Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554

In the Matter of ) ) Application for Renewal ofBroadcast Station ) File No. License of ) ) BRCT-20070201AJT Fox Television Stations, Inc. ) ) For Renewal ofStation License WWOR-TV, ) Secaucus, )

OPPOSITION TO INFORMAL OBJECTION

Fox Television Stations, Inc. ("Fox"), licensee oftelevision station

WWOR-TV, Secaucus, NJ, hereby submits its Opposition to the "Infonnal Objections in

Support ofPetitions to Deny Renewal Application" ("Objection") ofAristides Martinez dated December 22,2007.1 In the Objection, Mr. Martinez opposes the renewal ofthe broadcast television license ofWWOR-TV based primarily on an alleged insufficiency in the station's service to the Hispanic community within its coverage area. The Objection, however, just as the petitions it purports to support, does not meet the requirements of

Section 309 ofthe Communications Act because it fails to raise aprimajacie case that

WWOR-TV has not served the public interest. Its suggestion that the Commission review the content ofFox's programming raises serious constitutional issues, and in any event the Objection itselfdemonstrates within its four comers WWOR-TV's history of exemplary service to its viewers ofHispanic descent.

The Objection was sent to the Commission by first class mail (although a cover letter dated December 24, 2007 refers to "First Class E-Mail"). The Secretary accepted it with a date-stamp ofJanuary 15, 2008.

1 1. The Objection, like the Petitions it Purports to Support, Fails to Meet the Requirements ofSection 309(d)(l) and Fails to Raise a Prima Facie Question Warranting Designation ofthe Renewal Application for Hearing.

Although Mr. Martinez styles his filing as "informal objections," he attempts to address the Communications Act and FCC rules governing petitions to deny,2 apparently recognizing that petitions to deny were due months ago (not later than May 1,

200i). Section 309(d)(I) ofthe Communications Act4 requires that any petition to deny contain specific allegations offact sufficient to show that the petitioner is a party in interest and that a grant ofthe application would beprimajacie inconsistent with the public interest; such allegations must be supported by an affidavit ofa person with personal knowledge ofthe facts.s The pleading satisfies none ofthe requirements of

Section 309(d)(l).

First, Mr. Martinez cannot establish that he is a "party in interest." He claims only that he is a "resident ofthe State ofNew Jersey, a region within the station's

WWOR-TV, Channel 9, service area...,,6 Mr. Martinez is a resident ofPrinceton

Junction, in Mercer County, New Jersey, within the Philadelphia DMA. WWOR-TV's community oflicense, Secaucus, is in Northern New Jersey, within the DMA.

More importantly, Mr. Martinez does not claim to be a viewer ofWWOR-TV. He attempts to bootstrap himselfinto party-in-interest status by claiming to have personal

2 Mr. Martinez petitions to be considered a party interest. Given the untimeliness ofhis filing, he can only be accorded informal objector status. See 47 CFR §§ 73.3584 and 73.3587.

See 47 CFR §§ 73.3516(e) and 73.1020.

4 47 U.S.C. § 309(d)(1).

[d.

6 Objection, Annex 1, p. 1.

2 knowledge ofthe operations ofFox stations through his previous employment with

WTXF-TV, the Fox station in Philadelphia. This alleged knowledge ofWTXF-TV's operations is not only irrelevant to consideration ofthe WWOR-TV renewal application, it is out-of-date because his employment was terminated in 2004.7 In short, Mr. Martinez is not a party in interest within the meaning of Section 309(d)(I).

Nor has Mr. Martinez provided the requisite support from an affiant with personal knowledge ofhis allegations.8 Indeed, he supplies only his own affidavit, which, as demonstrated above, is not based upon personal knowledge as required by Section

309(d). Accordingly, Mr. Martinez utterly fails to present "adequate and specific factual allegations sufficient to warrant the reliefrequested.,,9 Moreover, Mr. Martinez's pleading, even ifconsidered as an informal objection, warrants no further Commission consideration.

