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`W1
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`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL’ AND APPEAL BOARD
`
`
`
`if
`
`
`
`APR 1 8 2011 "'
`
`Cancellation No. 92047809
`
`.
`
`75/(V 50 /56/O
`
`Registration No. 3179591
`Mark: OPERATION RESCUE
`
`) )
`
`) )
`
`)
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`)
`)
`)
`
`) )
`
`RANDALL A. TERRY
`
`Petitioner
`
`v.
`
`TROY NEWMAN
`
`Registrant
`
`M_~____M)
`
`PETITIONER’S SUBMISSION OF TESTIMONY
`OF ROSEMARIE SZOSTAK PH.D.
`
`In accordance with 37 CFR § 2.125, Petitioner hereby submits the testimonial
`
`deposition of Rosemarie Szostak, Ph.D. with exhibits.
`
`Date: April 18,2011
`
`W
`
`Michael S. Culver
`
`Millen, White, Zelano & Branigan, P.C.
`2200 Clarendon Blvd., Suite 1400
`
`Arlington, Virginia 22201
`Phone (703) 243-6333
`Fax : (703) 243-6410
`Email: culver@mwzb.com
`Attorneys for Petitioner
`
`Certificate of Service
`
`This is to certify that a copy of the foregoing was served this 18"‘ day of April
`2011 by first-class mail, postage prepaid, on the following:
`Brian R. Gibbons, Esq.
`Suite 300
`
`3936 South Semoran Blvd.
`
`Orlando, Florida 32822-4015
`
`3 ;
`:
`1,.,C.,._e.—§
`y Attorney for Petitioner
`
`" ’‘‘“
`HlllllHUIllllllllllllllllllllllllllllllllllllll
`
`We
`
`U4-18-2011
`
`Faisal
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`.3 Tr-1;];'.;,.In4_r15” Rm Di.
`
`:3,
`
`

`
`
`
`X
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`Page 1
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`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`
`Certified
`Transcript
`
`RANDALL A. TERRY,
`
`Cancellation No.: 92047809
`
`Petitioner,
`
`Registration No.: 3179591
`
`Vs.
`
`TROY NEWMAN,
`
`Mark: Operation Rescue
`
`Registrant.
`
`/
`
`TELEPHONIC DEPOSITION OF
`
`b
`
`ROSEMARIE SZOSTAK, PH.D.
`
`1230 Peachtree Street, Atlanta, Georgia
`
`March 16th, 2011
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`‘fifi
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`Reported By:
`
`Anna—Marie Cheak, RPR/CSR—B—1109
`Job No. NJ319764
`
`800-227-8440
`
`973-410-4040
`
`Veritext/NJ Reporting Company
`
`

`
`ROSEMARHESZOSTAK
`
`
`APPEARANCES OF COUNSEL
`
`Page 2
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`On behalf of the Petitioner:
`
`(via phone)
`
`MICHAEL S. CULVER, ATTORNEY AT LAW
`
`MILLEN, WHITE, ZELANO & BRANIGAN, P.C.
`
`2200 Clarendon Boulevard, Suite 1400
`
`Arlington, Virginia
`
`22201
`
`(703)243-6333
`
`culver@wmzb.com
`
`On behalf of the Registrant:
`
`(via phone)
`
`BRIAN R. GIBBONS, ATTORNEY AT LAW
`3936 South Semoran Boulevard, Suite 300
`
`Orlando, Florida
`
`32822
`
`(407)384-6156
`
`trademarks@briangibbons.com
`
`-
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`—
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`—
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`800-227-8440
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`973-410-4040
`
`Veritext/NJ Reporting Company
`
`

`
`ROSEMARIE SZOSTAK
`
`INDEX TO EXHIBITS
`
`Page 3
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`EXHIBITS
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`PAGE
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`Exhibit B
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`Search Results
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`800-227-8440
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`973-410-4040
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`Veritext/NJ Reporting Company
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`

`
`ROSEMARIE SZOSTAK
`
`INDEX TO EXAMINATION
`
`Page 4
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`WITNESS:
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`ROSEMARIE SZOSTAK
`
`EXAMINAT ION BY
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`PAGE
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`Mr . Culver
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`Mr . Gibbons
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`973-410-4040
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`Veritext/NJ Reporting Company
`
`

