CASE NAME: People of the State of California, ex rel. Spooner, et al., v Pacifica Foundation, et al.
CASE NO.: 8312520-3
REQUEST FOR ADMISSIONS, SET ONE (1)
"Attachment B"
1. December 28, 1987 letter Re: Ownership Report, from John Crigler, Law Offices Haley, Bader & Potts, to Mr. H. Walter Feaster, Secretary, Federal Communications Commission, and attachments thereto, including:
a. Ownership Report for Noncommercial Educational Broadcast Station, dated October 10, 1987, signed and certified as true on December 23, 1987 by David J. Salniker, Executive Director, and attachments thereto, including:
b. "Attachment A" to document 1, a., above, consisting of a list of the FM radio station licenses held by Pacifica Foundation, Inc.
c. "Attachment B" to document 1.a., above, consisting of a list of officers and directors of Pacifica Foundation, Inc.
2. Ownership Report for Noncommercial Educational Broadcast Station, dated May 10, 1988, signed and certified as true on May 10, 1988 by David J. Salniker, Vice Chair/Executive Director, and attachments thereto, including:
a. "Attachment A" to document 2, above, consisting of a list of the FM radio station licenses held by Pacifica Foundation, Inc.
b. "Attachment B" to document 2, above, consisting of a list of officers and directors of Pacifica Foundation, Inc.
3. March 29, 1990 letter Re: Pacifica Foundation, Inc., Ownership Report, from John Crigler, Law Offices Haley, Bader & Potts, to Ms. Donna R. Searcy, Secretary, Federal Communications Commission, and attachments thereto, including:
a. Ownership Report For Noncommercial Educational Broadcast Station, dated March 28, 1990, signed and certified as true on March 28, 1990 by David J. Salniker, Vice Chair/Executive Director, and attachments thereto, including:
b. "Attachment A" to document 3.a., above, consisting of a list of the FM radio station licenses held by Pacifica Foundation, Inc.
c. "Attachment B" to document 3.a., above, consisting of a list of officers and directors of Pacifica Foundation, Inc.
4. August 23, 1991 letter Re: Pacifica Foundation, Inc., Ownership Report, from David G. O’Neil, Law Offices Haley, Bader & Potts, to Ms. Donna R. Searcy, Secretary, Federal Communications Commission, and attachments thereto, including:
a. Ownership Report For Noncommercial Educational Broadcast Station, dated July 23, 1991, signed and certified as true on August 9, 1991 by David J. Salniker, Executive Director Vice-Chair, and attachments thereto, including:
b. "Exhibit 1" to document 4.a., above, consisting of a list of the FM radio station licenses held by Pacifica Foundation, Inc.
c. "Exhibit 2" to document 4.a., above, consisting of a list of officers and directors of Pacifica Foundation, Inc.
5. February 27, 1992 letter from John Crigler, Law Offices Haley, Bader & Potts, to Ms. Donna R. Searcy, Secretary, Federal Communications Commission, and attachments thereto, including:
a. Ownership Report For Noncommercial Educational Broadcasting Station, dated February 2, 1992, signed and certified as true on February 20, 1992 by David J. Salniker, Executive Director, and attachments thereto, including:
b. "Exhibit 1" to document 5.a., above, consisting of a list of the FM radio station licenses held by Pacifica Foundation, Inc.
c. "Continued Exhibit 2" to document 5.a., consisting of a continued list of officers and directors of Pacifica Foundation, Inc.
6. July 6, 1994 letter Re: Pacifica Foundation, Inc., FCC File No. BTCH-940523GJ-GO, from John Crigler, Law Offices Haley Bader & Potts, to Mr. William F. Caton, Acting Secretary, Federal Communications Commission, and attachments thereto, including:
a. Ownership Report For Noncommercial Educational Broadcast Stations, dated June 14, 1994, signed and certified as true on July 5, 1994 by David J. Salniker, Vice Chair, and attachments thereto, including:
b. "Exhibit 1" to document 6.a., above, consisting of a list of the FM radio station licenses held by Pacifica Foundation, Inc.
c. "Exhibit 2" to document 6.a., above, consisting of a list of officers and directors of Pacifica Foundation, Inc.
