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In 2013, the United States Department of Justice, under Attorney General Eric Holder, came under scrutiny from the media and some members of Congress for subpoenaing phone records from the Associated Press (AP). Under similar justifications, a 2010 subpoena approved by Eric Holder implicated Fox News reporter, James Rosen, as a possible co-conspirator under the Espionage Act of 1917. Investigators gained access to the times of his phone calls, and two days of Rosen's emails. Stephen Jin-Woo Kim eventually pleaded guilty to violating the Espionage Act for communicating North Korean nuclear test plans to Rosen. These investigations provoked considerable criticism from major news organizations, and precipitated the revision of media guidelines at the Department of Justice.
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