Following Mr. Martinez' termination from WTXF-TV, he filed charges ofage and national origin discrimination with the Pennsylvania Human Relations Commission. His case was dismissed on August 7, 2006, following which he filed a civil action based on the same claim in the U.S. District Court for the Eastern District ofPennsylvania, Martinez v. Fox Broadcasting Co. and Fox Television Stations. Inc., Subsidiary station d/b/a WTFX29, Philadelphia, Civil Action No. 06-4537. Mr. Martinez appears to have been involved in several prior discrimination lawsuits including: Martinez v. Quality Value Convenience. Inc., 63 F. Supp.2d 651 (E.D. Pa. 1999) (pollak, 1.), aff'd, 216 F.3d 1076 (3d Cir. 2000); Martinez v. Capital Cities / ABC-WPVI, No. 95-2954, 1996 WL 102295, at *3 (E.D. Pa. Mar. 5, 1996) (pollak, J.), afI'd, 103 F.3d 113 (3d Cir. 1996); Martinez v. Capital Cities / ABC, ABC News and WABC-TV7, No. 95-9910 (S.D.N.Y. 1995); Martinez v. American Media, LP, aIkIa Courtroom Television Network, No. 94-314 (S.D.N.Y. 1994); Martinez v. Educational Broadcasting, aIkIa WNETl3, No. 92-04294 (S.D.N.Y. 1992); and Martinez v. Nat'l Broadcasting Co., Consumer News Business Channel CCNBC), and WNBC TV, No. 92-02477 (D. N.J. 1992).

47 USC § 309(d)(1 ).

9 Letter to John V. Oldfield, DA 07-4343 (October 19,2007); citing Area Christian Television, Inc. , 60 RR 2d 862 (1986).

3 2. Mr. Martinez's Request that the Commission Interfere with WWOR-TV's Editorial Discretion Raises Serious Constitutional Issues and. in Any Event. Is Contradicted by the Station's Exemplary Record of Service to the Hispanic Community.

Although it is extremely difficult to decipher the meaning ofmuch ofthe

Objection, it appears to allege primarily that Fox has failed to meet the programming needs ofHispanic audiences within the WWOR-TV coverage area.

As the U.S. Supreme Court has stated time and again, regulatory schemes that tread unnecessarily on the editorial discretion ofbroadcasters contravene the First

Amendment and the broadcasting industry is entitled to exercise "the widest journalistic freedom consistent with its public [duties]."lo The Commission has often noted that

"Journalistic or editorial discretion in the presentation ofnews and public information is the core concept ofthe First Amendment's Free Press guarantee, and licensees are entitled to the broadest discretion in the scheduling, selection and presentation ofnews programming.,,1l Accordingly, the Commission should flatly reject the Objection's invitation to become involved in WWOR-TV's editorial and production decisions.

In any event, Fox takes very seriously its obligations to serve the needs and interests ofall ofits viewers, including its Hispanic audience. Indeed, Mr. Martinez is apparently aware ofWWOR-TV's service to Hispanic viewers in its service area, including Northern New Jersey. The Objection refers to WWOR-TV's Lynda Lopez and the half-hour public interest programs she has supervised, "Real Talk" and "Hispanic

10 Syracuse Peace Council v. FCC, 867 F.2d 654,684 (D.C. Cir. 1989) (Starr, concurring); citing Columbia Broadcasting System. Inc. v. FCC, 453 U.S. 367,395 (1981) and Columbia Broadcasting Co. v. Dem. Nat'l Comm., 412 U.S. 94, 110 (1973).

11 Application for Renewal ofLicense, WXYZ-TV, DA 07-3084 (July 10,2007) (citation omitted); see also Renewal ofLicense ofStation WTVTCTV), DA 07-3385, ~ 17 (July 24,2007).

4 Horizons.,,12 Attached to this Opposition is a listing ofthe public affairs programming directed specifically to the Hispanic community that Ms. Lopez has produced during

WWOR-TV's most recent license tenn. Ms. Lopez has treated issues of general interest to all residents ofNorthern New Jersey, such as Medicare Part B, AIDS, the problems of the elderly, civil rights, voter registration, identity theft, and others. But Ms. Lopez has tailored the treatment ofthese important issues to the specific interests and needs ofthe

Hispanic community in Northern New Jersey. "Hispanic Horizons" has also addressed issues ofspecific interest to the Latino community: English literacy, immigration, and

Hispanic genealogy. Additionally, Ms. Lopez's programs have featured the wealth of

Hispanic arts offerings available in the area, such as the Latino Film Festival, Gospelfest, and the International Salsa Museum.

