Dan J. Alpert 2120 N

The Law Office of

Dan J. Alpert 2120 N. 21st Rd. Arlington, VA 22201 [email protected] web site: COMMLAW.TV

(703) 243-8690 (703) 539-5418 (FAX) December 14, 2020

Ms. Marlene Dortch Secretary Federal Communications Commission 45 L St., NE Washington, DC 20554

Re: Estate of George V. Domerese Timothy Domerese, Administrator KMTL(AM), Sherwood, Arkansas Facility ID No. 23871 K249FE, Sherwood, AR Facility ID No. 201566 File No. 0000105222 Dear Ms. Dortch:

Transmitted, herewith, on behalf of the Estate of George V. Domerese, Timothy Domerese, Administrator, is its response to the Letter of Inquiry dated October 14, 2020, with respect to the pending application for renewal of license for Station KMTL(AM), and FM Translator K249FE.1 If there are any questions, please contact this office.

Very truly yours,

/Dan J. Alpert/

Dan J. Alpert

Counsel for Estate of George V. Domerese, Timothy Domerese, Administrator cc: Tom Hutton, Esq. tom.hutton@fcc Heather Dixon, Esq. heather.dixon@fcc. [email protected] [email protected]

1 By email dated November 13, 2020 from Heather Dixon, Attorney Advisor, Audio Division, an extension of time within to respond to the Letter of Inquiry was granted until December 13, 2020. Because December 13, 2020 fell on a Sunday, this response is being filed on the next business day, on December 14, 2020. DECLARATION

I, Timothy Domerese, hereby state as follows: I am the Administrator of the Estate of George V. Domerese. George V. Domerese was the owner of Station KMTL since its inception in 1983 until his death on February 27, 2017. The Order Appointing Administrator, appointing me as Administrator, is attached hereto as Attachment A. The Estate filed for and was granted an FM Translator for use in conjunction with the operation on the Station, Facility No. 201566. The construction permit for the facility previously known as K249FE was granted on January 1, 2018. File No. BNPFT-20171220ACT. The FM Translator facility began operation on or about May 31, 2019. The license to cover for the modified facility was granted on June 3, 2019. File No. BLFT-20190531AAO. The facilities of the FM Translator recently were modified to address interference concerns. The call sign of the FM Translator permit is K250CF. LMS File No. 129457. I do not have a radio background, so since the death of my father, Station KMTL and eventually its FM translator are operated with the assistance of Radio La Raza, LLC and MG Radio Communications, LLC. The principals who report to me about the Stations are Carlos Morón and Albino Gutierrez. The station is marketed as “La Raza 750AM-97.7FM”.” Attachments G and L. The Commission’s Inquiry Letter issued on October 14, 2020 is attached hereto as Attachment B. The FCC has requested information concerning the past and current operational status of Station KMTL and its associated translator. These matters are addressed as follows: KMTL(AM) Operational Status. We hereby request that the Estate provide a narrative statement that indicates KMTL(AM)’s operational status between January 1, 2020, and the present. Specifically, the Estate should indicate the dates on which KMTL(AM) has been silent, has operated with its licensed facilities, has operated at reduced power pursuant to STA, or has operated with technical parameters other than those specified in its license or its STA. The Estate should submit copies of all leases, personnel records, engineering records, station logs, invoices, bills (including utility bills), checks written or received, credit card charges, wire transfers or deposits of funds relating to KMTL(AM)’s operation. In addition, the Estate must include pictures of KMTL(AM)’s studio facilities and transmission facilities during this timeframe. The information being requested by the Commission’s Inquiry Letter is attached hereto as Attachments C - N. Since the land at which the tower and studios are located is owned by the Domerese Estate, there are no “leases.” There are no personnel records. Engineering records are attached in the form of declarations attached as Attachment D and E. Station issues/programs lists are attached as Attachment F. Invoices issued on behalf of the station are attached as Attachment G. Utility bills that are available are attached as Attachment H. Credit card receipts for FCC regulatory fees and FCC filing fees are attached as Attachment I. There are no wire transfer receipts. There are no documents available for deposit of funds. Photographs of the KMTL transmitter site, transmission equipment, and studio that have been requested are attached as Attachment J. A copy of the Tax Bill for the land for the transmitter site, owed by the George V. Domerese Trust, is attached as Attachment K. A copy of the station’s broadcast schedule is attached as Attachment L. Other information concerning operation of the Station is attached as Attachments M - O. Based upon the information that has been provided by Station personnel, although Station KMTL generally was able to maintain broadcast operations, it appears that due to equipment malfunction, Station KMTL was silent many times in March, April, and May 2020 for periods of time. Repairs to the Station’s transmitter had to be undertaken each time the equipment malfunctioned. The equipment had to be removed and sent away for more extensive repairs in October and November 2020. As reported to the FCC, the station officially was off the air from October 17, 2020 – November 25, 2020. Attachment P. While the KMTL transmitter still is unable to return to full-power operations, it is hoped that the most recent transmitter repair will allow the Station to operate on a more reliable basis. K249FE Programming. We request that the Estate provide a narrative statement that indicates the dates between January 1, 2020, and the present on which K249FE originated programming. The narrative statement should also identify the dates between January 1, 2020, and the present on which K249FE rebroadcast the signal of a primary station other than KMTL(AM). The Estate must include the call signs of these primary stations and note the dates on which K249FE broadcast their signals. The Estate should submit all documents in its possession relating to K249FE’s rebroadcast of the signals of any stations other than KMTL(AM). As explained in Attachments D, M - O, during several times when Station KMTL was silent due to equipment problems, a Station employee improperly kept the FM Translator operational, and placed on the FM Translator programming originating from nearby Station KTUV, which is another station that personnel from the Station is providing assistance. This error occurred on repeated occasions. FM Translators do not keep logs. In this case, no logs (automated or otherwise) showing the programming broadcast on K249FE exist. Although no authoritative complete list exists, based on the information provided by former Station employee Armando Gonzales, it is certain that programming from Station KTUV was improperly broadcast on Station K249FE on March 26, 2020; May 6, 2020; and May 14, 2020. It is possible that this improper broadcast occurred on other occasions when the KMTL transmitter was offline. As explained in Attachment M, Attachment N, and Attachment O, this improper programming was broadcast on Station K249FE due to Mr. Gonzales’ mistaken connection to K249FE of a computer used only for KTUV programming. The statement from Mr. Gonzales was received only in the form of an email from the employee that was fired due to allowing the impermissible programming to be placed on the translator. The following steps have been taken to ensure that this error cannot again occur in the future. First, the employee that principally was responsible for the violation of the Commission’s Rules has already been terminated. Secondly, a Compliance Handbook is being prepared that is being distributed to Mr. Morón and Mr. Gutierrez and will be used to train future Station employees, explaining the FCC FM Translator Rules, and the restriction contained in this particular license which restricts Station K250CF to only rebroadcasting Station KMTL. Third, a logging system now will be established, and a log entry will be made on a daily basis, whereby Station personnel now will confirm on a daily basis that the Station being rebroadcast on Station K250CF is KMTL. Fourth, steps will be taken to make it so Station K250CE equipment is not capable of receiving any Primary Station other than KMTL. Finally, the logs will be reviewed by the Station’s Chief Engineer on a weekly basis. In this manner, it is anticipated that this error will not, even conceivably, ever occur again. K249FE Power Levels. We request that the Estate provide a narrative statement regarding the TPO(s) and ERP(s) at which K249FE has operated since January 2020. The Estate must also submit station logs and/or records, and any other documents that corroborate the Estate’s response. The authorized power for Station K249FE was 250 watts ERP/400 watts TPO. It has been confirmed with Albino Gutierrez that the Station has at all times operated with the proper Transmitter Power Outputs and Effective Radiated Powers. Attachment N. The station currently is silent, due to an interference complaint, but has been granted permission to change frequencies and is about to begin operation on Channel 250. The services of Tom Bruce, of Canyon Lake Broadcasting, were utilized to determine the appropriate ERP and TPO for Station K249FE/K250CE. A copy and confirmation of the calculations is attached hereto as Attachment E. As noted above, FM Translators do not maintain logs. Therefore, logs have not been maintained in the past. However, as a part of its new compliance regimen, beginning immediately when it starts operation, Station K250CE shall voluntarily maintain on a weekly basis log entry of its TPO, for future review by the Commission.

