FCC 95D-09 Federal Communications Commission Record 10 FCC Red No. 18
Before the
Federal Communications Commission 
Washington, D.C. 20554
MM Docket No. 93-265
In re Application of
PINE TREE 
MEDIA, INC.
File No. BR-900817UF
For Renewal of License of Station KARW 
Longview, Texas
Appearances
Dennis J. Kelly, Esq. on behalf of Praise Media, Inc.; 
Gary P. Schonman, Esq. and Robert A. Zauner, Esq. on 
behalf of the Mass Media Bureau, Federal Communications 
Commission.
INITIAL DECISION OF ADMINISTRATIVE LAW 
JUDGE JOHN M. FRYSIAK
Issued: August 15,1995; Released: August 21,1995
(5) To determine, in light of the evidence adduced 
pursuant to the foregoing issues, whether the applica 
tion of Pine Tree Media, Inc. for renewal of license 
of Station KARW should be granted.
2. The HDO, at Section 16, placed the burden of pro 
ceeding with the introduction of evidence and the burden 
of proof on "Pine Tree Media, inc., its successors or as 
signs, and/or those now in control of Pine Tree Media, 
Inc., as appropriate."
3. By Order, FCC 95M-64 (released March 2, 1995), the 
Presiding Judge added the following issues against Pine 
Tree:
(1) To determine whether Pine Tree has the capabil 
ity and intent to expeditiously resume broadcast oper 
ations of KARW(AM) consistent with the 
Commission's Rules.
(2) To determine whether Pine Tree has violated 
Sections 73.1740 and/or 73.1750 of the Commission's 
Rules.
(3) To determine, in light of the evidence adduced 
pursuant to the foregoing issues, whether Pine Tree is 
qualified to be and remain the licensee of Station 
KARW(AM).
4. Hearings on all of the issues were held in Washington, 
D.C., on March 21-22, 1995. The record in this proceeding 
was closed on May 24, 1995. See Order, FCC 95M-132 
(released May 26, 1995).
PRELIMINARY STATEMENT
1. By Hearing Designation Order and Notice of Forfeiture, 
8 FCC Red 7591 (1993) ("HDO"), the Commission des 
ignated the application of Pine Tree Media, Inc. ("Pine 
Tree") for renewal of license of Station KARW(AM), Long- 
view, Texas, for hearing on the following issues:
(1) To determine whether one or more unauthorized 
transfers of control of Pine Tree Media, Inc. occurred 
in violation of Section 310(d) of the Communications 
Act of 1934, as amended, and Section 73.3540 and/or 
Section 73.3541 of the Commission's Rules.
(2) To determine whether Pine Tree Media, Inc. 
and/or persons acting on its behalf misrepresented 
facts in the station's 1990 renewal application.
(3) To determine whether Pine Tree Media, Inc. 
and/or persons acting on its behalf violated Section 
73.1015 of the Commission's Rules by failing to re 
spond fully to Commission correspondence dated 
September 9, 1992, September 23, 1992, December 3, 
1992, and/or February 10, 1993.
(4) To determine whether Station KARW is in com 
pliance with the following Commission rules: Section 
1.1307(b) (Environmental Assessment); Section 17.21 
through 17.23 (tower painting); Section 73.932 
(emergency broadcast equipment); Section 73.1745(a) 
(transmitter power); Sections 73.1800 and 73.1820 
(station logs); and Section 73.3526 (public file).
FINDINGS OF FACT
Transfer of Control Issue
5. On November 10, 1988, the Commission granted an 
application for consent to the transfer of control of Pine 
Tree Media, Inc. ("Pine Tree") from Herbert Wren 
("Wren") and Earl Jones ("Jones") to Kenneth Tuck 
("Tuck"). Wren, Jones, and Tuck consummated the trans 
fer of control on December 12, 1988. No ownership report 
was filed. Tuck apparently died sometime in May 1990 
(MMB Ex. 1, pp. 1 and 2).
6. Thereafter, on May 17, 1990, the promissory note 
made by Tuck in payment for the stock of Pine Tree and 
assets of KARW(AM) was transferred by Wren and Jones to 
American Plastics Products, Inc. ("American Plastics"). As 
consideration for the transfer of the Tuck note to Ameri 
can Plastics, Wren and Jones received a promissory note 
from American Plastics. American Plastics subsequently 
foreclosed on the Tuck note, acquired the stock of Pine 
Tree and the assets of KARW(AM), and commenced op 
erating the station. No application for consent to the trans 
fer of control of Pine Tree was filed with the Commission 
(MMB Ex. 1, p. 2).
