6-25-CV-01159-MC

📧 from White "I am proposing" more time for SBD

Hi Logan,

As we discussed, you have agreed to extend the time for Ms. Perry to respond to the pending discovery requests by 30 days. However, some of the requests are to both the defendants, specifically, the Requests for Admissions, the Requests for Production, and the “Interrogatories to Both Defendants” (starting on page 9 of the Interrogatory document. I believe these should also be included in the extended time for response.

To clarify, I am proposing to serve the responses to the Interrogatories to Shelly Boshart Davis (pages 6-8 of the Interrogatory document) by August 14, and hold off on the others until 30 days after August 14 (which is September 13, but that’s a Sunday so the due date would be September 14).

Thank you.

📧 to White "Two points, briefly"

Tracy, Thank you for the response. Two points, briefly. First, on the "not part of the operative complaint" objection: LAC has already produced ISAAC-LAC-SDT-000249, a document from this same date and subject matter, without maintaining a relevance objection against it. I'm not asking

📧 from White "We are not planning to produce"

Hi Logan, We are not planning to produce those. The Court has limited the case to the two Capitol restrictions occurring in January and February 2025. There is no indication this “threat assessment” bears on those.

📧 to White "we have conferred"

Tracy, To be precise: I have not expressed a feeling. Fed. R. Civ. P. 33(b)(1)(A), 34(b)(2)(A), and 36(a)(3) places the response obligation on "the party to whom the request is directed." I'd ask that my position be addressed

📧 from White "sorry you feel that way"

I’m sorry you feel that way. I will file a motion for an extension. I will state we’ve conferred unless you think we should discuss more? At 1445 Actually, I will be emailing the Court Deputy, as you previously did, to see if a formal motion is necessary.

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📧 to White "Two points, briefly"

📧 from White "We are not planning to produce"

📧 to White "we have conferred"

📧 from White "sorry you feel that way"