Attachment A

Attachment B Federal Communications Commission Washington, D.C. 20554 October 14, 2020

In Reply Refer to: 1800B3-HOD SENT BY EMAIL TO [email protected]

Dan J. Alpert, Esq. 2120 N. 21st Road Arlington, VA 22201 In re: Estate of George V. Domerese, Timothy Domerese, Administrator KMTL(AM), Sherwood, Arkansas Facility ID No. 23871 K249FE, Sherwood, Arkansas Facility ID No. 201566 File No. 0000105222 Letter of Inquiry

Dear Licensee: This letter concerns KMTL(AM), Sherwood, Arkansas, and its associated FM translator, K249FE, Sherwood, Arkansas, both of which are licensed to the Estate of George V. Domerese, Timothy Domerese, Administrator (Estate). We have before us informal objections1 to the Estate’s application to renew the licenses for KMTL(AM) and K249FE (Renewal Application).2 Pursuant to Section 73.1015 of the Commission’s Rules (Rules),3 the Estate is hereby required to provide the information and materials discussed herein, and to do so within thirty days of the date of this letter.

Background. The Estate became the licensee of KMTL(AM) on August 11, 2017.4 On March 1, 2018, KMTL(AM) went silent.5 The Estate later requested special temporary authority (STA) for KMTL(AM) to remain silent.6 Staff granted this STA request on July 27, 2018.7 On

1 Pleading File Nos. 0000114088, 0000116629. 2 File No. 0000105222. 3 47 CFR § 73.1015. 4 See File No. BAL-20170726AUC; Broadcast Actions, Report No. 49050, Public Notice (Aug. 16, 2017); Consummation Notice (filed Aug. 28, 2017). 5 See BLSTA-20180712AAD. 6 Id. 7 Estate of George V. Domerese, Timothy Domerese, Administrator, Letter Order (MB July 27, 2018). February 26, 2019, KMTL(AM) returned to the air pursuant to an STA authorizing reduced power operations.8 It continues to operate at reduced power.9

During a filing window opened as part of the efforts to revitalize the AM radio service, the Estate applied for and was granted a construction permit for a new cross-service FM translator for KMTL(AM).10 On June 3, 2019, we issued a license for this translator—K249FE—to the Estate.11 The license authorizes K249FE to operate on Channel 249 (97.7 MHz) and with a transmitter output power (TPO) of 400 watts and an effective radiated power (ERP) of 250 watts. The K249FE license includes the following conditions: (1) “[T]his facility may only, in perpetuity, be used to rebroadcast the authorized facilities of the AM primary station set forth in this construction permit,” (2) “[I]f the authorization of the AM primary station set forth in this construction permit is rescinded, revoked, surrendered, subject to special temporary authorization (STA) to remain silent, or is otherwise suspended from operation, the authorization of this cross- service FM translator station shall likewise be rescinded, revoked, surrendered, silent for the duration of the AM primary station’s STA to remain silent, or suspended from operation.” The K249FE license also specifies that any violations of these conditions “shall result in the rescission of the grant of this authorization and the dismissal, with prejudice, of the associated application and, if applicable, cancellation of the associated construction permit.”

On January 21, 2020, the Estate filed the Renewal Application. On May 20, 2020, we received an informal objection to the Renewal Application.12 The objection alleges that KMTL(AM) has been silent without STA in violation of section 74.1263(c) of the Rules.13 It also asserts that K249FE has continued to operate during KMTL(AM)’s silence. As a result, the objection argues that K249FE has failed to comply with the conditions placed on its license, and has either originated programming in violation of sections 74.1231(b) and 74.1263(b),14 or rebroadcast the signal of a different AM station—KTUV(AM), Little Rock, Arkansas—in violation of section 74.1231(e).15 Finally, the objection alleges that K249FE has been operating over power in violation of section 74.1251(b)(7) of the Rules.16

8 See File No. BSTA-20190225ABA. See also Estate of George V. Domerese, Timothy Domerese, Administrator, Letter Order (MB Feb. 26, 2019). 9 See File Nos. BSTA-20191120AAQ, BESTA-20200522AAA. See also Estate of George V. Domerese, Timothy Domerese, Administrator, Letter Order (MB Nov. 25, 2019); Estate of George V. Domerese, Timothy Domerese, Administrator, Letter Order (MB June 10, 2020). 10 File No. BNPFT- 20170802ADG. 11 File No. BLFT-20190531AAO. See also Broadcast Actions, Report No. 49502, Public Notice (MB June 6, 2019). 12 Pleading File No. 0000114088. 13 47 CFR § 74.1263(c) (requiring Commission approval if an FM translator discontinues operations “for 30 or more consecutive days”). 14 47 CFR §§ 74.1231(b), and 74.1263(b) (prohibiting an FM translator station from originating programming while its primary station is off the air, except under limited circumstances). 15 47 CFR § 74.1231(e) (“An FM translator shall not deliberately retransmit the signals of any station other than the station it is authorized to retransmit.”). 16 47 CFR § 74.1251(b)(7) (requiring “formal application on FCC Form 349” for “[a]ny increase of authorized effective radiated power”).

2 The Estate responded to the objection on June 10, 2020. Among other things, the Estate argued that the allegations were unsubstantiated.17 The objector (and another individual) submitted a pleading that serves as the objector’s reply and the other individual’s informal objection to the Renewal Application.18 Accompanying this pleading were eight videos— recorded between March 26, 2020, and June 8, 2020, a document listing the locations at which the videos were recorded, and a hyperlink to a website where the videos could be found and downloaded. The information contained in these videos is summarized below.

Date Location of Recording KMTL(AM) KTUV(AM) K249FE 3/26/20 Stagecoach Road and Sibley Hole Static Operational Operational Audio is the same Road, Alexander, Arkansas as audio on KTUV(AM). 5/6/20 Calais Cove and Bascom Drive, Static Operational Operational Audio is the same Little Rock, Arkansas as audio on KTUV(AM). 5/14/20 Stagecoach Road and Ottercreek, Static Operational Operational Audio is the same Little Rock, Arkansas as audio on KTUV(AM). 5/20/20 Mabelvale Plaza and I-30, Little Static Static Operational. Rock, Arkansas 5/21/20 Warden Rd and Somers Ave, Static Static Static Sherwood, Arkansas 5/23/20 Stagecoach Road and Briner Static Operational. Audio includes Circle, Little Rock, Arkansas station identification for “KMTL 760 AM and 97.7 FM.” 5/30/20 Bass Pro Road, Little Rock, Static Static Operational. Arkansas 6/8/20 Arkansas 5 and Alexander, Operational Operational. Audio not the Alexander AR same as audio on KMTL(AM).

To date, the Estate has not responded to this pleading or the videos that accompanied it.

Information and Materials Requested. KMTL(AM) Operational Status. Based on the video evidence before us, it appears KMTL(AM) was silent on March 26, 2020, May 6, 2020, May 14, 2020, May 20, 2020, May 21, 2020, May 23, 2020, and May 30, 2020. Even if KMTL(AM) was operating with the reduced power specified in its STA, it should have been possible to receive the KMTL(AM) signal at the locations where the video recordings were made on these dates.

We hereby request that the Estate provide a narrative statement that indicates KMTL(AM)’s operational status between January 1, 2020, and the present. Specifically, the Estate should indicate the dates on which KMTL(AM) has been silent, has operated with its licensed facilities, has operated at reduced power pursuant to STA, or has operated with technical parameters other than those specified in its license or its STA. The Estate should submit copies of all leases, personnel records, engineering records, station logs, invoices, bills (including utility bills), checks written or received, credit card charges, wire transfers or deposits of funds

17 Pleading File No. 0000115999. 18 Pleading File No. 0000116629.

3 relating to KMTL(AM)’s operation. In addition, the Estate must include pictures of KMTL(AM)’s studio facilities and transmission facilities during this timeframe.

