It's not a discovery request yet. It's simply MoRonica sent out preservation letters. But trying to Subpoena such communications from an Attorney is going to be an insanely stupid fools errand. Nick can fight any such subpoena's at pretty much zero cost to himself, another $30 grand costs to MoRonica, and a high likelihood of success. Or at least vastly limiting the scope of any inquiries. Nick meets all the tests for being a Journalist. He has an established and informative publication. He could escalate any subpoena requests up to the Federal Level, and he would not only make more money from his "Lawsplaining the Internet" publication in doing so, than what it would likely cost him. He could write off those expenses on his taxes as production costs.
I am still trying to figure out how anything in the new guys Document Retention Requests would fit into Casey's filed response?