WPC@ 2PBV`@Z3|PA Roman (TT)8xCdXXx{2 PQXP"5@^dC2CCdECCCCCCCd<d<CCYYdCCddCYCdYzzzzCCCCqodYYYYYYYYYYY8888dddddddnddddddd"5@^2Coddȧ8CCdr2C28ddddddddddCCrrrdzNdzoȐC8CtdCdoYoYCdo8Co8odooYNCodddYO,Oh2CC!CCPRCdodddddȐYYYYYN8N8N8N8oddddooooddoddddzodddYYYYYYddddooPoNoNCNodo8RoodȐYYoNoNNF2ldCdddddd%7777777777>>>1eOIIOC=OO%+OCbOO=OI=COOhOOC%%47%17171%777V7777%+77O77155<%%%%,-%77O1O1O1O1O1bII1C1C1C1C1%%%%O7O7O7O7O7O7O7O7O7O7O1O7O7O7O7O7=7O7O1O1I1I1I1C1C1C1O7O7OO7O7O7O7,7%7%%%7+O7CC-O7O7O7bOI%I-=+=+N&27%177777"SS7!TT7S!%%117n%%77ln%1n%!t%<<<<>mBBs,?>[N6Wms[77UUUH_%7777777777>>>1eOIIOC=OO%+OCbOO=OI=COOhOOC%%47%17171%777V7777%+77O77155%T7,OOOOOO=7111111I111117777777<7777777"5@^(1<by the Bureau, subject to review by the Commission. Declaratory Ruling, 6 FCC Rcd at 7513,  22.  xUnder either procedure, the complainant is entitled to limited discovery, subject to specific conditions set  Sh-forth in the Bureau's order. Declaratory Ruling, 6 FCC Rcd at 7513,  23.    S-  x5. Applying the guidelines set forth in the Declaratory Ruling, we find that Complainants have  S- xestablished a prima facie case of a violation by Station WALBTV of the LUC requirements of Section  x315(b)(1) of the Communications Act with respect to the sixty day period preceding the 1994 general  S- xelection. However, we find that Complainants have failed to establish a prima facie case of a LUC  xviolation by WALBTV during the fortyfive day periods preceding the 1994 primary and runoff elections.  SP- xWe also find that Complainants have established a prima facie case of a LUC violation with respect to  xLdisclosure to Complainants of its make good policy and audience delivery sales practices in effect during  xzthe 1994 general election period. Finally, we find that it would be improper to consider allegations of  S- xpolitical file violations in this Order. Following is a detailed discussion of the Bureau's specific findings" ,-(-(ZZ"  xwith respect to the issues raised, and the timetable and procedures for discovery, postdiscovery, and election of a procedure for resolving this complaint.  S`-v  I. LOWEST UNIT CHARGE ALLEGATIONS T  S-TP xA. Comparison With GenerallyAvailable Statistical Data  S-  x6. Complainants rely on generallyavailable statistical data to establish a prima facie case of  xovercharge by Station WALBTV. Specifically, Complainants allege that Station WALBTV charged rates  Sp- x[for political advertising which exceeded "SMART"based rates. SMART, the acronym for Spot Market  SH - xAnalysis of Rates for Television, a product of Media Market Guide, is a compilation of generallyavailable  S - x.statistical data on average rates charged by television stations in particular markets. T X -ԍ #C\  P6QP#This service was previously known as Spot Cost Outlook and Projections ("SCOOP").#&J\  P6Q &P# In support of their  x=allegations, Complainants state that by "[m]ultiplying the average rate for a given daypart in the Albany  x[market by the actual, stationspecific rating on WALB, it is evident that Complainants were overcharged  S - x-by significant amounts." yT Xq-ԍ #C\  P6QP#Complaint at 9.#&J\  P6Q &P#ц To arrive at SMARTbased rates for the third and fourth quarters, Complainants  xkmultiplied the SMART rates contained in the Media Market Guide published in the second and third  SX- xquarters of 1994 by Nielsen's July 1994 and November 1994 ratings.XT X-ԍ #C\  P6QP#Exhibit 2, Attachment A.#&J\  P6Q &P#я Complainants' calculations were  x[based on three different demographics, households, persons 18+, and Adults 2554. Complainants then  S- xycompared the stationspecific SMARTbased rates with the rates actually charged to each Complainant. I ;T X- xԍ #C\  P6QP#Complainants allege a substantial number of specific overcharges based on a comparison of the SMARTbased  xrates and the rates paid by Complainants. Complaint at Exhibit 2. The following is a representative sample of  xjspecific overcharge allegations. We note that in determining the amount of overcharges of 60second spots,  xwComplainants simply doubled the SMART rates, based on WALBTV's stated policy of charging twice the 30second  xrate for a 60second spot. Although we do not normally allow complainants do so, given WALBTV's statement on it ratecard (Exhibit 7), doubling the SMART rate seems justified in this instance.  