laurie partial deposition

EXHIBIT A

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 97-3 Filed 09/30/15 of 28

·1· · · · · · ·UNITED STATES DISTRICT COURT

·2· · · · FOR THE NORTHERN DISTRICT OF NEW YORK

·3

·4· ·LAURIE J. FINE,·5· · · · · · · · · ·Plaintiff,· · · ·Index No.·6· · · -against-· · · · · · · · · · ·5:12-cv-00836·7· · · · · · · · · · · · · · · · · (LEK) (DEP)

·8 ESPN, Inc., a subsidiary of· ·Walt Disney, Inc.; MARK·9 SCHWARZ, in his individual· ·capacity and as an employee10 of ESPN, and ARTHUR BERKO,· ·in his individual capacity11 and as an employee of ESPN,

12· · · · · · · · ·Defendants.

13

14

15· · · · · · · · · ·VIDEO DEPOSITION OF16· · · · · · · · · ·LAURIE J. FINE

17

18· · · · · · · · · September 3, 2014· · · · · · · · · · · · 9:56 a.m.19

20· · · · · · · · · · · Law First· · · · · · · · · · One Oxford Centre21· · · · · · · · · · ·Suite 4300· · · · · · ·Pittsburgh, Pennsylvania 1521922

23

24· · Dana M. Cunningham, Professional Court Reporter25

LAURIE J. FINE·FINE vs. ESPN

September 03, 2014

800.211.DEPO (3376)EsquireSolutions.com


September 03, 20141



·1· APPEARANCES OF COUNSEL:

·2· On Behalf of the Plaintiff:

·3· · ·LAWRENCE H. FISHER, ESQ.· · · ·Law First·4· · ·One Oxford Centre· · · ·Suite 4300·5· · ·Pittsburgh, Pennsylvania 15219· · · ·412-577-4040·6· · ·[email protected]

·7

·8· On Behalf of the Defendants:

·9· · ·PAUL J. SAFIER, ESQ.· · · ·NATHAN SIEGEL, ESQ.10· · ·Levine, Sullivan, Koch & Schulz, LLP· · · ·1899 L Street, NW11· · ·Suite 200· · · ·Washington, DC 2003612· · ·202-508-1184· · · ·[email protected]· · ·[email protected]

14· · Also Present:· Brandon Wilczek, Videographer15

16

17

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20

21

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25


September 03, 2014



September 03, 20142



·1· working?

·2· · · ·A.· · Yes.

·3· · · ·Q.· · Did you continue to work as you had

·4· children?

·5· · · ·A.· · On and off.

·6· · · ·Q.· · Doing what?

·7· · · ·A.· · Hairdressing.

·8· · · ·Q.· · And did you participate in the

·9· activities of the basketball team to any extent?

10· · · ·A.· · What activities?

11· · · ·Q.· · Did you go to games?

12· · · ·A.· · Yes.

13· · · ·Q.· · Did you go to any sports banquets or

14· dinners or things like that that they had?

15· · · ·A.· · Yes, yes.

16· · · ·Q.· · Have you worked at different salons

17· over time?

18· · · ·A.· · No.

19· · · ·Q.· · So what's -- the same one?

20· · · ·A.· · Yes.

21· · · ·Q.· · Which one is that?

22· · · ·A.· · Headlines.

23· · · ·Q.· · Has Headlines been owned by the same

24· person throughout your --

25· · · ·A.· · Yes.


September 03, 2014



September 03, 201414


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·1· · · ·Q.· · We obtained and we provided to your

·2· counsel several news stories about that boutique

·3· on local media.· How did those come about?

·4· About the opening of that boutique -- do you

·5· remember that?

·6· · · ·A.· · Yes.· My partner, who had a daughter,

·7· who had passed away, and they were trying to

·8· feature the story around her and what she was

·9· doing, now that her life was getting back on

10· track.

11· · · ·Q.· · Who was your partner?

12· · · ·A.· · Mary Joe Hicamp.

13· · · ·Q.· · To your knowledge how did -- did

14· somebody approach these television stations?

15· · · ·A.· · I don't recall.· I don't recall.

16· · · ·Q.· · I don't remember seeing anything

17· about Ms. Hicamp in those stories.· You were

18· featured in those stories --

19· · · ·A.· · I have a whole page with Mary Joe

20· featured on the back of the Post Standard.· Mary

21· Joe's name was mentioned all through it.

