An attorney representing convicted serial child molester Jerry Sandusky may not invoke the work-product doctrine to avoid complying with a protective order issued by the judge who presided over Sandusky's trial, which was put in place days after grand jury materials in the case were allegedly leaked to the media.

In an opinion filed Friday, a three-judge panel led by President Judge Correale F. Stevens rejected attorney Karl E. Rominger's position that the work-product doctrine applied to Commonwealth v.Sandusky. Even if it did, Stevens said Rominger had failed to show how the doctrine was violated by the order, adding, "We simply decline to develop this argument for attorney Rominger or otherwise become his advocate in this regard."