Before the Federal Communications Commission Washington, DC ) ) ) ) ) )
|
|
- Ernest Dalton
- 5 years ago
- Views:
Transcription
1 Before the Federal Communications Commission Washington, DC Jn the Matter of TRACFONE WIRELESS, INC. Petition for Declaratory Ruling Docket No SUPPLEMENT TO EMERGENCY PETITION FOR DECLARATORY RULING AND, IN THE ALTERNATIVE, PETITION FOR RULEMAKING TracFone Wireless, Inc. ("TracFone" hereby supplements its emergency petition for declaratory ruling filed with the Commission on October 23, Introduction In that Emergency Petition, TracFone asked that the Commission preempt state laws which impose state 911 fees and taxes on no charge Lifeline services, funded entirely by the federal Universal Service Fund ("USF" such as TracFone's SafeLink Wireless Lifeline service. As described in that Emergency Petition, such state Jaws undermine the goals and purposes of the federal Lifeline program by reducing the amount of the Lifeline benefit available to qualified low-income households below the level mandated by the Commission's rules. The Emergency Petition described how the Commission could lawfully exercise its authority to preempt such state laws under the Supremacy Clause of the Constitution of the United States, and under Section 253 of the Communications Act of 1934, as amended. 1 I 47 U.S.C. 253.
2 The Emergency Petition described how several states, including Alabama and Indiana, have attempted to construe and enforce state 911 tax laws in a manner which requires Lifeline service providers either to collect from their Lifeline customers state 911 taxes or to pay those state taxes themselves on behalf of their Lifeline consumers out of the service providers' own resources. As noted in the Emergency Petition, the Alabama 911 tax of $ per customer per month constitutes a tax of nineteen percent on the federally-mandated $9.25 Lifeline benefit provided to that state's Lifeline customers. The Indiana monthly 911 tax of $0.50 results in a tax of six percent on federal Lifeline service benefits in that state. Although a state-imposed tax of six percent is less burdensome on low-income Lifeline households and on the providers who serve those low-income households than is a state tax of nineteen percent, it is no less unlawful and is no less improper. Moreover, in both situations, the ultimate result is to reduce the amount of the federal Lifeline benefit available to the enrolled Lifeline households below the support amount codified in the Commission's rules. Irrespective of whether such state-imposed taxes and fees are paid by Lifeline customers or are paid by providers, the consequence is the same: the amount of Lifeline support from the USF provided to enrolled customers and actually received by those enrolled customers is reduced below the prescribed monthly Lifeline support amount codified in the Commission's rules, specifically Section (a(l. 2 By public notice, the Commission invited comment on TracFone's Emergency Petition. 3 Comments were filed both in support of the Emergency Petition and in opposition thereto. Not surprisingly, several of the most vociferous opposing parties were state 911 authorities from the 2 47 C.F.R (a(l. 3 Public Notice - Wireline Competition Bureau Seeks Comment on TracFone Wireless, Inc. Emergency Petition for Declaratory Ruling, WC Docket No , DA , released November 7,
3 states which have sought to impose 911 taxes on no charge Lifeline service. Much of the basis for that opposition focused on whether the Commission has the authority to preempt state tax laws in these circumstances. TracFone continues to believe that both the Supremacy Clause and Section 253 of the Communications Act afford the Commission more than ample authority to preempt those state laws which undermine the federal Lifeline program and that preemption would be appropriate and fully justifiable in these circumstances. Nonetheless, TracFone is mindful of the fact that any attempt to preempt state laws invites challenge and that the Commission may be reluctant to exercise its preemption authority in this situation. For that reason, TracFone, in this supplement/petition for rulemaking, proposes an alternative course for ensuring that Lifeline consumers in all states receive the full amount of federal Lifeline support from the USF which the law requires, and that telecommunications carriers providing Lifeline service not be forced by state govenunents to bear an undue economic burden in order to provide federally-supported Lifeline service in any state, including Alabama and Indiana. Petition for Rulemaking As an alternative to preempting state tax laws, TracFone respectfully proposes that the Commission exercise its rulemaking authority and promulgate appropriate rule revisions. Such rule revisions would prohibit any state from requiring Eligible Telecommunications Carriers ("ETCs" operating in that state to collect from their Lifeline customers state or local taxes where such tax collection would result in Lifeline customers having to contribute any portion of their federally-mandated Lifeline benefit to pay any state or local tax or fee where the effect of such taxation would be to reduce the net Lifeline support received by the Lifeline customer below the support level mandated by the Commission. A parallel Commission rule would also prohibit any state from requiring any ETC to pay any state tax or fee on behalf of the ETC's 3
4 Lifeline customers where the effect would be to place additional financial requirements on the ETC's provision of federally-funded Lifeline service. Specifically, TracFone proposes the following additions to the Commission's rules: 1. At the end of Section (a(l, insert the following language: No State may require an ETC either to collect from any Lifeline subscriber any state or local tax or fee or to pay on behalf of any Lifeline customer any state or local tax or fee that has the direct or indirect effect of decreasing the amount of Lifeline support received by a qualified enrolled Lifeline subscriber for the provision of voice telephony service. 