Michael McShane

📧 to McShane: "This material is unobjected"

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).

📧 to McShane: "email is correspondence, not conferral"

The attached email is correspondence, not conferral. LR 7-1(a)(1)(A) requires a personal or telephone conference; an email exchange doesn't substitute for one, however it's characterized. I offered three specific call times on September 13; none has been accepted. Plaintiff renews its opposition

📧 from White: "My ability to prove a prior conversation"

Attached is a copy of my earlier email today with Mr. Isaac discussing my desire to have conferral by email rather than phone or in person. My ability to prove a prior conversation this way is the reason I want to limit conversations to email.

📧 to McShane: "No good cause is shown"

Plaintiff opposes Ms. White's request to require all party conferrals to be conducted by email. No good cause is shown. Ms. White's stated reason — wanting an "accurate record" of conversations — identifies no specific incident from this case's phone or personal conferrals that

📧 from White: "I want to be sure any conversations... be accurately recorded"

Thank you for your response. I am sorry to trouble you with an additional matter, which I am happy to file as a motion if that would be better. I am requesting the Court to allow conferrals between the parties by email, rather than by personal or telephone contact. Plaintiff

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📧 to McShane: "email is correspondence, not conferral"

📧 from White: "My ability to prove a prior conversation"

📧 to McShane: "No good cause is shown"

📧 from White: "I want to be sure any conversations... be accurately recorded"