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Exhibit 15 A TT .....•..• c" • •• q ...... ""....• i(:ji~. ..",.·:.~.E"ti~r~~S (!.)' .~.". I. January 1, 1993 Chicago, IL, its suburbs, and northwest 1.7 million Tribune Indiana 2. NYI September 8, 1992 five boroughs ofNew York, NY 1.5 million Time Warner Cable 3. Texas Cable News January 1, 1999 Dallas-Fort Worth, Houston, and San 1.3 million Antonio 4. March 1992 New England communities 2.8 million AT&T Broadband and the Hearst Corporation 5. NorthWest Cable News December 18, 1995 , , , western 2.3 million Belo , , and northern 6. News 12 Long Island December 15, 1986 Nassau and Suffolk counties 800,000 Rainbow Media Holdings, Inc. 7. News 8 Austin September 13, 1999 Central Texas 300,000 Time Warner Cable 8. NewsChannel 8 October 7, 1991 Washington, D.C. metro area 1.1 million Allbritton Communications Co. 9. News 14 Carolina late 2001 Raleigh, Durham, Chapel Hill, 448,000 Time Warner Cable Fayetteville, Goldsboro, and surrounding areas 10. RNews April 22, 1990 An 11 county area in upstate New York 325,000 Time Warner Cable II. Capital News 9 October 11, 2002 Albany, NY 325,000 Time Warner Cable 12. BayNews 9 September 24, 1997 Tampa, FL 900,000 Time Warner Cable 13. February 24, 1997 Norfolk, VA area 394,000 Belo, Landmark Communications, and Cox 14. Arizona News Channel November 4, 1996 Phoenix, AZ area 420,000 MAC American Communications and Cox 15. NewsWatch on Channel 15 October 1998 New Orleans, LA area 326,000 Belo 16. Regional News Network December 1995 New York, Connecticut, and New Jersey 2.3 million New Mass Media 17. Six News Now July 17, 1995 Southwestern Florida 200,000 Sarasota Herald Tribune 18. Florida's News Channel September 28, 1998 Statewide 2.1 million privately held 19. Pittsburgh Cable News January 1, 1994 Pittsburgh, PA 650,000 Cox Channel 20. Ohio News Network May 1, 1997 Statewide 680,000 Dispatch Production, Inc. 2I. NewsChannel 5+ September 1996 Nashville, TN area 300,000 + Landmark Communications ofTennessee, Inc. 22. San Diego's News Channel October 1996 San Diego, CA market 97% cable McGraw-Hill Broadcasting, 15 penetration Cox, TCI, and Daniel in market Cablevision 23. Central Florida News 13 October 29, 1997 Central Florida 465,000 Time Warner and Tribune Declaration of Kimberly D. Croley

I, Kimberly D. Croley, hereby declare as follows:

1. I am employed as a Legal Assistant at Shaw Pittman LLP, 2300 N Street, NW, Washington, D.C. 20037. I have worked as a legal assistant at Shaw Pittman for over two years and previously worked for almost four years as a legal assistant at Fisher Wayland Cooper Leader & Zaragoza LLP (which merged into Shaw Pittman). During my employment at Shaw Pittman and Fisher Wayland, I have worked in the communications area and have conducted research on a number ofprojects.

2. I prepared the exhibit entitled "Local Cable News Channels." I began by researching local cable news channels on the Internet, searching Google.com, and then found local cable news channels listed on TVRadioWorld.com and also a list compiled by the Radio and Television News Directors Foundation (www.rtnda.org/resources/nonstopnews/). I also found information on a Time Warner cable website (www.twcnc.com) and on a website maintained by Belo (www.belo.com). After compiling a list oflocal cable news channels, I verified that the information was still accurate by looking up those channels listed. Ifthe channels were no longer active, I did not include them in the research. This research was conducted from October 30, 2002 - November 8, 2002.

Executed under penalty ofperjury this~ day ofDecember 2002.