📧 to McShane: "ask that Defense be held to... FRCP"

Thank you for the reminder. To be precise about what's pending: I have not asked for an extension of the Rule 16 discovery deadline (11/5), and I don't need one. My request is narrower — an order compelling OSP and LAC to complete production on Plaintiff's June 8 subpoenas by a date certain, under Fed. R. Civ. P. 45(d)(2)(B)(i). That is third-party subpoena compliance, not a scheduling-order extension, and it doesn't require the parties to confer on a Rule 16 motion.

I'd ask that Defense be held to the same production standards and timelines the FRCP requires of any party or non-party under subpoena. Had Defense provided a reasonable, committed timeframe for production when OSP and LAC first conceded these materials were non-objectionable, this request — and today's exchange — would not have been necessary.

I remain available for a phone conference at the Court's convenience.