This appeal presents the question whether an investigative author, at work on a forthcoming book, may be compelled to testify and produce notes and tape recordings of interviews he conducted with a source who happens to be a defendant in a defamation action. We hold, under the circumstances of this ease, that he may not.

I

Appellant Ronald Watkins is an investigative author of books on topical and controversial subjects. He became involved in this defamation action because of his work on a forthcoming non-fiction book about a long and bitter family feud over control of the highly successful U-Haul Company — a feud pitting the patriarch of the family and founder of U-Haul, Leonard Shoen, against two of his sons, Mark and Edward Shoen. In the midst of these family quarrels, Eva Berg Shoen, the wife of Leonard’s eldest son Sam, was found brutally murdered in her family’s log cabin in Telluride, Colorado. The murder remains unsolved.

Following Eva’s murder, Watkins, the author of two previous investigative books on issues of current interest, 1 secured a contract with a major publisher to write a book about the Shoen family, its battles over control of U-Haul, and the murder of Eva Shoen. The book, entitled Birthright, is slated for publication in late 1993.

Leonard Shoen agreed to cooperate with Watkins by providing source material for the book in exchange for a share of future royalties. Watkins then conducted a number of research interviews with Leonard, some of which were tape recorded by Watkins. Leonard’s cooperation as á source for Watkins’ book was not kept secret; nor does it appear that Leonard had any expectation that the information he provided Watkins would remain confidential.

Meanwhile, Mark and Edward Shoen, the two sons at war with Leonard over U-Haul, brought this defamation against their father, alleging that he made public statements linking them to the murder of their sister-in-law Eva. 2 Mark and Edward do not claim that *1291 their father made any of his allegedly defamatory statements to Watkins. However, as part of their pretrial discovery, plaintiffs served Watkins with a subpoena duces tecum ordering him to appear at a deposition, testify, and produce any notes, documents, electronic recordings, or any other records in his possession “relating to the death of Eva Berg Shoen.” After failing to obtain a protective order under Arizona’s statutory “press shield” law, 3 Watkins appeared at the scheduled deposition but refused to produce any documents or recordings or to answer any questions concerning the substance of his interviews with Leonard Shoen. When plaintiffs filed a motion to compel production of documents and testimony, Watkins responded with a motion to quash on the ground that compulsory disclosure of his interviews with Leonard Shoen would violate his qualified First Amendment privilege as a journalist.

The district court denied Watkins’ motion to quash and granted the plaintiffs’ motion to compel, ruling that Watkins, as an investigative author, had standing to invoke the journalist’s privilege, but that in the particular circumstances of this case, the qualified privilege must yield to the plaintiffs’ litigation needs. The court ordered Watkins to testify about all the “communications by [Leonard] Shoen to Mr. Watkins and [to produce] such materials as may memorialize those communications.” ER at 159. •

The scope of the court’s order later became a matter of dispute. In a telephone conference, the court stated that the plaintiffs were entitled to “each and every method, mode, scrap of paper, computer disk, note, recollection, shred of evidence that would evidence” Leonard Shoen’s communications to Watkins on matters concerning “the murder, the family feud, and any statements made as to ... the plaintiffs [Mark and Edward Shoen] themselves.” ER at 168.

When Watkins refused to appear at the second deposition, the district court held him in contempt. Watkins now appeals the contempt order on the ground that the discovery order compelling him to divulge all that Leonard Shoen told him for use in his book violates his qualified First Amendment privilege as a journalist. We agree and vacate the order holding Watkins in contempt. 4

II

The basic facts underlying the court’s discovery order are not in dispute. The analy *1292 sis begins with two threshold legal questions: First, does an investigative book author have standing to invoke the journalist’s privilege? Second, does the journalist’s privilege protect information and materials obtained without a guarantee of confidentiality? Because these are pure questions of law, our review is de novo. See United States v. McConney, 728 F.2d 1195, 1201 (9th Cir.) (en banc), cert. denied, 469 U.S. 824 , 105 S.Ct. 101 , 83 L.Ed.2d 46 (1984).

