Von Bulow v. Von Bulow, 811 F.2d 136 (2nd Cir. 1987), was a case appealed from a contempt ruling after a District Court rejected the claim of a reporter's privilege by Claus von Bulow and Andrea Reynolds.
Reynolds, a paralegal, appealed a contempt ruling after she refused to submit an unpublished document for discovery. The United States Court of Appeals for the Second Circuit upheld the contempt order. The Court reasoned that a person who had gathered information for private use without the intent to gather the information as part of an investigation for a publication was not entitled to a reporter's privilege.
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“If one mistreats citizens of foreign countries, one infringes upon ones duty toward ones own subjects; for thus one exposes them to the law of retribution.”
—Johann Wolfgang Von Goethe (17491832)