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Rebecca Melnyk and May Warren JN8107: Standards of Journalists Care School of Journalism, Ryerson University Date: Jan. 20, 2014

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Using Confidential Sources: Is there a Public Disconnect? .#/0!123%4!56%73/#%83*$!269+5#20!32!8:#+#!*!;9<$35!/3256%%#58=! >#'0!?2!2##%!3%!8:#!@6+/!5+*5'!25*%/*$(!*!4*;!$66A2!<#8B##%!8:#!;9<$35!;#+5#;836%! 67!56%73/#%83*$!269+5#2!*%/!8:#!#776+82!67!C69+%*$3282!3%!2#+D3%4!8:#!;9<$35!3%8#+#28E! F#<#55*!"#$%&'!*%/!"*&!)*++#%!#G;$6+#!8:#!$#4*$!*%/!#8:35*$!3229#2!*+69%/! 56%73/#%83*$!269+5#2(!#G*A3%3%4!8:#!;68#%83*$!<#%#7382!67!D#3$#/!269+5#2(!3229#2! *+69%/!%#4683*83%4!56%73/#%83*$38&(!56AA9%35*836%!<#8B##%!+#;6+8#+2!*%/!#/386+2(! *%/!29<8$#!6;836%2!86!3%5+#*2#!8+*%2;*+#%5&E!! ! "#!$%&%''(!)%*+#,!(+-!)(#!.(//%+! ! H+#5320!I%!"*&!-J,K(!<68:!8:#!!"#$%&'()&*'+"!*%/!8:#!,#-#(.#&/.'-!;9<$32:#/! 56%8+6D#+23*$!3%D#2834*83D#!286+3#2!3%D6$D3%4!2#;*+*8#!/+94!*$$#4*836%2!*<698!"*&6+! F6<!@6+/!*%/!:32!7*A3$&E!L68:!286+3#2!+#$3#/!9;6%!8:#!92#!67!56%73/#%83*$!269+5#2E! ! M:#!/.'-&286+&!76592#/!6%!*!5#$$;:6%#!D3/#6(!D3#B#/!<&!8:#!+#;6+8#+2!F6<&%! >66$388$#!*%/!N#D3%!>6%6D*%(!3%!B:35:!8:#!A*&6+!32!2##%!86!*$$#4#/$&!<#!2A6'3%4! 5+*5'!565*3%#E!M:#!!"#$%!286+&(!B+388#%!<&!+#;6+8#+!O+#4!"5?+8:9+!*%/!7+##$*%5#! C69+%*$328!P:*%%6%!N*+3(!*$$#4#/!8:*8!538&!569%53$$6+!>694!@6+/!:*/!6%5#!<##%!*!/+94! /#*$#+E! ! "*%&!+#*/#+2!/32*;;+6D#/!67!8:#!%#B2;*;#+2Q!+#$3*%5#!6%!56%73/#%83*$!269+5#2!*%/! B*%8#/!A6+#!3%76+A*836%!6%!8:#!+#;98*836%2!*%/!;#+26%*$!A683D*836%2!67!8:62#! 269+5#2E!L98!8:#!C69+%*$3282!3%D6$D#/!7#$8!8:#&!B#+#!*583%4!+#2;6%23<$&(!B+383%4! 286+3#2!3%!8:#!;9<$35!3%8#+#28E! ! R$#*+$&(!6%#!+#D#$*836%!8:*8!29+7*5#/!6D#+!8:#!569+2#!67!8:#!29AA#+(!$#*/3%4!9;!86! 8:#!S%8*+36!H+#22!R69%53$!:#*+3%4!6%!P#;8#A<#+!T(!-J,K(!B*2!8:*8!*!56AA9%35*836%! 4*;!<#8B##%!+#*/#+2!*%/!C69+%*$3282!:*2!86!<#!#G*A3%#/!A6+#!5$62#$&E!! ! I%!*%!*88#A;8!86!<+3/4#!<68:!23/#2!67!8:#!286+&U;9<$35!*%/!C69+%*$32835U8:32!#22*&! 3%5$9/#2!3%8#+D3#B2!B38:!R6%%3#!.*++326%(!8:#!+#;+#2#%8*83D#!56A;$*3%*%8!3%!8:#! !"#$%!5*2#!*%/!"5?+8:9+(!B:6!677#+2!3%234:8!3%86!:6B!8:#!92#!67!56%73/#%83*$!269+5#2! 569$/!:*D#!<##%!<#88#+!56AA9%35*8#/E!?%/+#B!"5I%862:(!*!76+A#+!+#;6+8#+!76+!8:#! 0'.+#('"&1#2.!B:6!B*2!3%D6$D#/!3%!8:#!:3286+35!34&524&0'.+#('"&1#2.!5*2#(!2:*+#2!:32! #8:35*$!7+*A#B6+'!*<698!B:#%!*%/!:6B!86!92#!D#3$#/!269+5#2E! ! L3620!F#<#55*!"#$%&'!4+*/9*8#/!7+6A!M:#!V#B!P5:66$!3%!V#B!W6+'!*2!*!F34436! .6%6+2!@#$$6BE!P:#!32!59++#%8$&!*!2#56%/!&#*+!289/#%8!3%!8:#!"*28#+!67!X69+%*$32A! ;+64+*A!*8!F&#+26%!1%3D#+238&E!.#+!B6+'!:*2!*;;#*+#/!3%!,6+2!A*4*Y3%#(!8:#! 0'.+#('"&1#2.!8:#!37%-2#(&3%5+%8&#9&:#;-('"+2<&*%/!=>*=!"*4*Y3%#E! ! !

