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The man following Vin Scully’s lead; covering the Warriors, more

Hear from Joe Davis on the story behind following Vin Scully’s lead, a media roundtable about covering the Warriors, plus more Media Circus.

The phone rang at 5 p.m. ET last Tuesday and since the number had no caller ID, Joe Davis decided to let it pass onto voicemail.

But no voicemail ever arrived.

No big deal, Davis thought. Wrong number.

A couple of hours later, Davis’s phone rang again. Once again, Davis looked down, saw no caller ID and let the call go to voice mail. But this time, a voicemail did indeed pop up. So Davis, who prior to last week was best known as a Fox Sports college basketball and football broadcaster, checked his voicemail. And the voice coming from his phone left him speechless.

“Hi, Joe. This is Vin Scully,” said the voice recognizable as an American institution.

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“Joe, I’ve tried twice and have not been able to get a hold of you so I believe I have started our relationship 0-for-2.”

It’s a call Davis won’t soon forget from a man Davis will be working with next year. Last week the Dodgers announced they had hired the 27-year-old Davis to call 50 road television games on SportsNet LA in 2016 with analysts Orel Hershiser and Nomar Garciaparra. In the televised games that Scully and Davis don’t work, Charley Steiner will do play-by-play. Steiner will also do play-by-play on radio with Rick Monday.

The Dodgers are understandably protective of Scully, the singular greatest living sports broadcaster. The 87-year-old announced last August that next year will be his final one in the booth. Prior to speaking with Davis, I received a call from Dodgers management with the explicit design of dissuading me from writing any narrative that Davis was replacing Scully. There was no need to call. Scully is impossible to replace but the Dodgers brass clearly see great potential in Davis, who has already worked for ESPN and Fox Sports (calling regional MLB games) just six years after graduating from Beloit College in Wisconsin.

Davis eventually tracked down Scully with the help of Dodgers executive vice president and chief marketing officer Lon Rosen. The two spent five minutes talking by phone, where Scully welcomed Davis to the Dodger family and told the young broadcaster that he remembered what it was like to be a 20-something being called up to the “big club.”

“When you start a new job there is always nerves about it so it’s always nice to have someone reassure you that you will be welcome,” Davis said. “When it is the guy who is the greatest person whoever lived in the profession you dreamed of getting into, it was one of the coolest things to ever happen to me. When I finally got hold of him I said, ‘Vin, you are 1-for-3 now, which I’m pretty sure is a Hall of Fame average.’ He said he looked forward to meeting me on the road, or if I was at a home game, he said he’d hope to steal some of my time. I said, ‘Yeah, I think I can carve out a few minutes.’”

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The morning after he spoke with Scully, Steiner called him from Bradley University, where Steiner went to school as an undergrad and was doing some symposiums at the school. They spoke for 15 minutes or so, the first time he had interacted with Steiner. “He welcomed me the same way Vin did for him when he joined 10–12 years ago,” Davis said. “He delivered a lot of same sentiments Vin did. So before the news was even released, I had a couple of guys I admired reach out to me.”

Davis he does not have a specific schedule yet for his 50 games but he believes he will do the majority of the weekday road games and a good number of weekend games prior to September. He will also spend 10 spring training games in March, juggling between his Fox Sports college basketball schedule.

He currently lives in Grand Rapids, Mich., and he and his wife plan to relocate to Southern California prior to the 2017 season. He signed a multi-year deal with the Dodgers.

“Clearly there is a lot more context with this position than any other 50-game package I might take with a team because of how spectacular Vin Scully is,” said Davis. “He is the greatest there ever was and the greatest there ever will be and comparisons are going to be natural in a spot the year before he does what he said he will do. So I realized coming into this that those comparisons will be made and, sure, there is some intimidation to that. But I have one shot a living this life and going through this career, and I’m not going to make decisions based on fear and fear of failure and fear of criticism. I don’t think that’s the way to live. I looked at this as a remarkable opportunity to have a chance, whatever that chance or opportunity may be or manifest itself over the coming years, to be with an organization that is one of the best in all of sports. That outweighed the fear of taking a job where you would inevitably be compared to Vin.”

Rosen said the Dodgers embarked on a two-year process to add another broadcaster and were excited with the addition of Davis.  "I just think he has mature delivery, a unique delivery and he wants to learn,” Rosen said.

