The following excerpt is from Gonzales v. National Broadcasting Co., Inc., 155 F.3d 618 (2nd Cir. 1998):
Responding to discovery may well take valuable time, decreasing to that extent resources available for news reporting. Yet in the immediate sense, the press here is not differently situated from any other business that may find itself possessing evidence relevant to a criminal trial. It has a relevant and protectible interest in not being unduly burdened, as, for example, by overly broad subpoenas for large amounts of data of dubious relevance. But this burden is case specific.
United States v. Smith, 135 F.3d 963, 970 (5th Cir.1998).
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