Look at the parsing in today's bombshell NY Times story fingering Cheney as the source of Plame's identity:

Mr. Libby's lawyer, Joseph Tate, would not comment on Mr. Libby's legal status.

Looks like Libby's lawyer may have commented on some other things, just not Mr. Libby's legal status.  It doesn't indicate that he didn't say anything else.  Thus he is probably the source of the leak.  The reporters could not have truthfully said that he didn't comment if he gave them the notes scoop.