3. Copies of subpoenas issued to reporters and news organizations during the
grand jury investigation, and any agreements by the FBI or Office of Special Counsel to limit the scope of the information supplied pursuant to those subpoenas.

Libby is taking no chances there will be a misunderstanding on the part of the Government as to what he is seeking.

....the term "documents" includes all written or recorded materials of any kind, all e-mails and electronically stored information, and all video or audio recordings. Documents and information are responsive as long as they relate to events or communications that occurred prior to July 14, 2003, even if they were generated after that date.

The term "Valerie Plame Wilson" means the wife of former Ambassador Joseph Wilson, whether referred to by name (including the names Valerie Plame, Valerie Wilson, Victoria Wilson, and Valerie Flame), or by other reference such as "Wilson's wife" or "wife" or initials where the reference is believed to concern Valerie Plame Wilson.

I'll update as I continue reading the documents.

First update: Libby says the "The Indictment Places News Reporters' Knowledge About Ms. Wilson's Employment Status Squarely at Issue ." He goes into "allegations" concerning Tim Russert, Matthew Cooper and Judith Miller.

Next, he argues that "Information About News Reporters' Sources Is Material to the Preparation of Mr. Libby's Defense."

Then he argues he needs the requested items to "Investigate Whether There Was a Plan to "Punish" Mr. Wilson by Leaking Information about Ms. Wilson to the Press."

Libby next argues that he is investigating "whether Ms. Wilson's Affiliation With the CIA Was Known Outside the Intelligence Community and Whether Such Information Was Regarded as Classified.

There's one more section in which Libby seeks agreements between Fitz and reporters limiting either the documents the reporters had to provide or testimony they had to give, and all supboenas issued to the media. Here's his argument:

The Government's Disclosure Obligations Extend to Subpoenas and Agreements to Limit the Scope of Documents or Testimony by Reporters

Finally, the defense is entitled to discovery of all subpoenas issued to the
press and any agreements the government may have reached with reporters or their employers to limit the scope of their testimony or the documents they would produce. The government has agreed to produce such information for the reporters referred to in the indictment and/or whom it intends to call at trial, but has refused to produce it for other reporters. This effort by the government to avoid its discovery obligations is based on the same fundamentally flawed view of materiality that has driven the government's refusal to provide other discovery from reporters that is not directly connected to Mr. Libby.

Information about subpoenas and agreements to limit their scope is discoverable under Rule 16 because it will help the defense ascertain what additional information must be obtained from news reporters to prepare for trial. The defense needs to determine whether to issue pretrial subpoenas to journalists or their employers for the necessary information, and may need to demonstrate that such subpoenas meet the prerequisites of Rule 17©. This need is not limited to documents the defense may seek with respect to Mr. Cooper, Mr. Russert, and Ms. Miller. Although they are the only reporters identified by name, the indictment refers repeatedly to "all reporters" or "reporters" generally, extending the universe of discoverable information beyond Cooper, Miller and Russert. Further, discovery of such agreements is necessary so the defense can adequately analyze the witness statements that the government will provide under the Jencks Act and Rule 26.2.

More to follow.