This is because in the correspondence the Bureau did not act in the role that their personnel usually fulfils, in that personnel do not represent their own interests. The Bureau officials were working with the Tribe, advocating "their" interests which meant the documents were not exempt from public disclosure of intra-agency communications. Souter wrote that "all of this boils down to requesting that we read an 'Indian trust' exemption into the statute, a reading that is out of the question". In concluding, Souter noted that Congress realized that not every secret under the previous version of FOIA would be kept secret under the newer version.