The NFL wrote in their letter:
"We also request that the
Times's reporters and editors who worked on this story preserve their notes, correspondence, emails, recordings and work papers and all other electronic and hard copy documents generated or received in connection with their work."
If I was the NY Times editor, I would respond with a statement saying. "Everything we wrote is true. We also request that the NFL league office and medical personnel preserve their notes, correspondence, recordings and work papers and all other electronic and hard copy documents generated or received in connection with the issue of CTE over the past 20 years."