22· · · ·Q.· · What about the television stories?

23· · · ·A.· · The television stories -- I don't

24· recall how that came to be, but I know they did

25· come up to the salon and film me there in the


·1· dog boutique because it was a new trend, you

·2· know, doggie things.

·3· · · ·Q.· · Okay.

·4· · · · · · ·Other than them coming up to the

·5· boutique did you have any contact with anyone

·6· from the television station?

·7· · · ·A.· · I don't recall.

·8· · · ·Q.· · Did you talk to anyone at any

·9· television station beforehand about them doing

10· this story?

11· · · ·A.· · I can't recall.

12· · · ·Q.· · When did you stop working for the

13· Boys and Girls Club?

14· · · ·A.· · October 2000 -- I think '11 or '12,

15· when this came to be.· I was already done there.

16· Going into a different job.

17· · · ·Q.· · And why did you stop working at the

18· Boys and Girls Club?

19· · · ·A.· · They merged with the Salvation Army,

20· so my position was eliminated.

21· · · ·Q.· · What was the different job you were

22· going into?

23· · · ·A.· · Save the Children, through a

24· detention center there, to work with youth that

25· were, you know, troubled.


·1· · · ·Q.· · And how did you obtain that job?

·2· · · ·A.· · A gentleman who worked at the Boys

·3· and Girls Club had been at this new job and

·4· approached me after the Boys and Girls Club had,

·5· you know, merged.

·6· · · ·Q.· · And what was that job going to be?

·7· · · ·A.· · You know, working with the children,

·8· doing some fundraising for them.· You know, just

·9· get funds for the children there.

10· · · ·Q.· · And what happened to that?

11· · · ·A.· · What happened?

12· · · ·Q.· · Did you ever start?

13· · · ·A.· · No.

14· · · ·Q.· · Why not?

15· · · ·A.· · The whole thing broke with this news

16· and I never started.

17· · · ·Q.· · And why is that?· What was the

18· relationship to the news breaking and you're not

19· starting?

20· · · ·A.· · You know, to be honest with you,

21· probably, you know, I just wasn't a good fit at

22· that point for them.

23· · · ·Q.· · Who was the name of the gentleman

24· who --

25· · · ·A.· · Jim Zarneack.


·1· · · ·Q.· · Did Mr. Zarneack or anybody else tell

·2· you that they no longer wanted you to work

·3· there?

·4· · · ·A.· · Not in so many words, but I got the

·5· idea.

·6· · · ·Q.· · How did you get the idea?

·7· · · ·A.· · I asked him would the position still

·8· be open and he said, you know, he would have to

·9· think about it and I never heard back from him.

10· · · ·Q.· · And do you attribute that to the news

11· stories?

12· · · ·A.· · Yes.

13· · · ·Q.· · Why so?

14· · · ·A.· · Well, it was very disparaging, and,

15· you know, I understood his reasoning.· I'd be

16· working with children.· So, you know, I totally

17· understood.

18· · · ·Q.· · Was raising money for children's

19· organization something that you had developed an

20· interest in by that point?

21· · · ·A.· · For any organization that needed

22· help, children, adult, any of them.

23· · · ·Q.· · In your Complaint -- your Complaint

24· alleges in Paragraph No. 2 that in light of her

25· connection to the basketball program charitable


·1· organizations often competed to employ Plaintiff

·2· in various capacities.· Is that true?

·3· · · ·A.· · Can you rephrase that?· I'm kind

·4· of --

·5· · · ·Q.· · It says in light of her connection to

·6· the basketball program, charitable organizations

·7· often competed to employ Plaintiff in various

·8· capacities.

·9· · · ·A.· · I wouldn't say competed, but, you

10· know, yes.· I did a good job, so yeah.

11· · · ·Q.· · And what was the connection to the

12· basketball program?

13· · · ·A.· · Very little because at that point I

14· developed my own thing and I didn't, you know,

15· rely on the basketball program at all.

16· · · · · · ·I mean, I got the job.· The

17· basketball program was a plus, but at the end of

18· the day you can be as good as you want, but you

19· got to do the job.

20· · · ·Q.· · How was the basketball program a

21· plus?

22· · · ·A.· · Because they were, you know, very

23· obviously loved in the community.· So that

24· certainly helped.

