Citibank, N. A. v. Wells Fargo Asia Ltd.

How later courts describe this case

• holding that a federal agency may edit the names and identifying information of private parties from documents that otherwise reveal the operations and activities of the agency because FOIA's central purpose is to shed light on the government's activities (citing Reporters Committee )
• discussing whether continued service as employee after stock promise constitutes adequate consideration and finding sufficient evidence to support jury’s finding under Massachusetts law
• Fed.R.CrimP.6(e) meets requirements of § 552(b)(3) such that exemption applies to identities of witnesses who testified before the grand jury and the substance of their testimony.
• reaffirming the United States Gypsum Co. test