Michael McShane

📧 to McShane: "oppose extending Defendant Davis's deadline"

Plaintiff does not oppose an extension for Defendant Perry given the medical circumstances described.

Plaintiff does oppose extending Defendant Davis's deadline on this basis. This is the third time State Defendants have sought to move Davis's independent deadline by tying it to Ms. Perry's circumstances rather than any reason specific to Davis: on July 31, 2026 (citing Perry's assistance and farm/harvest commitments) and again on August 11, 2026 (proposing bifurcation onto Perry's medical track). Both requests were declined, and Davis served complete, substantive responses by the operative deadline (August 14, 2026) regardless. Nothing in today's request identifies a Davis-specific basis for further delay.

Separately, for the Court's awareness: these are supplemental responses to discovery served June 24, 2026, with an original 30-day response deadline of July 24. That deadline has already moved twice — to August 14, then to September 14 — and the current request would move it a third time, to September 25: a 93-day response period against a 30-day rule. The November 5 fact-discovery cutoff and November 20 dispositive-motion deadline have not moved. Each extension narrows Plaintiff's remaining time to review production and prepare for the October depositions within those fixed dates.

Plaintiff respectfully requests that any further extension be limited to Defendant Perry.

📧 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"