Case 1:20-mc-00036-JEB-DAR Document 10 Filed 08/18/20 Page 27 of 29 security forces committed serious human rights violations against the Rohingya.46 The Report highlighted the 2012 violence as a “key recent turning point” that generated serious human rights violations and abuses.47 Importantly, civil society organizations have been raising concerns with Facebook regarding the abuse of its platform going back to 2012.48 (3) Request 13 asks for documents relating to any internal investigations conducted by Facebook of “coordinated inauthentic behavior” (or other terms of service violations) committed by accounts belonging to or controlled by Myanmar state officials, representatives, entities or groups acting in coordination, or suspected of acting in coordination, with Myanmar government entities. Contrary to Facebook’s representations, this is not a request for Facebook’s internal policies and procedures. (4) Request 14 asks for a Rule 30(b)(6) deposition that is limited to the information requested in Requests 1-13. A deposition will assist, among other things, in understanding why Facebook removed, suspended, blocked certain accounts, pages, or other information. In isolation, it will be difficult to understand why Facebook has taken down certain accounts, posts, and information. Thus, this information will provide important context. As stated in its application, if Facebook has any legitimate concerns regarding confidentiality and or the scope of any documents requested, The Gambia is willing to discuss a protective order to facilitate the production of the requested discovery. In re Ex Parte Application of Kleimar N.V., 220 F. Supp. 3d 517, 522 (S.D.N.Y. 2016). Moreover, to the extent the Court has any concerns regarding the scope of discovery, they can be cured.49 The Court can 46 Human Rights Council, Report of the detailed findings of the Independent International Fact-Finding Mission on Myanmar at 6, U.N. Human Rights Office of the High Commissioner (Sept. 17, 2018), https://www.ohchr.org/Documents/HRBodies/HRCouncil/FFM-Myanmar/A_HRC_39_CRP.2.pdf. 47 Id. 48 BSR, Human Rights Impact Assessment Facebook in Myanmar 28-29, Facebook (Oct. 2018), https://about.fb.com/wp-content/uploads/2018/11/bsr-facebook-myanmar-hria_final.pdf (“It is important to recognize the length of time, going back to 2012, that civil society organizations have been raising concerns with Facebook … ”). 49 Mees v. Buiter, 793 F.3d 291, 302 (2d Cir. 2015) (“[T]o the extent a district court finds that a discovery request is overbroad, before denying the application it should ordinarily consider whether that defect could be cured through a limited grant of discovery.”). 21