Joseph Tate is an American attorney who represented government official Lewis Libby in the CIA leak grand jury investigation.
Previously, Tate worked in the Antitrust Division of the United States Department of Justice.
Miller spent 85 days in jail for refusing to disclose the identity of her source, an unidentified government official.
Special Counsel Patrick Fitzgerald, investigating the CIA leak, wrote to Tate on September 12, 2005 to clarify that communication between Libby and Miller would not be obstruction of justice.
Tate continues to deny that Libby was Miller's protected source, instead, insisting that a written waiver was provided a year ago.