Baker & McKenzie LLP, 1111 Brickell Avenue, Suite 1700, Miami, Florida 33131 – (305) 789-8900 

UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

CASE NO: 20-CV-22995-KMW

SILVA HARAPETI, 

 Plaintiff, 

vs. 

CBS TELEVISION STATIONS INC., a 

Foreign Profit Corporation, et al., 

 Defendants. 

__________________________________/ 

DEFENDANTS’ STATEMENT OF MATERIAL FACTS 

IN SUPPORT OF MOTION FOR SUMMARY JUDGMENT 

 

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Index of Exhibits to Defendants’ Statement of Material Facts 

Exhibit Document Name 

A Declaration of Carl Larson 

B Harapeti Personnel Documents 

C June 22, 2021 Deposition of Silva Harapeti 

D July 12, 2021 Deposition of Silva Harapeti 

E Hank Tester LinkedIn Profile 

F David Sutta LinkedIn Profile 

G David Sutta Welcome Email dated March 30, 2007 

H Ted Schouten LinkedIn Profile 

I Carey Codd LinkedIn Profile 

J Ryan Fisher Employment Application 

K Josh Folk Welcome Email dated Nov. 9, 2009 

L Tiani Jones Personal Information Form 

M Declaration of Tiani Jones, Case No. 20-cv-20961 at (DE 29-1) 

N Amber Diaz Employment Application 

O Declaration of Lisa Cilli 

P Declaration of Silva Harapeti, Case No. 20-cv-20961 (DE 174) 

Q Evidentiary Hearing (Oct. 14, 2020) Case No. 20-cv-20961 at (DE 76) 

Additional Documents Referenced 

DE Document Name 

1 Plaintiff’s Original Complaint 

91 Plaintiff’s Corrected Fourth Amended Complaint 

52-1 Declaration of Joel Goldberg 

52-4 Declaration of Elizabeth Roldan 

Each of the above-referenced Exhibits has been filed as a separately marked exhibit to 

Defendants’ Statement of Material Facts. Documents already on the Court’s docket are referred 

to in Defendants’ Statement of Material Facts by their ECF filing number. 

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Pursuant to Rule 56 of the Federal Rules of Civil Procedure and Rule 56.1 of the Local 

Rules for the Southern District of Florida, Defendants CBS Television Stations Inc., CBS 

Broadcasting, Inc., and CBS Corporation (collectively, “Defendants” or “CBS”), by and through 

undersigned counsel, hereby file this Statement of Material Facts in support of their separately 

filed Motion for Summary Judgment.

Plaintiff’s Employment with WFOR 

1. Defendant CBS Television Stations Inc. operates WFOR-TV in Miami, Florida 

(“WFOR”). Declaration of Carl Larson (“Larson Decl.”), attached hereto as Exhibit A, at ¶ 3. 

2. Plaintiff Silva Harapeti (“Plaintiff” or “Harapeti”) was born February 25, 1975. See 

Harapeti Personnel Documents, attached as Exhibit B, at CBS-Harapeti-00000045. 

3. Plaintiff graduated from the University of Southern California with a Bachelor’s 

Degree in communications. See June 22, 2021 Deposition Transcript of Silva Harapeti (“Pl. 

Depo.”), attached as Exhibit C, at 11:11–16. Plaintiff received her first job as a television 

producer in or around 2002 and began reporting in or around 2003 or 2004. See id. at 11:25–13:8. 

4. Plaintiff worked as a television reporter and/or producer for several television 

stations throughout the United States from 2002 forward, before getting hired as a freelance (or 

“per diem”) reporter at WFOR in Miami, Florida. See Ex. C, Pl. Depo. at 39:2–11; Ex. B, 

Plaintiff’s Personnel Documents, at CBS-Harapeti-00000044–CBS-Harapeti-00000045 

(reflecting hire as a “reporter” with an effective date of 2/21/2011). 

