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# 📧 to Abrams: "two matters"
- URL: https://gijustice.com/20261001-0800-ordoj/
- Published: 2026-10-01T15:00:00.000Z
- Updated: 2026-11-10T19:48:46.000Z
- Author: Logan M Isaac
- Tags: ORDOJ, 6-25-CV-01159-MC, Marc Abrams

Thank you for stepping in for Ms. White. I'm writing about two matters and would like to discuss both by phone.

**Depositions.** In the LAC production I found an email from Ms. Perry to Mr. Hanes dated February 21, 2025, in which she wrote: "If only the conceal carry would be overturned for Members and staff, I could carry and NEVER feel unsafe or undefended - again." (ISAAC-LAC-SDT-000348) The same email says she wants to work "\[w\]ithout fearing for my physical safety," which I understand to refer to me. Given that, I am not comfortable deposing her in person at my place of business, which is the only location available to me at no cost.

I will therefore reschedule the Perry and Davis depositions, currently noticed for October 11 and 18\. I will ask the Court for leave to take them at the Courthouse, where security can be arranged. Please let me know by Friday, October 2, 2026, whether Defendants will stipulate or oppose. I am not going to proceed at the Salem DOJ office.

**LAC production.** The production is labeled ISAAC-LAC-SDT-000273 to 000490, but the last page I received is 000463\. Pages 000435 to 000459 are missing, and 000464 to 000490 are unaccounted for. There are also redactions without a privilege log, including 000279, 000322, 000425 and 000461, although LAC stated it would provide one (see Fed. R. Civ. P. 45(e)(2)(A)). On July 30 the State represented that roughly 750 further pages would follow the 22 OSP pages and 271 LAC pages already produced, and what I received is well short of that. Separately, I have found no communication that is clearly authored by Representative Davis apart from the signed February 7 letter. Please confirm whether her own devices and accounts were searched.

By Sunday, October 4, 2026, please provide the missing pages, a privilege log, and a written statement of what remains outstanding. 

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