The Objection additionally notes the telecast ofthe National Puerto Rican

Day Parade on June 10,2007; coverage ofthe Ballet Hispanico on May 5, 2007; and a discussion on Puerto Rican pride on June 6, 2007. 13 Mr. Martinez objects to such issues as WWOR-TV's production budgets,14 and he actually questions whether the arts could be relevant to the Hispanic community.ls Giving any consideration to the Objection would require that the Commission become inappropriately involved in the minute editorial and production decisions ofthe station. 16

12 Objection at 8.

13 Objection at 9.

14 Objection at 8.

IS Objection at 9.

16 See Columbia Broadcasting System, Inc. v. Democratic National Committee, 412 US 94, 120-121 (1973) ("[I]t would be anomalous for us to hold, in the name ofpromoting the constitutional guarantees offree expression, that the day-to-day editorial decisions ofbroadcast licensees are subject (cant/d) 5 Finally, the Objection provides a list ofissues ofimportance that were purportedly identified by "Hispanic political and community leaders in New Jersey" but does not provide any identification ofsuch leaders or information about how the list was developed. Mr. Martinez does not claim to be an elected or appointed representative of any Hispanic organization. In any case, most ofthe "Hispanic" issues are issues of import to the general public: poverty, crime, education, government responsiveness. 17

These are issues that WWOR-TV treats frequently and regularly in its news and public affairs programming, as detailed in exhibits to the station's renewal application as well as in response to the petitions to deny and in materials prepared in conjunction with the

Commission's Public Forum held in Newark, New Jersey on November 28,2007.18

3. Other Issues Raised by the Objection are Entirely Irrelevant and, In Any Event, Utterly Unsupported.

The Objection otherwise includes a random collection ofirrelevant and unsupported assertions which require no Commission consideration. Mr. Martinez alleges that WWOR-TV has not hired a "quota" ofHispanic employees. Yet, even he appears to recognize that the Commission has no authority to enforce hiring quotas. 19 Mr.

Martinez also makes vague and unsupported allegations that because the Fox News

(eont'dfrom previous page) to the kind ofrestraints urged by respondents. .. Application ofsuch standards to broadcast licensees would be antithetical to the very ideal ofvigorous, challenging debate on issues ofpublic interest.").

17 Objection at 7.

18 See Media Bureau Docket No. 07-260. Mr. Martinez apparently attended that meeting and refers to these materials as "Key Facts." Objection, Annex 2, ~ 8.

19 Objection at 10-11. The United States Court ofAppeals for the District ofColumbia Circuit determined that several ofthe Commission's previous EEO requirements were unconstitutional. Lutheran Church - Missouri Synod v. FCC, 141 F.3d 344, pet.for rehearing denied, 154 F.3d 487, pet. for rehearing en bane denied, 154 F.3d 494 (D.C. Cir. 1998).

6 Channel on cable purportedly speaks with a single viewpoint, among other imagined infractions, WWOR-TV should be somehow held accountable.2o Thus, Mr. Martinez invites the Commission to interfere with the constitutionally protected journalistic judgment ofa non-broadcast corporate affiliate ofWWOR-TV. The Objection finally details disputes that Mr. Martinez had with his supervisor during his previous employment with Fox's Philadelphia station?l These matters are irrelevant to the

Commission's determination regarding the renewal ofWWOR-TV's broadcast license and do not even approach the delineation ofany issues that would require the

Commission's attention in this proceeding.

4. Conclusion.

The Objection completely fails to allege, much less establish, a prima facie case that WWOR-TV disregarded its obligation to serve the public throughout its license term. Moreover, it is bereft ofthe requisite support ofan affidavit based upon personal knowledge. On the contrary, Mr. Martinez bases his contentions on his alleged experience years ago at an entirely different television station. Accordingly, the

Commission should reject the Objection and deny its request for evidentiary hearings.

20 Objection at 13-14.

21 Objection, Annex 2, passim.

7 Respectfully submitted,

FOX TELEVISION STATIONS, INC. BY:C(~.--..