7. On August 6, 1991, Wren and Jones foreclosed on the 
American Plastics note, reacquired the stock of Pine Tree 
and the assets of KARW(AM), and took over the operation 
of the station. No application for consent to the transfer of 
control of Pine Tree was filed with the Commission (MMB 
Ex. 1, pp. 2 and 3).
8. On February 10, 1992, Eugene Washington and Ray 
Lee Williams, acting on behalf of Praise Media Inc. 
("Praise Media"), executed several documents evidencing
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10 FCC Red No. 18 Federal Communications Commission Record FCC 95D-09
the purchase from Wren and Jones of certain real and 
personal property comprising KARW(AM) (Praise Ex. 2, p. 
5; MMB Ex. 1, Attachment 5). After the transaction was 
consummated, Praise Media began operating KARW(AM) 
(Praise Ex.. 2, pp. 6-7). No application for consent to the 
assignment of license of KARW(AM) to Praise Media was 
filed with the Commission (Praise Ex. 2, p. 6). It was then 
the belief of Janet Washington, Praise Media's third princi 
pal, that the license could be transferred to Praise Media at 
some unspecified time after Praise Media had paid off its 
note in full to Wren and Jones (Praise Ex. 2, p. 6).
9. Praise Media was incorporated on March 19, 1992 in 
the state of Texas. Initially, Eugene Washington was Presi 
dent, Ray Lee Williams was Vice President and Janet 
Washington was Treasurer. Although the company never 
issued any stock certificates, the planned ownership struc 
ture was for Mr. Washington to own 60 percent of Praise 
Media, Ms. Washington to own 15 percent of Praise Media 
and Williams to own 25 percent upon contributing cash or 
allowing the station to retain his commissions for any 
advertising sales made by him. Williams made no cash 
contributions under either option, and he is no longer 
considered a Praise Media shareholder. Mr. Williams was 
voted out of his position as Vice President in December, 
1992 (Praise Ex. 3, p. 1).
10. At present, Ms. Washington is the only active owner, 
officer or director of Praise Media. Mr. Washington was 
incarcerated on drug charges (Praise Ex. 3, p. 1). On July 
22, 1994 he gave to Ms. Washington a "Power of Attorney" 
giving her plenary authority over his property situated inter 
alia in Longview, Gregg County, Texas, and further au 
thorized her to operate and conduct the business of Praise 
Media and KARW(AM) Radio Station, situated in Long- 
view, Gregg County, Texas (Praise Ex. 12, p. 2). A quit 
claim deed was filed in Gregg County, Texas conveying Mr. 
Washington's interest in the station to Ms. Washington (Tr. 
71-72), and Mr. Washington is being formally removed as 
an officer of Praise Media (Praise Ex. 3, p. 1; Tr. 72).
11. Ms. Washington, the only individual to testify at the 
hearing, has no personal knowledge about events which 
preceded Praise Media's involvement in KARW(AM). Nei 
ther Wren nor Jones nor any principal of Pine Tree or 
American Plastics offered any testimony or other evidence 
under this issue.
Misrepresentation Issue
12. On August 17, 1990, the captioned application for 
renewal of license of KARW(AM) was filed with the Com 
mission. The applicant in the renewal application is iden 
tified as "KLGV - Ken Tuck - Pine Tree Media, Inc." 1 The 
application bears the signature of "Robert D. Murray" who 
is identified on the form as "General Manager" of the 
station (Praise Ex. 6, Attachment A).
13. Although the renewal application references "Ken 
Tuck" and "Pine Tree," Tuck apparently had died several 
months before the renewal application was filed, and 
American Plastics, not Pine Tree, was operating 
KARW(AM) at the time the renewal application was sub 
mitted to the Commission. Murray was never a principal of 
Pine Tree, and the record is silent as to the nature of his 
role in American Plastics beyond that of General Manager 
of KARW(AM). Praise Media disavows any knowledge
about events surrounding the filing of the renewal applica 
tion, and neither Murray nor anyone else associated with 
American Plastics offered any evidence under this issue 
(Praise Ex. 6).