2. Add new subsection (b(3 which would state as follows: All Lifeline subscribers must receive a Lifeline discount equal to $9.25 per month, or such other amount as the Commission sets forth in its rules. Lifeline service may not be subject to state or local taxes or fees that directly or indirectly decrease the amount of the Lifeline discount below the amount required by the Commission's rules. For those Lifeline subscribers who receive their Lifeline benefit in the form of no charge service, any requirement that such subscribers pay any State or local tax or fee constitutes a prohibited decrease in the amount of the Lifeline discount without regard to whether the tax or fee is paid by the subscriber or by an ETC on behalf of the subscriber. The purpose for the proposed rule revisions set forth above is limited. That purpose would be to preclude states from imposing state and local taxes and fees on a federal benefit where the result of such state or local taxation would be to reduce that benefit below the federally-mandated level. These rule revisions, though modest, are necessary and appropriate to ensure that qualified low-income households enrolled in the federal Lifeline program receive the full federal Lifeline benefit to which they are entitled without regard to which state in which they reside, and that no state may reduce federal Lifeline benefits received by Lifeline consumers in that state by taxing those benefits. There is precedent for federal governmental departments promulgating regulations which forbid state and local taxation of federal program benefits. For example, the United States Department of Agriculture (USDA has promulgated a regulation which explicitly prohibits state 4
5 and local taxation of Supplemental Nutrition Assistance Program ("SNAP" - formerly known as the Food Stamp Program benefits. That USDA regulation provides that a "State shall not participate in the Food Stamp program if State or local sales taxes or other taxes or fees, including but not limited to excise taxes, are collected within the State on purchases made with Food Stamp coupons." 4 That USDA rule was promulgated pursuant to 7 U.S.C. 2013(a. That statute prohibits states from participating in SNAP if State or local sales taxes are collected on food purchases made with program benefits. Alabama - one of the two states which are now attempting to tax federal Lifeline benefits - challenged the constitutionality of the prohibition on state taxation of federal benefits. The United States Court of Appeals for the Eleventh Circuit rejected Alabama's challenge to that prohibition. 5 Like SNAP/Food Stamps, Lifeline is a federal benefit program available in all fifty states (including Alabama and Indiana as well as in the District of Columbia and Puerto Rico. The court of appeals in State of Alabama v. Lyng concluded correctly that subjecting Food Stamp purchases to state tax would result in an indirect subsidy by the federal government to the states. As with Food Stamps, Lifeline providers receive federal funds in the form of support from the USF. ETCs are required by Commission rule to pass through to enrolled Lifeline households the entirety of that federal support amount. No portion of that federal support may be diverted from Lifeline recipients or providers to subsidize state or JocaJ governmental activities, no matter how important or worthwhile those state or local activities may be in the eyes of state or local governments or anyone else. 4 7 C.F.R State of Alabama v. Lyng, 811 F. 2d 567 (1l1h Cir
6 Additional authority for the Commission to promulgate rules prohibiting state taxation of federal Lifeline benefits is found at other provisions of the Communications Act, including Section 254, Section 201 (b, and Section 4(i. Section 254 Section 254 of the Act 6 authorizes the Commission, subject to referral to a Federal-State Joint Board on Universal Service, to establish rules to implement the universal service provisions of the Act. Those provisions include the rules governing the federal Lifeline program - a program funded by the federal USF. Section 254(b(7 empowers the Commission to add to the universal service principles codified in the Act. Notwithstanding the references to a Joint Board in Section 254, the Commission has the authority to promulgate universal service rules, including Lifeline rules, without Joint Board referrals and, in fact, has done so on various occasions. For example, in 2000, the Commission proposed a rule which would impose time limits on requests for state commission designation of ETCs. 7 Therefore, the Commission has authority under Section 254 to promulgate universal service rules, including rules to govern the Lifeline program. Section 201(b Additional authority for the Commission to promulgate rules preventing state taxation of federal Lifeline benefits is contained at Section 201 (b of the Act. 8 That section provides, in part, that "[t]he Commission may prescribe such rules and regulations as may be necessary in the public interest to carry out the provisions of this Chapter." Those provisions include the 6 47 u.s.c Federal-State Joint Board on Uni versnl Service (Twelf!h Report and Order. 15 FCC Red (2000. Although the Commission indicated that it would consult with the Joint Board, it did not issue a referral order and was not required to do so u.s.c. 201(b. 6
7 Universal Service sections of the Act such as Section 214(e and Section 254. The Commission's broad authority under Section 201(b to promulgate rules to implement the universal service portions of the Act added by the Telecommunications Act of 1996, 9 has been affirmed by the Supreme Court. See AT&T Corp. v. Iowa Utilities Board, 525 U.S. 366 (1999. Section 4(i Finally, Section 4(i of the Act confers additional rnlemaking authority on the Commission. Section 4(i provides that "[t]he Commission may perform any and all acts, make such rules and regulations, and issue such orders, not inconsistent with the chapter, as may be necessary in the execution of its functions." 10 This explicit grant of rulemaking authority in Section 4(i, generally referred to as "ancillary authority," may be exercised provided that two conditions are met: 1 the subject of the regulation must be covered by the Commission's general grant of jurisdiction under Title I of the Communications Act; 11 and 2 the subject of the regulation must be "reasonably ancillary to the effective performance of the Commission's various responsibilities. " 12 Title I of the Act confers upon the Commission broad jurisdiction over communications by wire or radio and the availability of such services. Section 1 of the Act, entitled Purposes of Act, Creation of Federal Communications Commission, states, in relevant part, as follows: For the purpose of regulating interstate and foreign commerce in communication by wire or radio so as to make available, so far as possible, to all the people of the United States, without discrimination on the basis of race, color, religion, national origin, or sex, a rapid, efficient, Nation-wide, and world-wide wire and 9 Pub. L , 110 Stat. 56 ( U.S.C. 154(i (emphasis added. 11 /\merjcan Library Association v. F.C.C F.3d 689 (D.C. Cir (quoting United States v. Southwestern Cable Co. 392 U.S. 157 ( Id, at