Molly Pauker John C. Quale Vice President David H. Pawlik FOX TELEVISION STATIONS, INC. Jared S. Sher 5151 Wisconsin Avenue, N.W. SKADDEN, ARPS, SLATE, Washington, D.,C. 20016 MEAGHER & FLaM LLP (202) 895-3088 1440 New York Avenue, N.W. Washington, D.C. 20005 Maureen O'Connell (202) 371-7000 Senior Vice President, Regulatory and Government Affairs Its Attorneys NEWS CORPORATION 444 North Capitol Street, N.W. Washington, DC 20001 (202) 824-6502

Ellen Agress Senior Vice Pn:~sident, Deputy General Counsel NEWS CORPORATION 1211 Avenue ofthe Americas New York, NY 10036 (212) 852-7204

Dated: February 7,2008

8 Representative WWOR-TV Public Affairs Programming HISPANIC HORIZONS and REAL TALK

November 4,2007 NJ Elections / Election Campaign 2008 - discussions with Assem. Joseph Cryan (Chairman, NJ Democratic State Committee), Tom Wilson (Chairman, NJ Republican State Committee), Wayne DeAngelo (Democratic Candidate for NJ Assembly), Adam Bushman (Republican Candidate for NJ Assembly), Idida Rodriguez (Democratic Strategist), and Steven Some (Republican Strategist).

October 28, 2007 New Jersey Political Races - interviews with Joseph Ferriero (Bergen County Democratic Chairman), Rob Ortiz (Bergen County Republican Chairman), State Senator Gerald Cardinale (R-NJ), Joseph Ariyan (Democratic Candidate .for State Senate, and Charles Stile (Political Stile, The Record).

September 16,2007 Hispanic Heritage - discussion with Ellie Diez, Co-Founder, Loisada Cortos Latino Film Festival. (This segment aired on "Real Talk" w/Lynda Lopez)

April 1, 2007 Jersey Guys / HPV Vaccine / Board ofEd. Kid - featured discussions with Rafael Collazo (Democracia USA), Miguel Cruz (You Don't Speak for Me), Assem. & Assem. Michael Doherty, and Michael Hughes (Running for Bd. ofEd., East Brunswick).

December 17,2006 Discussion with Senator Robert Menendez on "Real Talk" w/Lynda Lopez.

September 24, 2006 Latino Influences in Media - guests included Robert Rose, CEO ofAIM TV & Maximas Productions, Renzo Devia, President ofMaximas Productions, and Jennifer Pons, Correspondent for American Latino TV. (This segment aired on "Real Talk" w/Lynda Lopez)

September 17,2006 Latino Influences - discussions with Richard Canas - Director, NJ Office of Homeland Security - and Maria Tapia, President, Latino Gerontological Center. (This segment aired on "Real Talk" w/Lynda Lopez)

April 30, 2006 Medicare Part D- discussion with Mario Tapia - President, Latino Gerontological Center. (This segment aired on "Real Talk" w/Lynda Lopez)

November 26,2005 Interview with Congressman Robert Menendez (U.S. Senate) discussing the Democratic Federal Year in Review. (This segment aired on "Real Talk" w/Lynda Lopez)

July 10, 2005 Latinos in Technology / The Military - featured discussions with Jose Marquez, President & CEO/Founder, Latinos in Information Sciences & Technology Association (LISTA National) (New York, NY) - and Capt. Jesus Terrones, Graduate, U.S. Military Academy and Veteran, Operating Enduring Freedom 2 (West Point, NY).

1 June 12,2005 Elderly Latinos / Preserving Andean Culture - Mario Tapia, President & CEO, The Latino Gerontological Center (New York, NY) - Hugo Morales, Artistic DirectorlFounder, Festival de los Andes (Union City, NJ) - and Zenon Aranda, Director, Centro Cultural Khana (Perth Amboy, NJ).

May 8, 2005 Diversity ofHealthcare Work Force / AARP Hispanic Outreach - interviews with George Zappenfeldt-Cestero, President & CEO, National Hispanic Chamber ofCommerce on Health (New York, NY) - William Colon, Executive Director, The Latino Institute (Newark, NJ) - and Ismael Ortiz, National Director ofHispanic Membership Recruitment (Washington, DC).

April 10, 2005 Latinos & Mental Health / Latinos & Health Disparities - Frank Salano, Director, Puerto Rican Family Health InstitUte Mental Health Clinic (Jersey City, NJ) - and Lisa Obregoso, Service Coordinator, YAI National Institute for People with Disabilities (New York, NY).