Because we- answer both these threshold legal questions in the affirmative and hold that the qualified privilege applies in this case, we must decide a third question: Have the plaintiffs demonstrated a need for Watkins’ information that is sufficient to overcome the interests favoring non-disclosure? Because this question requires us to consider legal principles in the mix of fact, and law, and to exercise judgment in resolving conflicting legal values, we decide this question de novo. Id. at 1202.

Ill

We start with the premise that pretrial discovery is ordinarily “accorded a broad and liberal treatment.” Hickman v. Taylor, 329 U.S. 495, 507 , 67 S.Ct. 385, 392 , 91 L.Ed. 451 (1947). If no claim of privilege applies, a non-party can be compelled to produce evidence regarding any matter “relevant to the subject matter involved in the pending action” or “reasonably calculated to lead to the discovery of admissible evidence.” See Fed.R.Civ.P. 26(b)(1). This broad right of discovery is based on the general principle that litigants have a right to “every man’s evidence,” United States v. Bryan, 339 U.S. 323, 331 , 70 S.Ct. 724, 730 , 94 L.Ed. 884 (1950), and that wide access to relevant facts serves the integrity and fairness of the judicial process by promoting the search for the truth.

However, when facts acquired by a journalist in the course of gathering the news become the target of discovery, a qualified privilege against compelled disclosure comes into play. In Farr v. Pitchess, 522 F.2d 464, 467-68 (9th Cir.1975), cert. denied, 427 U.S. 912 , 96 S.Ct. 3200 , 49 L.Ed.2d 1203 (1976), we interpreted Branzburg v. Hayes, 408 U.S. 665 , 92 S.Ct. 2646 , 33 L.Ed.2d 626 (1972), as establishing such a qualified privilege for journalists. Eight of the other nine circuits that have decided the question read Branzburg the same way. 5

Rooted in the First Amendment, the privilege is a recognition that society’s interest in protecting the integrity of the newsgathering process, and in ensuring the free flow of information to the public, is an interest “ ‘of sufficient social importance to justify some incidental sacrifice of sources of facts needed in the administration of justice.’ ” Herbert v. Lando, 441 U.S. 153, 183 , 99 S.Ct. 1635, 1652 , 60 L.Ed.2d 115 (1979) (Brennan, J., dissenting) (quoting McCormick on Evidence 152 (2d ed. 1972)).

We held in Farr that the journalist’s privilege recognized in Branzburg was a “partial First Amendment shield” that protects journalists against compelled disclosure in all judicial proceedings, civil and criminal alike. Farr, 522 F.2d at 467 . Nevertheless, we stressed that the privilege is qualified, not absolute, and held that the process of deciding whether the privilege is overcome re *1293 quires that “the claimed First Amendment privilege and the opposing need for disclosure be judicially weighed in light of the surrounding facts, and a balance struck to determine where lies the paramount interest.” Id. at 468 .

IV

Before we weigh the competing interests at stake in this case, we must first decide two threshold legal questions of first impression in this circuit: whether Watkins, as an investigative book author, has standing to invoke the journalist’s privilege, and whether the privilege operates to shield information provided by a source without an expectation of confidentiality.

A

Plaintiffs argued below that Watkins has no standing to invoke the journalist’s privilege because book authors are not members of the institutionalized print or broadcast media. 6 We disagree.

So far, the only circuit that has addressed this question is the Second, which did so in von Bulow v. von Bulow, 811 F.2d 136 (2nd Cir.), cert denied 481 U.S. 1015 , 107 S.Ct. 1891 , 95 L.Ed.2d 498 (1987). In von Bulow, the Second Circuit held that the journalist’s privilege was not limited to reporters employed in the traditional print or broadcast media. The purpose of the journalist’s privilege, it reasoned, was not solely to protect newspaper or television reporters, but to protect the activity of “investigative reporting” more generally. Id. at 142-43. Thus, the court said, it makes no difference whether “[t]he intended manner of dissemination [was] by newspaper, magazine, book, public or private broadcast medium, [or] handbill” because “ ‘[t]he press in its historic connotation comprehends every sort of publication which affords a vehicle of information and opinion.’ ” Id. at 144 (quoting Lovell v. Griffin, 303 U.S. 444, 452 , 58 S.Ct. 666, 669 , 82 L.Ed. 949 (1938)).

