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Reynolds, a paralegal, appealed a contempt ruling after she refused to submit an unpublished document for discovery.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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“The true poet is called to take in the splendor of the world and for that reason will always be inclined to praise rather than to find fault.”
—Johann Wolfgang Von Goethe (1749–1832)