Failure to Respond to Commission Correspondence
14. On September 9, 1992, the Commission directed a 
letter of inquiry to Mr. H. E. Ferrell, c/o Pine Tree Media, 
Inc., regarding KARW(AM). The letter sought, among oth 
er things, to ascertain whether an unauthorized transfer of 
control of KARW(AM) had occurred. Praise Media was 
operating KARW(AM) at the time, and Janet Washington 
received the letter of inquiry. Because the letter was ad 
dressed to Pine Tree rather than Praise Media, and it 
pertained to activities at KARW(AM) which preceded 
Praise Media's involvement at the station, Janet Washing 
ton decided it was unnecessary to respond to the letter 
(Praise Ex. 4, p. 1; MMB Ex. 1, pp. 45-47).
15. On September 23, 1992, the Commission directed a 
second letter of inquiry to Pine Tree. The second letter 
notified Pine Tree of a deficiency in the pending renewal 
application for KARW, and it requested the station to 
submit "appropriate corrective amendments." It also noted 
that prior attempts to communicate with the licensee had 
been unsuccessful and requested information as to whether 
the station was still operating. Janet Washington received 
the second letter of inquiry and forwarded it to Eugene 
Washington in Chicago. Praise Media did not respond to 
this letter (Praise Ex. 4, p. 2; MMB Ex. 1, pp 49-50).
16. On December 3, 1992, the Commission directed a 
third letter to Pine Tree regarding KARW(AM). In its third 
letter, the Commission requested a response to the first 
(September 9, 1992) letter, and advised that failure to 
respond to that letter within 15 days could result in the 
imposition of sanctions. The Commission also noted that it 
views a failure to respond to official correspondence as a 
serious matter. Janet Washington received the third letter 
of inquiry and forwarded it to Eugene Washington in 
Chicago. Nearly two months later the Mass Media Bureau 
("MMB") received a letter, dated January 26, 1993, from 
Praise Media. In addition to being unsigned, Praise Media's 
letter failed to respond to several of the questions that the 
licensee had been directed by the Commission to answer in 
the three letters of inquiry (Praise Ex. 4, pp. 2 and 3; 
MMB Ex. 1, pp. 52-53 and 55-78).
17. On February 10, 1993, the Commission sent a fourth 
letter of inquiry to Pine Tree regarding KARW(AM). The 
fourth letter included copies of the previous three, and it 
identified the specific deficiencies in Praise Media's Janu 
ary 26, 1993, correspondence. It noted, for example, that in 
response to a request to identify the principals of Pine 
Tree, Praise Media had responded "See enclosed letter." 
But no letter was enclosed. Pine Tree was warned that 
failure to respond within 15 days to the Commission's 
fourth letter could result in the imposition of administra 
tive sanctions, including designation for hearing. Praise 
Media did not respond to this fourth letter. According to 
Janet Washington, she did not respond because she had no 
additional information to provide (Praise Ex. 4, p. 3; MMB 
Ex. 1, pp. 80-82).
The station's call sign was formerly KLGV.
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FCC 95D-09 Federal Communications Commission Record 10 FCC Red No. 18
Technical Issues
18. Praise Media presented no evidence to meet its bur 
dens under this issue insofar as the licensee's compliance with Section 1.1307(b) 
(Environmental Assessment) is con 
cerned. Praise Media does maintain, though, that it has 
properly painted its tower, in compliance with Section 17.21 through 17.23 
of the Commission's Rules; installed 
Emergency Broadcast System equipment, in compliance 
with Section 73.932 of the Commission's Rules; monitored 
and regulated (until such time as the station went off the air) KARW(AM)'s 
transmitter power, in compliance with 
Section 73.1745(a); and ensured that KARW(AM)'s trans mitter logs (until 
such time as the station went off the air) 
and public inspection file comply with Section 73.1800, 
73.1820 and 73.3526 of the Commission's Rules (Praise Ex. 5, p. 1).
Resumption of Operations Issue
19. On September 13, 1994, KARW(AM) went off the air 
because of vandalism and equipment problems (Tr. 220-222). Station 
KARW(AM) returned to the air at the 
end of September or the beginning of October. After a few 
weeks, the station went off the air again because of me chanical problems. 
On November 18, 1994, before the 
problems could be rectified, Southwestern Electric Power Company ("SWEPCO") 
disconnected electric power to the 
station because of non-payment by Praise Media of its 
electric bills (MMB Ex. 3). Thus, KARW(AM) has re 
mained silent ever since.
