (407) 440-4543
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Filing # E-Filed 08/31/2021 03:50:30 PM IN THE CIRCUIT COURT OF THE SEVENTH JUDICIAL CIRCUIT IN AND FOR VOLUSIA COUNTY, FLORIDA ANNA YURKO, CASE NO.: Plaintiff, v. SKYLA SOLLOWEN, Defendants. PLAINTIFF'S SOCIAL MEDIA REQUEST FOR PRODUCTION TO DEFENDANT, SKYLA SOLLOWEN Plaintiff, ANNA YURKO, by and through his undersigned counsel and pursuant to Rule 1.350 of the Florida Rules of Civil Procedure, and hereby requests the Defendant, SKYLA SOLLOWEN, to produce and permit the Plaintiff to inspect and copy each of the following documents on or before thirty {30) days after service hereof at the offices of the undersigned counsel: REQUEST FOR PRODUCTION 1. A copy of Defendant's Facebook "activity log" for the past three (3) years to include About Me, all status updates, posts by you, shares and videos; and not to include connections, events, following (a list of people you follow), last location, likes on others' posts, likes on your posts from others, likes on other sites, notes, posts to others, recent activities, registration date, removed friends, searches {this information should be redacted.) 2. A copy of Defendant's Facebook "downloaded info" for the past three (3) years, to include About Me, Address, Alternate Name, Check-Ins, Current City, Date of Birth, Education, Name, Name Changes, Photos, Photos Metadata, Status Updates, Work and Videos; not to include account status history, active sessions, ads clicked, ad topics, apps, birthday visibility, chat, connections, deleted friends, currency, emails, events, facial recognition data, family, favorite quotes, followers, friend requests, friends, gender, groups, hidden from news feed, hometown, IP Addresses, locale, logins, logouts, messages, notification settings, pages you admin, pending friend requests, phone numbers, physical tokens, pokes, political views, recent activities, 2021 11271 CIDL registration date, removed friends, screen names, spoken languages (this information should be redacted). 3. A color copy of any and all photographs Defendant has uploaded to Instagram in the last five years including the date the photographs were uploaded as well as any comments thereon. 4. A complete copy of Defendant's LinkedIn profile and photographs uploaded in the last three (3) years. 5. A complete copy of Defendant's Twitter profile, including any and all tweets, photographs and video uploaded, as well as any and all comments thereon. 6. A complete copy of Defendant's Tumblr page and any and all posts and photographs uploaded by Plaintiff as well as any comments thereon. 7. A complete copy of Defendant's Vine profile and any and all videos uploaded as well as the comments thereon. 8. Color copies of all photographs and videos of Defendant which have been uploaded to any other social media/networking website in the last three (3) years including the date the photographs and videos were uploaded as well as any comments thereon. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished via service of process simultaneously with the Summons and Complaint. Craig I \Ly , Esquire Florid'd B`arNo.: 122210 Jeffrey S. Kaufman, Esquire Florida Bar No.: 99538 Christopher H. Hunt, Esquire Florida Bar No.: 21705 Primary: craiglynd@kaufmanlynd.com Secondary: rrosso@kaufinanlynd.com Alternate: litigation@kaufmanlynd.com KAUFMAN & LYND, PLLC Counsel for Plaintiff 200 E. Robinson Street, Orlando, Florida 32801 Phone: (407) 706-3535 Fax: (407) 440-4543