25· · · ·Q.· · Backtracking a little bit, prior to


September 03, 2014





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·1· seriously and I did a good job.

·2· · · ·Q.· · Referring to your years of dedication

·3· to the city of Syracuse, what are you referring

·4· to?

·5· · · ·A.· · My fundraising.

·6· · · ·Q.· · Which had only begun a couple of

·7· years earlier; correct?

·8· · · ·A.· · Um-hum.

·9· · · ·Q.· · So you weren't referring to anything

10· else?

11· · · ·A.· · Other charity work that I had done.

12· · · ·Q.· · Which was what?

13· · · ·A.· · The Make-A-Wish Foundation.

14· · · ·Q.· · What's the Make-A-Wish Foundation?

15· · · ·A.· · It's for, you know, youth, children

16· with cancer.· You know, wishes are granted.

17· · · ·Q.· · What did you do for them?

18· · · ·A.· · Just volunteered, you know, raised

19· money, volunteered.

20· · · ·Q.· · Any other charitable organizations?

21· · · ·A.· · The Kidney Foundation, I raised very

22· little money for them.· It was just a very short

23· stint with them.· Enable -- we co-chaired an

24· event.· I really didn't raise any money.· We

25· just co-chaired the event.


·1· · · ·Q.· · Why did you consider your charitable

·2· work to be dedication to the City of Syracuse?

·3· · · ·A.· · Because I dedicated a lot of time and

·4· a lot of good effort and it was a dedication.

·5· Whether it was to Syracuse or anywhere, it was

·6· dedicated to, you know, the kids and whomever we

·7· raised money for.

·8· · · ·Q.· · Starting in April of 2010, or at

·9· least it appears to us, there were several times

10· that you served as a cohost on a television

11· program called Bridge Street?

12· · · ·A.· · Correct.

13· · · ·Q.· · That's a program on WSYR is the --

14· how did that come about?

15· · · ·A.· · They -- I filled in for the cohost

16· who was out that day.· They just called me and

17· asked me and I did it.

18· · · ·Q.· · Who called you?

19· · · ·A.· · I believe the producer of the show.

20· And I don't know -- I really forgot her name.

21· She's no longer there.

22· · · ·Q.· · Had you had any contact with that

23· producer of the show or anything before?

24· · · ·A.· · She may have come to an event.· I'm

25· unclear.· She may have come to a few things that


·1· I had done.

·2· · · ·Q.· · Why did she call you?

·3· · · ·A.· · Because I have a great personality

·4· and I was good with people.

·5· · · ·Q.· · It looks to us like you did that on

·6· -- again, I can show you these, but to save

·7· time, you did that on several different

·8· occasions in 2010 and at least once again in

·9· 2011.· How did that occur?

10· · · ·A.· · I did a good job and they asked me to

11· come back when someone was out and I gladly came

12· to them.

13· · · ·Q.· · Do you remember about how many times

14· you did it, you were the cohost of the show?

15· · · ·A.· · I don't, I don't.

16· · · ·Q.· · There were also several times when

17· you were invited as a guest on that program?

18· · · ·A.· · I remember one, for the Boys and

19· Girls Club perhaps, but other than that, no.

20· · · ·Q.· · Can we agree that the television

21· programs have given us the material and it is

22· what it is?

23· · · ·A.· · Okay.

24· · · ·Q.· · The time that you recall when you

25· talked about the work -- I think it was a


·1· fundraising galla or an event that the Boys and

·2· Girls Club --

·3· · · ·A.· · Yes, yes.

·4· · · ·Q.· · How did that come about that you came

·5· onto the program to talk about that?

·6· · · ·A.· · I believe the one time I recall we

·7· did a fashion show at my house and we came on to

·8· show the models clothing on there and we were a

·9· guest.· You know, I don't think I even appeared.

10· They had someone else speak.· So -- and we had

11· the models on there.

12· · · ·Q.· · There were times when you appeared to

13· talk about that --

14· · · ·A.· · Yes.

15· · · ·Q.· · And how did it come about that you

16· came on?

17· · · ·A.· · Onto the show?

18· · · ·Q.· · Yes.

19· · · ·A.· · I think I approached them because it

20· was a great selling point to get everything out

21· there.

22· · · ·Q.· · Who did you approach?

23· · · ·A.· · I'm not sure if it was Maggie or

24· someone else there.· I'm not sure.· At the --

25· you know, at the TV station whom.


