Matthew C.

Parks
ELAM &BURKE
251 E. Front St., Ste. 300
P.O. Box 1539
Boise, ID 83701
Telephone:
208.343.5454
Idaho State Bar No. 7419
Gary L. Bostwick (pro hac vice)
BOSTWICK LAW
12400 Wilshire Boulevard. Suite 400
Los Angeles, California 90025-1030
Telephone:
310.979.6059
Attorneys for PETER ZUCKERMAN

IN THE DISTRICT COURT OF THE SEVENTH .JUDICIAL DISTRICT OF THE

STATE OF IDAHO, IN AND FOR THE COUNTY OF BONNEVILLE
FRANKL. VANDERSLOOT, individual,
Plaintiff,

PETER ZUCKERMAN, individual,

Case No. CV-2014-2510

(Consolidated with Case No. CV-2013-532)

DECLARATION OF PETER
ZUCKERMAN IN SUPPORT OF
MOTION FOR SUMMARY JUDGMENT

Defendant.

Hearing Date:
September 17, 2015
Time:
9 a.m.
[Hon. Darla Williamson]

I, Peter Zuckerman, declare:

I. I am the defendant in this matter. I am a citizen and domiciliary of Oregon. I make this
Declaration upon personal knowledge. except as otherwise stated, and, if called upon to
testify, could and would testify competently hereto.

DECLARATION OF PETER ZUCKERMAN I/S/O MOTION FOR SUMMARY JUDGMENT

Page 1

2. I appeared on the Raebel Maddow Show on MSNBC network on May 4, 2012 (hereinafter
"the Show"). The Complaint alleges that I said certain things on the show and attaches what
purports to be a transcript of Maddow's questions and my words. (Ex. I to the Complaint); I
testify here regarding portions of the statements I made during the appearance.
3. During my appearance on the Maddow show, Maddow asked me about a full-page Ad
entitled "The Community Page Ad", "Paid for by Melaleuca, the Wellness Company", that
the Post Register published on June 5, 2005 (hereinafter "the Ad"). Part of the Ad was a
statement signed by Frank VanderSloot.
4. The Complaint alleges I said: There was a tremendous impact on me both personally and
professionally. The statement was true, and when I spoke those words I had no reason to
doubt what I said. At the time of these events, being exposed as gay \Vas no small matter, and
I was keenly aware of many reasons to feel that eastern Idaho was a hostile environment in
which to be exposed as gay. These included:

At the time you could be fired for being gay in Idaho and I had heard stories of that
happening to people.

At the time, in Idaho you could be denied housing or a job, be kicked out of an
apartment or expelled from some colleges for being gay. I had heard stories of that
happening.

At meetings for Parents and Friends of Lesbians and Gays (PFLAG), I had met
people who said they were suicidal because of their sexual orientation. I also met
people who said they had been harassed and faced employment housing, and family
issues because of their sexual orientation.

One of my friends, Laura Garcia. a bisexual who attended meetings f<.x PF LAG,

DECLARATION OF PETER ZUCKERMAN l/S/O MOTION FOR SUMMARY JUDGMENT

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killed herself.

Other people struggling with their sexual orientation in the area had also committed
suicide, including several high-profile cases of students at Brigham Young University
and a high-profile case of a man who killed himself on the steps of an LDS temple.

Although they had been overturned by the U.S. Supreme Court, laws were still on the
books in Idaho that made it a crime to be gay.

Boyd K Packer, highly placed in the LOS Church, had called gays enemies of the
church.

5. After the Ad, there was an immediate and dramatic impact in my life, which I believed was
directly tied to the publication of the Ad, and like nothing I'd experienced before. By outing
me in my own newspaper (and linking my orientation to an attack on my integrity as a
reporter) - the Ad profoundly affected my daily life as well as my professional reputation.
6. The Post Register was read by people who subscribed to the paper, which was, by
circulation, the second-largest newspaper in Idaho and the largest newspaper in eastern
Idaho.
7. The Post Register was my workplace. People I knew and worked with every day read the
newspaper carefully. Doing so was part of their job.
8. The Post Register was the newspaper of record and closely read by people who \vorked for
other media outlets in Idaho. Reading the ne\vspaper closely was pai1 of their jobs, and they
considered the Post Register a credible source. I often ran into these colleagues at other
media outlets while covering other news stories and was well aware that I might someday
work for or with some of these colleagues or at some of the news organizations that
subscribed to the Post Register.