8 radio communication service with adequate facilities at reasonable 13 c h arges... There is no doubt that the federal Lifeline program falls within the ambit of the Commission's statutory responsibility to make available to all the people of the United States a rapid, efficient, Nation-wide and world-wide wire and radio communication service with adequate facilities at reasonable charges. As such, the rule revisions proposed herein are within the scope of the Commission's Title I jurisdiction. The second prong of the two-pronged ancillary jurisdiction test also is met. Promulgation of a rule which would ensure that low-income households receiving federal Lifeline-supported service in all states and which would prohibit states from directly or indirectly reducing those benefits through taxation is not only reasonably ancillary to the effective performance of the Commission's statutory responsibilities; it is critical to the effective performance of those responsibilities. Universal Service has been a public interest goal since the enactment of the Communications Act of In 1996, universal service became explicit statutory requirement, primarily through the addition of Section 254 to the Act. If there was ever any doubt that universal service extended to making available affordable telecommunications service to lowincome Americans, that doubt was removed by the enactment of Section 254(b. That section includes among the statutory universal service principles that consumers throughout the nation, including low-income consumers, have access to affordable telecommunications service. While the Commission's Lifeline program dates back to 1987, that Commission-established policy became a statutory responsibility in Accordingly, promulgation of rule revisions which would ensure that uniform federal Lifeline benefits be available in all states and that states U.S.C
9 not be permitted to reduce those benefits through taxation would be essential to the Commission's performance of those statutory responsibilities. Conclusion For the reasons set forth in this Supplement to Emergency Petition for Declaratory Ruling and, in the Alternative, Petition for Rulemaking, as well as those set forth in TracFone's previously-filed Emergency Petition for Declaratory Ruling and reply comments in this matter, TracFone respectfully requests that the Commission promptly commence a rulemaking proceeding for the purpose of considering promulgation of the rule revisions proposed herein. Whether achieved through preemption or through promulgation of appropriate rules, the continued national availability of federal Lifeline benefits to low-income households in all states in a nationally-uniform manner compels that states by precluded from interference with those federal benefits through slate or local taxation. March 13,2015 Respectfully submitted, TRACFONE LESS, INC. y ~::~, / / - "' Mitchell F. Brecher Debra McGuire Mercer GREENBERG TRAURIG, LLP 2101 L Street, N.W., Suite 1000 Washington, DC ( Its Attorneys 9
BEFORE THE CORPORATION COMMISSION OF OKLAHOMA COMMENTS OF TRACFONE WIRELESS, INC.
AUG 25 ZU1k ' BEFORE THE CORPORATION COMMISSION OF OKLAHOMA COURT CLERK'S OFFICE - OKC PPRATON COMMISSION S OF OKLAHOMA IN THE MATTER OF A PERMANENT RULEMAKING OF THE OKLAHOMA CAUSE NO. CORPORATION COMMISSION
More informationBefore the Federal Communications Commission Washington, DC ) ) ) ) ) COMMENTS OF NTCA THE RURAL BROADBAND ASSOCIATION
Before the Federal Communications Commission Washington, DC 20554 In the Matter of TracFone Wireless, Inc. Petition for Declaratory Ruling WC Docket No. 11-42 COMMENTS OF NTCA THE RURAL BROADBAND ASSOCIATION
More informationBefore the FEDERAL COMMUNICATIONS COMMISSION Washington, DC ) ) ) ) ) ) ) ) ) )
Before the FEDERAL COMMUNICATIONS COMMISSION Washington, DC 20554 In the Matter of Special Access for Price Cap Local Exchange Carriers AT&T Corporation Petition for Rulemaking to Reform Regulation of
More informationBefore the FEDERAL COMMUNICATIONS COMMISSION Washington, DC ) ) ) ) ) ) ) ) ) ) ) ) ) COMMENTS OF THE UNITED STATES TELECOM ASSOCIATION
Before the FEDERAL COMMUNICATIONS COMMISSION Washington, DC In the Matter of Petition of USTelecom For Forbearance Under 47 U.S.C. 160(c From Enforcement Of Certain Legacy Telecommunications Regulations
More informationBEFORE THE FEDERAL COMMUNICATIONS COMMISSION WASHINGTON, DC 20554
BEFORE THE FEDERAL COMMUNICATIONS COMMISSION WASHINGTON, DC 20554 ) Assessment and Collection of Regulatory ) MD Docket No. 15-121 Fees for Fiscal Year 2015 ) ) COMMENTS OF THE AMERICAN CABLE ASSOCIATION
More informationBefore the FEDERAL COMMUNICATIONS COMMISSION Washington, D. C.
Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D. C. U NIVERSAL S ERVICE A DMINISTRATIVE C OMPANY Revised Federal Universal Service Support Mechanisms Quarterly Contribution Base for the Third
More informationFederal Communications Commission FCC
Before the Federal Communications Commission Washington, D.C. 20554 In the Matter of Federal-State Joint Board on Universal Service Petition of TracFone Wireless, Inc. for Forbearance from 47 U.S.C. 214(e(1(A
More informationBefore the Federal Communications Commission Washington, D.C ) ) ) ) REPLY
Before the Federal Communications Commission Washington, D.C. 20554 In the Matter of National Exchange Carrier Association, Inc. Tariff F.C.C. No. 5 ) ) ) ) Transmittal No. 1358 REPLY In the above-referenced
More informationBefore the FEDERAL COMMUNICATIONS COMMISSION Washington, DC ) ) ) ) ) ) ) ) ) ) COMMENTS OF ITTA THE VOICE OF MID-SIZE COMMUNICATIONS COMPANIES
Before the FEDERAL COMMUNICATIONS COMMISSION Washington, DC 20554 In the Matter of Connect America Fund Developing a Unified Intercarrier Compensation Regime Establishing Just and Reasonable Rates for
More informationBefore the FEDERAL COMMUNICATIONS COMMISSION Washington, DC 20554
Before the FEDERAL COMMUNICATIONS COMMISSION Washington, DC 20554 In the Matter of Petition for Rulemaking to Further Reform The Lifeline Program Lifeline and Link Up Reform And Modernization Lifeline
More informationBefore the Federal Communications Commission Washington, D.C ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ORDER
Before the Federal Communications Commission Washington, D.C. 20554 In the Matter of Telecommunications Carriers Eligible for Universal Service Support Federal-State Joint Board on Universal Service Head
More informationBefore the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C
Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 In the Matter of ) ) Rural Health Care Support Mechanism ) WC Docket No. 02-60 REPLY COMMENTS OF THE HEALTH INFORMATION EXCHANGE OF MONTANA
More informationBefore the Federal Communications Commission Washington, D.C ) ) ) ) ) ) ) ) SECOND ORDER ON RECONSIDERATION AND CLARIFICATION
