📧 to White "Following up on OSP's objections to Items 6 and 7"
Tracy,
Following up on OSP's objections to Items 6 and 7 of the subpoena, specifically the objection that "events on December 10, 2024" are "not part of the operative complaint" and therefore not reasonably calculated to lead to the discovery of admissible evidence.
LAC has already produced a document responsive to that same date and subject matter: an April 8, 2025 email from Trooper Hegney to Brett Hanes (Bates ISAAC-LAC-SDT-000249, forwarding chain continuing to -000258), forwarding an internal OSP thread from December 10, 2024. That thread references a complaint of "racist remarks" made by ODVA Director Nakeia Daniels and states that Trooper Anspaugh-Lubans performed a threat assessment in response, with a log entry summarizing the investigation and its conclusion.
Two items remain outstanding and are squarely within Items 6 and 7 as served:
- The complaint, report, or referral — however documented — that initiated Trooper Anspaugh-Lubans' assessment; and
- The complete threat assessment itself, of which the log entry in the Hegney email appears to be a summary rather than the full record.
Given that LAC has already produced material from this same date and incident despite lodging a parallel objection, please confirm in writing whether OSP intends to produce these two items, or whether OSP is maintaining its objection as to them specifically. I'd like to resolve this before further motion practice.