DECLARATION OF PETER ZUCKERMAN I/S/O MOTION FOR SUMMARY JUDGMENT

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9. The Post Register was closely read by people who worked for other media outlets across the
US. Reading the newspaper closely was part of their jobs, and they considered the Post
Register a credible source. I knew that some of my colleagues across the country kept close
track of what reporters like me were writing so that they could decide whom to hire when
there was an opening.
10. People on my beat read the newspaper closely because they were in iL because their bosses
were in it, because their workplaces were in it, because they knew me, because they wanted
to know what was happening within their organization and because staying on top of the
news coverage about their organization could be an important part of their jobs.

11. The Post Register vvas closely read by sources who were not on my beat but who provided
me information or were thinking about providing me information. Sources often decided
v.rhether or not they would talk to me based on what they read in the paper.
I 2. The Post Register was also read by people who casually knew me and followed what I write.
13. Compared to whoever a small radio show reached, I cared much more about my readers,
colleagues at work, colleagues in journalism, potential employers, beat members, sources.
possible sources, and casual readers, potential employers. It wasn't just how many people
were reached, it's who the people were and how close to my life they were. That difference
in audience caused the different impact on me.

14. The Complaint alleges I said: Pcrsonallv. it was reallv hard when mv bovfriend. at the time.
came home and said. "I don't have mv job anvmore. They know I'm gay. Thev know about
mv relationship with

VOLL

They don't want me there anvmore." The statement was true, and

when I spoke those words I had no reason to doubt what I said. It is a vivid memory for me
from a very stressful time. Many events demonstrate how stressful the period was for me:

DECLARATION OF PETER ZUCKERMAN 1/S/O MOTION FOR SUMMARY JUDGMENT

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My boyfriend at the time was Dylan Stone. The Ad came out on a Sunday, the day
that has the biggest circulation and the most readership. The Ad was as big as you
could buy them, the largest print media platform that you could buy in eastern Idaho.
That morning Dylan and l went to the Unitarian Universalist Church. It was quite the

topic of discussion. Dylan became sick, probably because of a neurological condition

that we later learned about, that he is still being treated for today and that is triggered
by stress. He went to bed early.

On Monday, a day after the Ad was published, I came home and he was on our futon
in the living room. It was around 6:30 p.m. He appeared to have been crying. I asked
what was wrong. He told me he had been fired because they had found out he is gay
as a result of the Ad. l did not grill him on the details, but he said the circumstances
were that he had been upset and told some co-workers why and gossip had gotten
around. We both had been fairly uncommunicative about our separate lives outside
the home for quite a while, especially when work was stressful, so I didn't know
much about his "job" at the time. l believed it involved working with people who had
mental illnesses.

For years after that conversation, when Dylan and l spoke about what happened, he
continued to tell me he had been fired because of the ads and how it had been very
hard on him.

I had read reports from other media outlets that had also reported that Dylan had been
fired because of the ads. I do not recall speaking to these outlets about that happening.
I assumed the reporters had independently verified this information. Based on
Dylan's personality, I also assumed that if these reports had been wrong, he would

JJZtd

;~

DECLARATION OF PETER ZUCKERMAN I/S/O MOTION FOR SUMMARY JUDGMENT

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have corrected them.

15. The Complaint alleges I said: And it was reallv hard for him. The statement was true, and
when I spoke those words I had no reason to doubt what I said. These are things I remember
from that time that caused me to conclude that the publication was very hard on him:

Dylan told me it was really hard for him. He had been upset about the ad at work, had
told others about it, and said that he was then fired (see Paragraph 14 above). He
described the people at his work as a bunch of homophobes.

Shortly thereafter, he complained of being ill and took to bed for long stretches, as
long as a week at a time, as if he had a cold or the flu. See my paragraph 16 below for
facts that also bear on this statement.

Dylan thereafter stopped or greatly reduced paying for shared expenses. See my
paragraph 17 below for facts that also bear on this statement.

Dylan continued, for years, to maintain that he had been fired for being gay after the
ad was published.

I had read reports from other media outlets that had also reported that Dylan had been
fired because of the ads. I do not recall speaking to these outlets about that happening.
I assumed the reporters had independently verified this information. Based on
Dylan's personality, I also assumed that if these reports had been \Vrong. he would
have corrected them.

