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# 📧 to McShane: "This material is unobjected"
- URL: https://gijustice.com/20260828-1412-mcshane/
- Published: 2026-08-28T21:12:00.000Z
- Updated: 2026-09-15T03:21:29.000Z
- Author: Logan M Isaac
- Tags: Michael McShane, Tracy White, 6-25-CV-01159-MC

I write regarding a discrete, ripe issue separate from the pending ECF 33 motion.

On July 30, 2026 (see attached), defense counsel represented in writing to the Court that OSP and LAC's remaining non-objected production (\~750 pages, in addition to the 22 pages/3 videos and 271 pages/1 video already produced) would be "out to plaintiff in the next 2-3 weeks." That window closed on or before August 20, 2026\. It is now August 28, and no further production or updated estimate has followed.

This material is unobjected — it is not the relevance dispute raised in ECF 33 (Items 6 & 7). Its continued absence is imposing ongoing burden and delay disproportionate to what Rule 26(b)(1) contemplates for conceded, non-objected material.

I respectfully ask the Court to compel OSP and LAC to complete production of this outstanding non-objected material by a date certain under Fed. R. Civ. P. 45(d)(2)(B)(i).