`
`ROS EMARIE SZOSTAK
`
`P R O C E E D I N G S
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`Page 5
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`Whereupon,
`
`ROSEMARIE SZOSTAK
`
`being first duly sworn, was examined and testified
`
`as follows:
`
`BY MR. CULVER:
`
`EXAMINATION
`
`Q
`
`A
`
`Q
`
`Could you state your name for the record.
`
`Rosemarie Szostak,
`
`S—Z—O—S—T—A—K.
`
`Is there anyone in the room present with you
`
`other than the court reporter?
`
`A
`
`Q
`
`No.
`
`All right. This deposition is being taken
`
`as a supplement
`
`to your prior deposition on
`
`September 28, 2010.
`
`Do you have with you the
`
`transcript of that deposition?
`
`A
`
`Q
`
`Yes,
`
`I do.
`
`And as part of that, do you have your
`
`Declaration that was marked as Exhibit A?
`
`A
`
`Q
`
`Yes,
`
`I do.
`
`And as part of that Declaration, do you have
`
`Exhibit 3 to that?
`
`A
`
`Q
`
`Yes;
`
`I have it here.
`
`Referring to your Declaration,
`
`in paragraph
`
`
`
`800-227-8440
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`973-410-4040
`
`Veritext/NJ Reporting Company
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`ROSENUUUESZOSTAK
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`Page 6
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`5, you described a specific search that you previously
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`did, and the results of that search as being expressed
`
`in Exhibit 3;
`
`is that correct?
`
`A
`
`Q
`
`That is correct.
`
`So specifically in Exhibit 3,
`
`the second
`
`column from the left describes a search that included
`
`the words "Operation Rescue" and "Randall Terry" or
`
`two other variations of his name that were all in the
`
`same lead paragraph of a news article;
`
`is that
`
`correct?
`
`A
`
`Q
`
`A
`
`Q
`
`A
`
`Q
`
`That is correct.
`
`And that search you did, 976 results?
`
`That's correct.
`
`And that's from the News Database, correct?
`
`That is from News Bank Database.
`
`Yes, and excerpts from that search were
`
`printed out as Exhibit 8, and that's in your
`
`Declaration on the last page at Paragraph 14;
`
`is that
`
`correct?
`
`A
`
`Q
`
`That is correct.
`
`At your prior deposition, do you recall that
`
`Mr. Gibbons, who is on the line here with us,
`
`questioned you about
`
`those search results, and whether
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`they would have printed out another potential
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`paragraph within the news article that was along the
`L_______%__________________
`Veritext/NJ Reporting Company
`
`800-227-8440
`
`973-410-4040
`
`

`
`
`
`ROSEMARIE SZOSTAK
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`Page 7
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`lines of Randall Terry was not currently affiliated
`
`with Operation Rescue, or Randall Terry was no longer
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`connected with Operation Rescue.
`
`Do you recall that testimony?
`
`A
`
`Q
`
`Yes,
`
`I do.
`
`Okay.
`
`MR. CULVER:
`
`I'll ask the reporter to
`
`mark as Exhibit B,
`
`a document that Ms.
`
`Szostak has brought with her today,
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`a new
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`search result.
`
`(Whereupon, marked for
`
`identification purposes,
`
`Exhibit B.)
`
`BY MR. CULVER:
`
`Q
`
`Can you describe for me what that document
`
`entails, what it shows?
`
`A
`
`The document that is described as Exhibit B
`
`contains the search results for the following search
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`strengths. There were two.
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`One is for "Randall Terry" and permutations
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`on that word,
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`that name,
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`in the lead first paragraph
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`before 12/6/2006, and also the term "Operation Rescue"
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`in the lead first paragraph.
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`It also looks for and searches for the term
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`"no," N-O, within 5 words of the word "Operation" in
`
`800-227-8440
`
`973-410-4040
`
`Veritext/NJ Reporting Company
`
`

`
`
`
`ROSEMARIE SZOSTAK
`
`Page 8
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`the entire text, and the term "no" near or within 5
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`words of the term "rescue" in the entire text, and 32
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`results were found from this search.
`
`Q
`
`And are those excerpts from those 32 results
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`printed out on the first 6 pages of that Exhibit B?
`
`A
`
`Yes.
`
`They are presented out
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`in the first 6
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`pages of Exhibit B.
`
`Q
`
`Okay.
`
`Then turning to page 7, do you
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`describe the second half of the search?
`
`A
`
`The second half of the search was similar to
`
`the first search;
`
`in other words, "Randall Terry" and
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`permutations in the lead first paragraph before
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`12/6/2006, and the term "Operation Rescue" in the lead
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`or first paragraph, and the search also looked for the
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`terms "not" near or within 5 words of the term
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`"Operation" in the entire text, and "not" within 5
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`terms of the term "Rescue" in the entire text.
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`In this case,
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`62 results were found.
`
`Q
`
`Okay.
`
`So would this search have essentially
`
`duplicated the previous search you did that we
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`discussed in Exhibit 3 in the second column from the
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`left with 976 results?
`
`A
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`Yes.
`
`It duplicates the prior search that
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`resulted in 976 results being found, and it adds one
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`more, or two more of variance, which is the "no" or
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`800-227-8440
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`973-410-4040
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`Veritext/NJ Reporting Company
`
`

`
`
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`ROSENUUUESZOSTAK
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`Page 9
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`"not."
`
`Q
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`And those words would have appeared anywhere
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`in the text, as long as they were within 5 words of
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`either "Operation" or "Rescue"?
`
`A
`
`Q
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`That is correct.
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`No matter what the context would have been,
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`it just —— it would have been found within the news
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`article?
`
`A
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`It did not discriminate if it was within one
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`word away,
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`2 words away, all the way up to 5 words
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`away from the terms "Operation" or "Rescue."
`
`Q
`
`Okay.
`
`So the search yielded two groupings,
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`one of 32 results, and one of 62 results, correct?
`
`A
`
`Q
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`That is correct.
`
`And you've printed out
`
`those excerpts that
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`show the words "no" or "not" within the context of the
`
`search?
`
`A
`
`Yes.‘
`
`I printed them out
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`in terms of the key
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`word in context format.
`
`Q
`
`Right.
`
`So referring to the words "no" or
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`"not" within 5 of "Operation" or "Rescue"?
`
`A
`
`Q
`
`That is correct.
`
`So that excerpt has been printed out for
`
`each of the results?
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`A
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`Yes.
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`__________________________________________________________J
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`800-227-8440
`
`973-410-4040
`
`Veritext/NJ Reporting Company
`
`