K249FE Programming. Based on the video evidence, it appears that K249FE was operational when KMTL(AM) was silent. It also appears that, on March 26, 2020, May 6, 2020, May 14, 2020, May 20, 2020, May 21, 2020, May 30, 2020, and June 8, 2020, K249FE either was rebroadcasting the signal of a primary station other than KMTL(AM), or originating programming.

We request that the Estate provide a narrative statement that indicates the dates between January 1, 2020, and the present on which K249FE originated programming. The narrative statement should also identify the dates between January 1, 2020, and the present on which K249FE rebroadcast the signal of a primary station other than KMTL(AM). The Estate must include the call signs of these primary stations and note the dates on which K249FE broadcast their signals. The Estate should submit all documents in its possession relating to K249FE’s rebroadcast of the signals of any stations other than KMTL(AM).19

K249FE Power Levels. The video evidence suggests that, despite the Estate’s assertion that “at no time has K249FE broadcast in excess of its licensed TPO (400 watts) and ERP (250 watts),” K249FE may have been operating at a higher power. Specifically, if K249FE were operating at its authorized TPO and ERP, its signal should have been subject to at least some interference at seven of the eight locations where the Objectors’ videos were recorded.20

We request that the Estate provide a narrative statement regarding the TPO(s) and ERP(s) at which K249FE has operated since January 2020. The Estate must also submit station logs and/or records, and any other documents that corroborate the Estate’s response.21

Affidavits or Declarations. In addition to the documentation noted above, the Estate must support its response with an affidavit or declaration under penalty of perjury, signed and dated by an authorized representative of the Estate, with personal knowledge of the representations provided in the response, verifying the truth and accuracy of the information therein and that all of the information requested by this letter which is in the Estate’s possession, custody, control or knowledge has been produced. If multiple persons contribute to the response, in addition to such general affidavit or declaration of the authorized representative of the Estate noted above, if such person (or any other affiant or declarant) is relying on the personal knowledge of any other individual, rather than his or her own knowledge, provide separate affidavits or declarations of

19 As used herein, “document(s)” means the complete original (or in lieu thereof, exact copies of the original) and any non-identical copy (whether different from the original because of notations on the copy or otherwise), regardless of origin or location, of any taped, recorded, transcribed, written, typed, printed, filmed, punched, computer-stored, or graphic matter of every type and description, however and by whomever prepared, produced, disseminated, or made, including but not limited to any broadcast, radio or television program, advertisement, book, pamphlet, periodical, contract, correspondence, letter, facsimile, e-mail, file, invoice, memorandum, note, text message, report, record, handwritten note, working paper, routing slip, chart, graph, photograph, paper, index, map, tabulation, manual, guide, outline, script, abstract, history, calendar, diary, agenda, minutes, marketing plan, research paper, preliminary drafts, or versions of all of the above, and computer material (print-outs, drives, disks and such codes or instructions as will transform such computer materials into easily understandable form). 20 The one location where no interference to the K249FE signal would be expected is Warden Road and Somers Road in Sherwood, Arkansas. 21 See supra note 19 (defining the term “documents”).

4 each such individual with personal knowledge that identify clearly to which responses the affiant or declarant with such personal knowledge is attesting. All such declarations provided must comply with Section 1.16 of the Commission’s rules,22 and be substantially in the form set forth therein. We remind the Estate that to knowingly and willfully make any false statement or conceal any material fact in reply to this inquiry is punishable by fine or imprisonment.1 Moreover, failure to respond appropriately to this letter of inquiry may constitute a violation of the Communications Act and the Commission’s rules.

The Estate’s response is due thirty (30) calendar days from the date of this letter. Please submit the response to the Office of the Secretary, Federal Communications Commission, 445 12th Street, S.W., Washington, DC 20554, and serve copies by email to Tom Hutton, [email protected], Heather Dixon, [email protected], and the individuals who submitted the informal objections, [email protected], and [email protected]. Mr. Reyes and Mr. Vega may reply to the Estate’s response within twenty (20) calendar days from the date they receive a copy of it by email. Finally, we remind all parties that this is a restricted proceeding, and thus that ex parte presentations are prohibited.23

Sincerely,

Albert Shuldiner

Albert Shuldiner Chief, Audio Division Media Bureau

cc: The Estate of George V. Domerese, Timothy Domerese, Administrator, by email to [email protected] Oscar Reyes, by email to [email protected] Edward J. Vega, by email to [email protected]

22 47 CFR § 1.16. 23 47 CFR § 1.1208.

5 Attachment C TIME BROKERAGE AGREEMENT

THIS TIME BROKERAGE AGREEMENT (this “Agreement”) is made as of February 20, 2020 by and between the ESTATE OF GEORGE V. DOMERESE, an Estate established under the laws of the State of Arkansas (“Licensee”) and MG RADIO COMMUNICATIONS LLC, a limited liability company organized under the laws of the State of Arkansas (“Programmer”).

WHEREAS, Licensee is licensee of KMTL(AM), Sherwood, AR, Facility No. 23871 and Station K249FE, Sherwood, AR, Facility No. 201566 (the “Stations”), which are authorized to operate pursuant to authorizations (the “Station Licenses”) issued by the Federal Communications Commission (“FCC”); and

WHEREAS, Licensee is entering into an Asset Purchase Agreement (“APA”) for the purchase of the Stations; and

WHEREAS, Programmer desires to provide programming for broadcast on the Stations on the terms set forth in this Agreement.

NOW, THEREFORE, taking the foregoing recitals into account, and in consideration of the mutual covenants and agreements contained herein and for other good and valuable consideration, the receipt and sufficiency of which are hereby acknowledged, the parties, intending to be legally bound, hereby agree as follows:

1. Term. The initial term of this Agreement (the “Initial Term”) will begin on February 18, 2020 and will continue for the earlier of (i) one year from the date of this Agreement; or (ii) the consummation of the APA for the sale of the Stations.

2. Programming. During the Term, Programmer shall purchase from Licensee airtime on the Stations for the price and on the terms specified below, and shall transmit to Licensee programming and content that it produces, licenses, or owns (the “Programming” or “Programs”) for broadcast on the Stations One Hundred Sixty-Eight (168) hours per week except for: (a) downtime occasioned by routine maintenance consistent with prior practice; (b) the period from 6:00 a.m. to 7:00 a.m. each Sunday morning and any other times mutually agreeable to Licensee and Programmer during which time Licensee may broadcast programming designed to address the concerns, needs and issues of the Stations’ listeners; (c) times when Programmer’s Programming is not accepted or are preempted by Licensee in accordance with this Agreement; and (d) times when the Stations are not broadcasting because of Force Majeure Events (the “Broadcasting Period”). Programmer will transmit, at its own cost, the Programming in a manner that ensures that the Programming meet technical and quality standards at least equal to those of the Stations’ broadcasts prior to commencement of the Term. In the event Programmer sells blocks of time to third party producers of informercials, Programmer shall ensure that all such Programming conform to all agreements, broadcasting policies, laws, and rules as provided herein. 1

3. Broadcasting. In return for the payments to be made by Programmer hereunder, during the Term, Licensee shall broadcast the Programming, subject to the provisions of this Agreement.

4. Advertising. During the Term (except as provided in Sections 9(b), 9(d) and 9(h)), Programmer will be responsible for the sale of advertising on the Stations during the Broadcasting Period and for the collection of accounts receivable arising therefrom, and Programmer shall be entitled to all such collections for advertising that is sold by Programmer. All contracts for advertising on the Stations which may be entered into by Programmer shall terminate upon the termination of this Agreement, unless this Agreement is terminated due to sale of the Stations to Programmer. Programmer may employ and shall be responsible for the salaries, benefits, employer taxes, insurance, and related costs of employment of personnel for the sale of advertising time and for the collection of accounts receivable with respect to commercial advertisements broadcast on the Stations.

