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.
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
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
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.
Tracy, I do not agree to the proposed bifurcation. Ms. Perry's extension to September 13/14 was agreed based on her individual circumstances and applies to her responses only. I expect Ms. Davis's complete responsive material — the Requests for Admission, Requests for Production, and all Interrogatories