`
`
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`F
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`ROSEMARIE SZOSTAK
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`Page 10
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`Q
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`Thank you.
`
`MR. CULVER:
`
`I have no further
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`questions.
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`MR. GIBBONS:
`
`I have just a few
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`questions.
`
`BY MR. GIBBONS:
`
`EXAMINATION
`
`Q
`
`I just want
`
`to explore a little bit about
`
`this search and what possible limitations it might
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`have.
`
`.This searched specifically for the words "no"
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`or "not;" is that correct?
`
`A
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`That is correct, but only within —— if it's
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`within 5 words away from the terms "Operation" or
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`"Rescue."
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`Q
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`All right. Did it also search for the
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`letters "N-O" or "N—O—T" as part of other words? Or
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`just --
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`A
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`No.
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`It only searched for the stand—alone
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`words "no" or "not."
`
`Q
`
`Okay.
`
`So for example, if an article did not
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`have "no" or "not" within 5 words of the key words,
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`but had the phrase "Randall Terry currently has
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`nothing to do with Operation Rescue," that would not
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`have been found in the search results?
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`A
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`It would not have been found in the search
`
`800-227-8440
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`973-410-4040
`
`Veritiext/NJ Reporting Company
`
`

`
`ROSEMARIE SZOSTAK
`
`1
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`Page 11
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`results.
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`Q
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`Okay.
`
`If an article didn't use the words
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`"no" or "not" within 5 words of the key words,
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`but
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`used a phrase like "former Operation Rescue leader,
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`Randall Terry," would that have been found by the
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`search?
`
`A
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`No, it would not have been found by the
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`search.
`
`Q
`
`Okay.
`
`How about an article which used
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`phrasing like "Randall Terry was once head of the
`
`Operation Rescue movement" --
`
`No --
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`—— would that have been picked up by the
`
`That would not have been picked up by the
`
`A Q
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`search?
`
`A
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`search.
`
`Q
`
`Okay. This search was specifically looking
`
`for the words
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`"no" or "not"?
`
`A
`
`Only if they were within 5 words of
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`"Operation Rescue."
`
`Q
`
`Okay. But if an article clearly indicated
`
`by context that Randall Terry was not associated with
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`Operation Rescue,
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`the search results would not have
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`1
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`found that unless it used the words
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`HI-loll
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`llnotll?
`
`A
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`That is correct.
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`800-227-8440
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`973-410-4040
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`Veritext/NJ Reporting Company
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`ROSENUUUESZOSTAK
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`Page 12
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`Okay.
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`MR. GIBBONS:
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`I don't have any
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`further questions.
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`MR. CULVER:
`
`No further questions.
`
`So that concludes this deposition. Does
`
`the reporter need any further information
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`from me, my address or anything?
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`REPORTER:
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`I've got all that
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`information.
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`I just need to know if one
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`or both of you will be needing this and
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`when you'll need it by, and what you want.
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`MR. CULVER:
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`I would like a full
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`transcript, you know,
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`just normal copy
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`with the Exhibit. What would be normal
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`turnaround, say within ten days,
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`two
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`weeks?
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`REPORTER:
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`Ten working days.
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`MR. CULVER: Working days,
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`that's
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`sufficient for me.
`
`-
`
`--
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`MR. GIBBONS:
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`I do not need a copy of
`
`the transcript.
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`REPORTER:
`
`Is signature reserved?
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`MR. CULVER:« Yes.
`
`MR. GIBBONS:
`
`Just noting as previous
`
`depositions, we don't need this to be
`
`800-227-8440
`
`973-410-4040
`
`Veritext/NJ Reporting Company
`
`

`
`ROSENUHUESZOSTAK
`
`Page 13
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`sealed,
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`that we are find with submitting a
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`copy of the transcript rather than a
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`sealed original from the court reporter.
`
`The reporter sometimes likes those
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`formalities.
`
`(Concluded at 11:22 a.m.)
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`(Signature is reserved.)
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`800-227-8440
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`973-410-4040
`
`Veritext/NJ Reporting Company
`
`

`
`C E R T I F I C A T E
`
`STATE OF GEORGIA:
`
`COUNTY OF FAYETTE:
`
`I hereby certify that the foregoing
`deposition was stenographically recorded by me as
`stated in the caption.
`The deponent was duly sworn
`to tell the truth,
`the whole truth,
`the truth.
`
`and nothing but
`The colloquies, statements, questions
`and answers thereto were reduced to typewriting
`under my direction and supervision and the
`deposition is a true and correct record,
`to the best
`of my ability, of the testimony/evidence given by
`the deponent.
`
`attorney or counsel, nor am I financially interested
`in the action. All rates charged are usual and
`customary.
`
`This the9f5
`day of W 90/}
`
`
`....1':~v‘.r:n>'LJ.*s.-rx.'..'..-z*;r.¢
`
`REPORTED BY: Anna-Marie Cheak, Court Reporter
`www.huseby.com
`HUSEBY, INC. - 555 North Point Center, E., #403, Alpharetta, GA 30022 (404) 875-0400
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`

