Alexander v. F.B.I.
United States District Court for the District of Columbia
186 F.R.D. 148 (D.D.C. 1999)
Alexander (plaintiff) sued the FBI and EOP (defendants) over alleged privacy violations from turning over White House personnel files, and sought Rule 30(b)(6) testimony from the EOP about White House recording and surveillance systems. The EOP designated its Director of Operations, Dankowski, who had 12 years' experience overseeing purchasing and consulted others to prepare, but the plaintiffs moved to compel re-designation, arguing he lacked surveillance expertise, didn't adequately prepare, and gave inadequate answers about a secret surveillance department and a 1992-94 voicemail system.
Whether a party may compel a governmental agency to designate a substitute Rule 30(b)(6) deponent when the agency's already-designated deponent was knowledgeable on the subject matter and adequately prepared.