At 22, Davis was the youngest Double-A broadcaster in the country when he landed a job with the Rays’ affiliate in Montgomery, Ala. That led to regional work calling college basketball for ESPN. In 2012 he joined that network full-time and called a variety of sports including college baseball, basketball, football, hockey and softball as well as spot duty for Major League Baseball games on ESPN Radio. On Dec. 26, 2013, Davis called the network’s broadcast of the Poinsettia Bowl between Utah State and Northern Illinois, becoming the youngest person, at 25, to ever announce a bowl game for ESPN. The following year he moved to Fox, where his assignments have included college football, college basketball and regional MLB games on FS1. Davis said he called about 20 MLB games for Fox over the last two years.

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Davis said the first time he heard anything from the Dodgers was when Rosen contacted his agent, Josh Santry of IF Management, last fall. “We shot them a [broadcast] reel over and did not hear much after that,” Davis said. But the Dodgers were impressed, and Davis met with briefly with Rosen in early 2015. Things then picked up significant steam midway through this summer. By the fall, both sides knew it would happen. When asked which broadcasters have served as sounding boards over the years, Davis cited Cubs broadcaster Len Kasper, Brewers announcer Brian Anderson, ESPN’s Mike Tirico and Fox’s Joe Buck among the broadcasters. He also cited Santry for believing in him at a young age.  

“The best piece of advice Vin would tell you Red Barber ever gave him was you bring something to this booth that nobody else does and that is you,” Davis said. “Don’t water your wine by listening to so many other people and taking so much from those other people that you dilute who you are. Baseball is a long season and you are going to expose yourself if you are being someone that you are not. I am hopeful that my style is one that people will get used to. I don’t make it about me. It’s about the game. Then it’s about the analysts, especially in television. That’s the analysts medium.”

Davis played quarterback and wide receiver at Division III Beloit College and said one of the sales pitches made by the coaches was that he could call the team’s basketball games as a freshman.

“I didn’t have a lot of competition to get those reps,” he said, laughing, “so that turned out very well.”


( examines some of the most notable stories this week in sports media)

1. What’s it like having a front row seat to one of the best sports teams on the planet? With the Golden State Warriors owning a record of 11–0 as of this writing, I asked three members of the full-time press corps to answer a few questions via email.

The panel:

Rosalyn Gold-Onwude, Warriors sideline reporter, Comcast SportsNet Bay Area

Diamond Leung, Golden State Warriors beat writer for Bay Area News Group.

Ethan Strauss, ESPN NBA writer based in Oakland.

Richard Deitsch: What has been the best part of your job so far this year, and why?

Gold-Onwude: Definitely watching Steph be even better than last year, and on the road, hearing the other team’s fans marvel at his wizardry on the court.

Leung: Besides the Warriors often winning in blowouts to give me more time to write on deadline? It’s that every day, I go to work knowing a lot of readers will be paying attention to what’s going on with the team 24/7, 365. The thirst for information and analysis from Warriors fans is insatiable. And because of the team’s success, there is an increased demand from a national audience for wall-to-wall coverage of a championship team and what Stephen Curry does and says. Taking on the responsibility of breaking news and telling stories about that kind of team is what drew me into this profession. Oh, and having a seat at every game to watch Curry shoot is fairly entertaining.

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Strauss:I enjoyed seeing Curry’s 53-point game in person. The performance was majestic, and then to cap it off, you got to step into New Orleans on Halloween night. The job gives you experiences you’ll remember forever and takes you to places you might not see otherwise.

The best part that isn’t pegged to a moment? I enjoy seeing an organization run by competent people, working together. I’m usually averse to the cliché of taking life lessons from sports, but I think I’ve learned something from watching how this operation runs. Steve Kerr and Bob Myers demonstrate the power of deferential leadership. They don’t fret about who gets credit, and try to encourage contributions from everyone. That ethos was epitomized by Kerr publicly praising 28-year old assistant Nick U’Ren for giving him the Finals lineup change idea. Seeing things like this led me to believe that ego can be corrosive to an organization, and its subversion can be vital.

RD: How would you assess your relationship as a media person with the Warriors players and front office, and why?

