There are no cases in the Fourth Circuit in which a privilege is asserted in response to a grand jury subpoena. However, the language in Shain, a criminal case, indicates that at the very best, the Court would consider a reporter's privilege only upon a showing of confidentiality and governmental harassment. See Shain, 978 F.2d at 852. Even if the reporter makes such a showing to initiate a balance of interests under the LaRouche test, a "compelling law enforcement interest" is likely to tip the balance in favor of disclosure. See King, 194 F.R.D.