yO-Candidate` ` Date Time Period@PaidhppSMARTBased Household Rate  yO-Millerx` ` 9/20/94 19001930@$375.00hpp$308.00  yO-Millerx` ` 10/6/94 21002200@$650.00hpp$426.30  yOL-Millnerx` ` 10/11/9419001930@$425.00hpp$359.80  yO -Millnerx` ` 11/2/94 19582100@$750.00hpp$510.40#&J\  P6Q &P#  xBased on their calculations, Complainants assert that Miller was overcharged between $20,099 and  xy$30,887, depending upon which demographic is used, and Millner was overcharged between $11,583 and  S-$17,398. T X#-ԍ #C\  P6QP#Complaint at 10#&J\  P6Q &P#. "] ,-(-(ZZ%"Ԍ S-  @x7. WALB argues that market average numbers are not reliable in Albany, Georgia, and should  S- xnot be utilized to establish a prima facie case. Specifically, WALB argues that market average numbers  xdo not "adequately portray actual market conditions in atypical markets like Albany, Georgia, where there  S- xare only two television stations and one of them very substantially predominates over the other." T X-ԍ #C\  P6QP#Answer at 4.#&J\  P6Q &P#у WALB  xnext argues that Complainants' analysis is deficient because it considers only "a relatively small part of  S8- xthe total time bought." 8yT X-ԍ #C\  P6QP#Answer at 3.#&J\  P6Q &P#у WALB speculates, without providing any support, that a full analysis might  x=establish that rates actually charged were below SMARTcalculated rates in a significant number of time  xperiods. Finally, WALB points out that Complainants' SMART calculations are limited to time purchased  S- x.during the 1994 general election LUC period. Accordingly, WALB asserts, no prima facie case has been made for the 1994 primary and runoff elections.  SH -  Nx8. The Commission has specifically endorsed the use of generally available industry or statistical  S - xdata on average rates to make a prima facie case of an LUC violation. While we recognize that the use  xkof such data may be more probative in some markets and less in others, absent the use of such data, a  S - xprima facie case of an LUC violation would be difficult to make. See WTVT(TV), 7 FCC Rcd at 6663,  xn. 11. Thus, we allow the use of such data in all market types and reject WALB's contentions that  S - xSMART data should not be used to establish a prima facie case of overcharges in this case. Of course,  xif any overcharges are ultimately found, and rebates are ordered, they will be based on the difference  S0- xbetween the rates actually charged by the station and the LUC. Id. at 6662, n.9, and 6663. We also reject  xWALB's argument that Complainants' SMART calculations are deficient because they consider only a  xy"small part of the total time bought." WALB only speculates that a full analysis might reveal that station  xrates were below SMART rates in a significant number of dayparts. It does not provide us with any data to support its conjecture.  S@-  |x9. For all the foregoing reasons, we find that Complainants have established a prima facie case  xof an LUC violation with respect to the rates charged Complainants during the 1994 general election  xperiod. Complainants have shown that in a significant number of instances they paid rates greater than  xythe SMARTbased rates during that time period. We do, however, agree with WALB that Complainants  S- xhave not established a prima facie case of an LUC violation with respect to rates charged Complainants  xduring the 1994 primary and runoff elections. Complainants' analysis is limited to time purchased during  xthe 1994 general election period and does not contain the necessary data with respect to the 1994 primary  x and runoff elections. Specifically, although Complainants include SMART information for the third  x.quarter of 1994, they do not provide copies of invoices for time purchased during the 1994 primary and  xrunoff election periods. Moreover, their calculations are limited to time purchased during the 1994 general  xelection period. Absent such data, the Commission cannot assess the accuracy of Complainants' claims  S- x\and a prima facie case has not been established. See Lawton Chiles, Bob Martinez, Bill Nelson and  S`- xJim Smith, 10 FCC Rcd 940,  13 (MMB 1995) ("WCPXTV"), citing WTVT(TV), 7 FCC Rcd at 666263, 8 FCC Rcd at 132. "p# ,-(-(ZZ%"Ԍ  S-x B. Comparison With Candidate and Commercial Records  S-  x 10. The Complaint asserts that Wesley Dunn, who was apparently a candidate during the 1994  xzGeorgia elections, was forced by Station WALBTV to purchase fixed time in order to ensure that his  xspots would clear. Comparing the rates he was charged with rates paid by the Georgia Lottery and  xanother candidate during the 1994 Georgia elections, the Complaint asserts that Wesley Dunn was  x[overcharged. Moreover, in this regard, allegations are raised with respect to improper steering, refusal to sell at intermediate rates, and failure to disclose.  Sp-  x 11. As WALB correctly points out, Wesley Dunn is not a named Complainant. The procedures  SH - xestablished for a prima facie analysis of LUC complaints are designed to protect the interests of the  S - x"parties" and to remedy apparent overcharges to "complaining candidates." Reconsideration Order. 