7. FCC 323-E, Ownership Report For Noncommercial Educational Broadcast Station, dated May 1, 1995, signed and certified as true on May 15, 1995 by Patricia Scott, Executive Director, and attachments thereto, including:
a. "Exhibit 1" to document 7., above, entitled "Pacifica Foundation, Inc., Broadcast Interests"
8. November 2, 1995 letter Re: Ownership Report from John Crigler, Law Offices Haley Bader & Potts, to Mr. William F. Caton, Acting Secretary, Federal Communications Commission, and attachments thereto, including:
a. Ownership Report For Noncommercial Educational Broadcast Station, dated October 1995, signed and certified as true on October 31, 1995 by Patricia Scott, Executive Director, and attachments thereto, including:
b. "Exhibit 1" to document 8.a., above, consisting of a list of the FM radio station licenses held by Pacifica Foundation, Inc.
c. "Exhibit 2" to document 8.a., above, entitled "Pacifica Foundation, Inc., Governing Board"
9. April 12, 1996 letter Re: Ownership Report from John Crigler, Law Offices Haley Bader & Potts, to Mr. William F. Caton, Acting Secretary, Federal Communications Commission, and attachments thereto, including:
a. Ownership Report For Noncommercial Educational Broadcast Station, dated April 11, 1996, signed and certified as true on April 11, 1996 by Patricia Scott, Executive Director, and attachments thereto, including:
b. "Exhibit 1" to document 9.a., above, consisting of a list of the FM radio station licenses held by Pacifica Foundation, Inc.
c. "Exhibit 2" to document 9.a., above, entitled "Pacifica Foundation, Inc., Governing Board"
10. August 6, 1996 letter Re: Pacifica Foundation, Inc., Ownership Report from John Crigler, Law Offices Haley Bader & Potts, to Mr. William F. Caton, Acting Secretary, Federal Communications Commission, and attachments thereto, including:
a. Ownership Report For Noncommercial Educational Broadcast Station, dated July 15, 1996, signed and certified as true on August 1, 1996 by Patricia Scott, Executive Director, and attachments thereto, including:
b. "Exhibit 1" to document 10.a., above, consisting of a list of the FM radio station licenses held by Pacifica Foundation, Inc.
c. "Exhibit 2" to document 10.a., above, entitled "Pacifica Foundation, Inc., Governing Board"
11. March 6, 1997 letter Re: Ownership Report from John Crigler, Law Offices Haley Bader & Potts, to Mr. William F. Caton, Acting Secretary, Federal Communications Commission, and attachments thereto, including:
a. Ownership Report For Noncommercial Educational Broadcast Station, dated February 20, 1997, signed and certified as true on March 3, 1997 by Patricia Scott, Executive Director, and attachments thereto, including:
b. "Exhibit 1" to document 11.a., above, consisting of a list of the FM radio station licenses held by Pacifica Foundation, Inc.
c. "Exhibit 1" [sic] to document 11.a., above, entitled "Pacifica Foundation, Inc., Governing Board"
12. FCC 323-E, Ownership Report for Noncommercial Educational Broadcast Station, dated July 1, 1997, signed and certified as true on July 28, 1997 by Patricia Scott, Executive Director, and attachments thereto, including:
a. "Pacifica Foundation, Inc., Governing Board"
b. "Exhibit 2" to document 12, above, entitled "Pacifica Foundation, Inc., Broadcast Interests"
13. FCC 323-E, Ownership Report for Noncommercial Educational Broadcast Station, dated January 2, 1998, signed and certified as true on January 27, 1998 by Patricia Scott, Executive Director, and attachments thereto, including:
a. "Exhibit 1" to document 13, above, entitled "Pacifica Foundation Board of Directors"
b. "Exhibit 2" to document 13, above, entitled "Pacifica Foundation Inc., Broadcast Interests"
14. September 7, 1999 letter Re: Ownership Report from John Crigler, Law Offices Haley Bader & Potts, to Ms. Magalie R. Salas, Secretary, Federal Communications Commissions, and the attachments thereto, including:
a. FCC 323-E, Ownership Report for Noncommercial Educational Broadcast Station, dated September 3, 1999, signed and certified as true on September 3, 1999 by Lynn Chadwick, Executive Director, and attachments thereto, including:
b.. "Exhibit 1" to document 14.a., above.