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"*&!)*++#%!32!*!2#56%/!&#*+!A*28#+!67!C69+%*$32A!289/#%8!*8!F&#+26%!1%3D#+238&E!! P:#!:*2!9%/#+4+*/9*8#!*%/!A*28#+2!/#4+##2!3%!;6$3835*$!253#%5#!7+6A!8:#!1%3D#+238&! 67!O9#$;:!*%/!Z9##%2!1%3D#+238&(!+#2;#583D#$&E!P:#!:*2!3%8#+%#/!*8!8:#!!"#$%&'()& *'+"?!8:#!!;%"@6&*%-A;-7!*%/!8:#!B(+.%)&C6;-A6&>$2%-5%-E!L#76+#!+#89+%3%4!86! C69+%*$32A!2:#!B6+'#/!3%!8:#!73#$/!67!4$6<*$!:#*$8:E! ! [[[[[! Globe and Mail investigative reporter Greg McArthur remembers standing at the home of an alleged drug trafficker whose name had come up as a potential source in his investigation into the family of Toronto mayor Rob Ford. McArthur had agreed to meet the man, but he wasnt home. Just as he started to leave, the man pulled into the driveway. They walked inside. Who else have you talked to? the man asked. McArthur told him that he couldnt talk about the sources with whom he had already spoken, and he wasnt going to tell anyone about their meeting. That was a test, the man said. They started to talk. Audio Clip #1. Listen to Greg McArthur talk about how he contacted another key source for the story:!123/(4%!52-6789:;;<9! 7%2=7689:>>9!?'/@**2+=89+@9!3/(4%&@/-%/89+@9! ?/'89766A?0BB5C?@D+-'*@D-C'@4BA*(#%/BED/*8766A?<FGBB(A2C?@D+-'*@ D-C'@4B6/(',?B:F;HI::IJK(4AL'@*@/833>>;;K(4AL(D6@MA*(#83(*?%K (4AL?7@5M(/65@/,86/D%9N1B23/(4%N! In the summer of 2013, both the Toronto Star and the Globe and Mail published explosive investigative pieces about Mayor Rob Ford and his family that relied on confidential sources. Both stories caused a sensation in Toronto and across the country and were criticized by the public. The Stars original May 16 story on the crack video scandal and its follow-up reporting featured unnamed sources. Most prominent was a man they called the broker, who had shown reporters Robyn Doolittle and Kevin Donovan the cellphone video of the mayor smoking what appeared to be crack cocaine. The man later identified himself on an episode of CBCs investigative program The Fifth Estate, as Mohamed Farah, a Somali community organizer. On May 25, the Globe published McArthurs piece with freelance journalist Shannon Kari. It relied on the accounts of ten anonymous sources that accused the mayors brother, Councillor Doug Ford, of having been a mid-level seller of hashish in the 1980s. The article contained allegations that Fords other brother,

