📧 from White
Dear Mr. Isaac,
Alice Jayne is my paralegal, who will be helping with document collection and production. I do not feel comfortable copying Mr. Tribble and do not plan to do so.
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📧 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