"Why?" is an interrogatory again. I can do that, but I have to be very careful as it's a limited resource and there are tons of ways to squirm out of giving a useful answer to the question. Remember, lawyers are going to answer this stuff, and they are not trying to be helpful to me.

However, "please give me documents regarding TSA checkpoints' compliance with 49 CFR Parts 171–175 or other applicable hazmat regulations" is perfectly fine. So is a request to admit that it wouldn't harm aviation security to let passengers carry on anything that's permitted by FAA regulations. (Which are actually airplane safety based.) So is a request to admit that TSA's prohibited items list includes items that are not a threat to aviation if carried on board.

Francine Kerner and David Pekoske are both on my list of potential deponents. So is Curtis "Blogger Bob" Burns, and a lot of other people you've never heard of who are more directly involved. I haven't yet decided whether to depose them or not, however. I only get 10, 7-hour-per-person depositions by default, and I have to use them wisely. (Plus if it's Kerner, I have to get around attorney/client privilege issues.)

Generally depositions come late in discovery, after most of the documents are already produced. That way you have all the evidence you need to pin them down, know what to ask, impeach them on the spot, etc. Just like having a witness testify at trial, you generally don't want to go into a deposition without already knowing what their answers will probably be.


ETA: Also, a 30(b)(6) deposition is much more useful than deposing the administrator. The administrator might not personally know about something, and if so, he can say that. But if I have a 30(b)(6) deposition, if they say they don't know, that means TSA the agency doesn't know, and it's binding on the agency. Way more powerful.