5. Payments. For the broadcast of the Programming and the other benefits made available to Programmer pursuant to this Agreement, during the Term, Programmer will pay Licensee as set forth on Schedule A attached hereto.

6. Control.

(a) Notwithstanding anything to the contrary in this Agreement, Licensee shall have full authority, power, and control over the operation of the Stations and over all persons working at the Stations during the Term. Without limiting the generality of the foregoing, Licensee will: (i) designate a manager for the Stations, who will report and be solely accountable to Licensee and will direct the day-to-day operations of the Stations, and who shall have no employment, consulting, or other relationship with Programmer and (ii) retain control over the policies, programming, and operations of the Stations. At no time during the Term shall Programmer or its employees or agents represent, hold out, describe or portray Programmer as the licensee or Licensee of the Stations.

(b) Nothing contained herein shall prevent Licensee from (i) rejecting or refusing Programming which Licensee believes in its sole discretion to be contrary to the public interest, the Communications Act of 1934, as amended (the “Communications Act”), or the FCC’s rules, regulations, and policies (the “Rules,” and together with the Communications Act, the “Communications Laws”) or (ii) substituting programs which Licensee believes in its sole discretion to be of greater local, regional or national interest or significance, or which are designed to address the problems, needs and interests of the local communities, or to use part or all of the hours of operation of the Stations for the broadcast of events of special importance. Without limiting the preceding sentence, Licensee reserves the right to (A) refuse to broadcast any Program containing content which Licensee in its sole discretion believes, or may be determined by the FCC or any court or other regulatory body with authority over Licensee or the Stations to, violate any right of any third party, constitute a personal attack or be defamatory, indecent, obscene, profane, or which does not meet the requirements of the Communications 2

Laws or the Program Standards (defined below) or is otherwise in violation of any law or contrary to the public interest, (B) preempt any Program in the event of a local, state, or national emergency, or (C) delete any commercial announcements that do not comply with the requirements of the FCC’s sponsorship identification policy. Programmer will immediately serve Licensee with notice and a copy of any letters it receives from a member of the public concerning any Program for Licensee review and inclusion in its public inspection file at sole the discretion of Licensee. In furtherance of the foregoing, Licensee may take any other actions necessary to ensure the Stations operations comply with the laws of the United States, the laws of the State of Arkansas, the Communications Laws (including the prohibition on unauthorized transfers of control), and the rules, regulations, and policies of other federal government authorities, including the Federal Trade Commission and the Department of Justice. Licensee may preempt, reject, or otherwise refuse to broadcast any Program under this Section 6(b) without reduction or offset in the payments due Licensee under this Agreement; however, Licensee expressly agrees that its right of preemption shall not be exercised for the commercial purposes of Licensee.

(c) Programmer shall cooperate with Licensee to ensure that EAS transmissions are properly performed in accordance with Licensee’s instructions.

7. Compliance with Copyright Act; Music License Fees. Programmer shall obtain and maintain his own music licenses, arranged for by Programmer with the applicable music licensing organizations, including ASCAP, BMI, and SESAC. Programmer shall be responsible for timely paying the costs for these separate licensing agreements. All Programming, including music supplied therein, supplied by the Programmer shall be (i) licensed by a music licensing agent such as ASCAP, BMI, or SESAC, as appropriate, (ii) in the public domain or (iii) cleared at the source by Programmer. Licensee shall not be obligated to pay any music licensing fees or other similar expenses required in connection with the material broadcast by Programmer on the Stations. Programmer shall not be obligated to pay for any music licensing or any similar expenses associated with content produced by Licensee. Programmer shall not broadcast any material on the Stations in violation of the Copyright Act or the rights of any person.

8. Programming.

(a) Programmer shall ensure that the contents of the Programming (i) conform to all Communications Laws and the “Program Standards” attached hereto as Schedule B and all other laws or regulations applicable to the broadcast of programming by the Stations and (ii) contain matters responsive to issues of public concern in the local communities, as those issues are made known to Programmer by Licensee. Programmer shall not air any contests, sweepstakes, or advertisements that pertain to gambling or political spots during any Program without Licensee’s prior written consent. Programmer shall consult with Licensee in the selection of the Programming to ensure that the Programming’s content conforms to obligations set forth in this Agreement. In addition, Programmer shall, upon request by Licensee, provide (i) information about Programming that is responsive to the public needs and interests of the area 3 served by the Stations, so as to assist Licensee in the preparation of any required programming reports, and (ii) other information to enable Licensee to prepare other records, reports, and logs required by the FCC or other local, state or federal governmental agencies. Licensee may amend or update the Program Standards in its sole discretion notwithstanding anything in Section 18 to the contrary. Any violation of subsection (i) of the first sentence of this Section 8(a) shall be deemed an uncurable Event of Default.

(b) Licensee shall oversee and take ultimate responsibility with respect to the provision of equal opportunities, lowest unit charge, and reasonable access to political candidates, and compliance with the political broadcast rules of the FCC. During the Term, Programmer shall cooperate with Licensee as Licensee complies with its political broadcast responsibilities, and shall supply such information promptly to Licensee as may be necessary to comply with the political broadcasting provisions of the FCC’s rules, the Communications Act of 1934, as amended, and federal election laws. Programmer shall release advertising availabilities during the Broadcasting Period to Licensee as necessary to permit Licensee to comply with the political broadcast rules of the FCC; provided, however, that revenues received by Licensee as a result of any such release of advertising time shall promptly be remitted to Programmer. Programmer agrees that it will not accept any consideration, compensation, gift, or gratuity of any kind whatsoever, regardless of its value or form including, but not limited to, a commission, discount, bonus, material, supplies or other merchandise, services or labor (collectively “Consideration”), whether or not pursuant to written contracts or agreements, unless the payer is identified in the program for which Consideration was provided as having paid for or furnished such Consideration, in accordance with applicable law and the rules of the FCC. Programmer shall at all times comply with the requirements of Sections 317 and 507 of the Communications Act and the related FCC rules.

(c) Licensee may review, on a confidential basis, any programming material relating to Programming as it may reasonably request, solely for the purpose of reviewing the Programmer's compliance with applicable laws and regulations and Station policies. Any material deviation when a Program is actually broadcast from the information provided about a Program prior to broadcast, without Licensee’s prior consent, shall be deemed an Event of Default. In addition, Programmer shall promptly (but no later than three (3) business days following receipt thereof) provide Licensee with copies of all correspondence received by Programmer relating to the Stations’ broadcasts and Programming from any federal, state, or local government or regulatory entity or member of the public.

9. Expenses. During the Term, Programmer will be solely responsible for (i) the salaries, taxes, insurance and other costs for all personnel and facilities used in the production or licensing of the Programming supplied to Licensee and in fulfillment of its rights and obligations under this Agreement., (ii) program license costs, including the costs described in Section 7 and (iii) the costs of delivering the Programming to Licensee. Licensee will pay for its employees contemplated by Section 6, maintenance of all Licensee’s studio and transmitter equipment and all other operating costs required to be paid to maintain the Stations’ broadcast operations in

4 accordance with FCC rules and policies and applicable law, and all utilities supplied to its main studio and transmitter sites.

10. Call Signs. During the Term, Licensee will retain all rights to the call letters of the Stations or any other call letters which may be assigned by the FCC for use by the Stations. Programmer, on behalf of Licensee, shall include in the Programming the station identification announcements at the beginning of each hour to identify such call letters, as well as any other announcements required by the rules and regulations of the FCC. Programmer is authorized to use such call letters of the Stations in its Programming as reasonably necessary and, upon Licensee’s prior written consent, in any promotional material in any media used in connection with the Programming.

11. Facilities. Subject to Section 13(d), during the Term, Licensee shall maintain the operating power of the Stations and shall repair and maintain the Stations’ towers and transmitter sites and equipment consistent with its past practice.

