📧 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 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).