Gold-Onwude: In my second year as the team sideline reporter, I feel I have strong relationships with the players. I've worked hard to build rapport and trust with them. I've been fortunate to walk into a team of professional men. They treat me with respect, are usually accessible if I have a question, and in Year 2 we have more chemistry to crack a joke here and there. One thing I appreciate so far is that they continue to speak with media not just when things are going well but also during moments of adversity. Of course there hasn't been a ton of adversity but I appreciated that maturity last year when asking about going down 2–1 in playoffs, or shooting slumps, or injuries etc. The front office is very healthy and I feel that trickles down to the rest of the organization. For example, [president and COO] Rick Welts wrote me a nice email to congratulate me on work I did last year. He took the time to write a note to the team’s first-year sideline reporter. I mean, he certainly doesn’t have to do that, nor does he probably have the time. There is a connection even to ownership: Joe Lacob has long been a supporter of Stanford athletics and basketball (where I played) and always has a warm hello to give. There is a sense of connectivity. I feel supported not only by our CSN broadcast team but by Warriors corporate staff as well.

Leung: I consider it to be very professional in my two years on the beat. The Warriors have a number of players comfortable with expressing themselves as well as media-friendly executives. When they do or say something that piques interest, I write about it. I build good working relationships along the way with the understanding that my responsibility is to my readers. If there’s perhaps an uncomfortable topic to address, they’ll get an opportunity to be interviewed about it and have their side presented fairly. If that means me showing up at speaking engagements or listening in for quotes on radio interviews, I’ll do that, too. These days, the majority of the story angles are positive.

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Strauss:It’s certainly less adversarial than it was because there’s far less to criticize. It wasn’t a comfortable place to show up in the final throes of the Mark Jackson era. Certain assistants felt insecure about their contributions and lashed out at criticism. Now, the atmosphere is lighter and more educational. When people are doing their jobs well, they’re more inclined to open up about why and how.

I don’t have a general assessment on my relationship with the players because individuals are different. They’re a mostly cordial group, though. Bogut and Iguodala are sharp guys who happen to be hilariously grumpy. Bogut will banter with you. So will Iguodala, but he won’t say your name. I think years of overly negative coverage in Philadelphia might have influenced him to keep media at a remove. Curry is polite and patient, with a sense of humor that expresses itself outside the interview setting. Draymond is a verbal savant. He truly has a gift for off the cuff analogies and descriptions. For example, I loved when he conveyed that Klay’s 37point quarter wasn’t like a video game because video games are too realistic for something like that to happen. Klay’s a bit shy, but has his outbursts of candor. Between those outbursts, he’s loathe to do media, but soldiers through. A favorite Klay trick of mine is how, when media enters the locker room, he often shrouds his face in a newspaper. If you’re wondering who’s still buying dead tree news, it’s Klay Thompson.

As for the front office, they’re fairly open and frank. Nobody’s flat out lied to me—as far as I know. Myers is a listener—he likes to know your opinion, because he’s always canvassing opinions. Assistant GM Kirk Lacob has a dry, wiseass sense of humor. So does assistant GM Travis Schlenk, but he shuns all publicity, and I’m only mentioning him here to annoy him. Jerry West is blunt while conveying nuances about the game that I’d never notice on my own.  

Praising Kerr might sound like an affront to journalistic objectivity, but I think he’s objectively great to deal with. There aren’t many coaches with whom you can discuss Arabic dialects one second, and motion offense the next. Kerr was raised by academics, so he’s inclined to share and educate -- more than most coaches, I think. Kerr’s a Popovich disciple, but his public persona stands in contrast to Pop’s opacity. That’s the difference between an academic background and a military background, I suppose.

RD: What kind of access do you have to Steph Curry on a daily basis?

Gold-Onwude: I have the same access to Steph Curry as any other media member which is whenever he is available for shootaround, practice, or postgame scrums. With his growing popularity and media requests, there are days he is unavailable or only for certain media outlets (usually national). I’ve only covered the NBA for a year but what I’ve learned is your access to one-on-one convos starts with your ability to build relationships. The better your relationship, the more likely you’re able to just walk over to a guy and say, ‘Hey, can I talk with you real quick?’ And he may say yes. I feel I have that relationship with Steph. I try to pick my battles on when to talk to him, understanding how much media burden he shoulders. I understand a guy may just not be in the mood to talk and respect that. I try not to keep guys too long during the conversation by having my game plan ready and organized. I am transparent about how I plan to use the information in order to keep that trust. Trust is everything. Even on the days I don't have questions for a player, I always say hello because too often reporters only talk to players when they want something and that makes the relationship too transactional.