5. From approximately 2011 to 2013, Plaintiff worked at WFOR as a freelance (“per 

diem”) reporter. See Ex. C, Pl. Depo. at 39:2–11; Ex. B, Plaintiff’s Personnel Documents, at CBSHarapeti-00000044–CBS-Harapeti-00000045 (reflecting hire as a “reporter” with an effective date 

of 2/21/2011), CBS-Harapeti-00000040 (reflecting termination effective 9/26/2011); CBSHarapeti-00000029 (reflecting re-hire as a per diem “reporter” on 1/18/2012), CBS-Harapeti0000023 (reflecting termination date of 8/31/2013). 

6. Plaintiff was re-hired at WFOR on or about July 20, 2015 as a freelance producer. 

See id. at CBS-Harapeti-0000007; see also Ex. C, Pl. Depo. at 37:13–38:22. 

7. During this period, Plaintiff was classified as a “freelance” or “per diem” employee, 

and received $210 for each day worked. Ex. B, Plaintiff’s Personnel Documents, at CBS-Harapeti0000008. This day rate was based on an annualized salary of $54,600.00. See id. at CBS-Harapeti0000007. 

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8. Plaintiff worked as a producer throughout 2015; however, she began taking on the 

responsibilities of a reporter in or around 2016. See Ex. C, Pl. Depo. at 37:13–40:19. 

9. Plaintiff requested the opportunity to take on reporter responsibilities from one of 

her superiors, Elizabeth Roldan (“Ms. Roldan”), because Plaintiff was “looking for an opportunity 

to get on air.” See Ex. C, Pl. Depo. at 47:18–49:1 (noting that Plaintiff “had been asking to be put 

on the air as a reporter in general . . . because that’s what [Plaintiff] [did] in the past”). 

10. A reporter or a producer’s pay is based on a variety of factors, including experience, 

seniority, budgetary concerns at the time of hire, and which show they are assigned to. See Ex. C, 

Pl. Depo. at 54:4–22, 55:13–56:13 (noting that “experience,” “specific knowledge in a specific 

area,” “contact lists,” and “specific skill[s]” are some factors that might impact a reporter’s pay), 

177:9–11; July 12, 2021 Deposition of Silva Harapeti (“July 12th Pl. Depo.”), attached as Exhibit 

D, at 51:3–7 (noting that, in general in Miami, “[e]xperience, how much you know about the 

market, how long you’ve been there [at the station] obviously impacts the pay” (emphasis added)). 

11. Additional factors impacting pay include: whether the individual is a full-time staff 

employee or a non-staff, freelance, part-time, and/or per diem employee; pay scale in that market; 

whether the individual has negotiated a Personal Services Agreement; whether the individual is 

represented by a talent agent; and the individual’s tenure at CBS. See Declaration of Joel Goldberg 

(DE 52-1) at ¶ 15. 

Plaintiff’s Gender Discrimination Claims

12. Plaintiff alleges that “Defendant paid male freelance employees at a higher rate 

than Plaintiff.” See Plaintiff’s Corrected Fourth Amended Complaint (DE 91) (“Compl.”) at ¶¶ 

59–63; Ex. C, Pl. Depo. at 165:18–25. 

13. Plaintiff identified Hank Tester (“Tester”) as a male per diem reporter who was 

paid more than the female per diem reporters. See Ex. C, Pl. Depo. at 165:18–166:23 (“I believe 

Hank [Tester] is the only per diem that I – while I was there[.]”). 

14. Plaintiff does not know what Tester was paid. Id. at 166:5–15. 

15. Plaintiff testified that Tester “has more experience than [her]” and that his 

experience was “possibly” a reason his pay was higher. Id. at 166:24–167:15. 

16. Tester has worked in television since 1969. See Hank Tester LinkedIn Profile, 

attached hereto as Exhibit E. From 1979 to 1992, Tester owned and operated television stations 

in Nevada and Arizona, while also serving various roles at those television stations including news 

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director, assignment editor, editorial writer, and on-air reporter. See id. Tester has worked as a 

reporter in Miami since 1992. See id. 

