Case 5:12-cv-00836-DEP Document 97-20 Filed 09/30/15 Page 1 of 5

EXHIBIT R
to the
DECLARATION OF THOMAS CURLEY
IN SUPPORT OF
DEFENDANTS MOTION FOR AN ORDER
FINDING PLAINTIFF TO BE A PUBLIC FIGURE

Case 5:12-cv-00836-DEP Document 97-20 Filed 09/30/15 Page 2 of 5

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UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF NEW YORK

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LAURIE J. FINE,

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Plaintiff,
-vs-

5:12-CV-0836 (LEK/DEP)

ESPN, INC., a Subsidiary of Walt

Disney, Inc., MARK SCHWARZ, in his

individual capacity and as an employee

of ESPN; and ARTHUR BERKO, in his

individual capacity and as an employee

of ESPN,

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Defendants.
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Deposition of DEBORAH A. GAETANO,

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Non-Party Witness, held at the offices of

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ACTION REPORTING SERVICE, LLC, Syracuse,

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New York, on 12/09/2014, 10:51 a.m., before

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PAMELA PALOMEQUE, RPR, CRR, and Notary Public

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in and for the State of New York.

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212-279-9424

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www.veritext.com

212-490-3430

Case 5:12-cv-00836-DEP Document 97-20 Filed 09/30/15 Page 3 of 5

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APPEARANCES:
For the Plaintiff:
(TELEPHONICALLY)
COHEN & WILLWERTH
Attorneys at Law
301 Grant Street
Suite 4300
Pittsburgh, PA 15219
BY:
LAWRENCE H. FISHER, ESQ.
412.894.8741
lawfirst@comcast.net
For the Defendants:
LEVINE, SULLIVAN, KOCH & SCHULZ, LLP
Attorneys at Law
321 West 44th Street
Suite 100
New York, New York 10036
BY:
RACHEL F. STROM, ESQ.
212.850.6102
rstrom@lskslaw.com
For the Witness:
SUGARMAN LAW FIRM
Attorneys at Law
211 West Jefferson Street
Syracuse, New York
13202
BY:
DONALD L. SCHOENWALD, ESQ.

212-279-9424

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Case 5:12-cv-00836-DEP Document 97-20 Filed 09/30/15 Page 4 of 5

Page 60
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the opinions of people who don't know Laurie?

MS. STROM:

Objection.

Q.

Don't know Laurie?

A.

No.

Q.

"No," you don't know or "no," I'm not right?

A.

Ask me the question again.

Q.

Do you have any idea of how the tape -- the

publication of that tape would have affected the

opinions of people who did not know Laurie?

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MS. STROM:

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Objection.

A.

No, I don't know how it would have affected

Q.

Because everyone you've spoken to knows

them.

Laurie Fine, right?

A.

Well, in this community, yes.

She made a

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point of getting herself known so she was out there.

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Everybody knew her.

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Q.

I understand that.

I'm just talking about

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the people that you've spoken to.

The people that

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you've spoken to about this tape know Laurie Fine,

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right?

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A.

Yeah, most of the people, yeah.

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Q.

Okay.

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MR. FISHER:

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MS. STROM:

212-279-9424

That's all I have.

Okay, great.

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Case 5:12-cv-00836-DEP Document 97-20 Filed 09/30/15 Page 5 of 5

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REPORTER'S CERTIFICATE

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I, PAMELA PALOMEQUE, RPR, CRR, and

Notary Public, certify:

That the foregoing proceedings were taken before me at

the time and place therein set forth, at which time the

witness was put under oath by me;

That the testimony of the witness and all objections made

at the time of the examination were recorded

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stenographically by me and were thereafter transcribed;

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That the foregoing is a true and correct transcript of my

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shorthand notes so taken;

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I further certify that I am not a relative or employee of

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any attorney or of any of the parties nor financially

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interested in the action.

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<%Signature%>
PAMELA PALOMEQUE, RPR, CRR

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Certified Livenote Reporter

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212-279-9424

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www.veritext.com

212-490-3430