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​​​Leung: The media gets to interview him at least once before every game or at the start of a back-to-back. He doesn’t usually do interviews in the media access period immediately before a game. He is on some days unavailable for group interviews while doing national TV interviews instead. But the access is good. He’ll accommodate one-on-one interviews. He’ll answer postgame questions with the team’s public relations staff keeping interviews to a reasonable length. It helps that because there usually isn’t an overwhelming number of media members surrounding him, every reporter is able to comfortably ask questions.

Strauss: There’s less Steph access these days, but he’s still quite accessible. It’s not like he’ll tell you to scram if you go up and chat with him. He’s available after every game, and most road practices. He doesn’t tend to give killer quotes, but he’s getting more expressive these days. Winning a billion games will add some comfort to your public interactions.

RD: What has been your favorite interaction with Curry, and why?

Gold-Onwude: As I got to know the Warriors, I realize there are different types of questions for different players. I know I can give Steph a more cerebral question and he will actually give it thought and a unique answer. I appreciate that so much. But Steph is way more interesting and funny when the cameras are off. A lot of the fun happens on the road. This year we spoke (bad) Spanish together in the locker room and pretended to do an intrevista (interview). Last year he tried to crack on my socks, saying they looked super thin and “Mom-ish.” (I’ve since upgraded my sock game.) He’s had serious critique of my shooting form and even imitated it. And during media day this season he pretended to post me up with a pretend basketball and tried to get to the rim for a shot (which I pretend blocked).

Leung: Occasionally when it’s just the two of us, he’ll greet me as pro wrestler Diamond Dallas Page using what appears to be the voice of a wrestling announcer. Most memorably to me, he even did the routine in the moments after winning the NBA championship. I smile and never seem to have a comeback. It humanizes Curry. We both are ultra-competitive and work hard at our craft while going through the rigors of the NBA travel schedule. Maybe at heart we’re just a couple of goofy wrestling fans, too?

Strauss:I liked this reminder of how Curry is a sanguine sort, prone to optimism. In Game 3 of last year’s first round series against the Pelicans, the Warriors were down 17 with six minutes left. They were dead, in other words. So of course they come roaring back to win, thanks in part to an iconic Curry three-pointer that he hits over half the population of New Orleans. In the jubilant locker room, David Lee asks if I thought they were going to lose. When I say, “yes,” Curry interjects, “You really thought we were going to lose?!” He couldn’t believe it. And yes, I think he was serious. Athletes, they’re different from us.

Honorable mention events: My yelling “turnover!” whenever he misses the laundry basket with a jersey toss (Because I’m a jerk), the time I hit a golf ball well despite his low expectations, the time he sneak attack sprayed me with deodorant as I interrogated David Lee about something. Steph’s achingly polite, but he’s not above roasting me. I think I bring that out of people.

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RD: What is the most remarkable thing you have seen at a practice or shootaround in your years covering the team, and why?

Gold-Onwude: This year during shootaround before the Clippers game, I had the chance to watch Steph work with his trainer Brandon Payne on ball drills. He never stops working. Steph did shootaround, then he did his usual extensive shooting routine afterward, and then did more extensive ball handling drill with Payne. He is usually the last one off the court. Almost every move we are excited to see Steph make on the court on game day, he has already practiced before. But on this day, to actually see him move his hands to bounce and catch basketballs and tennis balls and touch light sticks, while wearing vision-limiting-goggles all at the same time, and to see how quickly his hands moved, like a blur, it was nuts! He’s a Jedi with his hand-eye-brain coordination and as a former athlete myself, I respect his work ethic tremendously.

Leung: After a shootaround in Memphis last season, the team held a half-court shooting contest. What was different about this one was everyone in the traveling party took part. There were team trainers, a public relations official and coaches tossing up shots along with the players. Andre Iguodala drew laughs when he imitated the head athletic trainer’s awkward shooting form. And it was Steve Kerr at midcourt helping pass them the basketballs. As a rookie coach, he found a way to keep things loose, make everyone in the organization feel important, and win the championship.