17. Plaintiff also alleged that three additional male freelance reporters were paid more 

than her—David Sutta (“Sutta”), Ted Schouten (“Schouten”), and Carey Codd (“Codd”). See 

Compl. (DE 91) at ¶ 63. 

18. Plaintiff testified at deposition that Sutta, Schouten, and Codd were full-time 

reporters. Ex. C, Pl. Depo. at 167:25–168:3 (Sutta), 168:16–169:9 (Schouten), 170:9–23 (Codd); 

see also Ex. A, Larson Decl., at ¶¶ 7–9 (noting that in 2018, Sutta, Schouten, and Codd were fulltime staff reporters). 

19. Plaintiff does not know what Sutta’s pay was, but testified that he was paid more 

than Plaintiff because Plaintiff saw “a posting for a position similar to his.” Id. at 167:16–24. 

20. Plaintiff testified that Sutta was already working at WFOR prior to Plaintiff’s first 

stint of employment in 2011. Id. at 168:4–6. 

21. Plaintiff does not know whether Sutta had more experience than her. Id. at 168:7–

13. 

22. Sutta first began working at WFOR as a reporter at WFOR in 2007. See Ex. A, 

Larson Decl., at ¶ 7. 

23. Sutta has worked in television since 2001. See David Sutta LinkedIn Profile, 

attached hereto as Exhibit F. Prior to joining WFOR in 2007, Sutta worked at WBBH in Fort 

Myers, Florida, where he worked for 5 years as their lead investigative and crime reporter. See 

David Sutta Welcome Email dated March 30, 2007, attached hereto as Exhibit G. 

24. Plaintiff testified that she “believes” Schouten was paid more than her. See Ex. C, 

Pl. Depo. at 168:16–169:9. 

25. Plaintiff did not know what Schouten was paid. Id. 

26. Plaintiff testified that Schouten had been at WFOR for 10 to 15 years. Id. at 

169:10–12. 

27. Plaintiff does not know what Schouten’s experience was before he joined WFOR. 

Id. at 168:13–170:6. 

28. Schouten joined WFOR as a reporter in 1998. See Ex. A, Larson Decl., at ¶ 8. 

29. Schouten has worked in television as a reporter since 1989. See Ted Schouten 

LinkedIn Profile, attached hereto as Exhibit H. 

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30. Plaintiff does not know what Codd was paid and testified that she could “guess” 

that it was more than hers. See Ex. C, Pl. Depo. at 170:9–23 (“I don’t know [his pay] specifically 

but if I have to guess I’d say [it was more].”). 

31. Plaintiff does not know what Codd’s level of experience was. Id. 

32. Codd joined WFOR as a reporter in 2005. See Ex. A, Larson Decl., at ¶ 9.

33. Codd has worked in television as a reporter since 1997. See Carey Codd LinkedIn 

Profile, attached hereto as Exhibit I. Codd has a Bachelor’s Degree in communications, as well 

as a Master’s Degree in broadcast journalism from the University of Miami. See id.

34. Plaintiff also identified Ebenezer Mends (“Mends”). See Compl. (DE 91) at ¶¶ 65–

66. 

35. Mends is not a reporter, he is a videographer. See Ex. C, Pl. Depo. at 170:24–

171:11. Videographers, unlike reporters and producers, get paid hourly. See id.

36. Plaintiff testified that certain reporters were paid more because of their experience. 

See Ex. C, Pl. Depo. at 173:2–9. 

37. Plaintiff also identified Ryan Fisher (“Fisher”) as another per diem producer who 

Plaintiff believes was paid more. See Ex. C, Pl. Depo. at 174:1–175:10. 

38. Plaintiff does not know what Fisher was paid. Id. 

39. Plaintiff does not know what Fisher’s experience is. See id.

40. Fisher has been working as a television producer since 2001. See Ryan Fisher 

Employment Application, attached hereto as Exhibit J. 

41. Plaintiff identified Josh Folk (“Folk”). See Ex. C, Pl. Depo. at 174:1–175:10. 

42. Folk was a full-time contracted staff employee and resigned as of June 10, 2017. 

See id.; see also Ex. A, Larson Decl., at ¶ 10. 

