JMOO but I think the State wants some more time to continue looking into things, arguing over some technicalities and not addressing any specific claim whatsoever is certainly one way to do that now. Obviously it’s understandable if they have some hesitation, as that Clerk works on all the cases there, and if they reveal improper conduct in one case, could others be questioned too? Definitely is a slippery slope there.
I also think (but I am skeptical) that they include nothing to backup the “significant factual disputes” claim, not even one. JMOO but if they had anything of substance to refute any specific claims, and if they didn’t really want a hearing and/or new trial, then they’d include something to shut down defense claims. But if they don’t have anything yet, or if what they have may give the defense more room to respond, then it makes sense that they’re arguing over little details at this stage.