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Randy, was also involved in the drug trade, and had participated in violent drugrelated crime, and that their sister, Kathy, had dated a white supremacist. Confidential sources are people whose identities have been protected by reporters and sometimes editors in order to obtain necessary information in the public interest. The public never learns the true identity of these sources. Many valuable stories would never be told if these unattributed sources could not be utilized. But they can also be abused. Critics fear that an overreliance on veiled sources can threaten accuracy. Its also difficult to know how credible a source is without their identity. Powerful individuals can use these sources to manipulate the press and the public and spread false or fabricated information, leading to the diminished credibility of a news organization. Responsible journalists weigh their decisions to veil sources largely based on how well the investigation, and ultimately the story, will serve public interest. But communicating the reasons why sources must be veiled is not always taken as seriously. In the case of the Globes article about Doug Ford, there seemed to be an assumption that the public would naturally trust the reporter. While weighing public interest, journalists are simultaneously claiming to be acting justly (Meyers 273). But Connie Harrison, a representative complainant at the fall 2013 Ontario Press Council hearing concerning the Globes article on the Ford family, found the Globes exclusive use of anonymous sources to be unfair. They could be people with a grudge, an axe to grind, she says. We dont know who they spoke to. Harrisons wary outlook mirrors the results of a 2012 Ipsos poll that found only 31 per cent of Canadians trust journalists. Instead of trusting McArthurs investigative methods and the articles sole dependence on anonymous sources, Harrison was suspicious of how credible the sources were. Audio Clip #2. Click here to listen to Connie Harrison speak about why she doesnt trust confidential sources in this case:! 123/(4%!52-6789:;;<9!7%2=7689:>>9!?'/@**2+=89+@9!3/(4%&@/-%/89+@9! ?/'89766A?0BB5C?@D+-'*@D-C'@4BA*(#%/BED/*8766A?<FGBB(A2C?@D+-'*@ D-C'@4B6/(',?B:F;HI:F::K(4AL'@*@/833>>;;K(4AL(D6@MA*(#83(*?%K (4AL?7@5M(/65@/,86/D%9N1B23/(4%N Perhaps one revelation worth exploring is what Star columnist Heather Mallick described in a September 11, 2013 article as a great gulf of misunderstanding about how journalists work. On the one hand, important public interest stories would be neither confirmed nor published without the use of confidential sources. McArthur and Kari spent considerable time sniffing out their sources and investigating their motives to

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ensure they were credible. Yet the public does not know the extent of their laborious efforts. The Globe did make an effort to be transparent with their readers. Stackhouse did extensive interviews with other media outlets about the article. He penned a letter to readers explaining why the paper used confidential sources, citing the sources fear of the Fords. He was also featured in an explanatory video on the Globes website. The story itself contained a paragraph explaining that the sources wanted to remain confidential because they were concerned about exposing their ties to illegal drugs. But given the number of complaints from individuals across the country received by the Ontario Press Council, there is clearly still a public disconnect. Stackhouse reminded the Press Council panel of past cases where the Supreme Court of Canada has supported the use of anonymous sources to tell stories in the public interest (Harrison vs. the Globe and Mail, October 2013). But public interest does not align with public trust. McArthur acknowledges this issue with public perception. My biggest concerns were not so much ethical. My bigger concern was how was it going to be perceived by the readers, he says of the Ford family piece. I didnt want to run a story that I knew was true that was going to be discredited because there were so many anonymous sources. That really concerned me. McArthur says that in hindsight they could have maybe done a better job, communicating with the public about their use of confidential sources. Some of the readers confusion, he explains, may stem from the disconnect between what we wrote in the piece and what John Stackhouse wrote in his public letter about the sources reasons for wanting confidentiality. He and Kari wrote that people feared outing themselves as former drug dealers, while Stackhouse wrote about fear of the Fords. There is not really a discrepancy. Both are true; its just that we didnt get into the same level of detail in the piece, says McArthur. McArthur says if he could do it over again, he would include a more detailed sidebar explaining some of the reasons his sources gave for wanting to keep their names out of the paper. But in terms of granting the confidentiality, he wouldnt have changed anything. He says its a perfect example of using confidential sources to get vital information into the public sphere. Without confidentiality, he says, we would not have learned what we learned. And its no doubt true, and I think, generally most people accept it as true.

