📧 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 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].