Judge: Elaine W. Mandel, Case: 19SMCV00935, Date: 2023-01-31 Tentative Ruling



Case Number: 19SMCV00935    Hearing Date: January 31, 2023    Dept: P

Tentative Ruling

Dr. Stewart Lucas Murrey v. Cheaterreport.com et al., Case No. 19SMCV00935

Hearing Date January 31, 2023

Plaintiff Murrey’s Motion to Compel Production of Further Documents

 

Plaintiff alleges the website www.Cheaterreport.com published defamatory statements about him. On March 22, 2022, the court granted Murrey leave to conduct limited third party discovery to identify the person or persons who created the website. Murrey served subpoenas duces tecum on third parties Amazon, Facebook, Instagram, Yahoo and Cloudflare, seeking production of business records. He argues these entities’ responses were inadequate and moves to compel further production.

 

Upon a party’s motion, a court may make an order directing compliance with a subpoena duces tecum for production of documents. Cal. Code of Civ. Proc. §2016.010.

 

Amazon

Murrey argues Amazon’s responses were insufficient or consisted of invalid objections. Amazon argues it conducted a diligent search of its records and concluded the IP address identified by Murrey was never associated with an Amazon consumer, and the majority of Murrey’s other requests were overbroad and/or irrelevant.

 

Requests 1-2 are relevant in light of the court’s March 22, 2022 order that Murrey is permitted to conduct third-party discovery to identify the person who created Cheaterreport.com. Amazon states that it conducted a diligent search and found no responsive documents. Requests 3-4 seek relevant information, but as phrased are overbroad, seeking “any and all details” related to the alleged creator of Cheaterreport. This language is too vague to allow Amazon to meaningfully respond. Similarly, requests 5 and 6 are overbroad, seeking “any and all documents” created when Amazon allegedly “entered into business” with the creater of Cheaterreport, with no limitation as to content.

 

Requests 7-9, which seek payment information related to Cheaterreport.com are valid requests and not overbroad. As stated, the court ordered that Murrey may conduct discovery to identify the person who created the website and/or made the allegedly defamatory posts. Payments that individual made to the internet service provider are relevant to determining that person’s identity, so discoverable.

 

Amazon has shown requests 10-13 are overbroad, since the IP address in question is shared by a number of different AWS customers, whose identities are irrelevant to this lawsuit. The request implicates the privacy rights of third parties and are improper.

 

Requests 14 through 16 are overbroad, seeking “any and all documents” regarding Amazon’s alleged contractual relationship with Cheaterreport. Nonetheless, Amazon is required to make a good faith effort to produce responsive documents. Requests 17 and 18 fall outside the scope of the court’s March 22 order, which only granted leave to conduct discovery as to Cheaterreport.com, not the other websites named in the requests.

 

Requests nos. 19-46 are overbroad and/or irrelevant. They seek information related to the relationship between Amazon and various third parties, including Jeffrey Epstein and the U.S. Government. They fall outside the scope of the court’s limited third-party discovery order, which was narrowly framed to allow discovery related to the identity of the person who created and/or posted defamatory statements on cheaterreport.com.  

 

Amazon must provide further responses to requests 7-9 and 14-16. For the reasons stated, no further responses to the other requests will be compelled. No sanctions will be issued, as Murrey has not shown that Amazon acted in bad faith.

 

Meta (Facebook and Instagram)

The Stored Communications Act prohibits entities providing remote computing services from divulging “the contents of any communication which is carried or maintained on that service.” 18 U.S.C.A. §2702 (a)(1)-(3). There is no exception to the SCA for civil subpoenas. O’Grady v. Superior Court (2006) 139 Cal.App.4th 1423, 1443. Additionally, the court cannot permit production of identifying information that would confirm the existence of content protected under the SCA. Id. at 1448.

 

Murrey argues Facebook/Meta produced insufficient responses to his discovery requests and moves to compel further. Facebook/Meta argues most of the information sought is either irrelevant or protected.

 

Meta-- Facebook

Requests 1-11 to Facebook all request production of Facebook posts, comments, “likes,” or identifying information related to the same. This information is protected under the SCA, and its production cannot be compelled. Requests 12-14 seek information related to plaintiff’s own Facebook account. Facebook is not a party to this litigation, and its treatment of Murrey’s account is not relevant to his defamation claims against Cheaterreport.

 

Requests 15 and 16 seek any documents related to a contractual relationship between Facebook and Cheaterreport, and any documents demonstrating payments between Facebook and Cheaterreport. These documents are relevant to determining the identity of the website’s creator, so are discoverable under the court’s March 2022 order.

 

The remainder of the requests – nos. 17-36 – relate to Facebook’s internal policies or various third parties other than Cheaterreport. These requests fall outside the scope of the third-party discovery permitted in the court’s March order. Only documents related directly to the identity of Cheaterreport’s creator are discoverable under the order. These requests are improper.  

 

GRANTED as to requests 15 and 16. DENIED as to all other requests. No sanctions will be awarded, since Murrey has not shown Meta acted in bad faith.

 

Meta-- Instagram

All requests to Instagram either seek communications protected under the SCA, identifying information confirming the existence of such communications, irrelevant third-party information, or information related to the internal policies of Instagram. As such, no further production will be ordered. DENIED.

 

Yahoo

As with the Instagram requests, all requests to Yahoo either seek information protected under the SCA, irrelevant third-party information, or information related to plaintiff’s personal Yahoo account. All these categories fall outside the scope of the court’s third-party discovery order. DENIED.

 

Cloudflare

Several of the discovery requests seek information related to alleged Cloudflare employees Son Lam and Julia Rieper. These requests fall outside the scope of the Court’s order in March 2022, which was narrowly tailored to allow third-party discovery related to cheaterreport.com only. Additionally, the other requests – nos. 109, 111, 115, 116, and 117 -- ask for information related to Cloudflare’s relationship with the US government and third-party company Palantir, both irrelevant to the current litigation. DENIED.