📧 to ORDOJ: "Mr. Abrams may answer"

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📧 to ORDOJ: "Mr. Abrams may answer"

Thank you for the re-send. I will compare it against the 9/25 folder and report any difference.

1. My reaction. My 👍 to Ms. White's September 25, 4:04 PM email acknowledged receipt. It did not agree that a reduced production satisfies the July 30 representation of approximately 750 pages, and it waived nothing. That email gave no page count and no de-duplication method.

2. Bates. As I received it, the 9/25 production runs ISAAC-LAC-SDT-000273–000434 and 000460–000463. Please identify, by file name and page count, where 000435–000459 and 000464–000490 appear.

3. De-duplication. Please state the page count before and after de-duplication, whether it was done within or across custodians, and whether attachments were de-duplicated (LR 26-1(2)(D)).

4. Log. On June 23, 5:21 PM, Ms. White wrote: "We will be providing an FRCP-compliant privilege log once we have produced the documents." By the State's account, production concluded September 25. Objections were served June 18, and LR 26-5(b) requires the log "within a reasonable time after" them. Please provide the log, or a date certain in writing, by Sunday, October 4. If Ms. White is unavailable, Mr. Abrams may answer.