16. The Complaint alleges I said: He actually got sick soon afterwards and was in bed for a
month. The statement was true, and \Vhen I spoke those words. I had no reason to doubt what
I said. I had no reason to doubt because of the follovving:

IIilll

Dylan was sick and seemed to spend a great deal of time in bed. I was under the

LL

DECLARATION OF PETER ZUCKERMAN I/S/O MOTION FOR SUMMARY JUDGMENT

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impression that he was unemployed, and, as stated below in my paragraph 17, he

claimed to be too sick to find a new job.

I started coming home for lunch to save money, sometimes finding Dylan still at
home in bed. Although he had complained of illness and stress before the Ad, the
continual nature of his malady and extended periods in bed had not occurred before
the Ad.

I later learned that he has a severe migraine disorder that causes him to become sick
for long stretches at a time. Today he still suffers from this condition, and even with
years of medication, diet changes, lifestyle changes and treatment, he still becomes
sick for long stretches when in a stressful situation.

17. The Complaint alleges I said: I didn't know ho\V we were going to pay the bills. The
statement was true, and when I spoke those words I had no reason to doubt what I said. Here
are the reasons why:

1 recall I earned about $19,000 to $25,000 per year at the time. It was difficult for two
people to live on that. We were living paycheck to paycheck.

I cannot say for certain if I paid the bills in their entirety or not, but I do remember
feeling like I paid a lot more than Dylan did, could rarely afford to have fun, and
could not afford better clothes, even though some of my colleagues and some people
on my beat teased me for having holes in my sweaters.

Finances were always a touchy subject between me and Dylan, as they are for many
couples. I asked him to work harder on finding a job after the ad. He replied that he
was sick and would get on it \.vhen he was feeling better.

18. The Complaint alleges I said: It was reallv hard when people started leaving notes on mv

DECLARATION OF PETER ZUCKERMAN l/S/O MOTION FOR SUMMARY JUDGMENT

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doorstep. The statement was true, and when I spoke those words I had no reason to doubt
what I said. See my paragraph 21 below for facts that also bear on this statement.

The Complaint alleges I said: [It was really hard] when somebody kept calling in the middle
of the night threatening to rape me with his handgun. That was -- I mean. that was really
terrible. The statement was true, and when I spoke those words I had no reason to doubt what
I said. After the Ad, I answered a call and heard a male voice that said something like "Cut
this shit out, faggot. I'm going to fucking rape you with my handgun." It happened more than
once, but it only started after the Ad.

19. The Complaint alleges I said: And then professionally. it became much harder to do my job
because. yes. Idaho Falls was buzzing about mv sexual orientation. The statement \Vas true,
and when I spoke those words I had no reason to doubt what I said. See my paragraph 27
below regarding the difficulty I had collecting information once the Ad was published.
20. The Complaint alleges I said: And. you know. when I tried to talk to people. they would say
things like. "Oh. I can't talk to you. You're a homosexual. We don't associate with that." The
statement was true, and when I spoke those words I had no reason to doubt what I said. What
follows are some instances of the rejection:

Before the Ad was published, I would regularly get coffee at one of those drivethrough places that was basically just a little stand in a parking lot. These teenage
women worked there. They were bubbly and nice. flirting with me a bit and they
knew I worked at the newspaper because I'd told them and they read the newspaper
vvhen they were bored.

But a few days after the Ad ran, one of these women refused to serve me. She said
something like, "I read about you in the paper and knovv what you are. I have a right

DECLARATION OF PETER ZUCKERMAN 1/S/O MOTION FOR SUMMARY JUDGMENT

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to refuse service and it's against my beliefs to serve people like you. You aren't
welcome here and you don't belong in Idaho Falls".
21. The Complaint alleges I said in response to a Maddow question: MADDOW: Did all of this
happen because you were being discussed on a local radio show or did this happen not until
your name appeared on the ad? ZUCKERMAN: This did not happen until mv name appeared
in the Ad. The statement I made is true, and when I spoke those words I had no reason to
doubt what I said.

Although some attacks sta1ied before the Ad ran, probably as a result of a local radio
show, those attacks quickly died down. Much more serious events occurred after the
Ad was published. What happened after the ads ran was traumatic- one of the worst
periods of my life, and I would prefer to forget it and never speak of it again. The
attacks after the Ad were scarier and more vicious.

Maddow's segment was not about what happened to me because of a talk radio show.

