Which makes me think that he is not focused on convincing the trial judge. He is writing for the benefit of the appellate court or the voting public.
Or book sales?
He’s writing for the media and the pundits to report on. And also wants to win at any cost.
Smith is out of line here. There are many different laws and sometimes they conflict. Smith wants the judge to ignore the statute that allows POTUS to declassify documents and to declare which documents are personal. He wants the judge to nullify some of the defense arguments.