12. Representations. Programmer and Licensee each represent and warrant to the other that (i) it has the power and authority to enter into this Agreement and to consummate the transactions contemplated hereby, (ii) it is in good standing in the jurisdiction of its organization and is qualified to do business in all jurisdictions where the nature of its business requires such qualification, (iii) it has duly authorized this Agreement, and this Agreement is binding upon it, and (iv) the execution, delivery, and performance by it of this Agreement does not conflict with, result in a breach of, or constitute a default or ground for termination under any agreement to which it is a party or by which it is bound.

13. Events of Default; Termination.

(a) The occurrence of any of the following will be deemed an Event of Default by Programmer under this Agreement: (i) Programmer fails to timely make any payment required under this Agreement (“Payment Default”); (ii) Programmer fails to observe or perform any other obligation contained in this Agreement in any material respect; or (iii) Programmer breaches any representation or warranty made by it under this Agreement in any material respect. Any Payment Default will not be deemed to have occurred until after five (5) business days after Licensee has provided Programmer with written notice specifying the Payment Default and such payment remains uncured.

(b) The occurrence of the following will be deemed an Event of Default by Licensee under this Agreement: (i) Licensee fails to observe or perform any obligation contained in this Agreement in any material respect; or (ii) Licensee breaches any representation or warranty made by it under this Agreement in any material respect.

(c) Notwithstanding the foregoing, any Event of Default that is not a Payment Default and that is capable of being cured will not be deemed to have occurred until fifteen (15) calendar days after the non-defaulting party has provided the defaulting party with written notice

5 specifying the Event of Default and such Event of Default remains uncured. Upon the occurrence of an Event of Default, and in the absence of a timely cure pursuant to this Section, the non-defaulting party may terminate this Agreement, effective immediately upon written notice to the defaulting party. Upon the occurrence of a Payment Default or an Event of Default, the non-defaulting party may terminate this Agreement, effective immediately upon written notice to the defaulting party.

(d) The failure of Licensee to broadcast the Programming due to facility maintenance, repair or modification or due to any reason out of Licensee’s reasonable control (a “Force Majeure Event”) shall not constitute a breach of this Agreement, nor an Event of Default, by Licensee, and Licensee shall not be liable to Programmer therefor. In the event of a Force Majeure Event, Licensee may terminate this Agreement effective immediately upon written notice to Programmer.

(e) If this Agreement is terminated, the parties agree to cooperate with one another and to take all actions necessary to rescind this Agreement and return the parties to the status quo ante. Termination of this Agreement shall not relieve any party from liability for breach of this Agreement.

14. Indemnification. Programmer shall indemnify, defend, protect, and hold harmless Licensee and Licensee’s shareholders, officers, directors, employees, agents, partners, and affiliates from and against all losses and claims (including costs of investigation and defense and attorneys’ and other professionals’ fees) arising from or relating to (i) the Programmer’s use of the Stations, (ii) Programmer’s breach of any representation, warranty, covenant, or other agreement hereunder, or (iii) as provided for in Section 23. Without limitation of the generality of the preceding sentence, Programmer will indemnify and hold Licensee and Licensee’s shareholders, officers, directors, employees, agents, partners, and affiliates harmless from and against all liability arising from or relating to the programming and content produced or supplied by Programmer for broadcast on the Stations including, without limitation, liability for libel, slander, infringement of copyright, or other intellectual property right (including music licensing rights), violation of rights of privacy or proprietary rights, or violation of FCC rules, regulations, or policies or applicable law, and for any other claims of any nature including, without limitation, any investigation or fines or forfeiture imposed by the FCC for violation of any FCC rule, regulation, or policy including, without limitation, those relating to lotteries or games of chance, obscenity, or indecency, broadcast hoaxes, “personal attacks,” or the adequacy of sponsorship identification.

15. Assignment. Neither Licensee nor Programmer may assign this Agreement without the prior written consent of the other party. The terms of this Agreement shall bind and inure to the benefit of the parties’ respective successors and any permitted assigns.

16. Severability. If any court or governmental authority holds any provision in this Agreement invalid, illegal, or unenforceable under any applicable law, then so long as no party is deprived of the benefits of this Agreement in any material respect, this Agreement shall be 6 construed with the invalid, illegal, or unenforceable provision deleted and the validity, legality, and enforceability of the remaining provisions contained herein shall not be affected or impaired thereby. The obligations of the parties under this Agreement are subject to the rules, regulations, and policies of the FCC and all other applicable laws. The parties agree that Licensee may file a copy of this Agreement with the FCC, and that Licensee shall place a copy of this Agreement in the KMTL public inspection file.

17. Notices. Any notice pursuant to this Agreement shall be in writing and shall be deemed delivered on the date of personal delivery or confirmed facsimile transmission or confirmed delivery by a nationally recognized overnight courier service, or on the third day after prepaid mailing by certified U.S. mail, return receipt requested, and shall be addressed as follows (or to such other address as any party may request by written notice): if to Programmer:

MG Radio Communications LLC 6801 Cantrell Rd. Little Rock, AR 72209 if to Licensee: The Estate of George V. Domerese Timothy Domerese, Administrator 226 CR 3530 Clarksville, AR 78230

18. Miscellaneous.

(a) This Agreement may be executed in separate counterparts, each of which will be deemed an original and all of which together will constitute one and the same agreement. Faxed or scanned (e.g., PDF) copies of this Agreement and faxed or scanned (e.g., PDF) signature pages shall be binding and effective as to all parties and may be used in lieu of the original Agreement, and, in particular, in lieu of original signatures, for any purpose whatsoever. No amendment or waiver of compliance with any provision hereof or consent pursuant to this Agreement shall be effective unless evidenced by an instrument in writing signed by the party against whom enforcement of such amendment, waiver, or consent is sought. This Agreement is not intended to be, and shall not be construed as, an agreement to form a partnership, agency relationship, or joint venture between the parties. Neither party shall be authorized to act as an agent of or otherwise to represent the other party. The construction and performance of this Agreement shall be governed by the laws of the State of Arkansas without giving effect to the choice of law provisions thereof. The parties hereby agree that any action or proceeding arising out of or relating to this Agreement shall be brought exclusively in the state or federal courts located in the City of Little Rock, irrevocably submit to the exclusive jurisdiction of any such court and waive any objection that such party may now or hereafter have to the venue of any such action or proceeding in any such court or that such action or proceeding was brought in an 7 inconvenient court and agree not to plead or claim the same. Each party agrees not to bring any action or proceeding arising out of or relating to this Agreement in any other court. THE PARTIES HERETO HEREBY IRREVOCABLY AND UNCONDITIONALLY WAIVE TRIAL BY JURY IN ANY LEGAL ACTION OR PROCEEDING RELATING IN ANY WAY TO THIS AGREEMENT, INCLUDING WITH RESPECT TO ANY COUNTERCLAIM MADE IN SUCH ACTION OR PROCEEDING, AND AGREE THAT ANY SUCH ACTION OR PROCEEDING SHALL BE DECIDED SOLELY BY A JUDGE. This Agreement (including the Schedules hereto) constitutes the entire agreement and understanding among the parties hereto with respect to the subject matter hereof and supersedes all prior agreements and understandings with respect to the subject matter hereof.

(b) No failure or delay on the part of Licensee or Programmer in exercising any right or power under this Agreement shall operate as a waiver thereof, nor shall any single or partial exercise of any such right or power, or any abandonment or discontinuance of steps to enforce such a right or power, preclude any other or further exercise thereof or the exercise of any other right or power. The rights and remedies of the parties to this Agreement are cumulative and are not exclusive of any right or remedies which either may otherwise have.

(c) The headings set forth in this Agreement are for convenience only and will not control or affect the meaning or construction of the provisions of this Agreement. Whenever the words “include”, “includes” or “including” are used in this Agreement, they shall be deemed to be followed by the words “without limitation”.

19. Certifications.

(a) Licensee certifies that it maintains ultimate control over the Stations’ facilities including, specifically, control over the Stations’ finances, personnel, and programming. Programmer certifies that this Agreement complies with the provisions of 47 C.F.R. Sections 73.3555(a) and (c).