It was about Frank VanderSloot, Mitt Romney's finance co-chair, and what happened
to me after the ads he took out had run.

Right before I made this statement, Maddow had asked me about what had happened
to me as a result of the ad, not what had happened before it. I described what had
happened to me after the ad.

I understood Maddow' s question to be what I had just told her about: my experiences

after the appearance of the Ad, not about other, lesser incidents had happened earlier
to me.

When I said, "This did not happen until my name appeared in the ad,'' I was referring
to what I had just related to Maddow

the things that I had happened to me after the

DECLARATION OF PETER ZUCKERMAN I/S/O MOTION FOR SUMMARY JUDGMENT

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Ad was published.

All of the things that I described to Rachel Maddow were things that happened to me
after the Ad.

These were my experiences after the Trish and Halli show aired:

Some people on my beat found out my sexual orientation, but did not react by
shutting me out.

My office, home and cell phones rang through the night.

Twice, I was awakened at night by someone ringing the doorbell to "find out the
truth."

Most people that I talked to told me they didn't take the Trish and Halli show
seriously.

By early May, 2005, a month before the Ad, I wrote and told my boss that "everyone
seems to have forgotten. It's old news. The city of Idaho Falls seemed to go back to
normal." I felt that the controversy related to the articles had largely blown over, that
the negative blowback was subsiding and that it was not as bad as I'd feared. Then
the Ad was published and it was like a bomb going off.

What happened to me after the radio shows was disturbing, but nowhere close to the evil and
hatred that appeared after the Ad. These were my experiences after the Ad:

I received calls where people cussed me out, often using epithets. I decided at some
point to unplug the landline at night.

Several notes -five to I 0

were left on my car and doorstep. I read only a few of

them. One said "FUCK YOU FAGGOT" and another said 'You are over." I didn't
read the others and threw them out.

DECLARATION OF PETER ZUCKERMAN 1/S/O MOTION FOR SUMMARY JUDGMENT

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As described in Paragraph 20, r was refused service at a drive-through coffee stand.

At a Wal-Mart in the produce section, this guy asked me in a curt voice if[ was Peter
Zuckerman. He was maybe in his 40s and was alone. I said "Yes. r need to grocery
shop right now." The guy kept following me to other aisles. He stopped me again and
said "[ read about how you're homosexual and who you are. You're going to fucking
pay for this." I quickly left. He kept following me. I just left my grocery cart and left
the store.

The day of the ads, a Sunday evening, I told Dylan I was going to do some errands. I
got in the car and drove to the parking lot nearby, close to the movie theater, and just
started crying. The lot was right next to the apartment. I had a very distinctive car at
the time

a Honda Civic with a huge gash on the driver's side door and peeling paint

that I'd unsuccessfully tried to rustproof with spray paint that had turned fluorescent
blue, making the car look polka dotted. Someone -- also a middle-aged guy -knocked on the window. I opened it a crack. The conversation went something like
this:
Him: "Do you live here"
Me: "I'm really busy right novv."
Him: "I know who you fucking are."
Me: "Please leave me alone."
Him: "You better watch your back."
He was about to say more, but then his cell phone rang. He hit the pickup button
and, in a strangely more polite voice, said "Hold on a second." As he spoke into
his phone, I drove toward the apartment.

DECLARATION OF PETER ZUCKERMAN I/S/O MOTION FOR SUMMARY JUDGMENT

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He put the phone in his pocket and ran after me, yelling something.

I drove onto a main road, and drove around town for about 30 minutes, headed back
to the apartment, and while driving by the movie theater, tried to determine if the man
was gone. I didn't see him. I returned to the apartment. It is possible he was the
source of how people found out where I lived because that's when I started getting
notes. I had a very distinctive car and, unfortunately, it was parked right in front of
the stairs that led directly to the apartment.

22. The Complaint alleges I said in response to a Maddow question: MADDOW: When he savs
he wasn't outing you. evervbody knew already. you dispute that contention? ZUCKERMAN:
I absolutely dispute that contention. The statement I made is true, and when I spoke those
words I had no reason to doubt what l said. "Everybody" did not know already I am gay.

I knew nine people in Idaho Falls who knew I \Vas gay.

Outside of Idaho Falls. I had told between 40-50 people in total I was gay, but many
of them were family members. Some of my more distant family members did not
know I was gay.