March 13, 2005 Latinos and Civil Rights / Latinas in Construction - featured discussions with Frank Vespa-Papleo, Esq. - Director, NJ Division ofCivil Rights - and Rebecca Dogget - Founder, NewarklEssex Construction Careers Programs.

December 12, 2004 Ritz Theatre / Butterfly Foundation - interviews with George Castro, CEO/Owner, The Ritz Theatre and Performing Arts Center (NJ) - and Andre Moulton, MD - Founder, The Butterfly Foundation.

November 14,2004 Alzheimer's and Latinos / Puerto Rican History in New Jersey - discussions with Nellie Vaga, National Alzheimer's Association - Olga Wagenheim, PhD, Founder, Hispanic Research and Information Center (NJ) - and Ingrid Betancourt, Director, Multicultural Services, Newark Public Library.

October 10, 2004 McDonald's Gospelfest / H.A.C.E.R. Scholars - featured Juan de la Cruz, McDonald's Owner & Operator- Winners ofMcDonald's Gospelfest Awards from the Latino Community - Jennifer Padilla & Macella Garavaglia, Recipients of2003 Ronald McDonald's House Charities H.A.C.E.R. Scholarship.

September 12,2004 Immigration Security / Charter School- Carmelo Huertas, Director of Security and Investigations, NJ Motor Vehicles Commission - Michael Cutler, The Center for Immigration Studies - and Mike Pallante, Principal, Robert Treat Academy Charter School (NJ).

August 8, 2004 The Key / Prison Summit - featured interviews with Jorge Cano-Moreno, Publisher, Urban Latino Magazine - Luis Silva, Ombudsman, NJ Dept. of Corrections - and Cuqui Rivera, Outreach Supervisor, Hispanic Directors Association (NJ).

2 June 13,2004 Unsafe Remedies / Immigrant Guide - discussions with Reni Erdos, Director, NJ Division ofConsumer Affairs - Liz Sevcenko, Director ofInterpretation, Lower East Side Tenement Museum - and Emesto Ibanez, Recent Immigrant from El Salvador.

May 9, 2004 Latino Summit / Latinos and Asthma - discussions with Peter Fontanes, Founding Director, National-Latino American Summitt - Deborah Gonzalez, Director, Puerta Al Futuro, FDU - and Henry Acosta, Deputy Director, NJ Mental Health Institute.

April 11, 2004 Puerto Rican Voter Registration / Latinos and the Catholic Church - featured Gloria Soto, NJ Regional Director, Commonwealth ofPuerto Rico Federal Affairs Administration (NJ) - and Rudy Vargas, Executive Director, Northeast Hispanic Catholic Center.

March 12, 2004 Latino Astronauts / Latina Business Owners - discussions w/Daniel Lozano, NJIT and Alison Randoiph, Small Business Administration.

February 6, 2004 Identity Theft / Heart Disease - discussions with Reni Erdos - Director, NJ Division ofConsumer Affairs - and Juan Cortez, D.O. - Lutheran Medical Center, Brooklyn, NY.

January 11,2004 Dangers ofFlu / Undocumented Workers - guests included Juan Carlos Gil, MD ofSt. Joseph's Regional Medical Center, NJ and Michael Cutler - Former Senior Immigration & Naturalization Service Agent, The Center for Immigration Studies.

December 14, 2003 Ida Castro talks about her life, goals and role as the first Latino Commissioner ofthe New Jersey Department ofPersonnel.

November 9,2003 Asela Laguna-Diaz - Professor ofModem Languages at Rutgers University­ discusses the events, festivals and parades in New Jersey as Latinos celebrate Hispanic Heritage Month.

September 15,2003 Lizette Delgado, Asst. Secretary of State ofNew Jersey, and Daniel Santo Pietro, Director ofthe Hispanic Directors Association ofNew Jersey discuss the importance ofenrolling children in the state's free quality preschool.

July 13, 2003 Anna Rivera, Outreach Supervisor ofthe Hispanic Directors Association of New Jersey and Irene Rosas-Cabezas, Director ofHIV testing Services in Newark, discuss the growing problem ofHIV among Latin woman.

June 8, 2003 Daniel Santo Pietro - Executive Director ofthe Hispanic Directors Association ofNew Jersey - discusses the lack ofstate funding for Hispanic organizations in New Jersey.

