Sure, and you could also just submit fake warrants as many criminals have successfully done.

Neither of these approaches would enable bulk collection.

I'm sure the NSA can read essentially any specific emails they're interested in, they just can't do so at anywhere near the scale they used to pre-Snowden.

Not only that, these days almost all chats have moved to E2EE platforms. Reading that traffic in a stealthy manner requires compromising endpoints, bulk collection simply isn't possible.