under state law to discovery in federal courts. See id. Making the case for a privilege here even stronger than in Jaffee, federal authorities also favor recognizing a privilege for reporters’ confidential sources. As noted earlier, we ourselves have limited discovery of reporters’ sources in both civil and criminal litigation, see Zerilli, 656 F.2d at 707; Carey, 492 F.2d at 636; Ahn, 231 F.3d at 37, as have other federal courts, see, e.g., Bruno & Stillman, 633 F.2d at 593-99; Burke, 700 F.2d at 76-77; Silkwood, 563 F.2d at 436-37, including some acting on the basis of Rule 501, see, e.g., Riley v. City of Chester, 612 F.2d 708, 715 (3d Cir.1979) (recognizing a qualified common law privilege in civil litigation); but see In re Grand Jury Proceedings, 5 F.3d 397, 398 (9th Cir.1993) (<HOLDING>). In addition, the Justice Department
recognizing privilege holding that the joint defense privilege preserved the attorneyclient privilege against waiver in the context of a group with common interests seeking common representation holding that no scholars privilege exists under the first amendment or common law holding that there is no statutory deliberative process privilege in arizona and declining to create such a privilege under the common law holding that there is no first amendment or common law right of access to documents which played no role in a judicial decision