No need to for discovery. My argument was based upon the fact that the police have the burden of proving they are using a calibrated gun. I don't remember the code section, access TicketAss for that and more explanations. I'm in the legal profession and found the site to be very, helpful. Pretty much the same basic advice an attorney would give I'm sure.
In short, don't lie in the declaration, just place the burden the government. You're hoping the don't take the trouble to respond to everything more than anything else, not that your arguments are necessarily valid.