Are speech preparatory investigations expressive and subject to First Amendment protection?

John Doe conducted an anonymous investigation of public figure s based on concerns about corruption. Two elected officials, including t he Mayor of Reno, the target of the investigation, sought to use litigation to unmask John Doe. The Nevada Supreme Court refused to apply the First Amendment to the investigation, declaring that the speech preparations were “non expressive” and “not subject to First Amendment p rotection.” The q uestion presented is: Are speech preparatory investigations expressive and subject to First Amendment protection?