"The effect of the decision will be to discourage criminal defendants from speaking with reporters, and reporters from seeking to interview them, if it means the reporter should routinely expect to be compelled by the state to provide unpublished material and testify in court." https://www.bakersfield.com/news/californian-produces-notes-upon-order-of-appeals-court/article_5a42754e-843a-11ee-925b-73faf9df689d.html