Michael McShane

📧 from McShane: "Defendants shall have until 9/25/2026"

All,

Defendants shall have until 9/25/2026 to produce the documents at issue here. Going forward, the Court will refrain from managing the deadlines set by the parties between themselves for specific discovery items absent any indication of an effort to withhold discoverable material. The Court set the deadline by which fact discovery is to be completed on 11/5/2026. The parties may request reasonable extensions to this deadline supported by good cause.

📧 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"