43. Plaintiff does not know what Folk was paid. Ex. C, Pl. Depo. at 174:1–175:10. 

44. Plaintiff does not know what Folk’s experience was. Id. 

45. Plaintiff testified that Folk had been at WFOR longer than her. See id.; see also 

Ex. A, Larson Decl., at ¶ 10 (noting that Folk has been at WFOR since 2009). 

46. Folk worked at WFOR as a Senior Producer. Ex. A, Larson Decl., at ¶ 10. 

47. Prior to joining WFOR as a Senior Producer, Folk worked at WBBH in Fort Myers, 

Florida as an Executive Producer. See Josh Folk Welcome Email dated Nov. 9, 2009, attached 

hereto as Exhibit K. 

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48. An Executive Producer is responsible for the high-level management of the 

particular show or broadcast that they are responsible for. See Declaration of Elizabeth Roldan 

(DE 52-4) at ¶¶ 10–11; see also Declaration of Joel Goldberg (DE 52-1) at ¶ 12. 

49. Producers report to the Executive Producers, and are responsible for single 

broadcasts or segments. See Declaration of Elizabeth Roldan (DE 52-4) at ¶¶ 12–15; see also 

Declaration of Joel Goldberg (DE 52-1) at ¶ 12. 

Plaintiff’s Age Discrimination Claims 

50. Plaintiff alleges that CBS paid her younger female freelance counterparts 

“considerably more than Plaintiff.” See Compl. (DE 91) at ¶ 55. 

51. Plaintiff identified Tiani Jones (“Jones”) as a younger female freelance reporter 

who was allegedly paid more than Plaintiff. See Compl. (DE 91) at ¶ 45. 

52. Jones was born April 16, 1976. See Tiani Jones Personal Information Form, 

attached hereto as Exhibit L. 

53. However, Plaintiff does not know what Jones’ pay was relative to hers or whether 

Jones was paid more than Plaintiff. See Ex. C, Pl. Depo. at 156:3–14. 

54. Jones testified that she was paid a day rate of $200 per day. See Declaration of 

Tiani Jones, Case No. 20-cv-20961 at (DE 29-1), attached as Exhibit M, at ¶ 5. 

55. Jones left WFOR in July of 2017. See Ex. M, Consent to Join into Lawsuit, Case 

No. 20-cv-20961 at (DE 29-1). 

56. Plaintiff identified Rielle Creighton (“Creighton”) as a younger female freelance 

reporter who was allegedly paid more than Plaintiff. See Compl. (DE 91) at ¶ 52. 

57. Plaintiff does not know what Creighton was paid or whether Creighton was paid 

more than Plaintiff. See Ex. C, Pl. Depo. at 160:13–161:1. 

58. Creighton was born July 25, 1981. Ex. A, Larson Decl., at ¶ 4. 

59. Plaintiff identified Amber Diaz (“Diaz”) as a younger female freelance reporter 

who was allegedly paid more than Plaintiff. See Compl. (DE 91) at ¶ 53. 

60. Plaintiff testified that Diaz was paid $325/$350 per day. See Ex. C, Pl. Depo. 

161:2–22. 

61. Diaz has a Bachelor’s Degree in journalism from the University of Connecticut, 

and a Master’s Degree in broadcast journalism from Syracuse University. See Amber Diaz 

Employment Application, attached hereto as Exhibit N. 

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62. Plaintiff also identified Lauren Pastrana (“Pastrana”) and Oralia Ortega (“Ortega”) 

as two other individuals who were younger than Plaintiff and were paid more. See Ex. C, Pl. 

Depo. at 162:17–22. 

63. Both Pastrana and Ortega were full time, contracted reporters. See id. at 16:25–

17:19 (testifying that both Pastrana and Ortega were hired as full time reporters during Plaintiff’s 

first stint of employment from 2011 to 2013); see also Ex. A, Larson Decl., at ¶¶ 5–6 (noting that 

Pastrana was a full-time reporter from 2012 to 2015, and Ortega as of May 9, 2016). 

