Protected class in the statutes. Second-class in the streets.

📧 to USDOJ: "uninformed about your client's own prior efforts"

Hi Chelsea, it was good to chat just now.  This email is to follow up on that call, in which I reiterated that I did not hear in your request any tangible, concrete reason for the government's request for more time other than a vague desire. In our

📧 to USDOJ "it’s your job"

That’s not much detail, it’s more like a description of your job. If you cannot do your job by meeting the legal deadline, and have to ask the court for an extension, then please inform the Judge I do not agree for the reason stated above; it’s

📧 from USDOJ "I am working"

I am working to receive the information needed to ensure that our response is complete and accurate by collaborating with the FOIA teams in the Civil Rights and National Security Divisions. Individuals within those teams provide the information that informs my response to your complaint. A two-week extension would

📧 to USDOJ "I cannot agree"

I cannot agree to the two-week extension at this time. Please provide more detailed information regarding the reasons for the delay so I can reconsider your request.

📧 from Wein, USDOJ

I am an Assistant United States Attorney in the District of Oregon, and I have been assigned to your Freedom of Information Act case involving the DOJ Civil Rights and National Security Divisions. I am working to get the information needed to respond to your request. Would you be willing

📧 to McShane: "email is correspondence, not conferral"

The attached email is correspondence, not conferral. LR 7-1(a)(1)(A) requires a personal or telephone conference; an email exchange doesn't substitute for one, however it's characterized. I offered three specific call times on September 13; none has been accepted. Plaintiff renews its opposition

📧 from White: "My ability to prove a prior conversation"

Attached is a copy of my earlier email today with Mr. Isaac discussing my desire to have conferral by email rather than phone or in person.  My ability to prove a prior conversation this way is the reason I want to limit conversations to email.

📧 to McShane: "No good cause is shown"

Plaintiff opposes Ms. White's request to require all party conferrals to be conducted by email. No good cause is shown. Ms. White's stated reason — wanting an "accurate record" of conversations — identifies no specific incident from this case's phone or personal conferrals that

📧 from White: "I want to be sure any conversations... be accurately recorded"

Thank you for your response.  I am sorry to trouble you with an additional matter, which I am happy to file as a motion if that would be better.  I am requesting the Court to allow conferrals between the parties by email, rather than by personal or telephone contact.  Plaintiff

📧 from McShane: "Defendants shall have until 9/25/2026"

All, Defendants shall have until 9/25/2026 to produce the documents at issue here. Going forward, the Court will refrain from managing the deadlines set by the parties between themselves for specific discovery items absent any indication of an effort to withhold discoverable material. The Court set the deadline

📧 to McShane: "extending any Davis-specific deadline"

Noted — to be clear, Plaintiff's objection to extending any Davis-specific deadline without a Davis-specific reason stands, regardless of scope.

📧 from White: "I appreciate Mr. Isaac’s agreement"

Greetings!  In response to this, I appreciate Mr. Isaac’s agreement about Ms. Perry.  As for Representative Davis-Boshart, I believe the only information that would be postponed by this request would be responses to interrogatories.  Document production continues.