Law Review article, while only two or three were brought before. As of 2013, thirty nine states and the District of Columbia have some form of a reporter's shield law, ten other states have a common law privilege, and most federal circuits recognize a reporter's privilege as well—many using the language proposed in Goodale's law review article. Goodale's interpretation of Powell's concurrence was confirmed in 2007, when notes of Powell's were discovered saying reporter's privilege cases should be decided on a case-by-case basis. In October 1973, Vice President Spiro Agnew subpoenaed reporters for the New York Times and Washington Post for its sources on a story detailing the confidential criminal investigation into Agnew's dealings when he was Governor of Maryland. Instead of complying with the subpoenas, Goodale devised a strategy whereby the reporters' notes would be given to New York Times publisher A.O. Sulzberger and Washington Post owner Katharine Graham and they would refuse to hand them over to the court. If Agnew wanted the reporters' notes, the judge would have to send the owners of the two biggest newspapers in the country to jail. Agnew's subpoenas were dropped after he resigned the Vice Presidency the following month. In 1978, New York Times reporter Myron Farber was subpoenaed by a New Jersey state court in the murder trial of Dr. Mario Jascalevich and refused to testify on the advice of Goodale. He subsequently caused Farber and the Times to go into contempt of court. Farber spent 40 days in jail and the New York Times was fined a total of $101,000 dollars. The Governor later returned the fines and New Jersey passed a state law providing reporters a qualified privilege in response to the case. Because of his work at the New York Times, his law review article and subsequent media law seminars, Goodale has been called the "father of reporter's privilege." Post-New York Times career Goodale joined Debevoise & Plimpton in 1980, bringing The New York Times as a client with him. He established two practice groups, one for the representation of media companies, particularly new media companies such as cable television, the other for First Amendment and intellectual property litigation. At Debevoise, he or his groups have represented The New York Times, the Hearst Corporation, NBC, Cablevision, the New York Observer, Paris Review, Infinity Broadcasting, the NFL, NHL, and NBA. He has personally represented George Plimpton, Harry Evans,