·1· · · ·Q.· · But by that point, by the time that

·2· you appeared on the television programs, was

·3· at-risk youths something that you had taken a

·4· particular interest in?

·5· · · ·A.· · I took an interest in fundraising

·6· period.

·7· · · ·Q.· · You also in March of 2010 acted as

·8· sort of a guest reporter for WSYR --

·9· · · ·A.· · Correct.

10· · · ·Q.· · -- prior to a NBA playoff basketball

11· game.· How did that come about?

12· · · ·A.· · I think they asked me if I would do

13· it and I, you know, said yes, just to get, you

14· know, the inside scope.

15· · · ·Q.· · Who asked you?

16· · · ·A.· · I don't know.· It was someone at the

17· channel, but I don't -- I don't recall if the

18· president or Maggie or someone else.· I don't

19· recall that, how that came about.

20· · · ·Q.· · Who is Maggie?

21· · · ·A.· · Maggie was the producer of Bridge

22· Street.· Now that I said her name, now I know

23· it, Maggie.

24· · · ·Q.· · Is that the same Maggie who

25· participated in the fashion show?


·1· · · ·A.· · I don't know if Maggie did walk in

·2· the fashion.· She could have.· She could have.

·3· I did a few of them and she could have.

·4· · · ·Q.· · Okay.

·5· · · · · · ·Long blond hair?

·6· · · ·A.· · No.

·7· · · ·Q.· · Different Maggie probably.

·8· · · ·A.· · No, no, no.

·9· · · ·Q.· · What's Maggie's last name, the

10· producer Maggie?

11· · · ·A.· · I don't know.· It just came to my

12· mind.· I don't know.· She's no longer there.· So

13· I don't recall her last name.

14· · · ·Q.· · What about the -- was Maggie the one

15· who approached you for the basketball gig?

16· · · ·A.· · I don't recall that.· I don't.

17· · · ·Q.· · Okay.

18· · · · · · ·Your appearances on Bridge Street

19· were those -- were you paid for those?

20· · · ·A.· · No.

21· · · ·Q.· · The same thing with the basketball

22· story?

23· · · ·A.· · No.

24· · · ·Q.· · You were not paid?

25· · · ·A.· · No.


·1· · · ·Q.· · Was it Maggie that approached you for

·2· the basketball story?

·3· · · ·A.· · I don't recall.

·4· · · ·Q.· · Other than Bridge Street and the

·5· basketball story, was there any other work that

·6· you did in, let's first say TV media?

·7· · · ·A.· · Not that I recall, no.

·8· · · ·Q.· · Your complaint alleges that in 2011

·9· you were hired by a radio station owned by

10· Galaxy Communications.· It said in Paragraph No.

11· 26, "to conduct a radio show discussing the

12· Syracuse men's basketball program", is that

13· right?

14· · · ·A.· · Yes.· I did a morning show on

15· Wednesday's, correct.

16· · · ·Q.· · Tell me about that?

17· · · ·A.· · It was four or five minutes with Big

18· Mike with just talking about the basketball

19· team, just giving them an inside scope.

20· · · ·Q.· · Is that radio station Sunny 102?· Is

21· that what it's referred to?

22· · · ·A.· · Yes.

23· · · ·Q.· · And Big Mike is a host; right?

24· · · ·A.· · Yes.

25· · · ·Q.· · How often did you do that?


·1· · · ·A.· · I did it every Wednesday for maybe a

·2· year, you know, on and off.· It wasn't totally a

·3· year, but on and off for about a year or so.

·4· · · ·Q.· · And how did that come about?

·5· · · ·A.· · I think I was doing something again

·6· with the Boys and Girls Club and they heard me

·7· and they asked me if I wanted to come on just to

·8· do that and I don't know who approached me about

·9· that.

10· · · ·Q.· · And when you appeared on there did

11· you discuss the basketball program?

12· · · ·A.· · Some of the time.

13· · · ·Q.· · Anything else?

14· · · ·A.· · The Boys and Girls Club, any charity

15· events going on.

16· · · ·Q.· · What was the source of your knowledge

17· of the basketball program?

18· · · ·A.· · A source meaning?

19· · · ·Q.· · Well, how did you know about what you

20· were talking about?

