mune MORLAHOMA COLA THE DISTRICT COURT OF OKLAHOMA COUNTY STATE OF OKLAHOMA. OCT - 9 2019 REPRESENTATIVE JASON LOWE; ANDREA ) RIGK WARREN STONE; JOSHUA HARRIS-TILL; AMANDA ) 59 BRYANT; and ANGELA HOLMES, ) ) Plaintiffs, ) \ } case No. CH-2019-5628 ) GOVERNOR J. KEVIN STITT, in his official ) capacity, ) ) Defendant. ) PLAINTIFFS’ NOTICE OF CORRECTION TO BRIEF IN SUPPORT OF MOTION FOR PRELIMINARY INJUNCTION ‘On page 19 of the Motion for Temporary Injunction (“Motion”), Plaintiffs inadvertently cited to a study that examines the increase in firearm deaths as a result of “right to carry” state laws, which the study defines as “shall-issue” permit laws and not permitless carry laws. See Mot. at 19 & n.16 (citing Siegel et. al, 2017). The specific 8.6% increase in firearms-related deaths jiscussed in that study, and in the Motion, thus does no! apply here. Because, until recently, the sample size has been quite small, Plaintiffs are not aware of any similarly reputable, peer-reviewed studies dealing specifically with permitless carry laws.' Reviews of raw CDC data, however, have shown that states that have passed permitless carry laws have experienced a significant increase in firearm-related deaths.” And several more general studies, including the seminal Siegel study cited in the Motion, have linked less- ' And, of course, to our knowledge no studies have been done on the effect of, e.g., blanket immunity provisions for all state employees, like the one at issue here. ? See, e.g., Devin Hughes, “Point of View: Data, academic studies should guide firearm policy,” the Oklahoman, Feb. 18, 2019, available at https://oklahoman.com/article/5623095/point-of- view-data-academic-studies-should-guide-firearm-policy; see also Centers for Disease Control and Prevention, National Center for Injury Prevention and Control; Fatal Injury Reports, National, Regional and State (1981-2017).restrictive firearms laws to an increase in firearm-related crime and death.’ Accordingly, although the specific figures cited on page 19 of the Motion are not correct and should be disregarded, there is substantial evidence that the risk of firearm-related deaths will increase as a result of various provisions of this law. Plaintiffs’ counsel apologize for this error, and withdraw all statements regarding the empirical data contained on page 19 of the Motion. Plaintiffs nevertheless respectfully submit that, in addition to the constitutional and legal harm discussed in the other portions of the Motion, the risk that this new, untested law could result in even one unnecessary death also warrants a temporary injunction. Respectfully Submitted, ME! LS WILSON RUGHANI, OBA #30421 JORDAN E.M. SESSLER, OBA #33264 CROWE & DUNLEVY A Professional Corporation Braniff Building 324 North Robinson Avenue, Suite 100 Oklahoma City, Oklahoma 73102 (405) 235-7700 (405) 239-6651 (Facsimile) > See, e.g., Siegel et al., “Easiness of Legal Access to Concealed Firearm Permits and Homicide Rates in the United States,” American Journal of Public Health 107, no. 12 (December 1, 2017): pp. 1923-1929; Donohue et al, “Right-to-Carry Laws and Violent Crime: A Comprehensive Assessment Using Panel Data and a State-Level Synthetic Control Analysis,” Journal of Empirical Legal Studies 16, no 2 (June 2019), pp. 198-247; Lee et al., “Firearm Laws and Firearm Homicides: A Systematic Review,” Journal of the American Medical Association Internal Medicine 177, no. 1 (January 1, 2017): pp. 106-119; Webster et al., “Effects of the Repeal of Missouri's Handgun Purchaser Licensing Law on Homicides,” Journal of Urban Health 91, no. 2 (2014): 293-302; Webster et al., “Erratum to: Effects of the Repeal of Missouri’s Handgun Purchaser Licensing Law on Homicides,” Journal of Urban Health 91, no. 3 (une 2014): pp. 598-601; Crifasi et al., “Association between Firearm Laws and Homicide in Urban Counties,” Journal of Urban Health 95, no. 3 (June 2018): pp. 383-390; see generally Hughes, GVPedia Concealed Carry Literature Review, Feb. 27, 2019, available at https://www.gvpedia.org/report-concealed-carry-literature-review. 2melanie.rughani@crowedunlevy.com jordan,sessler@crowedunlevy.com ATTORNEYS FOR PLAINTIFFS CERTIFICATE OF SERVICE Thereby certify that a copy of the above and foregoing was emailed and hand-delivered on this 9th day of October, 2019, to: Mike Hunter, Oklahoma Attorney General Mithun Mansinghani, Solicitor General Office of the Oklahoma Attomey General 313 NE 2Ist St Oklahoma City, Oklahoma 73105 sas9478