|Results in 2019||3|
|Results in June||1|
Subpoenas or legal orders requiring journalists to testify in court or produce journalistic records or work product. This category also includes orders targeted at third parties who have access to journalistic records or 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.