3 April 13, 2003 Artist Duda Penteado, who is also the Director ofthe Hope Center Art Academy in New Jersey, discusses mentoring abused children who attend the Academy and teaching them the craft ofpainting.

March 9,2003 Hispanic Foster Families / Women's History Month - discussion with Doris Capello, PhD - Child Advocacy and Resource Association ofNJ - and Deborah Rosado-Shaw, Author "Dream Big"

February 9,2003 Carlomagno Ontaneda - Director ofthe Educational Opportunity Program at NJIT - talks about how many inner-city schools are not giving students the proper math and science preparations to pursue careers in engineering.

January 12,2003 Rosemary Crespo ofthe Hyacinth AIDS Foundation in New Jersey explains how Latin women continue to be at higher risk ofcontracting the AIDS virus than white women.

December 8, 2002 Martha Bahamon - Director ofResource Development ofthe United Way in New Jersey explains how donations to charities and philanthropic efforts in NJ and nationwide are at an all-time low after September 11 th.

October 11,2002 Latinos and Autism / Hispanic Genealogy - discussion with Claudia Moreno, PhD - NJ Center for Outreach and Services for the Autism Community - and Ann-Margaret Feliciano - Hispanic Genealogy Society ofNY.

August 11, 2002 Gloria Soto from the Commonwealth ofPuerto Rico Federal Affairs Administration in New Jersey discusses increasing Puerto Rican voter registration in NJ and nationwide.

July 14,2002 Mario Vargas ofNew Jersey Reads discusses increasing English literacy among Latinos in the state ofNew Jersey.

June 9, 2002 A one-on-one interview with Jose Torres - Paterson's first Latino Mayor.

April 14, 2002 Latinas and Folic Acid - guests ofthe show included Alexandra Pontoreiro­ Outreach Director, Hudson Prenatal Consortium - and Yvonne Ortiz-Haney­ Community Director, March ofDimes ofNorthem New Jersey.

March 10, 2002 Latina Heroes of9-11 - discussions with Juana Lomi, Paramedic, New York University Downtown Hospital, New York, NY and Maria Avila, Volunteer with Queens Disaster Action Team, American Red Cross ofGreater New York. December 9, 200] Henry Acosta, Director ofthe New Jersey Mental Health Institute discusses the impact ofthe World Trade Center attacks on New Jersey Latinos.

October 14,2001 Immigration Reform - discussion with Andrea Quarantillo, Immigration & Naturalization Services and Rep. William Pascrell (Democrat), District 8.

4 Juan Jimenez ofthe Dominican Empowerment Political Action Committee in Union discusses the Dominican influence in New Jersey.

July 8, 2001 NJ Assemblyman Wilfredo Caraballo discusses Latinos and the Census in the state ofNew Jersey.

June 10,2001 The Battle for Vieques featuring Anthony Cruz, Pro-Vieques Committee of Hudson County, Jersey City, NJ.

May 13,2001 Ileana Montes ofthe Hispanic Bar Association on New Jersey discusses discrimination during the election process and the importance ofprotecting Latino voters.

April 8, 2001 Dr. Ana Natale-Pereira ofthe Focus Community Health Center in Newark discusses the low rate of immunizations in Latino children.

March 11,2001 Dr. Roberto Roberti ofMid-Atlantic Cardiology in Springfield, NJ discusses the growing epidemic ofType 2 diabetes in young Latino children.

February 11,2001 Joe Hernandez ofthe International Salsa Museum in Washington Township discusses preserving salsa music and traditions.

January 14,2001 Tina Morales ofthe North Hudson Community Action Corporation in West New York discusses new protections for immigrant women in New Jersey.

5 CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy ofthe foregoing

"Opposition to Informal Objection" has been served by first-class mail, postage prepaid (except where otherwise indicated below), as ofthe 7th day ofFebruary,

2008, on the following persons at the address shown below:

Monica Desai,* Barbara Kreisman,* Clay Pendarvis,* Federal Communications Commission Media Bureau 445 1ih Street, S.W. Washington, D.C. 20554

Aristides Martinez 157 North Post Road Princeton Junction, NJ 08550 ,~-'/ft,~~ Katherine M. Coughlan'

* served via electronic mail

811910.04-D.C. Server lA - MSW