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I read that as original requests by then. Interestingly enough, I think that the way the lawsuit is worded, even if it is assumed proven that...

Texts or emails on whether he actually believes they have immunity, perhaps. His own footage of the events would certainly be one of the focuses...

That would be the mandatory initial disclosures under Rule 26 that are mandatory in all cases. https://www.law.cornell.edu/rules/frcp/rule_26...