We find' the Second Circuit’s reasoning in von Bulow persuasive. The journalist’s privilege is designed to protect investigative reporting, regardléss of the medium used to report the news to the public. Investigative book authors, like more conventional reporters, have historically played a vital role in bringing to light “newsworthy” facts on topical and controversial matters of great public importance. At the turn of the century, for example, muckraking authors such as Lincoln Steffens and Upton Sinclair exposed widespread corruption. and abuse in American life. 7 More recently, social critics such as Rachel Carson, Ralph Nader, Jessica Mitford, and others have written books that have made significant contributions to the public discourse on major issues confronting the American people. 8 Indeed, it would be unthinkable to have a rule that an investigative journalist, such as Bob Woodward, would be protected by the privilege in his capacity as a newspaper reporter writing about Watergate, but not as the author of a book on the same topic.

In sum, we see no principled basis for. denying the protection of the journalist’s privilege to investigative book authors while granting it to more traditional print and broadcast journalists. What makes journalism journalism is not its format but its content.

Hence, the critical question for deciding whether a person may invoke the journalist’s privilege is whether she is gathering news for dissemination to the public. The test, as the Second Circuit put it so nicely in von Bulow, is whether the person seeking to invoke the privilege had “the intent to use material — sought, gathered or received — to disseminate information to the public and [whether] such intent existed at the inception of the newsgathering process.” 811 F.2d at *1294 144 . If both conditions are satisfied, then the privilege may be invoked. 9

Ronald Watkins easily passes this test. It is uncontroverted that he undertook his present research with the intention of writing a book about the Shoen family, its longstanding feud over control of the U-Haul trucking empire, and the murder of Eva Shoen. Accordingly, Watkins has standing to invoke the journalist’s privilege.

B

We now turn to the question whether Watkins is barred from invoking the journalist’s privilege to shield the information he obtained from Leonard Shoen because the information was not obtained under a promise of confidentiality. 10

All three circuits that have addressed this question have held that the privilege protects a journalist’s resource materials regardless of whether these materials contain confidential information.

The Third Circuit was the first to address the confidentiality question. United States v. Cuthbertson, 630 F.2d 139 (3d Cir.1980), involved an attempt by a criminal defendant to obtain reporters’ notes and film “out-takes” (videotaped material not broadcast) collected by CBS reporters in preparation for a story broadcast on “60 Minutes.” Even though none of CBS’ information was obtained in confidence, the Third Circuit held that the journalist’s privilege shielded CBS’ unpublished resource materials. The court reasoned that,

Id. at 147 (citations omitted).

In von Bulow, the Second Circuit also held that the privilege may be invoked whether or not the information was obtained in confidence. In outlining the general principles underlying the journalist’s privilege, the Second Circuit said that “the relationship between the journalist and his source may be confidential or non-confidential for purposes of the privilege” and “unpublished resource material likewise may be protected.” 811 F.2d at 142 .

Finally, and most recently, the First Circuit addressed the question in United States v. La Rouche Campaign, 841 F.2d 1176 (1st Cir.1988), which involved an attempt by a criminal defendant to obtain film out-takes from an interview by NBC reporters with a prospective key witness for the prosecution. In appraising the First Amendment interests at stake, the court considered four different justifications presented by NBC for extending protection to non-confidential information:

Id. at 1182 (internal quotations omitted). The court agreed that there was merit to these asserted First Amendment interests. 11 It noted a “lurking and subtle threat” to the vitality of a free press if disclosure of non-confidential information “becomes routine and casually, if not cavalierly, compelled.” Id. The court continued,

Id. The First Circuit held that, because these were legitimate First Amendment interests, they must be balanced against the defendant’s interests before disclosure may be ordered.

As two distinguished commentators have written, elaborating on a point touched upon by the First Circuit in La Rouche, the compelled disclosure of non-confidential information harms the press’ ability to gather information by

Duane D. Morse & John W. Zucker, The Journalist’s Privilege in Testimonial Privileges 474-75 (Scott N. Stone & Ronald S. Liebman eds., 1988).

