> ## Content Index
> Fetch the complete content index at: https://gijustice.com/llms.txt
> Use this file to discover other available public pages before exploring further.

# 📧 to White "we have conferred"
- URL: https://gijustice.com/20260811-1451-white/
- Published: 2026-08-11T21:51:00.000Z
- Updated: 2026-08-12T00:59:44.000Z
- Author: Logan M Isaac
- Tags: Tracy White, ODJ

Tracy,

To be precise: [I have not expressed a feeling](https://gijustice.com/20260811-1437-white/). 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 on that basis going forward.

For the record: **this is the second time an extension of Ms. Davis's independent August 14 deadline has been proposed**. On July 31, the basis offered was that Ms. Perry helps her prepare responses and that she's occupied with her farm this summer — I declined, as that establishes inconvenience, not incapacity. Today's proposal — that her responses to jointly-directed requests should ride on Ms. Perry's separate medical extension — I decline for the reasons above.

We have conferred. You're welcome to state that in any communication to the Court, along with my opposition and the basis given. I have no objection to you raising this with \[the courtroom deputy\].