C. Third-party subpoenas

Maryland case law does not discuss a media interest in fighting subpoenas issued to third parties in an attempt to discover a reporter's source. Specifically, the Maryland Shield Law applies to "any person who is, or has been, employed by the news media in any news gathering or news disseminating capacity." Md. Cts. & Jud. Proc. Code Ann. § 9-112 (b).