21· · · ·A.· · Because I was married to one of the

22· coaches so --

23· · · ·Q.· · -- from talking to Bernie?

24· · · ·A.· · Yes.

25· · · ·Q.· · Did you ever talk to Bernie about


·1· what you were going to say on the air?

·2· · · ·A.· · No.

·3· · · ·Q.· · And when did you stop doing that

·4· radio program?

·5· · · ·A.· · Right about the time this whole case

·6· happened.

·7· · · ·Q.· · And why did you stop?

·8· · · ·A.· · Because I didn't really feel like I

·9· could, you know, any longer do it.· So I kind of

10· took myself out of the picture.

11· · · ·Q.· · As a result of the ESPN stories?

12· · · ·A.· · Correct.

13· · · ·Q.· · Were you -- did you ever do any paid

14· work for that radio station of any kind?

15· · · ·A.· · I'm trying to think.· I did some work

16· for them for an event.· Let me just think.· For

17· one of the events.· I don't know that I got

18· paid.· I can't recall, but I did do selling of

19· some -- you know, I marketed for Midnight

20· Madness.· I did marketing for them.

21· · · ·Q.· · Midnight Madness can mean a lot of

22· things in a lot of places.· What exactly does it

23· mean --

24· · · ·A.· · It was the start of the season at

25· midnight.· The first day we could practice is


·1· Midnight Madness.

·2· · · ·Q.· · Was there an individual named Ed

·3· Levine --

·4· · · ·A.· · Yes.

·5· · · ·Q.· · -- at the station?

·6· · · ·A.· · Yes.

·7· · · ·Q.· · Was he the person who approached you

·8· about it?

·9· · · ·A.· · It could have been.· He was the CEO.

10· · · ·Q.· · When you say you just took yourself

11· out of doing it after the news stories, did you

12· have a conversation with Mr. Levine about your

13· continuing or not to --

14· · · ·A.· · I don't recall.· I don't recall.

15· · · ·Q.· · Was there -- are there other media

16· appearances for want of a better word that you

17· did, around this timeframe, 2009, 2010 --

18· · · ·A.· · Other than Galaxy and Channel 9 WSYR,

19· no, not that I can think of, except the charity

20· work.

21· · · ·Q.· · Okay.

22· · · · · · ·How old is Bernie Fine today?

23· · · ·A.· · Today is he 68.

24· · · ·Q.· · And when did you meet him?

25· · · ·A.· · 1976, '77.


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·1· it.· That was it.· Never, hey, Laurie, what do

·2· you think about this.· Nothing.· Because no one

·3· could knock at the door.

·4· · · ·Q.· · Well, the District Attorney did ask

·5· you what you thought about it; right, and the

·6· police -- the Syracuse Police asked you what you

·7· thought about it?

·8· · · ·A.· · I don't recall them asking me what I

·9· thought about it, but to defend this in a way

10· where ESPN might have not printed it or printed

11· something else or you talk, no one ever knocked

12· on my door.

13· · · · · · ·Every other news entity came to that

14· door.· Every other one.· Not ESPN.

15· · · ·Q.· · And what did you tell them?

16· · · ·A.· · I had no comment.· I didn't want to

17· comment to CNN or MS-NBC.· They're not the ones

18· that wrote the story.

19· · · ·Q.· · Why didn't you want to comment to

20· them?

21· · · ·A.· · Because I was told not to talk on the

22· advice of my lawyer and I didn't talk.· All they

23· had to do was knock.· At least I would have had

24· a right to say no, I don't or yes, I do.· I was

25· never afforded that right.· They took that all


September 03, 2014





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·1· away from me.· All away from me.· They ran with

·2· a story maliciously, that they never vetted.

·3· They ran with facts they never asked me about.

·4· Again, malicious.· Everything they did was to

·5· hurt me.· They intended to hurt me and they did.

·6· They accomplished that.

·7· · · ·Q.· · Why do you have any reason to believe

·8· that your attorney wouldn't have advised you not

·9· to talk to ESPN?

10· · · ·A.· · Because they would make it my

11· decision.· I was advised not to, but if ESPN --

12· ESPN the one who wrote -- you know, published

13· this whole thing -- and at some point this story

14· or this tape went to the Post Standard.· They

15· found it not reasonable to publish it.· You

16· know, they didn't want to do that.

