An extra 27 months to respond to a discovery request because State is just too busy to produce the documents within the time required by the Federal Rules???????? Unbelievable! I hope the judge slams them.
https://www.law.cornell.edu/rules/frcp/rule_6
http://civilprocedure.uslegal.com/discovery/federal-rules-of-civil-porcedure-regarding-discovery/
Time to supply measured by hours, not months. Over two YEARS?
https://www.law.cornell.edu/rules/frcp/rule_45
Seems appropriate for a Motion to Compel production by Citizens, and requesting sanctions.