Before the Federal Communications Commission Washington, D.C. 20554 In the Matter of Connect America Fund ETC Annual Reports and Certifications Developing a Unified Intercarrier Compensation Regime WC
More informationPUBLIC NOTICE Federal Communications Commission th St., S.W. Washington, D.C
PUBLIC NOTICE Federal Communications Commission 445 12 th St., S.W. Washington, D.C. 20554 News Media Information 202 / 418-0500 Internet: http://www.fcc.gov TTY: 1-888-835-5322 DA 10-1033 Release Date:
More informationLance J.M. Steinhart, P.C. Attorney At Law 1725 Windward Concourse Suite 150 Alpharetta, Georgia 30005
Lance J.M. Steinhart, P.C. Attorney At Law 1725 Windward Concourse Suite 150 Alpharetta, Georgia 30005 Also Admitted in New York Telephone: (770) 232-9200 and Maryland Facsimile: (770) 232-9208 Email:
More informationBEFORE THE FEDERAL COMMUNICATIONS COMMISSION WASHINGTON, D.C
BEFORE THE FEDERAL COMMUNICATIONS COMMISSION WASHINGTON, D.C. 20554 In the Matter Lifeline and Link Up Reform and WC Docket No. 11-42 Modernization Federal-State Joint Board on Universal Service WC Docket
More informationBefore the Federal Communications Commission Washington, D.C ) ) ) ) ) ) ) ) ) ORDER AND SECOND ORDER ON RECONSIDERATION
Before the Federal Communications Commission Washington, D.C. 20554 In the matter of Multi-Association Group (MAG Plan for Regulation of Interstate Services of Non-Price Cap Incumbent Local Exchange Carriers
More informationSTATE OF MINNESOTA DEPARTMENT OF REVENUE
This document is made available electronically by the Minnesota Legislative Reference Library as part of an ongoing digital archiving project. http://www.leg.state.mn.us/lrl/sonar/sonar.asp STATE OF MINNESOTA
More informationTelecommunications Carriers Eligible to Receive Universal Service Support; Time Warner Cable Petition for Forbearance, WC Docket No.
Matthew A. Brill Direct: (202)637-1095 Email: matthew.brill@lw.com January 23, 2013 EX PARTE VIA ECFS Marlene H. Dortch, Secretary Federal Communications Commission 445 12th Street, SW Washington, DC 20554
More informationBefore the FEDERAL COMMUNICATIONS COMMISSION Washington, DC ) ) ) ) ) )
Before the FEDERAL COMMUNICATIONS COMMISSION Washington, DC 20554 In the Matter of Connect America Fund High-Cost Universal Service Support WC Docket No. 10-90 WC Docket No. 05-337 OPPOSITION OF CTIA THE
More informationMay 12, Lifeline Connects Coalition Notice of Oral Ex Parte Presentation; WC Docket Nos , , 10-90, 11-42
K E L L E Y D R Y E & W AR R E N L L P A LI MIT E D LIA BI LIT Y P ART N ER SHI P N E W Y O R K, NY L O S A N G E L E S, CA H O U S T O N, TX A U S T I N, TX C H I C A G O, IL P A R S I P P A N Y, NJ S
More informationBefore the FEDERAL COMMUNICATIONS COMMISSION Washington, D. C.
Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D. C. U NIVERSAL S ERVICE A DMINISTRATIVE C OMPANY Federal Universal Service Support Mechanisms Quarterly Contribution Base for the Fourth Quarter
More informationBefore the Federal Communications Commission Washington, D.C ) ) ) )
Before the Federal Communications Commission Washington, D.C. 20554 In the Matter of Federal-State Joint Board on Universal Service ) ) ) ) CC Docket No. 96-45 ORDER ON REMAND, FURTHER NOTICE OF PROPOSED
More informationBefore the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C.
Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. U NIVERSAL S ERVICE A DMINISTRATIVE C OMPANY Federal Universal Service Support Mechanisms Quarterly Contribution Base for the First Quarter
More informationBefore the Federal Communications Commission Washington, D.C ) ) ) ) ) ) SECOND FURTHER NOTICE OF PROPOSED RULEMAKING
Before the Federal Communications Commission Washington, D.C. 20554 In the Matter of Implementation of Section 621(a)(1) of the Cable Communications Policy Act of 1984 as Amended by the Cable Television
More informationCertified Mail Return Receipt Requested. September 30, 2015
U.S. Department of Transportation Office of the Secretary of Transportation GENERAL COUNSEL 1200 New Jersey Ave., S.E. Washington, DC 20590 Certified Mail Return Receipt Requested September 30, 2015 Evelyn
More informationBefore the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C ) ) ) ) ) ) ) )
Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 In the Matter of The Interpretation of Section 271 of the Telecommunications Act of 1996 as to Whether the Statutory Listing of Loops
More informationMarch 18, WC Docket No , Federal-State Joint Board on Universal Service Lifeline and Link Up Reform and Modernization
March 18, 2016 Ex Parte Notice Ms. Marlene H. Dortch, Secretary Federal Communications Commission 445 12th Street, S.W. Washington, D.C. 20554 RE: WC Docket No. 11-42, Federal-State Joint Board on Universal
More informationRules Implementing Amendments to the Investment Advisers Act of 1940
SECURITIES AND EXCHANGE COMMISSION 17 CFR Parts 275 and 279 [Release No. IA-1633, File No. S7-31-96] Rules Implementing Amendments to the Investment Advisers Act of 1940 AGENCY: Securities and Exchange
More informationJuly 2, Re: Contracts and Promises -- Interest and Charges -- Extension of Most Favored Lender Doctrine to State Banks
July 2, 1981 ATTORNEY GENERAL OPINION NO. 81-158 Roy P. Britton State Bank Commissioner Suite 600 818 Kansas Avenue Topeka, Kansas 66612 Re: Contracts and Promises -- Interest and Charges -- Extension
More informationBefore the Federal Communications Commission Washington, D.C
Before the Federal Communications Commission Washington, D.C. 20554 In the Matter of ) ) Additional Connect America Fund ) WC Docket No. 10-90 Phase II Issues ) COMMENTS OF THE UNITED STATES TELECOM ASSOCIATION
More informationBefore the Federal Communications Commission Washington, D.C ) ) ) ) ) ORDER. Adopted: May 31, 2013 Released: May 31, 2013
Before the Federal Communications Commission Washington, D.C. 20554 In the Matter of SureWest Telephone Petition for Conversion from Rate-of-Return to Price Cap Regulation and for Limited Waiver Relief
More informationBefore the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C
Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 In the Matter of ) ) Advanced Methods to Target and Eliminate ) CG Docket No. 17-59 Unlawful Robocalls ) Comments of the Credit Union
More informationSTATE OF MICHIGAN BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION
STATE OF MICHIGAN BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION In the matter, on the Commission s own motion, ) to determine potential changes to the Lifeline ) Case No. U-20335 discount pursuant to MCL
More informationBefore the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C ) ) ) ) ) ) ) PETITION FOR DECLARATORY RULING OF FAIRPOINT COMMUNICATIONS, INC.
Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 In the Matters of Implementation of Section 224 of the Act A National Broadband Plan for Our Future ) ) ) ) ) ) ) WC Docket No. 07-245
More informationBefore the Federal Communications Commission Washington, D.C ) ) ) ) ) ORDER. Adopted: October 6, 2016 Released: October 6, 2016
Before the Federal Communications Commission Washington, D.C. 20554 In the Matter of Access Charge Tariff Filings Introducing Broadband-only Loop Service ) ) ) ) ) WC Docket No. 16-317 ORDER Adopted: October
More informationOFFICE OF PERSONNEL MANAGEMENT. 5 CFR Part 179 RIN 3206-AM89. Administrative Wage Garnishment
This document is scheduled to be published in the Federal Register on 01/06/2014 and available online at http://federalregister.gov/a/2013-31500, and on FDsys.gov Billing Code 6325-23-P OFFICE OF PERSONNEL
More informationBefore the FEDERAL COMMUNICATIONS COMMISSION Washington, DC
Before the FEDERAL COMMUNICATIONS COMMISSION Washington, DC U NIVERSAL S ERVICE A DMINISTRATIVE C OMPANY Federal Universal Service Support Mechanisms Fund Size Projections for the Fourth Quarter 2006 UNIVERSAL
More informationBefore the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C
Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 In the Matter of ) ) Procedures for Assessment and Collection of ) MD Docket No. 12-201 Regulatory Fees ) ) Assessment and Collection
More informationCase 2:17-cv CB Document 28 Filed 02/28/18 Page 1 of 10 IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF PENNSYLVANIA
Case 2:17-cv-01502-CB Document 28 Filed 02/28/18 Page 1 of 10 IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF PENNSYLVANIA CONSUMER FINANCIAL PROTECTION ) BUREAU, ) ) Petitioner, ) Civil
More informationConcerning Effective Competition; Implementation of Section 111 of the STELA
This document is scheduled to be published in the Federal Register on 07/02/2015 and available online at http://federalregister.gov/a/2015-15806, and on FDsys.gov 6712-01 FEDERAL COMMUNICATIONS COMMISSION
More informationVia and ECFS EX PARTE. December 5, 2013
John E. Benedict Vice President Federal Regulatory Affairs & Regulatory Counsel 1099 New York Avenue NW Suite 250 Washington, DC 20001 202.429.3114 Via E-MAIL and ECFS December 5, 2013 EX PARTE Julie Veach
More informationBefore the Federal Communications Commission Washington, DC ) ) ) ) ) ) ) REPLY COMMENTS OF CTIA THE WIRELESS ASSOCIATION INTRODUCTION
Before the Federal Communications Commission Washington, DC 20554 In the Matter of Requests for Review by AT&T Inc., T-Mobile USA Inc., and Tracfone Wireless, Inc. of Decisions of the Universal Service
More informationLow Income Program AN OVERVIEW
Low Income Program AN OVERVIEW November 2010 1 Overview Low Income support reimburses eligible telecommunications carriers (ETCs) for providing eligible low-income customers with discounts. 2 Overview
More informationBefore the FEDERAL COMMUNICATIONS COMMISSION Washington, DC ) ) ) ) ) ) ) ) COMMENTS OF THE UNITED STATES TELECOM ASSOCIATION
Before the FEDERAL COMMUNICATIONS COMMISSION Washington, DC 20554 In the Matter of Protecting and Promoting the Open Internet Information Collection Being Submitted for Review and Approval to the Office
More informationUnited States Court of Appeals
United States Court of Appeals FOR THE DISTRICT OF COLUMBIA CIRCUIT Argued May 11, 2017 Decided July 25, 2017 No. 16-5255 ALLINA HEALTH SERVICES, DOING BUSINESS AS UNITED HOSPITAL, DOING BUSINESS AS UNITY
More informationBefore the FEDERAL COMMUNICATIONS COMMISSION Washington, DC
Before the FEDERAL COMMUNICATIONS COMMISSION Washington, DC U NIVERSAL S ERVICE A DMINISTRATIVE C OMPANY Federal Universal Service Support Mechanisms Fund Size Projections for Second Quarter 2014 UNIVERSAL
More informationSUMMARY: The Federal Housing Finance Agency (FHFA) is prescribing this final
This document is scheduled to be published in the Federal Register on 03/24/2017 and available online at https://federalregister.gov/d/2017-05894, and on FDsys.gov BILLING CODE: 8070-01-P FEDERAL HOUSING
More informationBefore the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C
Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 In the Matter of Lifeline and Link Up Reform and Modernization WC Docket No. 11-42 Telecommunications Carriers Eligible for WC Docket
More informationTHE UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION
THE UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION Inquiry Regarding the Effect of the Tax Cuts ) and Jobs Act on Commission-Jurisdictional ) Docket No. RM18-12-000 Rates ) MOTION
More informationPUBLIC NOTICE PARTIES ASKED TO REFRESH THE RECORD REGARDING PROPERTY RECORDS FOR RATE-OF-RETURN CARRIERS. CC Docket Nos.
