📧 "Documents to be produced" to OSU

SCHEDULE A — DOCUMENTS AND THINGS TO BE PRODUCED 

Subpoena Recipient: Office of General Counsel - Oregon State University (Department of Public Safety), 630 Kerr Administration Building, Corvallis, Oregon 97331 

Case: Isaac v. Boshart Davis et al., No. 6:25-cv-01159-MC (D. Or.) Issuing Court: United States District Court, District of Oregon, Eugene Division 

DEFINITIONS 

1. "You" and "Your" mean the Oregon State University Department of Public Safety ("OSU DPS"), including Interim Chief James Yon and OSU DPS officers, employees, and agents, and include records held by OSU DPS on behalf of "the OSU Threat Assessment Team." 
2. "Plaintiff" means Logan Martin Isaac. 
3. "OSP" means the Oregon State Police, including Lieutenant Casi Hegney. 
4. "Legislative Personnel" means the Oregon Legislative Assembly, Legislative Administration, any legislative office, and any legislator or legislative staff member, including Defendants Shelly Boshart Davis and Renee Perry. 
5. "Capitol Restrictions" means any restriction, condition, or exclusion on Plaintiff's access to the Oregon State Capitol, including the conditions for entry communicated to Plaintiff in or about February 2025 and any later modification or rescission of them. 
6. "The Yon Email" means the April 4, 2025 email from James Yon to Lieutenant Casi Hegney, produced by OSP as ISAAC-OSP-SDT-000039, in which Mr. Yon refers to "the OSU Threat Assessment Team" and to "a case involving Isaac." 
7. "Communication" means any written, electronic, or recorded exchange, including emails, text messages on any device (including personal devices used for OSU DPS business), voicemails, letters, memoranda, internal messages, and notes of calls or meetings. 
8. "Relevant Period" means December 1, 2024 through the date of Your response, unless an item states otherwise. 

SCOPE LIMITATION 

This request is limited to the Yon Email, Communications between You and OSP or Legislative Personnel concerning Plaintiff, and records concerning Plaintiff's Capitol Restrictions. It does not seek records of Plaintiff's May 6, 2025 meeting, Exclusion Notice 2025-082137, or the April 1, 2026 incident (Case 202600281), except to the extent a document is independently responsive to an item below. 

INSTRUCTIONS 

Produce all responsive materials in native format with metadata intact, or in searchable PDF with a load file if native production is not feasible. 

For any document withheld on a claim of privilege, provide a privilege log identifying the date, author(s), recipient(s), general subject matter, and privilege asserted. 

You may redact personally identifying information of students and non-party third parties that is protected from disclosure by law. For each redaction, identify the legal basis in a log entry. 

For any responsive item that no longer exists, identify it, state the date and manner of loss, and state the retention policy applied. 

ITEMS TO PRODUCE 

1. The Yon Email in native format with metadata, together with all replies, forwards, and attachments, and all Communications between You and OSP concerning Plaintiff during the Relevant Period. 
2. All Communications between You and Legislative Personnel concerning Plaintiff or the Capitol Restrictions during the Relevant Period. 
3. All records concerning Plaintiff created or received by You on or before April 4, 2025 that refer to OSP, Legislative Personnel, or the Capitol Restrictions, including any report, complaint, intake, or case-opening record for the matter described in the Yon Email, and documents sufficient to show who initiated that matter and when. 
4. All internal Communications among OSU DPS personnel, and between OSU DPS and the OSU Threat Assessment Team, before April 4, 2025 that describe or discuss the Capitol Restrictions. 
5. Documents sufficient to identify each member or participant of the OSU Threat Assessment Team referenced in the Yon Email at the time of the Yon Email. 
6. Your retention policies applicable to email, text messages, case files, and threat assessment records, and documents sufficient to show whether any responsive record was deleted, altered, or lost at any time after April 4, 2025.