20. Janet Washington estimates that to put the station back on the air Praise 
Media will require at least $30,000 
to purchase a replacement transmitter and other materials 
(Tr. 240, 242). Initially, Janet Washington testified that she had already placed 
money in escrow to purchase the neces 
sary equipment (Tr. 93). However, she subsequently tes 
tified that she did not have money in escrow with which to put the station back 
on the air (Tr. 237). Janet Washington 
also testified that Praise Media had already received a loan 
from a lending institution (Tr. 224-225). However, docu ments relating to 
this loan establish that Praise Media has 
only applied for a loan (Praise Exs. 9-11). Janet Washing 
ton also testified that she has arranged for a loan from an undisclosed friend 
(Tr. 237). However, she has received 
nothing in writing from the friend indicating his willing 
ness to provide Praise Media with any money. Other than 
Janet Washington's testimony, Praise Media offered nothing 
to support the availability of this loan (Tr. 239). Further 
more, Janet Washington concedes that neither she nor Praise Media has 
any present intention of spending any 
money for the purpose of putting KARW(AM) back on the 
air until the status of the station's license is resolved in Praise Media's favor 
(Tr. 93, 222, 241).
Silent Station Rules Issue (Section 73.1740 and 73.1750)
21. Although Janet Washington on September 12, 1994, 
prepared a brief letter notifying the Commission that "due 
to vandalism and theft of equipment," KARW(AM) was off 
the air and would remain silent until the stolen equipment 
was replaced (Praise Ex. 7), the correspondence was never 
filed with the Commission. Janet Washington also tele 
phoned the Commission in an attempt to orally inform the 
agency that KARW(AM) had ceased operations. Although 
she spoke with Commission employees in several different 
offices, Janet Washington was not successful in finding the 
correct office to inform (Tr. 83-90; Praise Ex. 7).
Lack of Candor/Misrepresentation
22. The MMB advances that misrepresentation and lack of candor findings regarding Janet Washington's testimony 
at the hearing should be made. The MMB maintains that 
Janet Washington lacked candor in her testimony about the availability of 
a loan to help restore KARW(AM) to 
operational status and dissembled concerning 
KARW(AM)'s silent status, her lawsuit against electric company official and 
her husband's incarceration.
23. Although no misrepresentation/lack of candor issues 
had been specified against Praise Media and Janet Washing 
ton, it is axiomatic that the credibility of a witness is always at issue. No issue 
need be specified in this respect. See 
RKO General, Inc., 78 FCC 2d 104 (1980). A misrepresen 
tation is a false statement of fact made with the intent to conceal. Lack of 
candor involves concealment, evasions 
and other failures to be fully informative. See Fox River 
Broadcasting, Inc., 93 FCC 2d 127 (1983).
24. Availability of Loan. At Tr. 224-225, Janet Washing ton alleged that she 
had a loan in place to help restore 
KARW(AM) to operational status. However, the documents 
she produced in support of this assertion (Exhibits 9, 10 and 11) indicate only 
that Janet Washington applied for a 
loan. At Tr. 92 and 95, Janet Washington alleged that she had invested nearly 
$200,000 in the radio station since taking it over. Later in her testimony she 
disclosed that of 
the $200,000 mentioned, $20,000 came from Don Grant 
who gave her the money in a single lump sum which she counted out (Tr. 
192-95). However by letter dated May 19, 
1995, counsel for Praise Media stated that Don Grant's 
loan was not made all at once, but over time (MMB Ex. 
10, p. 1; Tr. 320-21).
25. KARW(AM)'s Silent Status and Lawsuit Against 
Birdsong. At Tr. 149-150, Janet Washington testified that KARW(AM) continued 
to receive electric power after No vember 18, 1994. She claimed to have had 
personal knowl 
edge that the electricity was on when she visited 
KARW(AM) in December 1994 (Tr. 142-143). After testify ing that the station 
had power in December, Janet Wash 
ington was shown a letter, dated January 26, 1995, from B. 
M Birdsong, Area Manager for SWEPCO. In his letter Mr. 
Birdsong stated that electric power to KARW(AM) had 
been off continuously since November 18, 1994 (MMB Ex. 