PUBLIC NOTICE Federal Communications Commission 445 12 th St., S.W. Washington, D.C. 20554 News Media Information 202 / 418-0500 Internet: http://www.fcc.gov TTY: 1-888-835-5322 DA 13-1617 Released: July
More informationGENERAL ASSEMBLY OF NORTH CAROLINA SESSION 2011 SESSION LAW HOUSE BILL 129
GENERAL ASSEMBLY OF NORTH CAROLINA SESSION 2011 SESSION LAW 2011-84 HOUSE BILL 129 AN ACT TO PROTECT JOBS AND INVESTMENT BY REGULATING LOCAL GOVERNMENT COMPETITION WITH PRIVATE BUSINESS. Whereas, certain
More informationBefore the Federal Communications Commission Washington, D.C ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )
Before the Federal Communications Commission Washington, D.C. 20554 In the Matter of Federal-State Joint Board on Universal Service 1998 Biennial Regulatory Review Streamlined Contributor Reporting Requirements
More informationBefore the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )
Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 In the Matter of Connect America Fund A National Broadband Plan for Our Future Establishing Just and Reasonable Rates for Local Exchange
More informationBankruptcy Court Recognizes the Doctrine of Reverse Preemption
Bankruptcy Court Recognizes the Doctrine of Reverse Preemption Written by: Gilbert L. Hamberg Gilbert L. Hamberg, Esq.; Yardley, Pa. Ghamberg@verizon.net In In re Medical Care Management Co., 361 B.R.
More informationStatement of Chairman Cheryl A. LaFleur on Forward Capacity Auction 8 Results Proceeding
September 16, 2014 Chairman Cheryl A. LaFleur Docket No. ER14-1409-000 Statement of Chairman Cheryl A. LaFleur on Forward Capacity Auction 8 Results Proceeding The ISO-New England (ISO-NE) Forward Capacity
More informationBefore the FEDERAL COMMUNICATIONS COMMISSION Washington, DC. Federal Universal Service Support Mechanisms Fund Size Projections for Third Quarter 2014
Before the FEDERAL COMMUNICATIONS COMMISSION Washington, DC U NIVERSAL S ERVICE A DMINISTRATIVE C OMPANY Federal Universal Service Support Mechanisms Fund Size Projections for Third Quarter 2014 UNIVERSAL
More informationUNITED STATES OF AMERICA MERIT SYSTEMS PROTECTION BOARD 2006 MSPB 29. Docket No. DC I-1. Marc A. Garcia, Appellant, Department of State,
OPINION AND ORDER UNITED STATES OF AMERICA MERIT SYSTEMS PROTECTION BOARD 2006 MSPB 29 Docket No. DC-3443-05-0216-I-1 Marc A. Garcia, Appellant, v. Department of State, Agency. February 27, 2006 Gregory
More informationBefore the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) COMMENTS OF LEVEL 3 COMMUNICATIONS, LLC
Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 In the Matters of Numbering Policies for Modern Communications IP-Enabled Services Telephone Number Requirements for IP-Enabled Service
More informationSUMMARY: The Bureau of Consumer Financial Protection (Bureau) invites the public to take
This document is scheduled to be published in the Federal Register on 09/10/2018 and available online at https://federalregister.gov/d/2018-19385, and on govinfo.gov BUREAU OF CONSUMER FINANCIAL PROTECTION
More informationKELLEY DRYE & WARREN LLP A LIMITED LIABILITY PARTNERSHIP WASHINGTON HARBOUR, SUITE K STREET, NW WASHINGTON, D.C (202)
A LIMITED LIABILITY PARTNERSHIP NEW YORK, NY LOS ANGELES, CA CHICAGO, IL STAMFORD, CT PARSIPPANY, NJ WASHINGTON HARBOUR, SUITE 400 3050 K STREET, NW WASHINGTON, D.C. 20007-5108 (202) 342-8400 FACSIMILE
More informationUSAC Service Provider Identification Number (1) Serving Area (2) b) Data Month
FCC Form 497 LIFELINE AND LINK UP WORKSHEET Approved by OMB July 2008 Edition 3060-0819 USAC Service Provider Identification Number (1) Serving Area (2) (3) (4) Company Name: Mailing Address: a) Submission
More informationCOMMONWEALTH OF MASSACHUSETTS DEPARTMENT OF TELECOMMUNICATIONS AND CABLE COMMENTS OF CTIA
COMMONWEALTH OF MASSACHUSETTS DEPARTMENT OF TELECOMMUNICATIONS AND CABLE Petition of the State 911 Department for Approval of Fiscal Year 2018 Expenditures and Adjustment of the Enhanced 911 Surcharge
More informationERISA Fiduciary Rule. Fifth Circuit Vacates New ERISA Fiduciary Rule SUMMARY BACKGROUND. March 19, 2018
Fifth Circuit Vacates New SUMMARY On March 15, 2018, the Court of Appeals for the Fifth Circuit vacated, in its entirety, a 2016 Department of Labor (the DOL ) package of regulations providing an expansive
More informationBefore the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C
Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 In the Matter of ) ) Jurisdictional Separations and ) CC Docket No. 80-286 Referral to the Federal-State ) Joint Board ) COMMENTS OF
More informationFinal Rule: Revisions to Rules Implementing Amendments to the Investment Advisers Act of 1940 SECURITIES AND EXCHANGE COMMISSION
Final Rule: Revisions to Rules Implementing Amendments to the Investment Advisers Act of 1940 SECURITIES AND EXCHANGE COMMISSION 17 CFR Parts 275 and 279 (Release No. IA-1733, File No. S7-28-97) RIN 3235-AH22
