Hmm, I can't speak for others, but I have done my own tests because I own both CPU's. I run my 3200+ Venice at 2.8GHz though... but 2.7GHz is more apt to be the 'norm'.
At stock speeds, a 1M Super Pi run wound up showing near identical scores for both my 3200+ and 820 D, so I wouldn't worry too much about losing performance by choosing the 'wrong' CPU. I'd be quicker to recommend the 820D only because it's a dual core, and that will speed up multi-media production, as long as you are using multi-threaded applications.
In the end, I'd go with the 820 D simply because it's Dual Core. If you don't care about Dual Core, get the 3200+ as it will likely allow smoother gaming performance. Oh, I should mention that if you do want the 820 D... you should get at least a better air cooler for it. The stock cooler is -rediculously- loud... the whiniest stock cooler I've ever come across.