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# 📧 from Abrams: "a party has proven to be an unreliable narrator"
- URL: https://gijustice.com/20261001-1145-ordoj/
- Published: 2026-10-01T18:45:00.000Z
- Updated: 2026-11-10T19:49:57.000Z
- Author: Logan M Isaac
- Tags: ORDOJ, 6-25-CV-01159-MC, Marc Abrams, Tracy White

First of all, please do not presume to give direction to Ms. Jayne. She works for the Department of Justice and is part of the team representing defendants. She does not work for you and, to the extent any of your requests conform to the Rules of Civil Procedure, I or Ms. White will provide her direction; to the extent they do not, they will not be complied with.

Second, there has not been a “reduced production.” There has been production. Period. As I informed you in [my last e-mail](https://gijustice.com/20261001-0943-ordoj/), the estimate from July was just that. An estimate. There will be no second count provided, no direction from this office to you as to where to find documents. Nor will this office respond to the question about de-duplication. Our obligation is to provide discovery, not to walk you through our process. LR 26-1(2)(D) only states that “parties must discuss the possibility and feasibility of eliminating duplicative ESI.” It does not require page counts or discussion of techniques when de-duplication *has already occurred.*

Third, I have already told you that you will get a privilege log when it is possible given our other cases, our other workload, and time to produce a privilege log. Ignoring me and making the same request from Ms. Jayne is inappropriate. It will also not change the answer. We do not have a date as to which we will commit to production of the log and will not guestimate one that you will then attempt to hold as a contractual obligation. 

Fourth, as to telephonic conferral, there is no need. Even under LR 7-1, such telephonic conferral is only required for pre-motion practice, not all communications. In some instances, as here, where a party has proven to be an unreliable narrator, as I have been informed is the case with you, written communication is the only way of creating and preserving a clear record. For example, your attempt in this very e-mail to end run my telling you we would not commit to a date for production of a log by asking Ms. Jayne is precisely why this office will communicate with you by writing and *only* by writing.

Marc Abrams

PS As I do not know who the recipient of e-mails to \[Br. Timothy, HoSM\] is, I have removed that address from this (and all future) communications absent explanation of how this person relates to the litigation. 

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