I understand that... why is the plaintiff suing? What type of lawsuit is it? You are not going to find a case that says you cannot discover bank records because they are "personal". Everything about discovery is personal. This will come down to the law of evidence concerning relevant material in your type of lawsuit. So what type of lawsuit is it?
It sounds as if you have this under control. I doubt you will find a case that says that bank records are not relevant to a personal injury lawsuit as that would be a very broad ruling. Certainly bank records could be relevant to a personal injury lawsuit if your plaintiff were seeking lost earnings and certain out of pocket expenses (the bank records could show his/her actual income and expenses). It sounds like their request is over broad and amount to a fishing expedition that the court will not likely allow. I think your objection simply needs to be heard in court with the defense having to demonstrate why these records should be discoverable. I would go further to request the court allow submission under seal for an in camera review to determine admissibility and relevance should you get to that point.
I will now opt out and see if someone can find an actual case on point... but I doubt it.
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