How have courts dealt with the issue of production of access-limited contents of a Facebook profile?

The only case, however, to which counsel referred me on the question of the production of the access-limited contents of a Facebook profile was that of Rady, J. in Murphy v. Perger, [2007] O.J. No. 5511 (S.C.J.). That case also involved a claim for damages resulting from injuries suffered in a car accident, including a claim regarding loss of enjoyment of life. The plaintiff had posted photographs on her publicly-accessible Facebook profile showing her engaged in various social activities. The defendant moved for production of any photographs maintained on the private Facebook profile over which the plaintiff had control. In considering whether the defendant’s request represented a mere fishing expedition or whether relevant photographs likely were posted on the private site, Rady J. stated: 17 It seems reasonable to conclude that there are likely to be relevant photographs on the site for two reasons. First, www.facebook.com is a social networking site where I understand a very large number of photographs are deposited by its audience. Second, given that the public site includes photographs, it seems reasonable to conclude the private site would as well. 18 On the issue of relevancy, in this case, clearly the plaintiff must consider that some photographs are relevant to her claim because she has served photographs of her prior to the accident, notwithstanding that they are only "snapshots in time".