64. Pastrana was a full-time reporter from 2012 to 2015, but was promoted to an anchor 

position in September 2015. Ex. A, Larson Decl., at ¶ 5. 

65. When asked whether these individuals—Jones, Creighton, Diaz, Pastrana, and 

Ortega—were paid more because they were younger than Plaintiff, Plaintiff testified that it was “a 

possibility” and that this was based on her “opinion.” See Ex. C, Pl. Depo. at 162:23–163:3. 

Purported Retaliation Occurring After January 9, 2018

66. Plaintiff testified that on January 4, 2018 she had a meeting with WFOR’s News 

Director, Ms. Roldan, and complained to Ms. Roldan about being placed in dangerous situations 

while working as a reporter out in the field. See Ex. C, Pl. Depo. at 202:1–205:3. 

67. Plaintiff complained to Ms. Roldan about two specific instances where Plaintiff 

testified that she was assaulted by members of the public: once while covering Hurricane Irma1

in early September of 2017, and another time while covering a University of Miami football game 

in November of 2017. See Ex. C, Pl. Depo. at 177:12–183:14, 187:22–23, 188:7–197:5. 

68. Plaintiff testified that in response to her complaints about security while working 

in the field, Ms. Roldan told her “this is not a whining session.” Id. at 202:9–203:11. 

69. Plaintiff testified that Ms. Roldan’s response was “discriminatory” because “if any 

of the other male reporters had walked into [Ms. Roldan’s] office and had made some kind of 

safety concern she would have never told them to stop whining.” Id. 

70. After this January 4, 2018 conversation, Plaintiff testified that she was retaliated 

against by being “withheld from covering stories.” See Ex. C, Pl. Depo. at 212:25–214:7. 

 

1

 Hurricane Irma made landfall on September 10, 2017 in the Florida Keys. See National Oceanic 

and Atmospheric Administration, National Hurricane Center Tropical Cyclone Report for 

Hurricane Irma (available at https://www.nhc.noaa.gov/data/tcr/AL112017_Irma.pdf). 

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71. Plaintiff claims to have not been assigned to cover the Parkland High School 

shooting on February 14, 2018. See id. at 213:7–17. 

72. Plaintiff was assigned to cover the Parkland High School shooting, and reported on 

the shooting on February 14, 2018, the day of the shooting, as well as on subsequent days, 

including February 15th, 16th, 18th, and March 9th. See Declaration of Lisa Cilli, attached hereto 

as Exhibit O, at ¶ 4(a)–(e), and accompanying Screenshots of Harapeti Live Reports on the 

Parkland Shooting.2 

73. Plaintiff testified that she covered the Parkland hooting. See Ex. D, July 12th Pl. 

Depo. at 66:15–25 (“I covered nationally-related stories, Parkland, hurricanes, the Orlando 

shooting, front and center, always on top of the newscast . . . .” (emphasis added)). 

74. Plaintiff also admitted in a declaration that she covered the Parkland shooting, but 

claims that she was not assigned to cover the shooting on February 14, 2018 until later in the day 

at “around 5:00 P.M.” See Declaration of Silva Harapeti, Case No. 20-cv-20961 (DE 174), 

attached here as Exhibit P, at ¶¶ 8–9. 

75. Plaintiff could not identify any other instances of retaliation or discrimination in 

2018. See Ex. C, Pl. Depo. at 215:9–20. 

Plaintiff’s Resignation

76. In February of 2018, Plaintiff asked not to be scheduled on any future shifts. See 

Ex. C, Pl. Depo. at 141:17–142:9; 146:7–149:25; see also Ex. D, July 12th Pl. Depo. at 33:4–8. 

77. Plaintiff agreed to continue working for another several weeks after asking not to 

be scheduled, and continued working through March 17, 2018. See Ex. C, Pl. Depo. at 149:5–25; 

see also Ex. B, Plaintiff’s Personnel Documents, at CBS-Harapeti-0000001 (reflecting effective 

termination date of March 17, 2018). 

