The filing not only urged the court to deny the request, but claimed Musk should be forced to testify about his leadership of the company, based on depositions from several high-ranking ex-Twitter “key data privacy and security executives,” including Damien Kieran, chief privacy officer; Lea Kissner, chief information officer; and Andrew Sayler, director of security engineering.

The filing alleges that the social media company’s mass layoffs may have prevented it from meeting the obligations it agreed to last year in a settlement that revolved around charges the company had misled consumers about the privacy and security of their information.

“The information obtained revealed a chaotic environment at the company that raised serious questions about whether and how Musk and other leaders were ensuring X Corp.’s compliance with the 2022 Administrative Order,” the court filing reads. “Musk has unique, first-hand knowledge about the current state and direction of the company’s data practices and efforts to comply with the [order].”

Twitter did not respond to Fortune’s request for comment, other than its bot reply “Busy now, please check back later,” which it sends to all media requests.

Musk, in July, asked the court to terminate that agreement, saying the FTC’s ongoing investigation into whether the agreement was being honored, which began before his purchase of Twitter, had “spiraled out of control and become tainted by bias.” That same motion sought a protective order that would have prevented a deposition of Musk.

U.S. officials say the FTC spoke with five former executives and employees, whose roles revolved around security and privacy. The filing says the discussions were with ex-employees “because nearly every employee who has been identified as a point person for privacy or data security either resigned or was terminated before the FTC could talk to them.”

“Kissner testified that certain programmatic protections relating to product launch reviews, data access controls, and other ongoing security controls were effectively dismantled,” the filing reads. “Due to the mass employee exodus, about half of the controls in X Corp.’s information security program did not have a designated ‘owner’ responsible for their operation. Similarly, at his deposition, Kieran testified that the firings and layoffs meant no one was responsible for about 37% of X Corp.’s privacy program controls.”

Among the other examples of potential infractions mentioned in the filing is the launch of Twitter Blue, which Kissner said was implemented so quickly on Musk’s orders that the usual security and privacy review was not conducted. Sayler added to the concerns, describing “how some of the security team’s recommendations went unheeded, including measures for mitigating the risk that people would purchase verification to impersonate other accounts.”