Before the Ad, I had a strong feeling that the vast majority of people I interacted with
in Idaho did not know l am gay. My article on the Poynter Institute web site was so
obscure that it did not show up in search engine results under my name and could
only be found with advanced searching tools that few people besides professional
investigators knew how to use. It was not likely to have been seen by many people. I
did not know of anyone in Idaho besides my pa1tner Dylan who had read it. I did not
sense that anyone in Idaho Falls was likely to read that web site.

I knew that some people in Idaho Falls must have heard the radio shmv and suspected

DECLARATION OF PETER ZUCKERMAN I/S/O MOTION FOR SUMMARY JUDGMENT

Page 12

I am gay. The reactions I had gotten proved that. But the audience for the show was
relatively small, the show was not seen as a credible source. Most of the people who
found out through the show probably only considered it a rumor, not something that
was necessarily true, and 1 did not confirm the rumor to them. I did not fear that the
whole community knew or that most people I interacted with knew.

Most of the facts I experienced in my daily life proved to me I was not "out" in my
community and that I largely was in control of whether people knew.

When the Ad came out, that changed. As described in paragraph 21, my experience
was that I was "outed" because of the Ad -- a large audience, if not most people I
interacted with in Idaho, found out I am gay as a result of the Ad.

23. The Complaint alleges I said: The Idaho Falls Post Register was the place I worked. It was
mv colleagues 1 worked with. It was the people on mv beat. The statement was true, and
when I spoke those words I had no reason to doubt what I said.

After the Trish and Halli shovv, my ability to do my job was not significantly
impacted. As I wrote contemporaneously, the controversy was brief and, although
stressful, not horrific

After the ads ran, my ability to do my job V/as severely damaged. See more facts
stated related to this in paragraph 27 below.

24. The Complaint alleges I said: Yes. a handful of people knew I'm gav. Mv bovfriend knew I
was gay. Mv parents and boss knew I was gav. Mv boss knew I'm gav. The statement was
true, and when I spoke those words I had no reason to doubt what I said.

As stated in my paragraph 22 above, I knew nine people in Idaho Falls who knew I was gay.
Those people included my boyfriend, parents and boss.

DECLARATION OF PETER ZUCKERMAN l/S/O MOTION FOR SUMMARY JUDGMENT

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25. The Complaint alleges I said: But most -- I hadn't told anybody on my beat that I'm gay and
for good reason. because I was worried they wouldn't talk to me. The statement was true, and
when l spoke those words I had no reason to doubt what I said.
26. The Complaint alleges I said: And I feel like the worse part isn't so much that I was harassed.
but was that this was really important story that needed to get out there. This was a story
about child molesters in the boy scouts. It was about trying to protect kids from these kind of
pedophiles. The statement was true, and when I spoke those words I had no reason to doubt
what I said.
27. The Complaint alleges I said: And by making it so hard for me to gather information. it
actually really limited the story. There's a lot more to that story that I was not able to get.
And this was a major contributor for one of reasons I couldn't get it. The statement was true,
and when I spoke those words I had no reason to doubt what l said.

Before the Ads, I had received several tips about approximately I 0 other chi Id
molesters in the Boy Scouts in Idaho.

Before the Ads, I had also received some pages of the Boy Scouts "Perversion Files"
that included names of perhaps I 0 other people \Vho had been kicked out of Scouting
in Idaho for child molestation.

I had been making progress on those leads before the Ads ran and before the first
installment of the Scouts Honor series ran, resulting in several other follow-up
"Scouts Honor" stories.

But once the ads ran, people began shutting me out because they did not want to
associate with someone who is gay. Such reporting is delicate and people are easily

DECLARATION OF PETER ZUCKERMAN l/S/O MOTION FOR SUMMARY JUDGMENT

Page 14

spooked, and I was disappointed. This had not happened after the Trish and Halli
show was broadcast.

I did not want to report the events to the police because I covered them, because I
worried it would become a news story, attracting more attention, and because I had
promised to protect the source who had given me copies of the Confidential Boy
Scout files, and that person made me promise not to give them to anyone else. When
leaving Idaho Falls, however, I did encourage the police to ask for the Scouts for the
perversion files. -I do not know what happened as a result.

