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Orly has, once again, filed a brief which is long on rhetoric but short on responses to the precedents relied upon in the defendants’ brief.

She is refreshingly up front about this, stating (p.6):
"The question is not one of precedent, the question is whether politics dictate the outcome in many or most Obama-related cases, where avoiding discovery and fact-finding is the primary (and outcome-determinative) goal."

That's why I think that the question is whether Judge Carter will find that, "for the greater good," he can (or must) ignore the rules/precedent. That's, in a nutshell, what she is asking him to do.

And yes, only time will tell whether he determines that this issue is of such historic importance, that he can do as she requests.