c. "Exhibit 2" to document 14.a., above, entitled "Bylaws of Pacifica Foundation as Amended in 1997 and 1999"
d. "Exhibit 3" to document 14.a., above, entitled "Pacifica Foundation, Inc., Board of Directors"
15. Pacifica Foundation Bylaws as amended 1/31/84.
16. Pacifica Foundation Bylaws as amended 1/9/88.
17. Pacifica Foundation Bylaws as amended 2/9/91.
18. Pacifica Foundation Bylaws as amended 9/28/97.
19. Pacifica Foundation Bylaws as amended 2/28/99
20. Articles of Incorporation of Pacifica Foundation, filed with California Secretary of State on August 24, 1946.
21. Certificate of Amendment of the Articles of Incorporation of Pacifica Foundation, filed with California Secretary of State on August 20, 1948.
22. Certificate of Amendment of the Articles of Incorporation of Pacifica Foundation, filed with California Secretary of State on March 4, 1968.
23. Certificate of Amendment of the Articles of Incorporation of Pacifica Foundation, filed with California Secretary of State on April 9, 1971.
24. Certificate of Correction of the Certificate of Amendment of the Articles of Incorporation of Pacifica Foundation, filed with California Secretary of State on May 5, 1971.
25. Certificate of Ownership of WBAI-FM, Inc., by Pacifica Foundation, filed with California Secretary of State on or about November 1973. (Date not clear.)
26. Certificate of Amendment of Articles of Incorporation, filed with California Secretary of State on February 2, 1976.
27. June 6, 1995 Memorandum To: Pat Scott, Executive Director, From Gail Christian, General Manager, Re: "Dissolution of the WPFW Board"
28. July 12, 1995 Memo To: All Local Advisory Boards of Directors, From: Executive Committee of the Pacifica National Board, Re: "Interim Board Guidelines"
29. July 19, 1995 Memo To: Ruben Lizardo, Leonor Lizardo, Moneim Fadali, Mark Schubb, From: Jack O’Dell and the Pacifica Executive Committee, Re: "KPFK Board."
30. 2/28/96 letter to Programmers and Board Ops, from Mark Schubb, KPFK General Manager.
31. "Confidential Memorandum" to Jack, Loretta, Pat, Dick, Mary, Gail, Julie, and Pacifica station managers, from Burt Glass, dated 11 March 1997.
32. Corporation for Public Broadcasting, Office of Inspector General, Compliance Audit of Pacifica Foundation, Berkeley, California, Audit Report No. 97-01, dated April 9, 1997, signed by Armando J. Arvizu, Inspector General.
33. "A Vision for Pacifica Radio: Creating a Network for the 21st Century, Strategic Five Year Plan - April 1997" printed from Pacifica Foundation web page.
34. September 14, 1998 letter to Pat Scott, Executive Director, Pacifica Foundation, from Robert T. Coonrod, President and Chief Executive Officer, Corporation for Public Broadcasting.
35. February 24, 1999 letter to Ms. Lynn Chadwick, Executive Director, Pacifica Foundation, from Richard H. Madden, Vice President, Radio, Corporation for Public Broadcasting.
36. Email Sent: 7/9/19 8:33 AM, Received: 7/12/99 2:57 PM, From Palmer, Micheal @ Houston Galleria, mpalmer@cbrichardellis.com, To ‘Mary Frances Berry’, ma@igc.org
37. "Pacifica Board of Directors, Elections and Terms, Updated November 2, 1999" printed from Pacifica Foundation web page.
38. "The Theory of Listener Sponsored Radio" by Lewis Hill (1951), printed from KPFK-FM Radio station web page.
39. "Highlights of Pacifica Radio’s 50 Year History of Radio Broadcasting," printed from Pacifica Foundation web page.