`
`Rosemarie Szostak, Ph.D.
`Analyst
`Nerac Inc.
`
`March 15, 2011
`
`Search Results for ("Randall Terry" or "Randall A. Terry" or "Randy Terry") in
`Lead/First Paragraph and before 12/06/2006 in Date and "Operation Rescue" in
`Lead/First Paragraph and no NEAR5 operation in All Text and no NEAR5 meue
`in All Text 32 results fotmd
`
`by Year
`1998 (9)
`1996(1)
`I993 (10)
`I992 (4)
`1991 (4)
`1990 (1)
`1989 (3)
`
`1. OPERATION RESCUE FOUNDER BANKRUPT
`Boston Globe - November 9, 1998
`Length: 100 words (Estimated printed pages: 1)
`
`
`
`...clinics that have sued him. Randall 'l‘cr_ry , who is no longer the head of Operation
`Rescue , cited $1.7 million in debts...
`
`2. ANTI-ABORTION GROUP FOUNDER TALLIES DEBTS
`Akron Beacon Journal (OH) - November 8, 1998
`Length: 55 words (Estimated printed pages: 1)
`
`...abortion clinics that sued him. Randall Terry is no longer the head of Operation Rescue
`, which is now based in the Dallas-Fort...
`
`3. ANTI-ABORTION LEADER DECLARES BANKRUPTCY
`I-ierald~News (Joliet, IL) - November 8, I998
`Length: 154 words (Estimated printed pages: l)
`
`...clinics that have sued him. Randall Terry , who is no longer the head of Operation
`Rescue , cited $1.7 million in debts...
`
`4. Anti-abortion activist files for bankruptcy
`Milwaukee Joumal Sentinel - November 8, 1998
`Length: 61 words (Estimated printed pages: 1)
`
`Randall Terry , founder...anti-abortion group Operation Rescue , has filed...Terry who is
`no longer the head of Operation Rescue , has been...
`
`1
`
`EXHIBIT
`,7/5”
`
`

`
`Rosemarie Szostak, Ph.D.
`Analyst
`Nemc Inc.
`
`March 15, 2011
`
`5. METRO NEWS BRIEFS: NEW YORK An Anti-Abortion Leader Files For
`Bankruptcy
`New York Times, The (NY) - November 8, 1998
`Length: 209 words (Estimated printed pages: 1)
`
`Randall Terry , the founder...anti-abortion group Operation Rescue , filed fot...Terry, who
`is no longer the head of Operation Rescue , has been...
`
`6. UNITED STATES
`
`Plain Dealer, The (Cleveland, OH) - November 8, 1998
`Length: 495 words (Estimated printed pages: 2)
`
`...Syracuse, N.Y. - Randall Terry , the founder...anti-abortion group Operation Rescue ,
`has filed...Te'rry, who is no longer the head of Operation Rescue , has been...
`
`7. ANTI-ABORTION CRUSADER TERRY FILES FOR BANKRUPTCY
`THE ORLANDO SENTINEL — November 8, 1998
`Length: 80 words (Estimated printed pages: I)
`
`
`
`...clinics that have sued him. Randall Terry . who is no longer the head of Operation
`Rescue , which was noted for its aggressive...
`
`8. FOUNDER OF‘ OPERATION RESCUE FILES FOR BANKRUPTCY IN N.Y.
`The Palm Beach Post - November 8, I998
`Length: 458 words (Estimated printed pages: 2)
`
`...clinics that have sued him. Randall ’l'crr_\'
`Rescue , cited $1.7 million in debts...
`
`. with is no longer the head ot'(,)pcration
`
`9. OPERATION RESCUE FOUNDER BANKRUP'I'< TERRY SEEKS TO AVOID
`PAYING LAWSUITS
`
`Watertown Daily Times (NY) - November 8, 1998
`Length: 538 words (Estimated printed pages: 2)
`
`...clinics which have sued him. Randall '1‘my , who IS no longerthe head of Operation
`Rescue , has been ordered to pay the...
`
`10. WOMEN'S RIGHTS ADVOCATE STILL FIGHTING
`Sun-Sentinel - November 23, 1996
`Length: 376 words (Estimated printed pages: 2)
`
`...was forcibly "saved" by Operation: Rescue leader Randall Terry. Perhaps no one was
`better prepared to handle...
`
`

