Tracy White
Tracy, To be precise: I have not expressed a feeling. Fed. R. Civ. P. 33(b)(1)(A), 34(b)(2)(A), and 36(a)(3) places the response obligation on "the party to whom the request is directed." I'd ask that my position be addressed
Tracy White
I’m sorry you feel that way. I will file a motion for an extension. I will state we’ve conferred unless you think we should discuss more?  At 1445 Actually, I will be emailing the Court Deputy, as you previously did, to see if a formal motion is necessary.
ODJ
Tracy, I do not agree to the proposed bifurcation. Ms. Perry's extension to September 13/14 was agreed based on her individual circumstances and applies to her responses only. I expect Ms. Davis's complete responsive material — the Requests for Admission, Requests for Production, and all Interrogatories
ODJ
Hi Logan, As we discussed, you have agreed to extend the time for Ms. Perry to respond to the pending discovery requests by 30 days. However, some of the requests are to both the defendants, specifically, the Requests for Admissions, the Requests for Production, and the “Interrogatories to Both Defendants”
ODJ
Tracy, Rule 26(b)(1)’s standard is relevance to a claim or defense — not whether the December 10, 2024 assessment is itself connected to the later restrictions. Two points: First, to the extent Defendants’ position rests on any security rationale for the access restrictions, OSP’s own threat-assessment
ODJ
Hi Logan, Our production of an email referencing a prior situation does not mean we are conceding the relevancy of the prior information. I have no information suggesting the alleged December 10, 2024 “threat assessment” had anything to do with the later restrictions on your visiting Representative Boshart Davis’s
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:
ODJ
Tracy, Following up on OSP's objections to Items 6 and 7 of the subpoena, specifically the objection that "events on December 10, 2024" are "not part of the operative complaint" and therefore not reasonably calculated to lead to the discovery of admissible evidence. LAC
6-25-CV-01159-MC
Thank you for the reminder. To be precise about what's pending: I have not asked for an extension of the Rule 16 discovery deadline (11/5), and I don't need one. My request is narrower — an order compelling OSP and LAC to complete production on Plaintiff&
6-25-CV-01159-MC
All, Judge McShane would like to remind Mr. Isaac that the discovery deadline is not until 11/5 and that if the parties need more time to complete discovery, they should confer and then file a motion for extension of time.
Michael McShane
I want to correct the record before Judge McShane reviews this thread. Ms. White's email states that I "provide[d] nothing to suggest the agencies or DOJ have been behaving in anything other than good faith." That statement holds me to an evidentiary standard it does
Tracy White
This email is in response to plaintiff’s email dated July 17, 2026. As you know, I represent the defendants in this matter. I also represent the agencies who were issued document subpoenas by plaintiff: the Oregon State Police (“OSP”) and the Legislative Administration Committee (“LAC”). Attached are the subpoenas