(b) In accordance with Paragraphs 49 and 50 of United States Federal Communications Commission Report and Order No. FCC 07-217, Programmer agrees that it shall not discriminate in any contract for advertising on the Stations on the basis of race or gender, and all such contracts shall be evaluated, negotiated and completed without regard to race or gender. Programmer shall include a clause to such effect in all contracts for advertising on the Stations, and if requested shall promptly provide Licensee written confirmation of compliance with such requirement.

20. Insurance. Programmer shall maintain at its expense and with reputable insurance companies commercially reasonable coverage for broadcaster’s liability insurance, worker’s compensation insurance, commercial general liability insurance and property insurance, consistent with industry practice. Licensee shall be named as an additional insured on such policies, and such policies shall not be terminable without notice to Licensee with an opportunity

8 to cure any default thereunder. Programmer shall deliver to Licensee promptly upon request certificates establishing that such insurance is in effect.

21. Waiver of Conflict. Buyer and Seller each acknowledge that Dan J. Alpert and the Law Office of Dan J. Alpert have provided legal services to both parties in the past and has prepared and provided to both parties a draft of this Agreement for review by both parties. Both parties agree to waive any conflict that may otherwise exist in conjunction with the preparation of this Agreement.

SCHEDULE A TO TIME BROKERAGE AGREEMENT

Payments Due to Licensee by Programmer.

Payments During Renewal Terms. Programmer shall pay an Expense Reimbursement amount which shall reflect the actual operating expenses of the Stations including the following items. The amounts due for each item shall be substantiated to Programmer by actual invoices or contractual agreements with the vendors or suppliers:

1. Licensee’s tower rental fees.

2. Costs of electrical power to the Stations’ transmitter sites (for power used by Stations alone, if such invoice is divided among multiple stations sharing electricity).

3. Any grounds maintenance and property taxes for the Licensee tower site for which Licensee is responsible.

4. Any security costs for tower site for which Licensee is responsible.

5. The monthly retainer cost for an on-call engineer responsible for keeping the Stations on air (though not the cost of equipment he replaces).

6. Legal fees incurred in conjunction with the operation of the Stations or incurred as a result of mandatory filings with the FCC.

7. The cost of any telephone lines to the Stations’ transmitter.

8. FCC Annual Regulatory Fees.

9. Music licensing fees for Programmer’s Licensee Programming.

10. Costs for any repairs to the Stations.

SCHEDULE B TO TIME BROKERAGE AGREEMENT

PROGRAMMING STANDARDS

Programmer agrees to cooperate with Licensee in the broadcasting of Programming in a manner consistent with the standards of the Stations, as set forth below:

1. Political Programming and Procedures. At least 90 days before the start of any primary or at least 120 days before the start of any general election campaign, Programmer will coordinate with Licensee the rate that Programmer will charge for time to be sold to candidates for public office and/or their supporters to make certain that the rate charged conforms to all applicable laws and the Stations’ policies. Throughout a campaign, Programmer will comply with all applicable laws and rules concerning political candidacy broadcasts and will promptly notify the Stations’ manager of any disputes concerning either the treatment of or rate charged a candidate or political supporter.

2. Required Announcements. Programmer shall broadcast an announcement in a form satisfactory to Licensee at the beginning of each hour to identify the Stations, and any other announcement that may be required by law, regulation, or the Stations’ policy.

3. Commercial Record-Keeping. Programmer shall maintain such records of the receipt of, and provide such disclosure to Licensee, of any consideration, whether in money, goods, services, or otherwise, which is paid or promised to be paid, either directly or indirectly, by any person or company for the presentation of any programming on the Stations as are required by Sections 317 and 508 of the Communications Act of 1934, as amended, and by the rules of the FCC.

4. No Illegal Announcements. No announcements or promotion prohibited by federal or state law or regulation of any lottery, game or contest shall be made over the Stations. Any game, contest or promotion relating to or to be presented over the Stations must be fully stated and explained in advance in writing, and such explanation be presented to Licensee, which reserves the right, in its reasonable discretion to reject any game, contest or promotion.

5. Controversial Issues. Any broadcast over the Stations concerning controversial issues of public importance shall comply with the Rules.

6. Credit Terms Advertising. Pursuant to the rules and regulations of the Federal Trade Commission, any advertising of credit terms shall be made over the Stations in accordance with all applicable federal and state laws.

7. Respectful of Faiths. The subject of religion and references to particular faiths, tenets, and customs shall be treated with respect at all times.

8. No Denomination Attacks. Programming shall not be used as a medium for attack on any faith, denomination, or sect or upon any individual or organization.

9. Donation Solicitation. Requests for donations in the form of a specific amount, for example, $1.00 or $5.00, shall not be made if there is any suggestion that such donation will result in miracles, cures or prosperity. However, statements generally requesting donations to support the program broadcast or a church are permitted.

10. No Ministerial Solicitations. No invitation by a minister or other individual appearing or present on a religious program to have listeners come and visit him or her for consultation or the like shall be made if such invitation implies that the listeners will receive consideration or monetary gain.

11. No Vending of Miracles. Any exhortation to listeners to bring money to a church service is prohibited if the exhortation, affair, or service contains any suggestion that miracles, cures, or prosperity will result. This shall not preclude advertisements for legally authorized church or other non-profit bingos if permitted by FCC rules and regulations.

12. No Miracle Solicitation. Any invitation to listeners to meet at places other than a church and/or to attend other than regular services of a church is prohibited if the invitation, meeting, or service contains any claim that miracles will result.

13. No Plugola or Payola. The broadcast of any material for which any money, service or other valuable consideration is directly or indirectly paid, promised to or accepted by, programmer from any person is prohibited, unless at the time of such broadcast an announcement is made that the programming is paid for or furnished by such third person. Programmer shall advise the Stations’ manager with respect to any programming, including commercial material, concerning goods or services in which Programmer has a material financial interest. Any announcements for such goods and services shall clearly identify Programmer's financial interest.

14. Programming Prohibitions. Programmer shall not broadcast any of the following programs or announcements:

(a) False Claims. False or unwarranted claims for any product or service.

(b) Unfair Imitation. Infringements of another advertiser's rights through plagiarism or illegal imitation of program copy, or any other unfair competition.

(c) Obscenity/Indecency/Profanity. Any programs or announcements that are slanderous, obscene, profane, indecent, or vulgar, either in theme or in treatment.

(d) Hoaxes. Any programs or announcements violating applicable laws and rules concerning hoaxes.

(e) Conflict in Programming or Advertising. Any programming or advertising matter or announcement which, in the reasonable opinion of Licensee, may be injurious or prejudicial to the interests of the public, Licensee or the Stations.

15. Licensee's Discretion Paramount. In accordance with Licensee's responsibility under the FCA, Licensee and the Stations reserve the right to reject or terminate any programming proposed to be presented or being presented on the Stations which is in conflict with the

Stations’ policy or which, in the good faith, reasonable judgment of Licensee or the Stations’ manager would be contrary to the FCA.

Licensee may waive any of the foregoing standards in specific instances if, in its reasonable and sole opinion, waiver will serve the public interest.

Attachment D

DECLARATION OF JOHN MARCON

I, John Marcon, hereby declare under penalty of perjury as follows: 1. I live and work in the Little Rock, Arkansas, area. I am a professional broadcast engineer, holding certifications from the Society of Broadcast Engineers for Radio and Television Broadcast engineering.

2. I have conducted engineering work on a contract basis for AM radio station KMTL in Little Rock, Arkansas, at the direction of Carlos Moron and Albino Gutierrez for Radio La Raza, LLC.

3. I conducted repairs on the KMTL transmitter, primarily the replacement of transistors, on the following dates in 2020: May 23 and 26; June 24 and 29; July 9; August 2; and September 8. On each of the above dates, the station was off the air when I arrived at the transmitter site, and was back on the air (but operating at the reduced power of 1,000 watts) when I left.

