Read the brief. Discovery

Read the final outcome: Watkins

"Material" limitation in subsection (a) (at least with respect to physical objects) means tending to show any fact relevant to the case (whether exculpatory or inculpatory and whether admissible or not). Subsection (h) has no materiality limit either (i.e., broader than Brady), at least with respect to duty to identify and disclose.

So it took the Court 53 pages.... Hmm, I think it can be summed up as "If the State is going to put an 'exhibit sticker' on it, then it needs to be disclosed."