6:26-cv-00832-MTK
📧 to USDOJ: "I cannot agree"
I cannot agree to the two-week extension at this time. Please provide more detailed information regarding the reasons for the delay so I can reconsider your request.
6:26-cv-00832-MTK
I cannot agree to the two-week extension at this time. Please provide more detailed information regarding the reasons for the delay so I can reconsider your request.
6:26-cv-00832-MTK
I am an Assistant United States Attorney in the District of Oregon, and I have been assigned to your Freedom of Information Act case involving the DOJ Civil Rights and National Security Divisions. I am working to get the information needed to respond to your request. Would you be willing
Mac Loftin
Thanks for the reply, and for the specific pushback — I want to take it seriously rather than just restate myself. On the letter to the editor: I won't be sending Century a condensed version, and I won't be pitching them anything else either. I have a
Mac Loftin
Thanks for this message, and I appreciate the careful and critical read of my essay. I know the Century’s submission process is backed up, but you should condense this down to a letter to the editor. They frequently publish critical letters. Just as a quick response over email, I
Michael McShane
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
Tracy White
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.
Michael McShane
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
Tracy White
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
Michael McShane
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
Michael McShane
Noted — to be clear, Plaintiff's objection to extending any Davis-specific deadline without a Davis-specific reason stands, regardless of scope.
Tracy White
Greetings! In response to this, I appreciate Mr. Isaac’s agreement about Ms. Perry. As for Representative Davis-Boshart, I believe the only information that would be postponed by this request would be responses to interrogatories. Document production continues.
Michael McShane
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