To answer your question and back up diamondguru's assertion before a judge issues a search warrant you have to prove that there's a minimum of Reason to issue the warrant.
For a Judge to order discovery, the Judge has been presented with evidence to prove there's a smoking gun.
Also even if WMI Lawyers have evidence, they cannot present it until they get discovery or the evidence can be kicked out due to some technicality.
Any lawyer worth their salt would never go down this rabbit hole and seek discovery if they didn't have the smoking gun.
For Ye shall know the truth, and the truth shall set you free