TPS is trying to get discovery from SNH's prior to Confirmation Hearing.
Or in the alternative, have the SNHs not be able, at the confirmation hearing, use such materials that they didn't turn over.
Example they gave -- they claimed their trading was benign, decisions made based on legal information {not MNPI} -- and said so in last conf hearing. TPS is saying, if they won't turn over material, then they can't say things like that at confirmation.