28. The Complaint alleges I said in response to a Maddow question: MADDOW: And in your
reporting you did in Idaho, in any of the reporting that you have done. have you ever dealt
with somebodv who is as interventionist in terms of trving to control the coverage that a
publication that you were involved in was actually standing behind? ZUCKERMAN: Not
quite like this. I've never had somebody run paid ads in the newspaper

rm working at as

trving to discredit me as a person. The statement I made is true, and when I spoke those
words I had no reason to doubt what I said. I have never experienced anyone try to control
the coverage of a .story to this extent in a newspaper I was working for.
I declare under penalty of perjury under the laws of the State of Idaho that the foregoing
I

0 1''(\

is true and correct, and was executed this _/_,_ clay of July, 2015 at Portland, Oregon.

DECLARATION OF PETER ZUCKERMAN I/S/O MOTION FOR SUMMARY JUDGMENT

Page 15

CERTIFICATE OF SERVICE
I certify that on the 15111 day of Julv, 2015, I served true and accurate copies of
DECLARATION OF PETER ZUCKERMAN IN SUPPORT OF MOTION FOR
SUMMARY JUDGMENT on the following persons, either by deposit in the U.S. Mail,
addressed as follows and with the correct first-class postage affixed thereto, or be deposit in the
designated courthouse mailbox, or by hand-delivery, as indicated below:
Ryan D. Nelson
Michael L. LaClare
Jennifer Hall
Keith Woffinden
MELALEUCA, INC.
3910 South Yellowstone Hwy.
Idaho Falls, ID 83402
Email rnelson@melaleuca.com
Email mlaclare@melaleuca.com
Email jehall@melaleuca.com
Email kwoffinden@melaleuca.com

]
]
]
]
]

U.S. Mail, postage prepaid

Hand Delivery
Fax
Overnight Mail
Email

]
]
]
]
]

U.S. Mail, postage prepaid

Hand Delivery
Fax
Overnight Mail
Email

]
]
]
]
]

U.S. Mail, postage prepaid

Hand Delivery
Fax
Overnight Mail
Email

Counselfor Plaint(/fs
Thomas A. Clare
Elizabeth M. Locke
Megan Meier
CLARE LOCKE LLP
902 Prince Street
Alexandria, Virginia 22314
Email tom@clarelocke.com
Email libby@clarelocke.com
Email megan@clarelocke.com

Counselfor

Plaint(/!~

Marvin M. Smith
Marcia Morrissey
SMITH & BANKS PLLC
3010 Jenner Lee Drive
Idaho Falls, ID 8340 I
Email mmsmith@smithbanks.net
Email mmorrissey@smithbanks.net

Counselfor Defendants The Foundationfor National

Progress, dba j\;fother Jones. iV!onika Bauerlein, and
Stephanie Mencimer

Charles A. Brown

[ I U.S.

Mail, postage prepaid

DECLARATION OF PETER ZUCKERMAN l/S/O MOTION FOR SUMMARY JUDGMENT

Page 16

P.O. Box 1225

324 Main Street
Lewiston, ID 8350 I
Email charlesabrown@cableone.net

]
]
]
]

Hand Delivery
Fax
Overnight Mail
Email

]
]
]
]
]

U.S. Mail, postage prepaid

Hand Delivery
Fax
Overnight Mail
Email

]
]
]
]
]

U.S. Mail, postage prepaid

Hand Delivery
Fax
Overnight Mail
Email

Counsel.for Defendants The Foundation.for National

Progress, dba J\lfother Jones, Monika Bauerlein, and
Stephanie kfencimer
James M. Chadwick
David E. Snyder
Tenaya Rodewald
Robin Regnier
SHEPPARD, MULLIN, RICHTER & HAMPTON LLP
379 Lytton Avenue
Palo Alto, CA 9340 I
Email jchadwick@sheppardmullin.com
Email dsnyder@sheppardmullin.com
Emai I trodewald@sheppardm u 11 in.com
Email rregnier@sheppardmullin.com

[
[
[
[
[

Counsel for Defendants The Foundationfi:Jr National

Progress. dba Mother Jones, Monika Bauerlein, and
Stephanie Mencimer
Matthew C. Parks
ELAM & BURKE
251 E. Front Street, Ste 300
Boise. ID 83702
Email mcp@elamburke.com

Counsel.for Defendant Peter Zuckerman

Gary L. Bostwick
Attorney.for Defendant Peter Zuckerman

DECLARATION OF PETER ZUCKERMAN I/S/O MOTION FOR SUMMARY JUDGMENT

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