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Most newsrooms have their own policies and guidelines to help reporters decide when it is appropriate to use a confidential source. A key legal landmark on whether journalists may be forced to reveal sources in court was reached when the Supreme Court of Canada decided on a case involving National Post reporter Andrew McIntosh. In April 2001, McIntosh received a brown envelope. Inside were documents that showed that then Prime Minister Jean Chrtien benefited from a $615,000 loan made to a hotel in his home riding of Shawinigan, Quebec. If true, they would catch him in a conflict of interest as Prime Minister. The bank officials said that the documents were forged and involved the RCMP, who demanded that McIntosh and the Post hand them over in a search warrant. McIntosh, seeking to protect the identity of his source, refused (Jobb 149). Ultimately, the newspaper gave the document to the RCMP but, with the CBC and the Globe and Mail, challenged the legality of the search. In 2010, the Supreme Court of Canada overturned the Posts appeal of an earlier ruling and, in effect, quashed the idea of offering journalists blanket protection of their confidential sources. Instead, the issue was to be approached on a case-by-case basis, employing a series of criteria called the Wigmore test to determine whether a journalist-source relationship should be protected (R vs. National Post). THE WIGMORE TEST: Under the Wigmore Test, a journalists confidential source may be protected if a court finds all four of the following statements to be true:

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The McIntosh ruling was reinforced by another 2010 Supreme Court judgment, this time in a case brought by the Globe and Mail and their reporter Daniel Leblanc, who refused to expose the identity of key confidential sources in the reporting of the federal sponsorship scandal (Globe and Mail v. Canada). Many journalists thought the rulings didnt go far enough to protect reporters and their sources. Jamie Cameron, a law professor at Osgoode with York University, thinks a case-by-case determination is not sufficient. A privilege that is determined on a case-by-case basis places a journalist's source at risk that his or her confidentiality will not be protected, and this can deter the source from disclosing information that is in the public interest to know, Cameron wrote in an email. But the rulings did recognize the importance of using confidential sources and a journalists legal right, grounded in the Canadian Charter of Rights and Freedoms, to protect the identity of sources in certain cases. Audio Clip #3. Click here to see how the legal protection of sources influenced McArthurs decision-making process: <iframe width="100%" height="166" scrolling="no" frameborder="no" src="https://w.soundcloud.com/player/?url=https%3A//api.so undcloud.com/tracks/130481507&amp;color=ff6600&amp;aut o_play=false&amp;show_artwork=true"></iframe> Legal issues are only one aspect of what journalists and their editors must consider when deciding whether to use confidential sources. Often, ethical dilemmas are a more worrisome matter. McIntosh has developed his own ethical framework to decide when such promises of confidentiality are appropriate. First, he uses such sources only as a last resort, when people cannot be persuaded to talk for publication or broadcast and if he cannot get important, vital public interest information for his readers or viewers in any other manner. I weigh carefully if and how the information from a confidential source helps the reader-viewer and shapes or completes the story, he wrote in an email. If it doesnt help the reader much, I often dont use it. Even more ethically demanding is the situation when a source approaches a journalist with information he or she wishes to divulge. McIntosh says he examines the sources motives and does everything he can to ensure unbiased, accurate information. I ask them why they want this information out and who stands to gain by its publication and who will get hurt, he says. Whether approached by a source or actively pursuing a source, McIntosh validates

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credibility in various ways: checking a sources professional background, career track record and personal life for any sign of dishonesty and misconduct. Similarly, Gene Foreman, the former managing editor of the Philadelphia Inquirer, urges readers to be aware of the two types of unnamed people: sources who have an interest in getting the truth out there but are worried about the repercussions for their lives and livelihoods, and sourcers who have an interest in using the press as a means to an end. He developed a checklist to make sure the sources get through and the sourcers dont (Foreman 125). Sometimes, when entering into a confidentiality agreement, McIntosh asks sources to write and sign a sworn affidavit to carefully describe the matter that may be discussed. This additional step often protects him from sources who change their stories in shifting political winds or sands. McArthur has also developed an ethical framework. He says he usually starts from a place of anonymity and works backwards to get people to go on the record in order to make them feel comfortable. Generally I try and treat every initial interview as a background research interview because I think that thats what going to yield the most information. Im not there to assemble quotes for publication, he says. Im not even thinking about how the storys going to be framed because I dont understand yet what happened. I dont know what the story is. The one ethical issue that McArthur recognized with the Ford article was whether or not someone has a right to know the identity of his or her accuser when it is such a serious accusation. In this case, he says, the paper takes on that role. He [Doug] gets to know that his accuser is the Globe and Mail and that were standing on our reputation for solid research and excellent journalism, that we feel confident enough to make what some would frame as an accusation. Audio Clip #4. Click here for more about McArthurs methods:! <iframe width="100%" height="166" scrolling="no" frameborder="no" src="https://w.soundcloud.com/player/?url=https%3A//api.so undcloud.com/tracks/130481575&amp;color=ff6600&amp;auto _play=false&amp;show_artwork=true"></iframe> In North America, the idea of confidential sources and the clich of a reporter receiving a brown paper envelope with earth-shattering documents inside will always be linked to the Watergate Scandal of the 1970s. Washington Post cub reporters Bob Woodward and Carl Bernstein relied on a confidential source nicknamed Deep Throat, later revealed to be FBI agent Mark Felt, to expose a political scandal involving then President Richard Nixon.

