The request directed to the DOC was very detailed and specific.
It sought copies of training manuals or other materials pertaining to the training of execution team members, use of execution chemicals and/or execution facilities; the identity of outside persons or agencies who participated in the training of execution team members, documentation regarding professional licensure, certification or other formal accreditation of execution team members, documentation regarding the procurement, maintenance and preparation of the chemicals used in lethal injection, and similar documentation regarding any of the equipment which would be used during the process. PC-W Vol. III 413-16
It also requested a certification that such documentation did not exist if that were the case.