______John Marcon

December 13, 2020

{01490772-1 } Attachment E CANYON LAKE BROADCASTING

Broadcast Technical Consultants  Telephone 830- 899 – 4575

December 11, 2020

TECHNICAL STATEMENT

This firm is the technical consultant for K249FE and K250FC. We provided the necessary engineering data for the applications for the construction permits and the followup license to cover for both. The engineering software from RadioSoft was used to calculate the respective TPO for K249FE and

K250FC. Attached is an exhibit showing the TPO calculations for the license to cover applications of both translators.

CERTIFICATION OF TECHNICAL CONSULTANT

I declare, under penalty of perjury, that this technical statement is true and accurate to the best of my knowledge and belief. Furthermore, I have more than 20 years of experience as a technical consultant before the Federal Communications Commission; and am familiar with the Code of Federal

Regulations Title 47 (the Rules) as applicable to this statement.

Tom Bruce Technical Consultant December 11, 2020

K249FE K250FC Attachment F

Attachment G

Attachment H

Attachment I CDBS Print https://licensing.fcc.gov/cgi-bin/ws.exe/prod/cdbs/forms/prod/cdbsmenu....

Federal Communications Commission Approved by OMB FOR FCC USE ONLY Washington, D.C. 20554 3060-0386 (July 2002)

FOR COMMISSION USE ONLY Extension of Existing Engineering STA FILE NO. - 20200522AAA Read Instructions/FAQ before filling out form Section I - General Information 1. Legal Name of the Applicant ESTATE OF GEORGE V DOMERESE, TIMOTHY DOMERESE, ADMINISTRATOR Mailing Address 226 CR 3530

City State or Country (if foreign address) Zip Code CLARKSVILLE AR 72830 - Telephone Number (include area code) E-Mail Address (if available) 4797744602 FCC Registration No Call Sign Facility ID Number 0027257005 KMTL 23871 2. Contact Representative (if other than licensee/permittee) Firm or Company Name DAN J. ALPERT THE LAW OFFICE OF DAN J. ALPERT Mailing Address 2120 N. 21ST RD.

City State or Country (if foreign address) ZIP Code ARLINGTON VA 22201 - Telephone Number (include area code) E-Mail Address (if available) 7032438690 [email protected] 3. Purpose: Engineering STA

Extension of Existing Engineering STA File Number: BSTA - 20191120AAQ

Legal STA

Extension of Existing Legal STA 4. Service: AM 5. Community of License: City: SHERWOOD State: AR 6. If this application has been submitted without a fee, indicate reason for fee exemption (see 47 C.F.R. Section 1.1114): Governmental Entity Noncommercial Educational Licensee/Permittee Other N/A (Fee Required)

7. Environmental Protection Act. The proposed facility is excluded from environmental Yes No processing under 47. C.F.R. Section 1.1306 (i.e., The facility will not have a significant environmental impact and complies with the maximum permissible radiofrequency electromagnetic exposure limits for controlled and uncontrolled environments). Unless the See Explanation in applicant can determine compliance through the use of the RF worksheets in Appendix A, [Exhibit 33] an Exhibit is required.

By checking "Yes" above, the applicant also certifies that it, in coordination with other users of the site, will reduce power or cease operation as necessary to protect persons having access to the site, tower or antenna from radiofrequency electromagnetic exposure in excess of FCC guidelines.

1 of 2 5/22/2020, 7:07 AM CDBS Print https://licensing.fcc.gov/cgi-bin/ws.exe/prod/cdbs/forms/prod/cdbsmenu....

8. Please explain in detail the "extraordinary circumstances" which warrant temporary [Exhibit 34] operations at variance from the Commission's Rules. In addition, please specify 1)the specific rules and/or policies from which the applicant seeks temporary relief; 2) how the public interest will be furthered by grant; and 3) the expected duration of the STA and the licensee's plan for restoration of licensed operation. If requesting variance with other than authorized technical facilities, please specify the exact facilities sought.

9. Anti-Drug Abuse Act Certification. Applicant certifies that neither applicant nor any party Yes No to the application is subject to denial of federal benefits pursuant to Section 5301 of the Anti-Drug Abuse Act of 1988, 21 U.S.C. Section 862.

I hereby certify that the statements in this application are true, complete, and correct to the best of my knowledge and belief, and are made in good faith. I acknowledge that all certifications and attached Exhibits are considered material representations.

Typed or Printed Name of Person Signing Typed or Printed Title of Person Signing TIMOTHY DOMERESE ADMINISTRATOR Signature Date (mm/dd/yyyy) 5/22/2020

WILLFUL FALSE STATEMENTS ON THIS FORM ARE PUNISHABLE BY FINE AND/OR IMPRISONMENT (U.S. CODE, TITLE 18, SECTION 1001), AND/OR REVOCATION OF ANY STATION LICENSE OR CONSTRUCTION PERMIT (U.S. CODE, TITLE 47, SECTION 312(a)(1)), AND/OR FORFEITURE (U.S. CODE, TITLE 47, SECTION 503).

Exhibits

Exhibit 34 Description: JUSTIFICATION

DUE TO TRANSMITTER PROBLEMS, THE STATION IS STILL NEEDING TO OPERATE DAYTIME AT 1000 WATTS

Attachment 34

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Pay.gov Tracking Information Application Name: Remittance Advice Pay.gov Tracking ID: 26P0R20R Agency Tracking ID: PGC3396560 Transaction Date and Time: 05/22/2020 07:06 EDT Payment Summary Address Information Account Information Payment Information Account Holder Credit Card Type: Discover Payment Amount: $200.00 Dan J Alpert Name: Credit Card Number: *************3444 Transaction Date 05/22/2020 07:06 2120 N. 21st and Time: EDT Billing Address: Rd. Billing Address 2: City: Arlington State/Province: VA ZIP/Postal Code: 22201 Country: USA

1 of 1 5/22/2020, 7:08 AM CDBS Print https://licensing.fcc.gov/cgi-bin/ws.exe/prod/cdbs/forms/prod/cdbsmenu....

Federal Communications Commission Approved by OMB FOR FCC USE ONLY Washington, D.C. 20554 3060-0386 (July 2002)

FOR COMMISSION USE ONLY Extension of Existing Engineering STA FILE NO. - 20201202AAM Read Instructions/FAQ before filling out form Section I - General Information 1. Legal Name of the Applicant ESTATE OF GEORGE V DOMERESE, TIMOTHY DOMERESE, ADMINISTRATOR Mailing Address 226 CR 3530

City State or Country (if foreign address) ZIP Code ARLINGTON VA 22201 - Telephone Number (include area code) E-Mail Address (if available) 7032438690 [email protected] 3. Purpose: Engineering STA

Extension of Existing Engineering STA File Number: BSTA - 20191120AAQ

Legal STA

1 of 2 12/2/2020, 11:17 PM CDBS Print https://licensing.fcc.gov/cgi-bin/ws.exe/prod/cdbs/forms/prod/cdbsmenu....