7 FCC  xlRcd at 4127. Wesley Dunn is not named as a party to this proceeding and cannot be considered a  xcomplaining candidate. Moreover, as WALB states, allegations raised with respect to Wesley Dunn in  xthis regard are not relevant to the allegations made by Complainants. Accordingly, allegations with respect  S -to time purchased by Wesley Dunn are not properly considered in this Order.  S0-x C. Disclosure  S-  3x 12. Complainants contend that WALBTV's ratecard is deficient and is in violation of  xCommission Rules. In support of their allegations, a ratecard provided to Wesley Dunn is attached as  S- xExhibit 7 to the Complaint. Although, as discussed supra, Wesley Dunn is not a named Complainant,  xWALB admits that the same ratecard was provided to Complainants. Accordingly, on that basis, we shall consider Complainants' allegations in this regard.  S-  x 13. Complainants assert that the ratecard available to candidates failed to disclose a 79 a.m.  xzdaypart, and perhaps others. Specifically, pointing to WALBTV's ratecard in effect during the 1994  xgeneral election, Complainants contend that WALB offered only 78 a.m. ($115 fixed) or a 89 a.m. ($110  x?fixed) dayparts to candidates, but that it sold a 79 a.m. daypart for $110 to the Georgia Lottery.  xComplainants assert that "a candidate may not care" whether a spot ran from 78 a.m. or 89 a.m. and  x would have preferred to pay the lower price. WALB responds that the ratecard at issue listed some  xrepresentative rotations and indicated that other rotations were available upon request. While a licensee  xNhas an affirmative obligation to disclose its rates and sales practices to candidates, the "method of  S- xdisclosure is left to the discretion of individual stations." Codification of the Commission's Political  S- xProgramming Policies, 7 FCC Rcd 678, 689 (1991) ("Codification Report"); see also 47 C.F.R.   x73.1942(b). Moreover, the Commission has held that if a licensee chooses to use a ratecard, it need not  xlist every rotation on the ratecard so long as it states that other classes or rotations are available on  S - xrequest. Codification Report, 7 FCC Rcd at 689. The ratecard at issue listed some rotations and indicated  xthat other rotations were available. Thus, WALB's failure to disclose the availability of the 79 a.m.  S!- xdaypart on its ratecard does not constitute a prima facie case of failure to disclose political rate information. "& ,-(-(ZZn("Ԍ S-  x 14. Complainants also contend that the WALBTV's ratecard is deficient because it did not  xindicate a make good policy for most classes of time and did not disclose information about sales practices  x[based on audience delivery. Again, Complainants rely on WALBTV's ratecard in effect during the 1994  xgeneral election period. WALB responds that although it did not have a "formal" make good policy, it  xdid work "informally" with advertisers to reschedule preempted spots. Answer at 56. It asserts that the  x[station did not "generally" sell time based on "audience delivery," apparently conceding, however, that it  xoccasionally sold time on that basis. Answer at 6. Although the lack of information on the ratecard at  xissue is not dispositive of a violation, the licensee's own Answer (Answer at 6) indicates that WALBTV,  xat least during the 1994 general election period, may not have consistently disclosed information about  S-its make good policy and audience delivery practices. Accordingly, we find that a prima facie case of an  xLLUC violation has been established with respect to WALBTV's disclosure to Complainants of its make good policy and audience delivery sales practices in effect during the 1994 general election period.  S -  II. POLITICAL FILE ALLEGATIONS T  S -  TP x15. Complainants allege that WALBTV violated the political file requirements contained in  xSection 73.1943 of the Commission's Rules. Specifically, the Complaint states that Marc Hershovitz, who  xwas hired by Wesley Dunn's buyer, was permitted access to the public file but not allowed to copy its contents. WALB disputes the allegations.  S-  ?x16. This Order is issued pursuant to procedures for a prima facie analysis of LUC complaints as  S- xLset forth in the Declaratory Ruling, and allegations of violations of political file violations are not subject  xto those procedures. Thus, they will be handled as a separate complaint and will not be addressed herein.  S@- xSee Roy Barnes, Johnny Isakson, Zell Miller, et al., DA 97512, n. 5., released March 11, 1997 ("WMGTê S-TV").  