1-4 wants shit related to any expert witnesses that will be called (Fudd Buster will call no experts)
5-8 Any material relating to DEFCAD, Cody Wilson, Defense Distributed, and Dioskouri.
9. Any communications between counter defendants (Fudd Buster and friends)
10. Any material relating to the word "Gatalog" & Gatalog Foundation
11. Communications regarding litigation hold notices issued in this case
12-13 Any business relationships or employment relationships between the counter defendants individually or collectively
14. Any material relating to the gatalogs file submission approval process, legal reviews and bounty payments
15. Wants all ITAR regulations, including compliance policies (noted in stream: this is vague, whose ITAR regs? the Gov? Mr. Buster's personal ITAR regs and compliance policies?)
16. Mirrors 15 but for EAR regs.
17-18 Any information relating to the websites "
www.thegatalog.com" and "chat.deterrencedispensed.com"
19. Any material relating to Fuddbuster's Discord, including private channels that include any Counter defendant
20. Any material relating to the publication of digital firearms data on Odysee
21. Any material on "beta rooms" or private chat rooms operated by you or any counter defendant including membership records, file transfers and message content
22. And material relating to websites where anyone hosts 3D gun files
23. Any material relating to any servers owned/managed by anyone to discuss or distribute 3D printable gun files
24. Any material identifying any policies and procedures on any website or chatroom about what can be posted
25. Any material relating to the word "FEDCAD"
26. Any posts you've made about "FEDCAD" in the last 5 years
27. Any material relating to the publication of the "RGB Crescent" files, including any condition or coordination surrounding their release.
28. Like 27 but for the "Rogue 9."
29. Like 27 but for the "FNT.3" and "FTN.4."
30. Like 27 but for the "Uratau."
31. Any material relating to any digital forearm file transfer to or coordination with, including payments to, foreign entities or individuals, including but not limited to communications with or regarding Myanmar, ZeCarioca, ImmortalRevolt, and Jstark,
32. Any evidence supporting claims that DEFCAD did not properly encrypt or securely store its data.
33. Any material relating to any evidence you use to support your claim that DEFCAD "has been hacked and dumped multiple times."
34. Any materials relating to the creation of the FEDCAD meme.
35. Any materials relating to the promotion of MAF, gatalog, ctlrpew, Fuddbusters or any site used by you or counter defendant regarding 3D printable gun files.
36. Any materials relating to the selection and delegation of responsibilities to Rocketchat server administrators and beta managers including "Freeman1337" "Dr. Death" "UberClay" and "Pla.boi"
43. Any materials relating to David Gringras' website, including but not limited to communications discussing how that website could be disrupted
44. Any material relating to statements made by you concerning this lawsuit
45. Any material related to any copyright claim to the 3d printable gun files hosted on DEFCAD asserted by you or any counter defendant
46. Any material related to your contention that DEFCAD stole from you or any other counter defendant
48. Any material relating to the management, deletion, or alteration of record or communications during the 6 months preceding the filing of this lawsuit
49. A complete backup of the gatalogs rocketchat server and communications, including private and admin messages, predating Peter Celentano's Sep 20 2024 deletions
50. Any material relating to Peter Celentano's possession of restricted firearms or machine guns
51. Any material relating to any interactions with gov agencies related to digital firearms information
52. Any material relating to the psuedonymous figures Pla.boi, Dr. Death, UberClay, ArmedJ0y, and Pablo Diaz / Bloblems
53. Any material relating to any communications between any plaintiff/counterdefendant and any defendant/counterplaintiff.
54. Any material relating to any communication between you and the defendant's employees, including but not limited to Garret Walliman
55. Any material relating to any 3rd party's use of DEFCAD website, including but not limited to FFFTech and Unseenkiller
56. Any materials relating to the Everytown for Gun Safety v. DEFCAD lawsuit
57. All communications related to developing, printing or sharing NFA items, including but not limited to communications between you and any other counter defendant and and Freeman, Zecarioca, and Pla.Boi
58. Any material related to any communication between you and Elik regarding the development any/or creation of any file involved in the copyright suit, including but not limited to the MP99, Amigo Grande, and Hitchhiker