Typed or Printed Name of Person Signing Typed or Printed Title of Person Signing TIMOTHY DOMERESE ADMINISTRATOR Signature Date (mm/dd/yyyy) 12/2/2020

Exhibits

Exhibit 34 Description: JUSTIFICATION

DUE TO TRANSMITTER PROBLEMS, THE STATION IS OPERATING DAYTIME AT 1000 WATTS

Attachment 34

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Payment Summary

Remittance ID: 3453474 FCC Bill Applicant Applicant Call PTC Amount Code FCC Code 2 Number FRN Name Sign 1

Mekaddesh N/A 0024636276 Group NEW 2016 $1,075.00 198750 Corporation

Mekaddesh N/A 0024636276 Group NEW 2016 $1,075.00 198752 Corporation

Mekaddesh N/A 0024636276 Group NEW 2016 $1,075.00 198754 Corporation

Mekaddesh N/A 0024636276 Group NEW 2016 $1,075.00 198755 Corporation

Mekaddesh N/A 0024636276 Group NEW 2016 $1,075.00 198756 Corporation

Mekaddesh N/A 0024636276 Group NEW 2016 $1,075.00 198757 Corporation

Mekaddesh N/A 0024636276 Group KZAM 2042 $1,625.00 164195 TXPLEASANTVALLEY Corporation

Timothy N/A 0026705608 Domerese, KMTL 2039 $3,400.00 23871 ARSHERWOOD Administrator

Timothy N/A 0026705608 Domerese, K249FE 2068 $315.00 201566 AR,SHERWOOD Administrator

Total Amount Due : $11,790.00

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Payer FRN : 0003777588 Payer Name :Dan Alpert Voucher # : E003453474

Amount Amount $11,790.00 $0.00 filed : paid :

Agency Payment Tracking Date: ID:

Licensee : Mekaddesh Group Corporation (FRN: 0024636276)

Call Late P T C Quantity FCC Code 1 FCC Code 2 Bill Number Amount Sign Fees NEW 2016 1 198750 N/A $1,075.00 $0.00 NEW 2016 1 198752 N/A $1,075.00 $0.00 NEW 2016 1 198754 N/A $1,075.00 $0.00 NEW 2016 1 198755 N/A $1,075.00 $0.00 NEW 2016 1 198756 N/A $1,075.00 $0.00 NEW 2016 1 198757 N/A $1,075.00 $0.00 TX PLEASANT KZAM 2042 1 164195 N/A $1,625.00 $0.00 VALLEY Total: ***** 7 ******** ******** ******** $8,075.00

Licensee : Timothy Domerese, Administrator (FRN: 0026705608)

Call Late P T C Quantity FCC Code 1 FCC Code 2 Bill Number Amount Sign Fees KMTL 2039 1 23871 AR SHERWOOD N/A $3,400.00 $0.00 K249FE 2068 1 201566 AR, SHERWOOD N/A $315.00 $0.00 Total: ***** 2 ******** ******** ******** $3,715.00 $0.00

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Total Amount: $11,790.00

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indicates required fields Agency Tracking ID PGC3453474 Payment Amount $11,790.00 Payment Method Plastic Card Account Holder Name Dan J. Alpert Card Type VISA Card Number ************7580 Billing Address 2120 N. 21 Rd. Billing Address 2 City Arlington Country United States State/Province VA ZIP/Postal Code 22201 I authorize a charge to my card account for the above amount in accordance with my card issuer agreement. Previous Cancel

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Total Amount $11,790.00 Payer FRN 0003777588 Payer Name Dan J Alpert Remittance ID 3453474 Treasury Tracking ID 26Q1RJ1Q

Thank you for your payment!

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CDBS Print https://licensing.fcc.gov/cgi-bin/ws.exe/prod/cdbs/forms/prod/cdbsmenu....

Federal Communications Commission Approved by OMB FOR FCC USE ONLY Washington, D.C. 20554 3060-0386 (July 2002)

FOR COMMISSION USE ONLY Notification of Suspension of Operations / Request for Silent FILE NO. STA BLSTA - 20201127AAF

Read Instructions/FAQ before filling out form Section I - General Information 1. Legal Name of the Applicant ESTATE OF GEORGE V DOMERESE, TIMOTHY DOMERESE, ADMINISTRATOR Mailing Address 226 CR 3530

City State or Country (if foreign address) Zip Code CLARKSVILLE AR 72830 - Telephone Number (include area code) E-Mail Address (if available) 4797744602 FCC Registration No Call Sign Facility ID Number 0026705608 KMTL 23871 2. Contact Representative (if other than licensee/permittee) Firm or Company Name DAN J. ALPERT THE LAW OFFICE OF DAN J. ALPERT Mailing Address 2120 N. 21ST RD.

City State or Country (if foreign address) ZIP Code ARLINGTON VA 22201 - Telephone Number (include area code) E-Mail Address (if available) 7032438690 [email protected] 3. Purpose: Notification of Suspension of Operations

Notification of Suspension of Operations and Request for Silent STA

Request for Silent STA

Request to Extend STA

Resumption of Operations 4 Community of License: City: SHERWOOD State: AR 5. Reason for going silent: Technical Financing Staffing Program Source Other

6. Please provide a justification for the request [Exhibit 1]

7. Date Station has gone / will go silent: 10/17/2020 (mm/dd/yyyy)

8. Anti-Drug Abuse Act Certification. Applicant certifies that neither applicant nor any party Yes No to the application is subject to denial of federal benefits pursuant to Section 5301 of the Anti-Drug Abuse Act of 1988, 21 U.S.C. Section 862.

1 of 2 12/14/2020, 3:52 PM CDBS Print https://licensing.fcc.gov/cgi-bin/ws.exe/prod/cdbs/forms/prod/cdbsmenu....

Typed or Printed Name of Person Signing Typed or Printed Title of Person Signing TIMOTHY DOMERESE ADMINISTRATOR Signature Date (mm/dd/yyyy) 11/27/2020

Exhibits

Exhibit 1 Description: JUSTIFICATION

THE STATION IS SILENT DUE TO TECHNICAL PROBLEMS WITH THE STATION'S TRANSMITTER.

Attachment 1

2 of 2 12/14/2020, 3:52 PM CDBS Print https://licensing.fcc.gov/cgi-bin/ws.exe/prod/cdbs/forms/prod/cdbsmenu....

Federal Communications Commission Approved by OMB FOR FCC USE ONLY Washington, D.C. 20554 3060-0386 (July 2002)

FOR COMMISSION USE ONLY Resumption of Operations FILE NO.

Read Instructions/FAQ before filling out form Section I - General Information 1. Legal Name of the Applicant ESTATE OF GEORGE V DOMERESE, TIMOTHY DOMERESE, ADMINISTRATOR Mailing Address 226 CR 3530

City State or Country (if foreign address) Zip Code CLARKSVILLE AR 72830 - Telephone Number (include area code) E-Mail Address (if available) 4797744602 Call Sign Facility ID Number KMTL 23871 2. Contact Representative (if other than licensee/permittee) Firm or Company Name DAN J. ALPERT THE LAW OFFICE OF DAN J. ALPERT Mailing Address 2120 N. 21ST RD.

Notification of Suspension of Operations and Request for Silent STA

Request for Silent STA

Request to Extend STA

Resumption of Operations 4 Community of License: City: SHERWOOD State: AR 5. Date station went silent: 10/17/2020 6. Date station commenced operation: 11/25/2020 (mm/dd/yyyy)

7. Please explain under which parameters the facility commenced operations (i.e. license, [Exhibit 3] technical sta, construction permit)

I hereby certify that the statements in this application are true, complete, and correct to the best of my kowledge and belief, and are made in good faith. I acknowledge that all certifications and attached Exhibits are considered material representations.

Typed or Printed Name of Person Signing Typed or Printed Title of Person Signing DAN J ALPERT LEGAL COUNSEL Signature Date (mm/dd/yyyy) 12/2/2020

WILLFUL FALSE STATEMENTS ON THIS FORM ARE PUNISHABLE BY FINE AND/OR IMPRISONMENT (U.S. CODE, TITLE 18, SECTION 1001), AND/OR REVOCATION OF ANY STATION LICENSE OR CONSTRUCTION PERMIT (U.S. CODE,

1 of 2 12/2/2020, 11:01 PM CDBS Print https://licensing.fcc.gov/cgi-bin/ws.exe/prod/cdbs/forms/prod/cdbsmenu....

TITLE 47, SECTION 312(a)(1)), AND/OR FORFEITURE (U.S. CODE, TITLE 47, SECTION 503).

Exhibits

Exhibit 3 Description: PARAMETERS

PARAMETERS SPECIFIED IN BESTA-20200522AAA

Attachment 3

2 of 2 12/2/2020, 11:01 PM Application Filing Results https://licensing.fcc.gov/cgi-bin/ws.exe/prod/cdbs/forms/prod/cdbsmenu....

Federal Communications Commission

FCC MB - CDBS Electronic Filing Account number: 654861

Description: RESUMPTION NOTICE

Successfully filed at Dec 2 2020 11:00PM

Based on the information supplied, no fee is required.

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