1.   At least six times in the past two years, federal prosecutors, primarily independent counsel Kenneth Starr, have subpoenaed the notes, audiotapes or videotapes of journalists.

2.   Microsoft attorneys hoped that the notes collected by Yoffie and Cusumano would paint a different picture, and so the company tried to subpoena their notes.

3.   Notes can be subpoenaed.

4.   Police investigating gang and vigilante violence in Cape Town subpoenaed the notes of local and international journalists Thursday.

5.   The notes had been subpoenaed by a House committee.

6.   Tribune reporter Linn Washington Jr. was not asked to testify, though his notes had been subpoenaed.