More informationBefore the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C
Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 ) In the Matter of ) ) WC Docket No. 06-172 Remands of Verizon 6 MSA Forbearance Order ) and Qwest 4 MSA Forbearance Order ) WC Docket
More informationGroup Health Plan Design Under the Illinois Civil Union Act
Group Health Plan Design Under the Illinois Civil Union Act Background On January 31, 2011, Governor Pat Quinn signed into law the Illinois Religious Freedom Protection and Civil Union Act ( Civil Union
More informationWall Street Reform and Consumer Financial Protection Act of 2010
Wall Street Reform and Consumer Financial Protection Act of 2010 Federal Preemption August 6, 2010 Presented By Oliver Ireland and Joseph Gabai 2010 Morrison & Foerster LLP All Rights Reserved mofo.com
More informationBEFORE THE FEDERAL COMMUNICATIONS COMMISSION WASHINGTON D.C REPLY COMMENTS OF THE MICHIGAN PUBLIC SERVICE COMMISSION
BEFORE THE FEDERAL COMMUNICATIONS COMMISSION WASHINGTON D.C. 20554 In the Matter of: ) ) WC Docket No. 12-61 Petition of US Telecom for Forbearance ) Under 47 U.S.C. 160(c) From Enforcement ) of Certain
More informationCOMMENT LETTER AND PETITION FOR DISAPPROVAL
August 28, 2014 Via Electronic Mail (rule-comments@sec.gov) U.S. Securities and Exchange Commission 100 F Street, N.E. Washington, DC 20549-1090 Attention: Kevin M. O Neill, Deputy Secretary COMMENT LETTER
More informationBefore the Federal Communications Commission Washington, D.C ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )
Before the Federal Communications Commission Washington, D.C. 20554 In the Matter of Connect America Fund A National Broadband Plan for Our Future Establishing Just and Reasonable Rates for Local Exchange
More informationThe Gramm-Leach-Bliley Act and its Impact on the Discovery of Customer Lists and Policyholder Files. By Edgar M. Elliott, IV
The Gramm-Leach-Bliley Act and its Impact on the Discovery of Customer Lists and Policyholder Files By Edgar M. Elliott, IV In November 1999, Congress enacted the Federal Financial Modernization Act, better
More informationBefore the FEDERAL COMMUNICATIONS COMMISSION Washington, DC ) ) ) ) ) ) PETITION FOR STAY PENDING RECONSIDERATION
Before the FEDERAL COMMUNICATIONS COMMISSION Washington, DC 20554 In the Matter of Connect America Fund ETC Annual Reports and Certifications WC Docket No. 10-90 WC Docket No. 14-58 PETITION FOR STAY PENDING
More informationENTERED TAWANA C. MARSHALL, CLERK THE DATE OF ENTRY IS ON THE COURT'S DOCKET
Case 14-42974-rfn13 Doc 45 Filed 01/08/15 Entered 01/08/15 15:22:05 Page 1 of 12 U.S. BANKRUPTCY COURT NORTHERN DISTRICT OF TEXAS ENTERED TAWANA C. MARSHALL, CLERK THE DATE OF ENTRY IS ON THE COURT'S DOCKET
More informationBefore the Federal Communications Commission Washington, DC ) ) ) ) ) ) ) ) )
Before the Federal Communications Commission Washington, DC 20554 Petition of NTCA The Rural Broadband Association and the United States Telecom Association for Targeted, Temporary Forbearance Pursuant
More informationCase: Document: 56 Page: 1 11/13/ IN THE UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT
Case: 13-3769 Document: 56 Page: 1 11/13/2013 1091564 20 13-3769 IN THE UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT THE OTOE-MISSOURIA TRIBE OF INDIANS, a federally-recognized Indian Tribe, GREAT
More informationNo UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT. RONAN TELEPHONE COMPANY and HOT SPRINGS TELEPHONE COMPANY,
Case: 05-71995 07/23/2012 ID: 8259039 DktEntry: 132-2 Page: 1 of 25 No. 05-71995 UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT RONAN TELEPHONE COMPANY and HOT SPRINGS TELEPHONE COMPANY, v. Petitioners,
More informationfiled by General Communication, Inc. ( GCI ) of the Commission s grant of forbearance relief
Before the Federal Communications Commission Washington, D.C. 20554 In the matter of Petition of USTelecom for Forbearance Pursuant to 47 U.S.C. 160(c) From Enforcement of Obsolete ILEC Legacy Regulations
More informationTHE AYCO COMPANY, L.P. Investment Advisors Act of Section 205(a)(3) December 14, 1995
THE AYCO COMPANY, L.P. Investment Advisors Act of 1940 -- Section 205(a)(3) December 14, 1995 TOTAL NUMBER OF LETTERS: 2 SEC-REPLY-1: SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 December
More informationM E M O R A N D U M. Executive Summary
M E M O R A N D U M From: Thomas J. Nichols, Esq. Date: March 12, 2019 Re: 2017 Wisconsin Act 368 Authority Executive Summary State income taxes paid by S corporations and partnerships, limited liability
More information,... G B. M & GIUDITTA, P.C. BEVAN, MOSCA
B. M,... G DL BEVAN, MOSCA & GIUDITTA, P.C. T r 0 R N F Y S A T I..'\ \V 222 MOUNT AIRY ROAD, SUITE 200 BAS Kl NG RIDGE, NJ 07920-2335 (P) 908.753.8300 (F) 908.753.8301 www.bmg.law WILLIA.1\1 K. MoscA,JR.