17· · · ·Q.· · Well, if you wanted to get your side

18· of the story out, why didn't you tell them --

19· · · ·A.· · I wanted to tell ESPN my side of the

20· story and at least give me a chance to speak on

21· this.· They are the ones who wrote the story.

22· Nobody else.· Or released the story.· No one

23· else did.

24· · · ·Q.· · Did you ever contact ESPN to ask them

25· to give --


September 03, 2014





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·1· · · ·A.· · No, I did not.

·2· · · ·Q.· · Why not?

·3· · · ·A.· · Because apparently, you know, there

·4· was people waiting for me to come out and

·5· waiting for me to talk.· And they wanted to

·6· again, hearsay, they wanted to get me alone so

·7· Bernie wouldn't know about that they were

·8· waiting to talk to me.

·9· · · · · · ·Well, at the end of the day, you

10· know, again, never came, never saw them, never

11· knocked, never called ever, ever.· You know, so

12· you print one side of the story and you run with

13· it.

14· · · · · · ·You know, it's funny to me how the

15· Jerry Sandusky story comes out and this is all

16· piggie-backed to Jerry Sandusky.· Then we get

17· Zak Tommaselli.· Gee, someone should have looked

18· into that.· You know.

19· · · · · · · · ·MR. SIEGEL:· We're at 12 minutes

20· ·and 38 seconds.

21· · · · · · · · · ·(Tape playing)

22· BY MR. SIEGEL:

23· · · ·Q.· · So he says the thing about Bernie, I

24· call him a pedophile --

25· · · ·A.· · He --


September 03, 2014





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·1· · · · · · · · ·MR. FISHER:· Right here

·2· ·(indicating).

·3· BY MR. SIEGEL:

·4· · · ·Q.· · We just got to the second graph from

·5· you on Pg. 12.· Where it says, hey, I married

·6· him and he never helped me.· You never said

·7· that --

·8· · · ·A.· · I mean, let me just -- right.· You

·9· know, I mean, he never did help me.· I mean, I

10· worked at a salon where he could have maybe

11· opened the door so I could do other things.· No.

12· He never helped me.· I worked at the salon.· I

13· didn't make like great money.· Then, you know, I

14· could have done bigger, better things which when

15· this whole case developed I was on my way to

16· really come into myself and really make a name,

17· you know, a good name for myself.

18· · · · · · ·At that time, obviously, with this

19· case coming out I couldn't.· But at this time he

20· wasn't looking to help me.· We had three kids.

21· I think he wanted me to stay home.· He wasn't

22· really looking to offering me anything or help

23· me out in the least because he wanted me at

24· home.· Is where -- because I worked maybe

25· part-time at that point at the salon.· I wasn't


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·1· there full-time.

·2· · · ·Q.· · You were on your way to making a good

·3· name for yourself with what?

·4· · · ·A.· · I was going to another job, Save the

·5· Children, when this whole case came to fruition.

·6· I was going to start a morning talk show for

·7· Galaxy to, you know, get the women's inside take

·8· on basketball.· I was starting to market for

·9· some plastic surgeons in town.· I was really

10· starting to build a career.· I really did it on

11· my own merit because I wasn't in the shadow of

12· Bernie Fine anymore.· The good work I had done,

13· people recognized that.

14· · · · · · ·You can hire anybody.· If you don't

15· tow the weight, you're gone and I knew that.

16· · · ·Q.· · You had discussed with Galaxy doing

17· your own show?

18· · · ·A.· · No.· It was with two other gentlemen

19· that hosted a sports show, but I would be the

20· women's perspective on that show.

21· · · ·Q.· · Who were the other gentlemen?

22· · · ·A.· · Steve and I forgot the other kid was

23· from Galaxy.· And the other guy is from Channel

24· 9, Steve Insante.

25· · · ·Q.· · That was something different than the


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·1· Big Mike Show?

·2· · · ·A.· · Yeah.· It was totally different.

·3· Totally, yes.· So I was coming to start this and

·4· then this all happened.· So there was no way the

·5· show was going to happen.

·6· · · · · · · · ·MR. SIEGEL:· We're at 14 minutes

·7· ·and 34 seconds into the tape.

·8· · · · · · · · · ·(Tape playing)

·9· BY MR. SIEGEL:

10· · · ·Q.· · So when Bobby said the only thing he

11· cared about, referring to Bernie, was one thing,

12· that was like touching me or whatever.

