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# from White: "discovery concerns are unjustified"
- URL: https://gijustice.com/20260625-1158-white/
- Published: 2026-06-25T18:58:00.000Z
- Updated: 2026-09-15T02:50:18.000Z
- Author: Logan M Isaac
- Tags: Tracy White, Michael McShane, 6-25-CV-01159-MC

Dear Ms. Pew,

This is in response to Plaintiff’s email regarding the response to subpoenas send to the Oregon State Police (“OSP”) and the Legislative Administration Committee (“LAC”). I’ve attached copies of the subpoenas here. 

First, as I stated in conferral with Plaintiff, LAC is, in fact, searching for emails to or from Senator Manning regarding the access restrictions. See Plaintiff’s pdf containing the email between Plaintiff and myself (“Email pdf”), page 6: “We have searched for him after all.” Therefore, Plaintiff’s concerns are unfounded.

Second, the objection to producing documents based on security concerns is justified. The requested items from LAC are: “All documents identifying the cameras, recording devices, or systems that were operating in the areas of the Capitol through which Plaintiff moved on December 10, 2024, and January 27, 2025, including any floor plans, camera maps, or system inventories.” See LAC subpoena, page 4\. It is obvious on its face that this request is broad and invasive of security. Moreover, Plaintiff has indicated no reason why such a broad request is relevant to his case. Note that Plaintiff has also requested any recordings of Plaintiff at the Capitol on those dates, which do not exist. See LAC subpoena, page 3, Item 1; LAC objections, page 2, Item 1\. Therefore, this additional request is unnecessary. 

Third, the Oregon State Police does intend to produce footage from the January 27, 2025, incident. The objection was only in the event something concerning was identified and redacted, which has not happened and is not anticipated to happen. As I told Plaintiff, “If we redact any portion of the footage, we’ll let you know.” Email pdf, page 3\. I also stated, “We can’t provide this information \[regarding redaction\] until we’ve reviewed the material and made a determination.” Email pdf at 6\. This concern is thus premature and unlikely to happen. 

For these reasons, Plaintiff’s discovery concerns are unjustified and should be rejected.