`
`Rosemarie Szostak, Ph.D.
`Analyst
`Nerac Inc.
`March 15, 2011
`
`ll. ‘RESCUE’ FOUNDER TO VISIT
`
`Dayton Daily News (OI-I) — August 9, 1993
`Length: 526 words (Estimated printed pages: 3)
`
`Randall Terry , the controversial...founder of Operation Rescue , will visit...supporters of
`the Operation Rescue movement have no plans to...
`12. Much ado about nothing - Operation Rescue avoided the arrests and
`confrontations of past campaigns
`Star Tribune: Newspaper of the Twin Cities - July 18, 1993
`Length: I 191 words (Estimated printed pages: 4)
`
`...letter by Randall Terry , founder... Operation Rescue spokeswoman...director of
`Operation Rescue , April 6...the past. No arrests were made of Operation Rescue
`recruits...
`
`I3. ANTI-ABORTION GROUP FOUNDER RALLIES CROWD POLICE
`ARREST 35 PROTESTERS AFTER SCUFFLE IN LOS GATOS
`
`San Jose Mercury News (CA) - July 15, 1993
`Length: 840 words (Estimated printed pages: 3)
`
`
`
`...victor.“ Randall Terry admonishe¢..in which Operation Rescue protesters...about 50
`Operation Rescue protesters. Although no injuries...
`
`14. TERRY DECLARES ‘CITIES OF REFUGE‘ IS SUCCEEDING
`San Jose Mercury News (CA) - July 15, 1993
`Length: 455 words (Estimated printed pages: 2)
`
`Rescue founder Randall Terry declared. ..in which Operation Rescue protesters...about
`50 Operation Rescue protesters. Although no injuries...
`
`15. A VOICE AGAINST ABORTION OPERATION RESCUE FOUNDER HAS
`TAKEN TO THE AIRWAVES
`
`State, The (Columbia, SC) - July 15, 1993
`Length: 649 words (Estimated printed pages: 3)
`
`...show. Randall Terry -- founder of Operation Rescue , master of...‘l”crr_,v is no longer
`officially linked to Operation Rescue , he remains...
`
`I6. THE VOICE OF RESISTANCEIIOPERATION RESCUE FOUNDER
`RANDALL TERRY PROMOTES HIS CONSERVATIVE CAUSE - AND
`
`HIMSELF - VIA HIS RADIO SHOW, BOOKS AND THE SPEAKING CIRCUIT.
`St. Paul Pioneer Press (MN) - July 14, 1993
`Length: 1415 words (Estimated printed pages: 5)
`
`
`
`

`
`Rosemarie Szostak, Ph.D.
`
`Analyst
`Nerac Inc.
`
`March 15, 2011
`
`...show. Randall Terry - founder of Operation Rescue , master of...Terry. 34, is no longer
`olTrci.'1Hy linked in Operation Rescue , he remains...
`
`17. OPERATION RESCUE FOUNDER URGES GROUP TO BATTLE BILL
`HALTING CLINIC BLOCKADES — TERRY SAID A PROPOSED LAW WOULD
`BE DEATH FOR THE ANTI-ABORTION GROUP.
`
`THE ORLANDO SENTINEL - July 12, 1993
`Length: 276 words (Estimated printed pages: 2)
`
`...fe1ons," Randall Terry said during a speech...being targeted by Operation Rescue . No
`arrests were made...
`
`18. Abortion protest leader handed S-month sentence
`The Tampa Tribune - June 12, 1993
`Length: 239 words (Estimated printed pages: 1)
`
`Rescue founder Randall Terry was sentenced...demonstrated no remorse...had barred
`Operation Rescue and Terry...back." Operation Rescue leader Randall ...demonstrated no
`remorse for...
`
`
`
`19. Q&A ON THE NEWS
`San Jose Mercury News (CA) - May 12, 1993
`Length: 255 words (Estimated printed pages: 2)
`
`...background of Randall Terry , founder of Operation Rescue , and to know'...White of
`Operation Rescue said Teny receives no salary, and...
`
`20. RANDALL TERRY LABELS SLAIN DOCTOR ‘MASS MURDERER'
`National Public Radio - March] 1, 1993
`Length: 714 words (Estimated printed page: 3)
`
`...WERT1-IEIMER, Host: Randall Terry is the founder of Operation Rescue , an anti-
`abortion...TERRY: Well, no . First of...Griffi'n had no hisrory with Operation Rescue
`whatsoever...
`
`21. JUDGE ORDERS ARREST OF 6 ABORTION FOES
`THE ORLANDO SENTINEL - July 16. 1992
`Length: 168 words (Estimated printed pages: 1)
`
`...arrested are Randall Terry , founder of Operation Rescue , and Keith...executive. No
`reprcscrrtatiws from Operation Rescue appeared...
`
`22. CITY SHOULD HAVE NO WELCOME FOR OPERATION RESCUE
`TACTICS IN WICHITA. RIGHTS WERE TRAMPLED, CITY DISRUPTED
`
`4
`
`

