I just finished the "Deadly" tier of Smuggler's Run and noticed that Raid Han wasn't shooting first. The opponent was taking two or three turns before Raid Han took a turn. Isn't he always supposed to shoot first (unless he's going up against another Raid Han)?
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Also, there is nothing in his description that states he should go first. He gets a bonus turn at the start of the encounter, but due to RNG picking who goes first with 100% TM, there are many situations where he may not.
Thia above point is up for debate as to if it should be this way but this is the current situation.