Judith Miller: How Did They Know?
According to her lawyer Floyd Abrams, they've assumed it's because one of the white house officials told the grand jury he had talked to her about it.
Asked why prosecutors sought Miller's testimony when she never wrote a story about Plame, Times attorney Floyd Abrams said, "We don't know, but most likely somebody testified to the grand jury that he or she had spoken to Judy."
Who would it be? Most likely, in my opinion, Lewis Libby. Miller has said that even though her source gave a general waiver, she can't be sure it was not coerced and therefore wouldn't credit it. Also, the subpoenas she received only concerned communications with a single, identified person. From the DC Court of Appeals decision (pdf):
In the meantime, on August 12 and August 14, grand jury subpoenas were issued to Judith Miller, seeking documents and testimony related to conversations between her and a specified government official “occurring from on or about July 6, 2003, to on or about July 13, 2003, . . . concerning Valerie Plame Wilson (whether referred to by name or by description as the wife of Ambassador Wilson) or concerning Iraqi efforts to obtain uranium.”
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