`
`Rosemarie Szostak, Ph.D.
`Analyst
`Nerac Inc.
`
`March 15, 2011
`
`Bufialo News. The (NY) - January 7, 1992
`Length: 474 words (Estimated printed pages: 2)
`
`...should shun. Randall Terry , radical leader of the Operation Rescue anti-abortion...s
`have no red carpet...
`
`23. ABORTION FOES TARGET BUFFALO OPERATION RESCUE SAYS
`ACTION MAY RIVAL WICIIITA
`Buffalo News, The (NY) - January 4, 1992
`Length: 799 words (Estimated printed pages: 3)
`
`Rescue leader Randall Terry said Friday...of Project Rescue Western New...welcome
`the Operation Rescue demonstrations...sa.id that no matter what Operation Rescue does
`this...
`
`24.. ABORTION PROTESTERS SI-IOW FETUSES
`Watertown Daily Times (NY) - January 4, [992
`Length: 317 words (Estimated printed pages: 2)
`
`
`
`said Randall Terry , founder of Operation Rescue , a nationwide...There are no laws
`preventing. Operation Rescue members from...
`
`25. AIDING ‘RESCUE’ MAY COST BENEFACTOR TAX STATUS -
`NONPROFIT GROUP HELPED PAY PROTESTERS' DEBT
`Washington Post - November 24, 1991
`Length: 1148 words (Estimated printed pages: 5)
`
`Randall A . Terry remembers...probably true of Operation Rescue ‘s role...lt made no
`mention of Operation Rescue '2: lobbying...
`
`26. PROTESTS AGAINST ABORTION PLANNED IN UP TO 65 CITIES
`OPERATION - RESCUE MUM ABOUT CLINICS HERE
`The Buffalo News - October 17. 1991
`Length: 517 words (Estimated printed pages: 2)
`
`...65 cities the week of Nov. 17. Randall Terry , Operation Rescue founder. said no
`decision has been made on including...
`
`27. TERRY AND HIS CAUSE ALLOW NO NEUTRALITY
`Wichita Eagle, The (KS) - August 25, I991
`Length: 5032 words (Estimated printed pages: 16)
`
`Randall Terry ‘s wife thinks...the founder of Operation Rescue . As with the abortion
`question. no one is neutral...
`
`5
`
`

`
`Rppemarie Szostak, Ph.D.
`nalyst
`er-ac Inc.
`
`March I5, 2011
`
`28. LOCAL ABORTION PROTESTER VOWS TO RETURN TO WICI-IITA
`Plain Dealer, The (Cleveland, OH) - August 9, l99l
`Length: 767 words (Estimated printed pages: 3)
`
`...including founder Randall Terry . "It... Since Operation Rescue began its...among the
`Operation Rescue leaders...I have no reason to...maintains Opera ‘un Rescue means no
`harm to clinic...
`
`29. TERRY SEES DISCRIMINATION AGAINST CHRISTIANS, PRO-LIFERS
`Post-Standard, The (Syracuse, NY) - April 28, 1990
`Length: 856 words (Estimated printed pages: 3)
`
`Randall Terry was no child preacher...Terry founded Operation Rescue , which grew... A:
`No . We will continue to rescue children as...
`
`30. ORGANIZER OF ABORTION PROTESTS LAST SUMMER ARRESTED IN
`ATLANTA
`
`THE ORLANDO SENTINEL - July 12, 1989
`Length: 174 words (Estimated printed pages: l)
`
`...arrest of Randall A . Terry , organizer of Operation Rescue , was the...000 bond.
`Operation Rescue officials said there were no immediate...
`
`31. No felony charge for Operation Rescue leaders
`The Orange County Register - March 28, 1989
`Length: 844 words (Estimmed printed pages: 3)
`
`Rescue founder Randall Terry and three...of central operations . Pro-choice...Kenneth
`Tanner, Operation Rescue 's local...there was no way to press...
`
`32. ANTI-ABORTION PROTESTERS SPEND EASTER IN LA. JAILS
`Daily News of Los Angeles (CA) - March 27, 1989
`Length: 533 words (Estimated printed pages: 2)
`
`Rescue leader Randall Terry , who was...Angeles area by Operation Rescue .
`Operatiop ...there was no police brutality. Operation Rescue spokeswoman...Christmas if
`Randy Terry isn...
`
`
`
`

`
`Rosemarie Szostalt, Ph.D.
`Analyst
`Nerac Inc.
`
`March 15, 2011
`
`Search Results for ("Randall Terry" or "Randall A. Terry" or "Randy Terry") in
`Leadllilrst Paragraph and before 12/06/2006 in Date and "Operation Rescue" in
`LeadlFlrst Paragraph and not NEAR5 operation in All Text and not NEAR5 rescue
`in All Text 62 results found
`
`by Year
`1998 (3)
`1995 (4)
`1994 (4)
`1993 (9)
`1992 (9)
`1991 (8)
`1990 (16)
`1989 (6)
`1988 (3)
`
`1. Tracing the Path of a Hard-Line Foe of Abortion
`New York Times, The (NY) - November 6, 1998
`Length: 1203 words (Estimated printed pages: 4)
`
`
`
`mblockades, but several Operation Result: veterans insist he has not maintained contact
`with...
`
`2. Terry, NOW reach accord on abortion clinic lawsuit
`St. Petersburg Times - January 10, 1998
`Length: 224 words (Estimated printed pages: 1)
`
`Randall Terry , the anti-abortion activist...founded the militant Operation Rescue , has
`agreed not to block the entrances...
`
`3. Abortion foe agrees to settle decade-old lawsuit
`Associated Press Archive - January 9, 1998
`Length: 374 words (Estimated printed pages: 2)
`
`Operation Rescue founder Randall Terry and the National Organization...covers only
`Teny, not Operation Rescue . He did not admit...
`
`4. MEDICAL JOURNAL GEARS UP FOR ABORTION PROTESTERS
`[CORRECTION - Date: Saturday, September 2, 1995: CORRECTION: A story and
`headline in yesterday's Metro/Region section incorrectly suggested that the antiabortion
`group Operation Rescue planned to hold protests at the offices of the New England
`Journal of Medicine in response to a journal article about drug-induced abortions.
`Operation Rescue did not plan a local protest, although the group said it would
`demonstrate at the New York office of the doctor who headed the study.]
`
`7
`
`

