Michael McShane

📧 to McShane: "42 days since service"

Thank you for the call. Per your request, here is what I'm asking the Court to compel from OSP and LAC's June 8, 2026 subpoenas. It has been 42 days since service. Production to date is video and incident reports from OSP; LAC has produced nothing.

OSP — outstanding:

Item 5 (no objection raised): documents/communications reflecting OSP's role in creating, requesting, recommending, approving, implementing, or enforcing the Access Restrictions.
Items 1, 2, 3, 4 (as to communications; excludes Senator Manning per OSP's own objection), 6, 7, 8, 10 (policies/SOPs), 11, and 12: OSP conceded, in narrowed form, to produce each of these and has not done so.

LAC — outstanding:

Item 7 (no objection raised): documents/communications concerning the Access Restrictions, including factual basis, requests or recommendations to impose them, and approval or authorization.
Items 6 and 11: LAC conceded, in narrowed form, to produce these and has not done so.

Happy to provide the underlying subpoenas, objections, and correspondence on request. Available at the Court's convenience.

📧 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