📧 from USDOJ: "I have requested an extension"
I have requested an extension for both the NSD and CRD answers, not only the NSD answer. I have filed with the court since I did not hear from you. Your opposition to the extension was noted.
I have requested an extension for both the NSD and CRD answers, not only the NSD answer. I have filed with the court since I did not hear from you. Your opposition to the extension was noted.
Thank you for the clarification. If you give me a date certain by which the DOJ is willing to represent to the Court that the NSD will submit its Final Response to me, I am willing to grant an extension to the NSD answer. I am not willing to grant
As I indicated on our call, the National Security Division has conducted searches for responsive documents and is preparing to issue a final response. The requested extension would allow time to simultaneously issue that final response and respond to your Complaint, which requires a separate response in addition to the
To clarify - time has passed. My question, before I allow an extension, is what exactly has been done with time your agency has already had to respond to this request? I can't in good faith grant more time without knowing whether the DOJ can be trusted as a
As I stated on the call, the reason for our request is to allow time to receive the necessary information to respond to your complaint and to simultaneously prepare a final response to your FOIA request involving the National Security Division. I am unable to speak to FOIA requests you
Hi Chelsea, it was good to chat just now. This email is to follow up on that call, in which I reiterated that I did not hear in your request any tangible, concrete reason for the government's request for more time other than a vague desire. In our
That’s not much detail, it’s more like a description of your job. If you cannot do your job by meeting the legal deadline, and have to ask the court for an extension, then please inform the Judge I do not agree for the reason stated above; it’s
I am working to receive the information needed to ensure that our response is complete and accurate by collaborating with the FOIA teams in the Civil Rights and National Security Divisions. Individuals within those teams provide the information that informs my response to your complaint. A two-week extension would
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.
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
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
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
Tracy White
The parties have a number of discovery disputes besides the one Mr. Isaac outlined. I plan to send an email outlining those shortly. But of immediate concern to the State Defendants is the need to push out the September 14th deadline for discovery responses by another two weeks.  As you
Michael McShane
You have filed a Motion to Compel. The Court will await defense filed response and rule accordingly.
Michael McShane
I write regarding a discrete, ripe issue separate from the pending ECF 33 motion. On July 30, 2026 (see attached), defense counsel represented in writing to the Court that OSP and LAC's remaining non-objected production (~750 pages, in addition to the 22 pages/3 videos and 271
6-25-CV-01159-MC
Isaac v. Manning et al., No. 6:25-cv-01159-MC (D. Or.) is a federal civil-rights lawsuit against James Ivory Manning Jr., Shelly Boshart Davis, Renee Perry, and Doe defendants, filed in the U.S. District Court for the District of Oregon on July 3, 2025. Docket Text:
Michael McShane
Here is Judge McShane’s response to Mr. Isaac’s questions below. 1. Because the Court granted the defendants' request to set a deadline of September 14, 2026 for the production of certain outstanding materials, the Court denied Plaintiff's request to compel production in advance of September
Michael McShane
I write to request clarification on the procedural status of third-party subpoena production from Oregon State Police and Legislative Administration & Services. Timeline: * June 8, 2026: Subpoenas served on OSP and LAC (14-day compliance term, due June 22) * June 22–25, 2026: Partial production received only after Court-