Strauss: Curry’s post-practice shooting routine is the most remarkable thing we’ve gotten numb to. As for specific events, I enjoyed watching Steve Kerr nearly kick a halfcourt shot in. Apparently he’s actually pulled it off (but I’d like to see the proof).​

RD: The Warriors are often dubbed as the most media friendly team in the league. As someone who covers the team on a day to day basis, why do you think they have earned that tag?

Gold-Onwude: Well, I think it starts with a great PR staff. Raymond Ridder and his staff are prepared, organized, accessible, engaged and proactive. Information packets/sheets/notes are always on time and thorough. I think he does a good job of managing all the “asks” he gets from national to local media. I’m sure that wasn’t easy with the media circus at NBA Finals last year. In a league of many egos, the PR position isn’t easy. Some PR guys are afraid to bother their players. I think Raymond has built a rapport with the guys so they take his requests seriously. I feel lucky that my first experience with the NBA has been under his watch. He has helped to guide me and helped me plan for what to expect and I appreciate him.

Leung: It starts with Raymond Ridder, the team’s long-time PR director. As a loyal employee during the lean years, he knows what it’s like to have to work hard for positive press. That isn’t so much an issue any longer, but he hasn’t changed. Raymond rolls out the red carpet when media members come to town and has given great access to bloggers. He suggests unique story ideas, accommodates interviews for them, and provides stats you can’t find anywhere else.  When we have a disagreement, we can talk about it and move on. Above all, he understands that relationships matter. It’s no accident that Curry also mentioned public relations officials Dan Martinez, Lisa Goodwin, Brett Winkler and Matt de Nesnera in his MVP speech. They all do a great job.

Strauss:The staff prides itself on attentiveness, PR head Raymond Ridder is indefatigable and the players comport themselves well in public. Also, they’ve had so much practice trying to wring positive coverage out of this formerly awful team. It’s like Raymond’s been swinging with the batting donut on for years. Now the weight has been lifted and then some.

There’s another aspect to this, though: Kerr allows his assistants to talk. Some coaches don’t, fearing that they might be undermined by their subordinates. Kerr’s secure enough in his position to ignore the paranoia that’s usually endemic to coaching.

RD: What is a realistic regular-season win count for this team, and why?

Gold-Onwude: I don’t even know anymore. I thought maybe they would lose eight or so more games than last season but with the way they’ve started, I don’t know. I’m just enjoying the ride and very thankful for my up-close seat to fun basketball. 

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Leung: Seventy is a realistic number, assuming the Warriors stay relatively healthy. They won 67 games last year, and this team clearly has improved and isn’t resting on its laurels. The Warriors can perhaps approach the 72-win mark, but they won’t necessarily go all out to break the Bulls’ NBA record. Assuming Kerr returns to the bench later this season, I don’t see him or his staff devoting the energy and risking the health of players late in the season to chase 72. If the Warriors got close, it would be unlikely that playoff seeding or home court advantage would be factors at that stage of the season. They are laser-focused on preparing for the playoffs and winning a second straight championship.

Strauss: I’ll guess 66 wins, but won’t be shocked if they do better than 72. The latter figure would exceed my expectations because A) It requires an extreme combination of health and drive B) They don’t actually need to win so many games. A title is the goal, and in keeping with that, Golden State will rest star players on occasion. Blame Steve Kerr’s Spurs roots, I guess.

2.The Late Show with Stephen Colbert gets the coveted post-Super Bowl spot this year. A live broadcast of the talk show will air immediately following Super Bowl 50 on Feb. 7, 2016. CBS said The Late Show will be the first late night series ever to air in the post-Super Bowl slot.

2a. CBS rules analyst Mike Carey has taken a lot of social media abuse since he was hired by the network but he nailed a crucial play late in the fourth quarter of the Patriots’ win over the Giants. Carey immediately called an Eli Manning-to-Odell Beckham pass incomplete after it was ruled a touchdown on the field. The rules analyst explained cogently that Beckham failed to control the ball long enough to become a runner after the getting his feet down following the catch. Good moment for him.

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2b. CBS coverage of Alabama’s victory over LSU (30–16) in primetime on Nov. 7 was the highest-rated and most-watched college football game to date for the 2015 season, drawing 11.1 million viewers.

2c. Last week’s College GameDay show from Tuscaloosa averaged 2,233,000 viewers, the most-watched regular season College GameDay since the show expanded to three hours in 2013.