`
`Rosemarie Szostalc, Ph.D.
`Analyst
`Nerac Inc.
`
`March 15, 2011
`
`Boston Globe - September 1, 1995
`Length: 262 words (Estimated printed pages: 2)
`
`...su1-gery. An Operation Rescue spokesman...s founder, Randall A . Terry , will
`lead...irreponsib1e not to. However...
`
`5. JOURNAL TAKES SECURITY MEASURES AFTER ABORTION ARTICLE
`Philadelphia Inquirer, The (PA) - September 1, 1995
`Length: 436 words (Estimated printed pages: 2)
`
`...abortions. Randall Terry , an activist from Operation Rescue , sent a fax...irresponsible
`ofhint not to hire extra...something from Operation Rescue and they're not happy with...
`
`6. JOURNAL TIGHTENS SECURITY OVER ABORTION-STUDY REACTION
`Seattle Post-Intelligencer - September I, 1995
`Length: 183 words (Estimated printed pages: 1) A
`
`Rescue activist Randall Terry sent a fax Tuesday...sometl-ting from Opera ‘on Rescue
`and tl1ey're not happy with you...
`
`
`
`7. OPERATION RESCUE FOUNDER TO JOIN TALK-SHOW CROWD LET
`DOWN RY LIMBAUGII, TERRY MAKES IT CLEAR I-IE WON'T TOE GOP
`LINE
`
`Rocky Mountain News (CO) - May 6, 1995
`Length: 349 words (Estimated printed pages: 2)
`
`Operation Rescue founder Randall Terry is hitting the airwaves... 1 9 Oklahoma bombing,
`is not a likely product of the...
`V
`
`8. Supreme Court rejects abortion protester’s plea
`Austin American-Statesman - October 18, 1994
`Length: 306 words (Estimated printed pages: 2)
`
`...Anti-abortion leader Randall Terry appeared headed...contending that the Operation
`Rescue leader has not been arrested or...
`
`9. ABORTION FOE LEADER LOSES APPEAL LAWYER ASKS FOR
`LENIENCY
`.
`
`Greensboro News & Record - October 18, 1994
`Length: 227 words (Estimated printed pages: 1)
`
`Anti-abortion leader Randall A . Terry appeared headed...ground that the Operatio
`Rescue leader has not been arrested...
`'
`.
`
`

`
`Rosemarie Szostak. Ph.D.
`
`10. SIZING UP A NEW TARGET - RANDALL TERRY STEPS DOWN FROM
`
`OPERATION RESCUE TO GO ON THE ATTACK AGAINST BILL CLINTON
`Chicago Tribune - August 15, 1994
`Length: 1625 words (Estimated printed pages: 6)
`
`...their heroes: Randall Terry , who in l985...anti-abortion group Operation Rescue and
`now hosts...ofiice did not return phone...president of Operation Rescue , he has not left
`the...
`
`11. OPERATION RESCUE FOUNDER T0 SPEAK AT CHURCH IN L.B.
`Press-Telegram (Long Beach, CA) - July 1, l994
`Length: 38] words (Estimated printed pages: 2)
`
`...evening, when Randall Terry , founder of Operation Rescue , speaks at...clinics does
`not violate free...CARRL). Operationkeecue tacu":s~ are no as peaceful...
`
`12. Much ado about nothing - Operation Rescue avoided the arrests and
`confrontations of past campaigns
`.
`Star Tribune: Newspaper of the Twin Cities - July 18, I993
`Length: 1191 words (Estimated printed pages: 4)
`
`...letter by Randall Terry , founder...consciousness as Operation Rescue ‘s
`militant...resemblance to Operation Rescue ...protesters was not an effective...supporters
`of Operation Rescue - not clinic workers...
`
`13. RANDALL TERRY; PETTY DEMAGOGUE
`Seattle Post-Intelligencer - July 17, 1993
`Length: 196 words (Estimated printed pages: 1)
`
`...from both sides. But one need not look for it from Operation Rescue founder Randall
`Terry . Terry's own words...
`
`I
`14. A SECTION
`Journal Gazette, The (Fort Wayne, IN) - July 9, 1993
`Length: 784 words (Estimated printed pages: 3)
`
`...protester not connected with Operation Rescue , has been...EOP} } Randall Terry ,
`Operation
`
`15. A SECTION
`
`Journal Gazette, The (Fort Wayne, IN) - July I, 1993
`Length: 535 words (Estimated printed pages: 2)
`
`
`
`

