Federal Communications Commission Record DA 95-904
10 FCC Red No. 9 Federal Communications Commission Record DA 95-904 that she is a Dallas resident, a member of ART, that she is Before the "one of the signers of the Anti-Howard Stern Petition Federal Communications Commission prepared by [ART] for submission to the Attorney General Washington, D.C. 20554 of the United States," and that "[a]s one of the signers of [that] petition, I have personal knowledge of the indecency violations broadcast on the Howard Stern Show which LETTER form the basis of the petition to deny." In the second affidavit, dated November 3, 1993, Terry Rakolta ("Rakolta") states that she is the founder of ART, that ART Released: April 28, 1995 "speaks upon behalf of a group of Dallas listeners support ing ART," that "[Turnage] has personal knowledge of the In Reply Refer To: allegations of fact," and that the facts set forth in the ART 1800B3-KDY pleading "are true and correct to the best of my knowl edge, information and belief." should designate the Ernest T. Sanchez, Esquire ART contends that the Commission subject assignment application for hearing because Infinity Baker & McKenzie "is an unfit licensee."4 ART states that the "Commission 815 Connecticut Avenue, N.W. has determined that on at least twenty-one occasions Infin Washington, D.C. 20006-4078 ity violated indecency standards over the last seven years."5 ART also argues that Infinity "defiantly continues to broad In re: KLUV(FM), Dallas, Texas cast indecent material." In support, ART references three BTCH-940919GI 1994 complaints filed with the Commission against Stern broadcasts: (1) a March 4, 1994 complaint against Transfer of Control of Station License WWKB(AM), Buffalo, New York (the "WWKB Com plaint");6 (2) a March 17, 1994 complaint against BALH-940919GH WBCN(FM), Boston, Massachusetts (the "WBCN Com Assignment of Station License plaint");7 and (3) a September 2, 1994 complaint against WRNO(FM), New Orleans, Louisiana (the "WRNO Com Dear Mr.
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