We find this body of circuit case law and scholarly authority so persuasive that we think it unnecessary to discuss the question further. 12 Accordingly, we hold that the journalist’s privilege applies to a journalist’s resource materials even in the absence of the element of confidentiality. We add, however, that the absence of confidentiality may be considered in the balance of competing interests as a factor that diminishes the journalist’s, and the public’s, interest in non-disclosure. As the Third Circuit said in Cuthbert-son, “the lack of a confidential source may be an important element in balancing the defendant’s need for the material sought against the interest of the journalist in preventing *1296 production in a particular case.” 680 F.2d at 147.

Having decided that Watkins has properly invoked the privilege on the facts of this case, we now must determine whether plaintiffs’ need for the information outweighs the First Amendment interests at stake. 13

V

Once the privilege is properly invoked, the burden shifts to the requesting party to demonstrate a sufficiently compelling need for the journalist’s materials to overcome the privilege. At a minimum, this requires a showing that the information sought is not obtainable from another source. See In re Petroleum Prods. Antitrust Litig., 680 F.2d 5, 7 (2d Cir.), cert. denied, 459 U.S. 909 , 103 S.Ct. 215 , 74 L.Ed.2d 171 (1982); United States v. Criden, 633 F.2d 346, 358-59 (3d Cir.1980); Silkwood, supra at 438. In other words, before disclosure may be ordered, the requesting party must demonstrate that she has exhausted all reasonable alternative means for obtaining the information. Zerilli, supra at 713.

We hold that plaintiffs have not satisfied this threshold requirement because they failed to take Leonard Shoen’s deposition before trying to penetrate the journalist’s shield that protects Watkins’ source materials. 14

Plaintiffs do not dispute that their father is an obvious alternative source for discovering what he said to Watkins in their conversations. Rather, plaintiffs argue that they have exhausted Leonard as a source by serving him with written interrogatories which produced uninformative answers. Plaintiffs’ written interrogatories asked their defendant father the following question:

In response, plaintiffs received the following answer:

Then, after describing generally the dates and locations of his conversations with Watkins, approximately how many took place in person and over the phone, and indicating that only Watkins and he were present during these conversations, Shoen stated the following:

Appellee’s Joint Supplemental Excerpts of Record at 206 (emphasis added).

At that point, plaintiffs abandoned their attempt to discover from Leonard Shoen what he told Watkins. They argue that it would be futile to take their father’s deposition because his answers to the interrogatories establish that he has no recollection of the content of the conversations. Thus they rely exclusively on Interrogatory No. 7 to satisfy the requirement of exhausting all reasonable alternatives before compelling Watkins to disclose his source materials.

Written interrogatories are rarely, if ever, an adequate substitute for a deposition when the goal is discovery of a witness’ recollection of conversations. Leonard Shoen’s answer to Interrogatory No. 7 illustrates this common sense proposition. His answer, such as it is, cries out for follow-up questions. Although he claims to be unable to recall the “specific content” of his conversations with Watkins, he admits to remembering that such conversations did take place, where and when they took place, and whether in person or by telephone. This admission, combined with the implied admission that he remembers at least something about the content of the conversations, if not their “specific content,” provides plaintiffs’ lawyers with material they can exploit in asking follow-up questions designed to test and refresh his recollection of the details of the conversations. Follow-up questions such as these are virtually impossible in interrogatories.

Only by examining a witness live can a lawyer use the skills of his trade to plumb the depths of a witness’ recollection, using to advantage not only what a witness may have admitted in answering interrogatories,' but also any new tidbits that usually come out in the course of answering carefully framed and pin-pointed deposition questions. Written interrogatories are not designed for that purpose; pointed questions at deposition are the only effective way to discover facts bottled up in a witness’ recollection, particularly when the witness is as hostile as Leonard Shoen is sure to be as a defendant sued by two sons for allegedly linking them to the murder of their sister-in-law. Indeed, the allegations in this' case, revolving around the murder of Eva Shoen, are so dramatic that it may be impossible for Leonard Shoen to testify, if asked, that he has no recollection of discussing the murder in conversations with an.author writing a book about the murder, especially when he had a contract to cooperate with that author.

