On February 13, 2018, in a unanimous decision, the New York Court of Appeals held, in Forman v. Henkin, 2018 NY Slip Op. 01015 (“Forman”), that disclosure demands for a party’s “private” social media account should not be reviewed under a heightened standard but, instead, are subject to the “material and necessary” standards set forth in CPLR § 3101(a).