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The story, which eventually led to President Nixons resignation, is a classic example of an unnamed whistle blower bringing vital information in the publics interest to light (Sheehy 90-91). But in a 2010 study examining the use of unnamed sources at the Washington Post, Sheehy writes that since that story, the Post and other major US media outlets have indulged too heavily in the use of confidential sources. Sheehy argues that without named sources to hold accountable, accuracy can be in danger and a newspapers account is less credible and potentially damaging to their reputation (Sheehy 94). Unnamed sources were part of Jayson Blairs fraudulent reporting at the New York Times in 2003 (Sheehy 84). And they played a key part in disseminating false information during the lead-up to the Iraq War (Duffy and Williams 9). Confidential sources were used maliciously in a Canadian context in the case of Maher Arar. In a 2007 Walrus article, Andrew Mitrovica writes that journalists were fed incorrect information from confidential sources about Arar in an attempt to discredit him while the Canadian government was negotiating his release from a Syrian prison (Mitrovica 36). The case shows the dangers of journalists being manipulated by confidential sources for their own means to an end. Mitrovica argues that when journalists are in this situation, they should expose their unnamed sources and hold themselves to the same high standard of transparency that they expect of everyone else (Mitrovica 36). McIntosh says that he includes a key caveat, in all verbal or written agreements he makes with sources about confidentiality: If I learn that a source has deliberately misled me, or I learn that they knowingly fed me false information or documents that they know to be false, then the confidentiality deal is null and void, he wrote in an email. Veiled sources can be particularly tricky in the context of political reporting. A lack of precise attribution makes it difficult for audiences to evaluate whether a source has an outside agenda. A 1999 study by Steven A. Esposito found that over 70 per cent of television news reports on the Bill Clinton/ Monica Lewinsky scandal used veiled sources (15). The findings suggested that confidential sources were being heavily used and potentially abused for political gain (17). A 2005 review of The Globe and Mails use of anonymous sources argued that they could sometimes be manipulated in the form of strategic leaks. The study analyzed the use of confidential sources in the Globe and Mail during a period of six months. It found that the reason for the source remaining anonymous was not usually explained, and they were often merely described in partisan terms such as a Liberal insider or a high-level Conservative (Rudnicki 56-58).

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Reporters didnt state that they had tried to get the source on the record before granting them anonymity. Rudnicki also found that confidential sources were being allowed to take political potshots at each other and that the highest use (70 per cent) of confidential sources was to add colour and commentary and not important information in the public interest (Rudnicki 61-63). But a 2011 study found that the use of confidential sources in the New York Times and the Washington Post dropped in 2008 to levels not seen since the 1950s. It also found that when reporters did use confidential sources, they made more of an effort to describe the sources in a way that provided more context for the reader; for example, using high-level Pentagon source instead of informed source (Duffy and Williams 18). McArthur says that because his editors understood that he started with anonymity, it was never discussed whether or not he would be able to grant it. What was discussed was how many sources were enough. There was no clear answer. Eventually the figure came back and I think this was based on consultations between John Stackhouse and Peter Jacobsen [the Globes lawyer] and Sinclair [Stewart: the news editor] that ten sources would be sufficient, he recalls. He is not sure about how high the discussions went and whether or not the publisher and owner were involved. They werent involved in any discussions that I was involved in, he says. In a 2011 study of the decision-making process used by journalists when evaluating whether to use confidential sources, Kimball identified a common process used when deciding to rely on such sources, which one journalist called an art. First, they would evaluate the information being offered and if it was in the public interest. Second, they would evaluate the potential source, inquiring whether they had a legitimate reason for requesting anonymity and if they had other potential motives for providing the information.!A government official worried about losing his or her job for whistleblowing, for example, would make the cut. A communications professional feeding a reporter a story to discredit someones reputation would not (Kimball 39-42).! Journalists would then bring their editor into the discussion, to make sure that they were informed and onboard. Finally, when communicating with a source or making the deal, they were transparent about the process and how far they were willing to go to protect them (Kimball 43-44). McArthur says that despite the Canadian legal framework, he essentially took the position that he could offer his sources blanket protection. He says he would be willing to go to jail for a source but feels that the chances of this happening are remote.