Alleged Joint Employers 

78. ViacomCBS and its corporate affiliate entities own and operate 29 local television 

stations in various markets throughout the United States. See Declaration of Joel Goldberg (DE 

52-1) at ¶ 5. These stations operate under the “CBS Television Stations” (“CBS/CTS”) business 

unit within ViacomCBS. Id.

 

2

 Complete videos of Plaintiff’s live reports regarding the Parkland High School Shooting on 

February 14th, 15th, 16th, 18th, and March 9th are available upon request. 

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79. In turn, the 29 local stations are owned and operated by separate legal entities. See 

Declaration of Joel Goldberg (DE 52-1) at ¶ 5. 

80. Defendant CBS Broadcasting Inc. owns and directly operates a number of CBSaffiliated television stations throughout the United States, including WCBS (New York), KCBS 

(Los Angeles), WBBM (Chicago), KPIX (San Francisco), KYW (Philadelphia), KDKA 

(Pittsburgh), WWJ (Detroit), WCCO (Minneapolis) and KCCW (Walker, Minnesota). See 

Declaration of Joel Goldberg (DE 52-1) at ¶ 6. 

81. Defendant CBS Broadcasting Inc. does not own or operate WFOR in any respect. 

See Declaration of Joel Goldberg (DE 52-1) at ¶ 6. 

82. Defendant CBS Corporation no longer exists—it ceased to exist in December of 

2019, when it merged with Viacom to create ViacomCBS. See Transcript of Evidentiary Hearing, 

Case No. 20-cv-20961 (Oct. 14, 2020), attached hereto as Exhibit Q, at 13:13–14:1. 

83. Although ViacomCBS—and its predecessor entity, CBS Corporation—operate the 

29 local television stations under the CBS/CTS Group, this operation is only with respect to highlevel guidance, including negotiating labor agreements and programming agreements. See Ex. Q, 

Evidentiary Hearing Transcript at 7:20–9:17. 

 

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Respectfully submitted this 20th day of October, 2021. 

BAKER & MCKENZIE LLP 

Attorneys for CBS Television Stations, Inc. 

 Sabadell Financial Center 

 1111 Brickell Avenue, Suite 1700 

 Miami, Florida 33131 

 Telephone: (305) 789-8900 

 Facsimile: (305) 789-8953 

 By: /s/ William V. Roppolo 

William V. Roppolo, Esq. 

Florida Bar No. 182850 

william.roppolo@bakermckenzie.com 

Benjamin C. Davis, Esq. 

Florida Bar No. 110734 

benjamin.davis@bakermckenzie.com 

– and – 

Blair J. Robinson (Pro Hac Vice) 

Paul C. Evans (Pro Hac Vice)

BAKER & MCKENZIE LLP 

452 Fifth Avenue 

New York, NY 10018 

Telephone: (212) 626-4100 

Facsimile: (212) 310-1632 

blair.robinson@bakermckenzie.com 

paul.evans@bakermckenzie.com 

 

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CERTIFICATE OF SERVICE 

I HEREBY CERTIFY that on October 20, 2021, I electronically filed the foregoing 

document with the Clerk of the Court using CM/ECF. I also certify that the foregoing document 

is being served this day on all counsel of record or pro se parties identified on the attached Service 

List in the manner specified, either via transmission of Notices of Electronic Filing generated by 

CM/ECF or in some other authorized manner for those counsel or parties who are not authorized 

to receive electronically Notices of Electronic Filing. 

By: /s/ Benjamin C. Davis 

 Benjamin C. Davis, Esq. 

 

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SERVICE LIST

SILVA HARAPETI, 

v. 

CBS TELEVISION STATIONS, INC., et al.,

CASE NO. 20-22995-CIV-Williams 

UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

Peter M. Hoogerwoerd, Esq. 

REMER & GEORGES-PIERRE, PLLC 

44 West Flagler Street 

Suite 2200 

Miami, Florida 33130 

pmh@rgpattorneys.com 

Phone: (305) 416-5000 

Facsimile: (305) 416-5005 

Attorneys for Plaintiff Silva Harapeti

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