In sum, plaintiffs’ reliance on Leonard Shoen’s interrogatory answer that he cannot recall the “specific content” of his conversation fails as an excuse for not taking his deposition before turning their discovery weapons against Watkins. Nor can they avoid the exhaustion requirement by speculating, without supporting evidence, that Leonard Shoen’s advanced age may have dulled his faculties. Cf. Zerilli, supra at 715 (The moving parties “cannot escape their obligation to exhaust alternative sources simply because they feared that deposing [numerous] employees would be time-consuming, costly, and unproductive.”). As the court noted in Carey v. Hume, 492 F.2d 631 (D.C.Cir.), cert. dismissed, 417 U.S. 938 , 94 S.Ct. 2654 , 41 L.Ed.2d 661 (1974), compelled disclosure from a journalist must be a “last resort after pursuit of other opportunities has failed.” Id. at 639.

Plaintiffs’ failure to depose Leonard Shoen before pursuing Watkins highlights an important distinction between this case and Farr . In Farr , a trial judge sought disclosure from a third-party journalist to determine which of the attorneys in a celebrated murder case had violated a gag order by leaking a witness statement to the journalist. The journalist was ordered to disclose his source only after the court held a series of hearings, at which each of the attorneys still alive denied, under oath, that he was the source of the leak. At that point, the only untapped source for the wrongdoer’s identity was the journalist. Here, in contrast, by failing to depose Leonard Shoen, plaintiffs have failed to exhaust the “most patently available other source.” Riley v. City of Chester, 612 F.2d 708, 717 (3d Cir.1979).

In sum, it is too early in the discovery process for Watkins’ journalist privilege to yield. In so holding, we do not say that *1298 plaintiffs will never be able to overcome the presumption in favor of the privilege; we say-only that they have failed to provide a sufficiently compelling reason to do so at this stage of the litigation.

REVERSED AND REMANDED.

. Ronald Watkins is the author of High Crimes and Misdemeanors (1990), an account of the impeachment of former Arizona governor Evan Mecham, and Evil Intentions (1992), an account of the recent murder of Suzanne Rossetti.

. Among the statements plaintiffs allege to be defamatory are the following examples:

Edward J. Shoen’s Complaint for Defamation at 2-9.

. The First, Second, Third, Fourth, Fifth, Eighth, Tenth, and District of Columbia circuits have all interpreted Branzburg as establishing a qualified privilege for journalists to resist compelled discovery. See Bruno & Stillman, Inc. v. Globe Newspaper Corp., 633 F.2d 583, 595-96 (1st Cir.1980); United States v. Burke, 700 F.2d 70, 77 (2d Cir.), cert. denied, 464 U.S. 816 , 104 S.Ct. 72 , 78 L.Ed.2d 85 (1983); United States v. Cuthbertson, 630 F.2d 139, 147 (3d Cir.1980), cert. denied, 449 U.S. 1126 , 101 S.Ct. 945 , 67 L.Ed.2d 113 (1981); LaRouche v. National Broadcasting Co., 780 F.2d 1134, 1139 (4th Cir.), cert. denied, 479 U.S. 818 , 107 S.Ct. 79 , 93 L.Ed.2d 34 (1986); Miller v. Transamerican Press, 621 F.2d 721, 725 (5th Cir.1980), cert. denied, 450 U.S. 1041 , 101 S.Ct. 1759 , 68 L.Ed.2d 238 (1981); Cervantes v. Time, Inc., 464 F.2d 986 , 992-93 & n. 9 (8th Cir.1972), cert. denied, 409 U.S. 1125 , 93 S.Ct. 939 , 35 L.Ed.2d 257 (1973); Silkwood v. Kerr-McGee Corp., 563 F.2d 433, 436-37 (10th Cir.1977); Zerilli v. Smith, 656 F.2d 705, 714 (D.C.Cir.1981).

Only the Sixth Circuit reads Branzburg as denying a qualified First Amendment privilege to journalists. See In re Grand Jury Proceedings, 810 F.2d 580, 584-85 (6th Cir.1987). The Seventh and Eleventh Circuits have yet to decide the question.