More informationNo UNITED STATES COURT OF APPEALS FOR THE EIGHTH CIRCUIT. Charter Advanced Services (MN), LLC, et al., Plaintiffs-Appellees,
No. 17-2290 UNITED STATES COURT OF APPEALS FOR THE EIGHTH CIRCUIT Charter Advanced Services (MN), LLC, et al., Plaintiffs-Appellees, v. Nancy Lange, in her official capacity as Chair of the Minnesota Public
More informationNew NYSE and NASDAQ Listing Rules Raise the Accountability of Company Boards and Compensation Committees Through Flexible Standards
New NYSE and NASDAQ Listing Rules Raise the Accountability of Company Boards and Compensation Committees Through Flexible Standards By Todd B. Pfister and Aubrey Refuerzo* On January 11, 2013, the U.S.
More informationBefore the Federal Communications Commission Washington, D.C ) ) ) ) ) ) ) RECOMMENDED DECISION
Before the Federal Communications Commission Washington, D.C. 20554 In the Matter of Comprehensive Review of the Part 32 Uniform System of Accounts Jurisdictional Separations and Referral to the Federal-State
More informationSTOP LOSS INSURANCE MODEL ACT
Model Regulation Service July 2002 Table of Contents Section 1. Section 2. Section 3. Section 4. Section 5. Section 1. Purpose and Intent Definitions Stop Loss Insurance Coverage Standards Actuarial Certification
More informationImplementation of the Middle Class Tax Relief and Job Creation Act of 2012; Establishment of a
This document is scheduled to be published in the Federal Register on 11/29/2012 and available online at http://federalregister.gov/a/2012-27672, and on FDsys.gov 6712-01 FEDERAL COMMUNICATIONS COMMISSION
More informationAGENCY: Employment and Training Administration, Labor. SUMMARY: The Employment and Training Administration (ETA) of the U.S.
This document is scheduled to be published in the Federal Register on 08/01/2016 and available online at http://federalregister.gov/a/2016-17738, and on FDsys.gov DEPARTMENT OF LABOR Employment and Training
More informationBefore the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. ADMINISTRATIVE COMPANY
Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. UNIVERSAL SERVICE ADMINISTRATIVE COMPANY Federal Universal Service Support Mechanisms Fund Size for Third Quarter 2017 1 UNIVERSAL SERVICE
More informationBefore the FEDERAL COMMUNICATIONS COMMISSION Washington, DC REPLY COMMENTS
Before the FEDERAL COMMUNICATIONS COMMISSION Washington, DC 20554 In the Matter of ) ) Amendment of Parts 1 and 17 of the ) RM - 11688 Commission s Rules Regarding Public ) Notice Procedures for Processing
More informationBefore the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C
Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 In the Matter of ) ) Connect America Fund ) WC Docket No. 10-90 ) Developing a Unified Intercarrier Compensation Regime ) CC Docket No.
More informationPUBLISHED UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT. No
PUBLISHED UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT No. 13-1106 EQUAL EMPLOYMENT OPPORTUNITY COMMISSION, v. BALTIMORE COUNTY, and Plaintiff - Appellee, Defendant Appellant, AMERICAN FEDERATION
More informationS T A T E O F T E N N E S S E E OFFICE OF THE ATTORNEY GENERAL PO BOX NASHVILLE, TENNESSEE April 7, Opinion No.
S T A T E O F T E N N E S S E E OFFICE OF THE ATTORNEY GENERAL PO BOX 20207 NASHVILLE, TENNESSEE 37202 April 7, 2004 Opinion No. 04-059 Effect of Federal Banking Rules on State Predatory Lending Laws QUESTIONS
More informationTitle 4 DEPARTMENT OF ECONOMIC DEVELOPMENT Division 240 Public Service Commission Chapter 31 Missouri Universal Service Fund EMERGENCY AMENDMENT
Title 4 DEPARTMENT OF ECONOMIC DEVELOPMENT Division 240 Public Service Commission Chapter 31 Missouri Universal Service Fund EMERGENCY AMENDMENT 4 CSR 240-31.010 Definitions. The commission is amending
More information[Billing Code: P] [Docket No. TTB ; T.D. TTB 146; Re: Notice No. 167]
This document is scheduled to be published in the Federal Register on 01/04/2017 and available online at https://federalregister.gov/d/2016-31417, and on FDsys.gov [Billing Code: 4810 31 P] DEPARTMENT
More informationFinal Rule Relating to Time and Order of Issuance of Domestic Relations Orders
DEPARTMENT OF LABOR Employee Benefits Security Administration 29 CFR Part 2530 RIN 1210-AB15 Final Rule Relating to Time and Order of Issuance of Domestic Relations Orders AGENCY: Employee Benefits Security
More informationBefore the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C REPLY COMMENTS OF INCOMPAS
Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 In the Matter of ) ) Rural Call Completion ) WC Docket No. 13-39 ) REPLY COMMENTS OF INCOMPAS INCOMPAS, by its undersigned counsel, hereby
More informationPatient Protection and Affordable Care Act; Exchange Functions: Standards for
DEPARTMENT OF HEALTH AND HUMAN SERVICES 45 CFR Part 155 [CMS-9955-P] RIN 0938-AR75 Patient Protection and Affordable Care Act; Exchange Functions: Standards for Navigators and Non-Navigator Assistance
More informationALABAMA STATEWIDE NINE-ONE-ONE BOARD ADMINISTRATIVE CODE CHAPTER 585-X-4 COLLECTION AND DISBURSEMENT OF SERVICE CHARGES TABLE OF CONTENTS
Nine-One-One Board Chapter 585-X-4 ALABAMA STATEWIDE NINE-ONE-ONE BOARD ADMINISTRATIVE CODE CHAPTER 585-X-4 COLLECTION AND DISBURSEMENT OF SERVICE CHARGES TABLE OF CONTENTS 585-X-4-.01 Determination Of
More informationIN THE COMMONWEALTH COURT OF PENNSYLVANIA
IN THE COMMONWEALTH COURT OF PENNSYLVANIA Allstate Life Insurance Company, : Petitioner : : v. : No. 89 F.R. 1997 : Commonwealth of Pennsylvania, : Argued: December 9, 2009 Respondent : BEFORE: HONORABLE
More information