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In a November 6 article for the Toronto Star, Robyn Doolittle described the process of deciding whether or not to pay alleged drug dealers a three-figure sum for the Rob Ford crack video, and also whether or not to quote anonymous sources in the subsequent story. The Star has agreed not to release the brokers identity until he says so, Doolittle confirmed during a panel discussion at Ryerson University organized by Investigative Reporters and Editors. After the Fifth Estate aired an interview with Mohamed Farah where he was identified as the broker, she tweeted, Both networks [CBC and City TV] claim to have an interview with the crack broker. I wont be confirming identity. We have promised confidentiality.

Works Cited Cameron, Jamie. Email Interview. 12 Dec. 2013. Doolittle, Robyn, and Kevin Donovan. Rob Ford in crack cocaine video scandal. Toronto Star. 17 May 2013. Web. Nov. 12. Doolittle, Robyn. Rob Ford crack video story started with an anonymous early morning phone call to a reporter. Toronto Star. 6 Nov. 2013. Web. Nov. 12. Doolittle, Robyn. Twitter Post. Nov. 8, 2013. http//twitter.com/@robyndoolittle. Duffy, Matt J., and Williams Ann E. "Use of Unnamed Sources Drops from Peak in 1960s and 1970s." Newspaper Research Journal 32.4 (2011): 6. Print. Esposito, Steven A. "Anonymous White House Sources: How They Helped Shape Television News Coverage of the Bill Clinton-Monica Lewinsky Investigation." Communications and the Law 21.3 (1999): 1. Print. Globe and Mail. Doug Ford Drug Story: Statement by Globe and Mail Editor John Stackhouse. 10 Sept. 2013. Web. 13 Dec. 2013. <http:// www.thestar.com/news/gta/2013/09/10/doug_ford_drug_story_

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statement_by_globe_and_mail_editor_john_stackhouse.html>. ! Globe and Mail vs. Canada (Attorney General)- 2 S.C.R. 592- 2010E!SCC Cases (Lexum). Web. 28 Dec. 2013. Harrison, Connie. Personal Interview. 11 Dec. 2013. Ipsos.com. Life-Sellers, Medical Professionals Top the List of Most Trusted Professionals. 16 June 2013. Web. 6 Dec. 2013. http://www.ipsosna.com/news-polls/pressrelease.aspx?id=5663. Foreman, Gene. "Confidential Sources: Testing the Readers' Confidence." Nieman Reports 53/54.4/1 (1999): 123. Print. J Source. Twitter Post. Nov. 9, 2013. http//twitter.com/@jsource. Jobb, Dean. Media Law for Canadian Journalists 2nd Edition. Toronto: Edmond Montgomery Publications Limited, 2011. Print. Kimball, Michele Bush. "Granting Sources Anonymity Requires Complex Process." Newspaper Research Journal 32.2 (2011): 36. Print. Mallick, Heather. Hurt feelings meet hard facts in Ford hearing. 11 Sept. 2013. Web. 10 Dec. 2013. <http://www.thestar.com/opinion/commentary/ 2013/09/11/hurt_feelingsmeet_hard_facts_in_ford_hearing_mallick. html>. McArthur, Greg. Globe Investigation: The Ford familys history with drug dealing. The Globe and Mail. 25 May 2013. Web. Nov 12. ---. Personal Interview. 6 Dec. 2013. McIntosh, Andrew. Email Interview. 11 Dec. 2013. Mitrovica, Andrew. Hear No Evil, Write No Lies. The Walrus. (2007).!KE,JEK^E

! Print.

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Meyers, Christopher, ed. Journalism Ethics: A Philosophical Approach. New York: Oxford University Press, 2010. Print. Ontario Press Council decision: Harrison vs. Globe and Mail, Oct. 2013. R. vs. National Post 1 S.C.R. 477. Supreme Court of Canada. 2010. SCC Cases (Lexum). Web. 28 Dec. 2013. Rudnicki, Denise. Insiders Say: The Use of Unnamed Sources in the Globe and Mail. Canadian Journal of Media Studies 2.1 (2005). 41. Print. Sheehy, Michael W. "Study Examines Unnamed Source Policies at the Washington Post." Newspaper Research Journal 31.1 (2010): 84. Print.

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