From: (USAFLS)" To: ' (USAFLS)" (USAFLS)" Subject: FW: discovery issues in the CVRA case mtc on final production? motion for extra pages? etc. What's your position? Date: Thu, 07 May 2015 13:15:34 +0000 Importance: Normal I was going to seek a two week extension, from May 14, 2015 to May 28, for the government to respond to the supplemental request for production and request for admissions. I have a summary judgment due on May 15, which is consuming much of my time. I understand from Ed that you are going to be out of the office on vacation for an extended period. I need your assistance in responding to the requests for production that we are not objecting to, as well as the requests for admissions, that we are not objecting to. Is the two weeks, to May 28, 2015, enough for you? Do you have any more responsive documents to produce? The last time we spoke, you were going through a batch of emails to determine if they were responsive. Once you have completed that review, and we turn over what is responsive and not privileged, I believe we can certify that we conducted a reasonable search for responsive documents and have either produced them or invoked a privilege. I would like to respond to Cassell today. Thanks. From: Paul Cassell [mailto: Sent: Thta May 07, 2015 8:47 AM To: M, (USAFLS); , (USAFLS); (USAFLS) Cc: Brad Edwards Subject: RE: discovery issues in the CVRA case - mtc on final production? motion for extra pages? etc. What's your position? Dear 1. As you know from the email sent to you (and others in your office) more than a week ago (see below), we are trying to voluntarily obtain final production from you of court-ordered discovery. You have refused to do so voluntarily and now, more than a week later, we have not even received any answer from you to our email. Accordingly, we are preparing a motion to compel, asking the Court to direct you to provide by a date certain all discovery that you have been ordered to produce.