`
`Rosemarie Szostak, Ph.D.
`
`Analyst
`Nerac Inc.
`
`March 15, 201 I
`
`...But it was not well received at
`Terry . “Any politi...
`
`peration Rescue . ‘ ‘If Operation ...br/> der Randall A .
`
`16. RANDALL TERRY LABELS SLAIN DOCTOR ‘MASS MURDERER'
`
`National Public Radio - March 1 1, 1993
`Length: 714 words (Estimated printed pages: 3)
`
`...WERTI-IEIMER, Host: Randall Terry is the founder of Operation Rescue , an anti~
`abortion...he says is not affiliated with Rescue America...murder should not reflect on
`Operation Rescue or...
`
`17. Operation Rescue founder convicted
`St. Petersburg Times - March 7, 1993
`Length: 682 words (Estimated printed pages: 3)
`
`Operation Rescue founder Randall Terry was convicted Friday...already ordered him and
`Operation Rescue not to follow through...
`
`18. ANTIABORTION LEADER TERRY IS CONVICTED
`Washington Post - March 7, 1993
`Length: 192 words (Estimated printed pages: 1)
`
`
`
`Rescue founder Randall Terry has been...He could not be reached...message that
`Operation Rescue '5 lawlessness will not be tolerated...
`
`19. OPERATION RESCUE LEADER CONVICTED IN EFFORT TO GIVE
`FETUS TO CLINTON
`
`Press ofAtlantic City, The (NJ) - March 6, 1993
`Length: I39 words (Estimated printed pages: 1)
`
`Operation Rescue founder Randall Terry was convicted Friday...already ordered him and
`Operation Rescue not to follow through...
`
`20. OPERATION RESCUE CHIEF FOUND GUILTY
`San Jose Mercury News (CA) - March 6, 1993
`Length: 74 words (Estimated printed pages: 1)
`
`Opcmtiun Rescue founder Randall Terry was convicted Friday...already ordered him and
`Operation Rescue not to follow through...
`
`21. ABORTION FOES PROTEST OUTSIDE CLINIC IN HOUSTON
`THE ORLANDO SENTINEL - September 2, 1992
`Length: 83 words (Estimated printed pages: 1)
`
`
`
`I0
`
`

`
`Rosemarie Szostak, Ph.D.
`Analyst
`Nerac Inc.
`
`March 15, 201 1
`
`...court order did not shuw up. Seventeen Operation Rescue supporters
`founder Randall Terry , were freed on...
`
`Rescue
`
`22. Operation Rescue takes day to regroup
`Fort Worth Star-Telegram - April 27, 1992
`Length: 230 words (Estimated printed pages: 1)
`
`Rescue founder Randall Terry worked to...Abort Operation Rescue ." Two...they
`should not fear being...
`
`23. ADVERSARIES ADD STRENGTH FOR WEEKEND TOP LEADERS,
`BACKERS INCREASE IN NUMBER
`
`The Buffalo News - April 24, 1992
`Length: 719 words (Estimated printed pages: 3)
`
`Rescue founder Randall A . Terry . But most...request of Operation Rescue leaders
`in...individuals but not as a separate...Christ will not stand out unless Operation Rescue
`decides to...
`
`
`
`24. STUDY DISPUTES ROLE OF WICHITA CHURCHES PRO-CHOICE
`FORUM HEARS FINDINGS
`
`The Buffalo News - March 29, I992
`Length: 248 words (Estimated printed pages: 1)
`
`...And ( Randall ) Terry gushed over...movement do not Suppnrt the militancy of
`Operation Rescue ," she...
`
`25. OPERATION RESCUE CANNOT BE ABOVE THE LAW
`
`Buffalo News, The (NY) - January 25, 1992
`Length: 332 words (Estimated printed pages: 2)
`
`...l2 story on Randall Terry and Operation Rescue . I, as an honest...financial status,
`Operation Rescue is not accountable...
`
`26. RANDALL TERRY NOT WELCOME. AMHERST TOWN BOARD SAYS
`Buffalo News, The (NY) - January 8, 1992
`Length: I37 words (Estimated printed pages: l)
`
`...approved a resolution declaring that Randall Terry and Operaliort Rescue “are not
`welcome" in Buffalo's largest...
`
`27. COUNCIL JOINS OPERATION RESCUE FOES FAHEY OPPOSES
`RESOLUTION STATING ABORTION FOES ARE NOT WELCOME
`
`Buffalo News, The (NY) ~ January 8, I992
`
`ll
`
`
`
`

`
`Rosemarie Szostak, Ph.D.
`Analyst
`Nerac Inc.
`
`March 15, 2011
`
`Length: 660 words (Estimated printed pages: 3)
`
`...{ Randall ) Terry has shown...but does not believe the...Terry and Operzuion Rescue
`"are not welcome...
`
`28. GRIFFIN VOWS FAIRNESS FOR OPERATION RESCUE MAYOR ALSO
`SAYS DEMONSTRATORS WILL FACE ARREST IF THEY BREAK THE LAW
`Buffalo News, The (NY) - January 7, 1992
`*
`Length: 332 words (Estimated printed pages: 2)
`
`Rescue founder Randall Terry and his supporters...cl-iildren, not to abuse...they hope
`Oper

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