Lee CATLEDGE, petitioner, v. Robert S. MUELLER, III, Director, Federal Bureau of Investigation, et al.Case below, 323 Fed.Appx. 464. Petition for writ of certiorari to the United States Court of Appeals for the Seventh Circuit denied.
However, if the means and "circumstances" of the techniques and procedures are not publicly known as well, the known investigative techniques and procedures become protected under Exemption 7(E). See Catledge v. Mueller, 323 F. App'x 464, 467 (7th Cir. 2009) (citations omitted). DISCUSSION
To pursue those investigations, the FBI may use NSLs to collect information from NSL recipients, such as financial institutions, 12 U.S.C. § 3414(a)(5)(A), credit reporting companies, 15 U.S.C. §§ 1681u, 1681v, telephone companies, and internet service providers, 18 U.S.C. § 2709(b)(1). Catledge v. Mueller, 323 Fed.Appx. 464, 466 (7th Cir. 2009).
Although FOIA favors disclosure, its exemptions are meant to have "meaningful reach and application." Catledge v. Mueller, 323 F. App'x 464, 466 (7th Cir. 2009) (quoting John Doe Agency v. John Doe Corp., 493 U.S. 146, 152 (1989)). For example, the Seventh Circuit has observed that "personal identifying information is regularly exempt from disclosure.