What happens on Facebook does not stay on Facebook

I have introduced Facebook photos and screenshots as evidence in many a divorce or custody trial.  But, I have yet to meet an attorney who has successfully subpoenaed Facebook for this information.  I assume it has happened somewhere, ever, but not in my neck of the woods. Yet in my world of DC/Montgomery County divorces, Facebook contains a lot of valuable information and it's a struggle to figure out how to get it ALL in discovery.

What's significant that can be found on Facebook?  People post photos of their paramours, how they spend their money (vacations, designer stuff, you name it), and they tag their locations.  It bears on finances and judgment. Information from Facebook posts can be pertinent to alimony, child support, custody-  the full gamut. 

I have requested the content of a party's Facebook page in discovery, but the question is, what is "everything"?  I usually get dribs and drabs in response.  Every time that person "likes" an article, do I need that?  How does a person even obtain that information, assuming they want to bother to give it to me?  What about if certain posts are public and others are private?  If someone is posting privately, how will I ever know whether everything has been produced in discovery?

Have you ever scrolled the feed of a frequent user and just hit Expand, Expand, Expand?  It can be a daunting project to unravel all the posts and print or take screen shots of them all. And you still can't be sure you got it all, for example, if a post has been deleted.

When I am preparing the discovery request, I need to be concerned about tailoring it narrowly enough to make it possible for the person to reasonably respond. But I always want it to encompass everything I need.  

So... I just realized something that blew my mind a little bit.  I noticed while using Facebook, the ability to download all activity.

 And, with that, I'll be amending my discovery requests accordingly in the very near future. I'm looking forward to seeing what it yields.