Tracy White

📧 from White: "he does not agree to the extension"

The parties have a number of discovery disputes besides the one Mr. Isaac outlined. I plan to send an email outlining those shortly. But of immediate concern to the State Defendants is the need to push out the September 14^th deadline for discovery responses by another two weeks.

As you know, on August 18, 2026, ECF No. 32, the Court granted Defendants Perry and Davis-Boshart through September 14 to respond to discovery requests, based primarily on Ms. Perry’s surgery and recovery period. Unfortunately, her recovery has not gone as well as hoped and she remains on leave through a doctor appointment set for Sept. 14. Hopefully, she’ll be released at that time. However, due to this extended recovery period, she has not been able to work with me on the discovery responses. We are requesting through September 25 to file these responses.

I have conferred with plaintiff on this and he does not agree to the extension.

📧 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"