"Anchors and executives have been preparing for depositions and have been forced to hand over months of private emails and text messages to Dominion." Among the current and former Fox personnel who have given or were set to give depositions in August were Steve Doocy, Dana Perino, and Shepard Smith. Sources also told the Times that Dominion was focusing on Lachlan Murdoch's reaction to President Trump's anger at the network calling Arizona for Biden, seeking to place him "in the room when the decisions about election coverage were being made". Accounts hold that the younger Murdoch did not pressure anyone to reverse the call, but "he did ask detailed questions about the process that Fox's election analysts had used after the call became so contentious." While Fox continues to claim that any statements made on air were covered by the First Amendment, and as such can not be considered defamation, the Times reported that "Fox has also been searching for evidence that could, in effect, prove the Dominion conspiracy theories weren't really conspiracy theories." Looking for connections to the Venezuelan dictator who died in 2013, lawyers for Fox in court filings have asked Dominion to turn over any internal communications going back over a decade that include any of the words "Hugo", "Chavez", "tampered", "backdoor", "stolen", or "Trump". Fox's recent replacement of its outside legal team with one of the nation's most prominent trial lawyers was seen as "a sign that executives believe that the chances the case is headed to trial have increased". In mid-August 2022, documents from the Dauphin County prothonotary's office revealed that Dominion plans to subpoena the Pennsylvania Department of State for records related to its case against Fox News. In accord with this action, they were to seek a deposition from former Secretary of the Commonwealth Kathy Boockvar. On August 31, 2022 Sean Hannity was deposed by Dominion's lawyers. The New York Times noted that in most defamation cases settlements are reached before any depositions are taken. As an example they pointed to how Fox News had settled in 2020 after the parents of Seth Rich sued due to Hannity and other Fox personnel trying to link his death to an email hack. In that case Fox settled the case before Hannity could be deposed. This was taken as further proof that both sides anticipated the case going to trial. Dominion's lawyer, Mary Kathryn Sammons,