2d. NFL Network staffers Marshall Faulk, Michael Irvin, Mark Kriegel, Kurt Warner and Steve Wyche discussed how players deal with media in the locker room off the recent events with Cowboys wide receiver Dez Bryant.

2e. Warner on Johnny Manziel: “He doesn’t make the easy plays and he doesn’t read the field the way you want a franchise quarterback to read the field. You have to make the easy throws. He doesn’t do that. He makes some special throws but you just can’t live in that world.”

2f. ESPN/ABC analyst Kirk Hebrstreit apologized to Baylor defensive back Terrell Burt on Sunday via Twitter. Thoughtful exchange.

3. The 29th episode of the Sports Illustrated Media Podcast features ESPN NBA analyst Jeff Van Gundy, who partners with play by play announcer Mike Breen and fellow analyst Mark Jackson to call The NBA Finals on ABC.

In this episode, Van Gundy discusses how Marv Albert helped him break into broadcasting, how he prepares for each game, the reporters he reads to stay current, how honest NBA broadcasters can be on air, how often he hears from the league about something he says, his reaction to Howard Stern calling him out after Van Gundy mocked him for leaving a Knicks game early, why Chris Paul would make for an excellent broadcaster, what lines he can’t cross because of ESPN’s business interests, how he approaches calling his brother Stan Van Gundy's games, what his relationship would be with the local media if he returned to coaching and much more. 

A reminder: you can subscribe to the podcast on iTunes and Stitcher, and you can view all of SI's podcasts here. If you have any feedback, questions or suggestions, please comment here or tweet at me.

4. Sports pieces of note:

• Profile writing at its best. SI’s Tim Layden on Michael Phelps.

• SB Nation’s PFT Commenter attended the GOP Debate.

Cosmopolitan’s Abigal Pesta had a revealing piece on Glory Johnson and the dissolution of her marriage to Brittney Griner.

The New York Times’s Chris Clarey on those impacted by allegations of Russian doping.

• The MMQB’s Jenny Vrentas wrote an interesting piece on NFL teams using the science of sleep for better performance.

• From ESPN’s Brett Forrest: How the world's biggest bookie was snared at last year's WSOP ... and walked a free man.

• SI’s Peter King had a cool mini-oral history on the 2007 regular-season game between the Giants-Pats.

• From Indianapolis Star columnist Gregg Doyel: LeBron James sends a letter to Emanuel Duncan.

Non sports pieces of note:

• Financial Times reporter Simon Kuper, writing from inside the Stade de France on Friday.

• Via The Nation: What I Discovered From Interviewing Imprisoned ISIS Fighters.

• A donor meets the young woman who saved his life: This Michael Vitez for Yahoo! will make you feel good about people:

• The covers of French papers on Saturday morning.

• From Charles P. Pierce: There is only one way to defeat ISIS—and it starts with money.

• From Time Magazine: A special report on the Charleston Shooting: What it takes to forgive.

A World War II romance, 70 years later.

5. The late Eagles owner Leonard Tose was the subject of a 30 for 30 short from director Mike Tollin and producer Trey Wingo.

5a. Vice interviewed Hajo Seppelt, the German investigative journalist and documentarian whose work broke the Russian sports doping scandal.

5b.The Men In Blazers chaps held a BlazerCon last weekend

5c. Former SI and ESPN writer Jeff Bradley on being an out-of-work sportswriter.

5d.Fast Company looked at Bleacher Report’s social-first plan.

5e. HBO Real Sports Bryant Gumbel tells Newsday’s Neil Best that “so much of what passes for sports coverage is so sycophantic it's nauseating.”

5f. MSG Networks has added Liberty forward Swin Cash as a Knicks studio analyst for select games during the 2015-16 season. Cash has broadcasting experience with CBS Sports Network, ESPN, NBA TV and NBCSN.

5g. The Big Lead website reported last week that ESPN settled a sexual harassment claim involving longtime NFL host Chris Berman and a makeup artist who had worked at ESPN as an independent contractor. Asked last week by Sports Illustrated if ESPN president John Skipper or ESPN executive vice president of production and programming John Wildhack wished to comment on the TBL report, ESPN PR said “they respectfully decline any comment beyond the statement issued which is ‘our thorough investigation revealed the harassment claims had no merit. We settled it solely to save a considerable amount of time and litigation costs.’”