d. Language

There is no stock language or preferred text that should be included in a motion other than what is provided for in Miss. R. Civ. P. 45(e)(2), which states that "[w]hen information subject to a subpoena is withheld on a claim that it is privileged or subject to protection as trial preparation materials, the claim shall be made expressly and shall be supported by a description of the nature of the documents, communications, or things not produced that is sufficient to enable the demanding party to contest the claim." One should also include the criteria necessary to overcome a journalist's qualified privilege: (1) the testimony of the reporter is highly relevant to the seeking parties case; (2) there is a compelling need for the testimony sufficient to override the reporter's First Amendment privilege; and (3) the seeking party has unsuccessfully attempted to obtain the information possessed by the reporter from other sources.