3). Janet Washington claimed that the letter was "totally 
incorrect;" she attacked Birdsong personally, asserting that 
"this is why Mr. Birdsong is going to court;" and she 
testified unequivocally that Birdsong "is currently being 
sued" by her for informing the Commission that the sta 
tion was off the air because of lack of electricity. The next 
day, however, Janet Washington returned to the witness stand and conceded 
that KARW(AM) was in fact without any electric power during the month 
of December (Tr. 
132, 158). Further, she testified that she has no lawsuit pending against the 
SWEPCO official (Tr. 290).
26. Eugene Washington's Incarceration. Janet Washington 
indicated that Eugene Washington was unavailable to 
testify in this proceeding because he is incarcerated. When pressed as to why 
her husband is in prison, Janet Washing 
ton claimed that she did not know the reason for his 
incarceration. However, in direct written testimony given months earlier, Janet 
Washington had represented that Eu gene Washington is serving time in a 
federal prison on 
drug-related charges (Praise Ex. 3, p. 1). The next day, while still claiming she did not know the "exact reason"
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10 FCC Red No. 18 Federal Communications Commission Record FCC 95D-09
for Eugene's incarceration, she testified that the charge was "[a] drug conspiracy, wire tapping or 
something like that." 
(Tr. 290).
CONCLUSIONS OF LAW
Transfer of Control Issue
27. Pine Tree is the licensee of record. It is undisputed 
that an unauthorized transfer of control occurred in 1990 
when American Plastics took over KARW(AM) and in
1991 when Wren and Jones reacquired the station. Praise 
Media acquired control of KARW(AM) on February 10,
1992 and it readily concedes that the Commission never 
approved this transfer.
28. Section 310(d) of the Communications Act of 1934, as amended, states in pertinent part:
No construction permit or station license, or any 
rights thereunder, shall be transferred, assigned, or 
disposed of in any manner, voluntarily or involuntar ily, directly or indirectly, or by transfer 
of control of 
any corporation holding such permit for license, to 
any person except upon application to the Commis 
sion and upon rinding by the Commission that the 
public interest, convenience, and necessity will be 
served thereby.
29. It follows that each of the above cited transfers was 
made in violation of Section 301(d) of the Communica 
tions Act of 1934, as amended. The transfer of control must be and 'IS RESOLVED against Pine 
Tree and against Praise 
Media.
Misrepresentation Issue
30. The misrepresentation issue deals with the allegations made in the renewal application for 
KARW(AM) filed on 
August 17, 1990. Pine Tree did not appear in this proceed ing and did not otherwise respond 
to this issue. This issue 
IS RESOLVED against Pine Tree.
31. This misrepresentation issue specified in the HDO 
does not concern Praise Media since Praise Media was in 
no way involved in the preparation or filing of the renewal application for KARW(AM).
Failure to Respond to Commission Correspondence
32. The record reflects that the Commission directed 
mailings to Pine Tree Media on September 9, 1992, Sep 
tember 23, 1992 and December 3, 1992. Janet Washington 
disregarded the first mailing because it was not addressed to 
her even though Praise Media claims to be a successor in interest to Pine Tree Media. She forwarded the other two 
mailings to Eugene Washington in Chicago. Praise Media 
finally filed a response, though incomplete, on January 26, 1993. A fourth Commission letter 
was sent February 10, 
1993, but Praise Media did not respond to this letter.
33. Section 73.1015 of the Commission's Rules provides:
The Commission or its representatives may, in writ ing, require from any applicant, 
permittee, or li censee written statements of fact relevant to a 
determination whether an application should be
granted or denied, or to a determination whether a license should be revoked, or to 
any other matter 
within the jurisdiction of the Commission ....
34. All of the Commission's letters addressed important 
and urgent matters. They also warned the addressee of dire 
consequences upon failure to respond. Praise Media as 
successor to Pine Tree Media was grossly negligent in failing to respond promptly and correctly 
to the Commis 
sion's inquiries. Janet Washington's failure to respond to 
official Commission inquiries manifests that she is 
unreliable and renders Praise Media unfit to hold the 
KARW(AM) license. The issue IS RESOLVED against 
Praise Media.