13· · · ·A.· · Yeah.· Again, I -- again, now looking

14· at what he was saying there, I didn't know.· But

15· it truly wasn't the one thing he only cared

16· about was the friendship.· He cared about the

17· money.· That was his basis for everything.· It

18· wasn't a friendship with Bernie.· It wasn't a

19· friendship at all with Bernie.· He didn't care

20· about that.· He didn't care about a friendship

21· at all with Bernie.

22· · · ·Q.· · You understood that Bobby was talking

23· about touching him sexually?

24· · · ·A.· · At this point, I gotta be honest with

25· you, I cannot say for sure.· I do not know at


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·1· working.· Just, you know, the damage to my name

·2· and what they put out there.· Just for my

·3· sanity.· You know, I'm on high blood pressure

·4· medication.· I'm on Xanax.· I wouldn't recognize

·5· the person I am now.· I don't even know her.

·6· · · ·Q.· · Anything else?

·7· · · ·A.· · No.

·8· · · ·Q.· · The job that you testified that you

·9· were going to start at the Save the Children

10· Foundation, how much did that pay?

11· · · ·A.· · We had not worked that out yet.· We

12· had not worked that out.

13· · · ·Q.· · Do you believe or did you have any

14· belief as to whether it would pay more than the

15· Boys and Girls Club, about the same, less?

16· · · ·A.· · Probably more than the Boys and Girls

17· Club because now I had experience doing it and

18· they were looking for me at that point.· So more

19· than the Boys and Girls Club.

20· · · ·Q.· · Do you have any belief as to how much

21· money you would be earning today, roughly, on an

22· annual basis if these stories did not get out?

23· · · ·A.· · Well, the one radio show that I was

24· going to be paid for -- I did some work for

25· Paradise Medical which is a local thing.· The


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·1· doctors.· I don't know.· It could have been --

·2· at that point with what I was doing it could

·3· have been well over $200,000 year.

·4· · · ·Q.· · You think that you were making 50 to

·5· 60 in 2011 and you could be making well over

·6· 200 --

·7· · · ·A.· · I had come into my own.· I finally

·8· found a niche that I was actually good at.

·9· Yeah, absolutely.

10· · · · · · ·I mean, prior to the Boys and Girls

11· Club I was making nothing.· I came from hundreds

12· of dollars to at least something at least a good

13· job.· 50 to 60,000 a year.

14· · · ·Q.· · Do you contend that the broadcast

15· affected you physically?· Did it cause any --

16· · · ·A.· · Yes.

17· · · ·Q.· · What?

18· · · ·A.· · The high blood pressure which I never

19· had and now I'm being treated for.· The anxiety

20· which I never had, now I'm being treated for.

21· Things of that nature.

22· · · ·Q.· · Is there a contention that you never

23· had high blood pressure before the broadcast --

24· · · ·A.· · I was never taking any medication for

25· high blood pressure.· No.· I was good.· Pretty


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·1· · · · · · · · · · ·CERTIFICATE

·2· · COMMONWEALTH OF PENNSYLVANIA )·3· · · · · · · · · · · · · · · ·) SS.· · COUNTY OF WESTMORELAND· · · ·)·4· · · ·I, Dana M. Cunningham, a Court Reporter -·5· Notary Public in and for the Commonwealth of· · Pennsylvania, do hereby certify that the·6· witness, LAURIE FINE, was by me first duly sworn· · to tell the truth, the whole truth, and nothing·7· but the truth, and that the above deposition was· · recorded in stenotype by me and reduced to·8· typewriting under my direction.

·9· · ·I further certify that the said deposition· · constitutes a true record of the testimony given10· by said witness; that the foregoing deposition· · was taken at the time and place stated herein.11· · · ·I further certify that the inspection,12· reading and signing of said deposition were· · waived by counsel for the respective parties and13· by the witness.

14· · ·I further certify that I am not a relative,· · employee or attorney or counsel of any of the15· parties, or a relative or employee of such· · attorney or counsel or financially interested16· directly or indirectly in this action.

17· · ·IN WITNESS WHEREOF, I have hereunto set my· · hand and affixed my seal of office this 15th day18· of September, 2014.

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22· · · · · · · · · · · · · ·_______________________· · · · · · · · · · · · · · · ·Dana M. Cunningham23

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laurie partial deposition

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