. The district court denied Watkins' motion for a protective order under Arizona’s "press shield” law, Ariz.Rev.Stat.Ann. §§ 12-2214, 12-2237, because an intervening decision by the Arizona Court of Appeals had construed the application of the shield law to exclude investigative book authors such as Watkins. See Matera v. Superior Court, 170 Ariz. 446 , 825 P.2d 971 (Ariz.Ct.App.1992).

. Our jurisdiction to review the contempt order rests on 28 U.S.C. § 1291 . See Newton v. National Broadcasting Co. Inc., 726 F.2d 591, 592 (9th Cir.1984).

.The district court held that, as an author, Watkins was entitled to invoke the journalist’s privilege. Plaintiffs do not challenge this ruling on appeal. We nevertheless reach the issue here because it is essential to our reasoning in deciding this appeal.

. See Lincoln Steffens, The Shame of the Cities (1904); Upton Sinclair, The Jungle (1906).

. See Rachel Carson, The Silent Spring (1962); Ralph Nader, Unsafe at any Speed (1965); Jessica Mitford, The American Way of Death (1963) and The American Way of Birth (1992).

. We do not decide whether the journalist's privilege may be invoked by a person writing a book about a recent historical figure, such as Harry Truman or Albert Einstein, where the intent, arguably, is not the dissemination of "news,” but the writing of history. We do not rule out the possibility but simply leave the question for another day.

. Watkins states, generally, that he had confidential relationships with sources in the course of writing this book. But Watkins does not say that Leonard Shoen had any expectation that the information he provided to Watkins would remain confidential.

Indeed, it appears from the record that Leonard expected the information he provided to Watkins to be disclosed publicly in Watkins’ forthcoming book. Soon after Leonard agreed to be a source for Watkins’ book, Watkins wrote a letter to the public relations manager of U-Haul, stating that Leonard was "extending his complete cooperation [on the book] without preconditions." ER at 28 (emphasis added).

It may be the case that Leonard expected the information and its source to remain secret until the book was published. But an expectation of delayed disclosure is not the same as an expectation of confidentiality.

The critical question is whether Leonard reasonably expected to be protected by a cloak of confidentiality even after publication. Because Watkins makes no claim that Leonard had such an expectation, our analysis proceeds on the assumption that no element of confidentiality is at stake.

. The court in La Rouche did not use the term journalist's privilege. Rather, it spoke in terms of weighing the First Amendment interests before compelling disclosure of a journalist's sources. Nevertheless, the court recognized that the difference in terminology was simply one of semantics:

841 F.2d at 1181 (quoting Bruno & Stillman, Inc. v. Globe Newspaper Co., 633 F.2d 583, 595 (1st Cir.1980)).

. See also Miller v. Mecklenburg County, 602 F.Supp. 675, 678 (W.D.N.C.1985) (noting that the "majority view [among the district courts] clearly is that non-confidential material received by a reporter from an investigative source is protected by the qualified privilege”).

. We respect the efforts made in the concurring opinion to reverse the discovery and contempt orders on the non-constitutional ground that the district court abused its discretion under Fed. R.Civ.P. 26(b). However, this effort to avoid Watkins' claim of privilege under the First Amendment falls short. Absent the claim of privilege, the district court would have been well within its discretion in ordering Watkins to answer the interrogatories and the deposition questions about his conversations with defendant Leonard Shoen relating to the murder of Eva Shoen. Those conversations are plainly "relevant to the subject matter involved in the pending action,” Fed.R.Civ.P. 26(b)(1), and there is nothing in the discovery rules that requires a party to depose an adverse party before a third party witness. Indeed, Watkins does not challenge the discovery and contempt orders as an abuse of discretion under Rule 26; rather he' challenges the orders solely on the legal ground of the journalist’s qualified First Amendment privilege.

. Because we hold that plaintiffs have not satisfied the exhaustion requirement, we express no opinion on whether plaintiffs have made a sufficient showing on the other questions considered in the balance — i.e., whether the information sought is relevant, material, and non-cumulative, and whether it is crucial to the maintenance of plaintiffs’ legal claims. See generally In re Petroleum Prods., supra at 7; Los Angeles Memorial Coliseum Comm'n v. National Football League, 89 F.R.D. 489, 494 (C.D.Cal.1981) (and cases cited therein).