6-25-CV-01159-MC

OSU Subpoena Response

On Behalf of Kareem Walcott, please find Oregon State University's objections to the subpoena recieved by our office on October 19, 2026. A copy of this letter will also be sent via US Mail.

Greetings. Pursuant to Fed. R. Civ. P. 45, this letter constitutes non-party OSU's objections to the above-referenced subpoena.

OSU makes the following objections to the subpoena in its entirety. Any response to the subpoena that may occur is subject to and without waiving any of these objections. Unless otherwise stated, each general objection is incorporated into OSU's response to each and every category of documents requested. OSU reserves the right to raise other objections in the event of any motion hearing on the subpoena.

GENERAL OBJECTIONS

Pursuant to Fed. R. Civ. P. 45(d)(l) and 45(d)(2)(B), OSU objects to the subpoena as overly broad and unduly burdensome as written and for at least the following reasons:

OSU is not a party to this proceeding. OSU objects to the subpoena requests to the extent that they seek information and/or documents that are not within OSU's possession, control, or custody. Similarly, OSU objects to the subpoena requests insofar as they would require OSU to produce documents in the possession, custody, or control of any entity (party or otherwise) other than OSU.
OSU objects to the subpoena requests to the extent they seek information and/or documents that Plaintiffs could seek or retrieve through sources other than OSU andvia less burdensome steps, such as through parties to the litigation, public sources, records that are equally available to Plaintiffs, or the survey offered by Defendants as a less burdensome means to coordinate with conference offices to collect the information Plaintiffs seek. See Rule 45(d)(l) (requiring a party issuing a subpoena to "take reasonable steps to avoid imposing undue burden or expense on a person subject to that subpoena.").
OSU objects to the subpoena requests, including Schedule A containing Definitions and Instructions, to the extent they are unreasonable and create an undue burden on OSU to (a) object in all particulars; and (b) that they propose obligations beyond or inconsistent with obligations imposed by the Federal Rules of Civil Procedure and related authorities.
OSU objects to the subpoena as unduly burdensome. In more detail, OSU objects to the subpoena to the extent it seeks discovery of both electronically stored information and non-electronically stored information from sources that are not reasonably accessible in light of the burdens or costs required to locate, restore, review and produce whatever responsive information may be found.
OSU objects to the subpoena Scope Limitation to the extent it seeks information outside of the identified Scope Limitation as vague and ambiguous, overly broad and unduly burdensome because, among other things, they purpmi to require investigation or determination of records that are outside of the Scope Limitation that may independently be responsive to a requested item.
OSU objects to: (a) all requests with language "documents sufficient to ... ,"; (b) the Definitions, including Numbers l, 3, 4 and 7 of Schedule A, as vague and ambiguous, overly broad and unduly burdensome because among other things, they purport to require investigation or determination of or what falls within the expansive wording or definition provided.
Pursuant to Fed. R. Civ. P. 45(e)(2), OSU objects to the extent that information requested contains attorney-client privileged communications, or otherwise protected by the work-product doctrine or similar privileges, laws or immunities. Due to the overly broad and unduly burdensome request, it is not possible to search, review and specify at this stage if such material exists and which materials would be listed in a privilege log, and therefore OSU retains a right to claim privilege or protection over certain communications or documents if necessary, in the future.
OSU objects to Instruction as vague, ambiguous, overly broad and unduly burdensome to the extent records are outside of OSU's record retention policy. For records outside ofOSU's record retention policy, OSU has no way of knowing if a responsive record existed and, if it did exist, was purged per our policies.
OSU objects to the subpoena requests to the extent they seek information including confidential business or other proprietary information, confidential information received by OSU pursuant to an obligation of confidentiality or nondisclosure, or personal information that is not public. OSU will determine if nonpublic personal information require appropriate redactions and notifications to limit risk of public disclosure of personal information. Confidential information captured in Plaintiffs' broad requests that is neither relevant nor reasonably calculated to lead to discovery of relevant evidence will not be produced by OSU, because such production is unduly burdensome relative to the limited value of such information to determine the issues, facts and legal questions in this litigation.
OSU objects to all request in the Subpoena to the extent they seek "all documents" or "all records" as those terms are not particularly defined and as a result would require unreasonable, overbroad searches and production of unnecessary and duplicative documents.
OSU objects to the subpoena requests to the extent they seek "all documents" or "all communications" relating to a particular topic since 2024, which would require unreasonable, overbroad searches and production of unnecessary and duplicative documents.
OSU objects to Requests 2, 3, 4 and 5 to the extent they seek records outside of the Scope Limitation as they are not relevant to the underlining matter.

Any below responses that OSU submits will be sent to the email address logan@pewpewhg.com and are notwithstanding and subject to these objections. Please let me know if you withdraw this subpoena, narrow the subpoena or will provide more time, or file any Motion to Compel.