Technical Issue
35. Praise Media's allegations that it has complied with 
Sections 17.21 through 17.23 (tower painting); Section 
73.932 (emergency broadcast equipment); Section 73.1745(a) (transmitter (power); 
Sections 73.1800 and 
73.1820 (station logs); and Sections 73.3526 (public file) 
have not been challenged. Praise Media, however, has failed to provide the Environmental 
Assessment required 
by Section 1.1307(b) of the Commission's Rules and the 
MMB requests that any grant herein should be conditioned on Praise Media submitting a proper 
Environmental As 
sessment. The issue IS RESOLVED favorably except that 
the Environmental Assessment is still outstanding.
Resumption of Operations Issue
36. Station KARW(AM) has been off the air since at least 
November 18, 1994, in part, because Praise Media cold not 
afford to pay the station's electric bill. The record shows that Praise Media does not have the 
present wherewithal to 
restore station operation nor is Janet Washington inclined 
to restore station operation pending the resolution of the license status. Praise Media is in 
no position to expedi- 
tiously return KARW(AM) to the air. The issue IS RE 
SOLVED against Praise Media.
Silent Station Rules Issue
37. The record is clear that although she may have tried, 
Janet Washington failed to notify the Commission that 
KARW(AM) went off the air on September 13, 1994. Fur thermore at no time did Praise Media 
request authority 
from the Commission for KARW(AM) to remain silent 
beyond 30 days. These failures are clearly in violation of 
the Commission's Rules. Section 73.1740(a)(4) of the Com 
mission's Rules provides that:
In the event that causes beyond the control of a licensee make it impossible to adhere 
to the operat ing schedule of this section or to continue operating, 
the station may limit or discontinue operation for a 
period of not more than 30 days without further authority from the FCC. Notification 
must be sent to 
the FCC in Washington, D.C. not later that the 10th 
day of limited or discontinued operation. During such period, the licensee shall continue 
to adhere to the requirements in the station license pertaining to 
the lighting of antenna structures. In the event nor mal operation is restored prior to 
the expiration of 
the 30 day period, the licensee will so notify the FCC 
of this date. If the causes beyond the control of the licensee make it impossible to comply within the
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FCC 95D-09 Federal Communications Commission Record 10 FCC Red No. 18
allowed period, informal written request shall be 
made to the FCC no later than the 30th day for such 
additional time as may be deemed necessary.
Section 73.1750 provides:
The licensee of each station shall notify the FCC in 
Washington, D.C. of permanent discontinuation of 
operation at least two days' before operation is dis 
continued. Immediately after discontinuance of op 
eration, the licensee shall forward the station license 
and other instruments of authorization to the FCC, 
Washington, D.C. for cancellation.
The issue IS RESOLVED against Praise Media.
Testimony - Misrepresentation/Lack of Candor
38. The record indicates that Janet Washington has made 
numerous false statements during her testimony. The state ments were made to mislead the Commission into acting 
favorably on the issues specified in this proceeding. Al 
though some false statements were recanted or modified, 
the overall demeanor of this witness manifested that she 
cannot be relied upon to be at all times truthful. In light of 
this, it is concluded that Janet Washington d/b/a Praise Media is not qualified to be a Commission licensee.2
ULTIMATE CONCLUSIONS
39. Pine Tree has not appeared in this proceeding to 
address the issues specified against it. The record is clear 
that Pine Tree, without Commission authority transferred 
control of its license twice; once to American Plastics and 
then to Praise Media. The record also contains ample 
evidence that Praise Media, the alleged successor to Pine 
Tree, is not qualified to be a Commission licensee.
Accordingly, IT IS ORDERED that unless an appeal 
from this Initial Decision is taken by a party, or the 
Commission reviews the decision on its own motion in 
accordance with Section 1.276 of the Rules, the renewal 
application of Pine Tree Media, Inc. (File No. BR- 
900817UF) and its alleged successor in interest, Praise Me 
dia, Inc. IS DENIED.3
FEDERAL COMMUNICATIONS COMMISSION
John M. Frysiak 
Administrative Law Judge
2 Praise Media argues that Praise Media's rule violations should 
be overlooked because they are no more egregious than the violations of applicants in certain other cases where the Com 
mission resolved the specified issues favorably. The cases cited 
in support are totally inapposite. None bear the least resem 
blance to the fact situation herein. Praise Media's argument is
deemed specious and is rejected.
3 In the event exceptions are not filed within 30 days after the release of this Supplemental Initial Decision and the Commis 
sion does not review the case on its own motion, this Sup 
plemental Initial Decision shall become effective SO days after 
its public release pursuant to Rule 1.276(d).
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