1987),[1] was a case appealed from a contempt ruling after a United States 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Reynolds, a paralegal, appealed a contempt ruling after she refused to submit an unpublished document for discovery.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.

This article relating to case law in the United States or its constituent jurisdictions is a stub.