If you are interested in documentary film, you probably should be a member of the D-Word on-line community. I mention this because the discussion on the "Legal Corner" section of their forum pages has been very enlightening on this case. As Mark Barroso correctly notes, Judge Kaplan didn't deny that Berlinger was functioning as a journalist with a qualified version of the usual protectons. Rather, he said that "when comes to possessing evidence needed in civil action in a foreign court, it doesn't matter." Barroso goes on from there with several other useful explanations and concludes, quite rightly, that what we really need is a federal shield law protecting journalists and their sources. Go to The D-Word, register and check out his posting.