Bureau of Investigation (FBI) misuse of organized crime informants James J. Bulger and Stephen Flemmi, and Justice Department deliberations about President Bill Clinton's fundraising tactics. Bush invoked executive privilege "in substance" in refusing to disclose the details of Vice President Dick Cheney's meetings with energy executives, which the GAO did not appeal. In a separate Supreme Court decision in 2004, however, Justice Anthony Kennedy noted, "Executive privilege is an extraordinary assertion of power 'not to be lightly invoked.'" United States v. Reynolds, 345 U.S. 1, 7 (1953). Further, on June 28, 2007, Bush invoked executive privilege in response to congressional subpoenas requesting documents from former presidential counsel Harriet Miers and former political director Sara Taylor, citing that: The reason for these distinctions rests upon a bedrock presidential prerogative: for the president to perform his constitutional duties, it is imperative that he receive candid and unfettered advice and that free and open discussions and deliberations occur among his advisors and between those advisors and others within and outside the Executive Branch. On July 9, 2007, Bush again invoked executive privilege to block a congressional subpoena requiring the testimonies of Taylor and Miers. Furthermore, White House Counsel Fred F. Fielding refused to comply with a deadline set by the chairman of the Senate Judiciary Committee to explain its privilege claim, prove that the president personally invoked it, and provide logs of which documents were being withheld. On July 25, 2007, the House Judiciary Committee voted to cite Miers and White House Chief of Staff Joshua Bolten for contempt of Congress. On July 13, less than a week after claiming executive privilege for Miers and Taylor, Fielding effectively claimed the privilege again, this time concerning documents related to the 2004 death of Army Ranger Pat Tillman. In a letter to the House Committee on Oversight and Government Reform, Fielding claimed certain papers relating to discussion of the friendly fire shooting "implicate Executive Branch confidentiality interests" and would therefore not be turned over to the committee. On August 1, 2007, Bush invoked the privilege for the fourth time in a little over a month, rejecting a subpoena for Karl Rove. The subpoena would have required Rove to testify before the Senate Judiciary Committee in a probe over fired federal prosecutors. In a letter to Senate Judiciary chairman Patrick Leahy, Fielding claimed that "Rove, as an immediate presidential advisor, is immune from compelled congressional testimony