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# 📧 to White "Two points, briefly"
- URL: https://gijustice.com/20260811-1634-white/
- Published: 2026-08-11T23:34:00.000Z
- Updated: 2026-08-12T01:04:30.000Z
- Author: Logan M Isaac
- Tags: ODJ, Tracy White

Tracy,  
  
Thank you for [the response](https://www.gijustice.com/20260811-1611-white?ref=gijustice.com). 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 you to reconcile OSP's position with LAC's — I'm noting that **the same counsel representing both agencies has treated this subject matter as producible in one instance and objectionable in the other,** on materials arising from the same underlying event.  
  
Second, on relevance itself: Rule 26(b)(1) measures relevance against the claims and defenses actually pled, not against whether a specific date appears in the operative complaint. **A contemporaneous OSP threat assessment of me**, conducted seven weeks before the conduct at issue in this case, **is** **reasonably calculated to bear on defenses already raised, independent of whether December 10, 2024 itself is a pled date.**  
  
Please let me know by August 14 whether OSP will produce (1) the complaint or referral that initiated Trooper Anspaugh-Lubans' assessment, and (2) the complete assessment itself, of which the log entry in the Hegney email appears to be a summary. **Absent that, I intend to move to compel these two items specifically** under Rule 45(d)(2)(B)(i).