|Results in 2019||2|
Subpoenas issued by government prosecutors or agencies ordering journalists to testify in court. Subpoenas requested by private parties will not be included. This category also includes legal orders for the production of journalist records or work product, which may be targeted at journalists or at third parties who have access to the work product. Because many subpoenas are not publicly reported and legal orders for journalist records are conducted with high levels of secrecy, the numbers in this category are likely to underestimate actual cases.