S-g  III. TIMETABLE AND PROCEDURES FOR DISCOVERY T  SP-  TPx17. In the Declaratory Ruling, the Commission determined that, once a prima facie showing has  xbeen made, the complainant will be entitled to limited discovery, subject to specific conditions established  S- xby the Bureau. See Declaratory Ruling at 751314, 7521, n. 49. See also, WTVT 7 FCC Rcd at 6665.  xAccordingly, we will allow Complainants limited discovery on the issue of overcharges during the sixty  xdays preceding the November 8, 1994, general election. The documents set forth in Appendix A to this  S- xOrder, and answers to the written interrogatories set forth in Appendix B to this Order, must be served  xupon counsel for the abovereferenced Complainants (not the Commission) by WALB on or before the  S:- xfirst day of the discovery period, which will be 30 days after the release date of this Order. See Appendix C.  S!-  _x18. Any request for further discovery by Complainants must contain a showing that such  x?discovery is necessary to resolve the issue of overcharges. Any discovery request by WALB for  xproduction of documents, answers to written interrogatories, or for the taking of depositions must  xdemonstrate that the information requested is necessary for WALB to respond to arguments or claims that  x]could be made by Complainants in their amended complaint. We emphasize that any request for depositions must also demonstrate that depositions are necessary to resolution of the issue of overcharges "& ,-(-(ZZn("Ԍ S- xand include a list of the proposed deponents.\ T Xh- x<Ѝ #C\  P6QP#See WTVT, 8 FCC Rcd 714, 717 (MMB 1993). In this regard, we require the party seeking depositions to  yOQ- xKdemonstrate with respect to each witness they seek to depose, that the individual's testimony is necessary to the  yO- xresolution of the issues upon which discovery has been granted herein. This must include "specific" arguments  xdemonstrating the necessity of the proposed testimony both in terms of the information sought and the use of  xdepositions as the means of securing the necessary information and should be supported by documentary evidence."  yOq-Id.#&J\  P6Q &P#\ All discovery requests must be filed within the discovery period set forth in Appendix C. The Bureau will rule on all such requests as expeditiously as possible.  S-  ^x19. Documents produced by WALB that contain proprietary information may be redacted to  xdelete the identities of commercial advertisers, including the name of the commercial advertiser, its address  xand telephone number, the name(s) of any person employed by the advertiser, and the name of any media  xcompany or agency representing the commercial advertisers and any persons employed by such media  xcompany or agency. Where any such information is redacted, WALB shall advise Complainants of the  xtype of information deleted. Further redactions will be allowed only if the information redacted is  xproprietary and not relevant to resolution of the complaint. Should Complainants serve documents upon  xWALB they may redact proprietary information and so advise WALB of the type of information deleted.  x.Any objections to redactions that are not resolved by the parties should be submitted to the Bureau in a  xwritten pleading for resolution, along with copies of the documents at issue with the disputed information  x<intact. As with all discovery matters, the parties should make good faith attempts to resolve any discovery disputes before presenting such a dispute to the Bureau.  S -  x20. Any documents, answers to written interrogatories, or deposition transcripts, if any, produced  xduring discovery, and the information revealed thereby, shall not be provided to any third party other than  xythe Commission. Copies of all documents, answers to written interrogatories, and deposition transcripts  xproduced shall be stamped with the statement: "This document is subject to a protective order entered  xby the Federal Communications Commission." It shall be the responsibility of the party producing the documents, answers to written interrogatories, or deposition transcripts to affix the stamp.  Sh-  ]x21. The parties must take reasonable measures to prevent unauthorized access to the documents,  xLanswers to written interrogatories, and deposition transcripts. Access must be limited to Complainants,  xthe management of WALBTV, their attorneys and staffs, and expert witnesses. Either party may require  x[the other to disclose in writing the names of staff and experts who have access to documents and written  xMinformation. Each party must explain to all staff and experts that the documents, answers to written  xinterrogatories, deposition transcripts, and their contents may not be disclosed to any entity other than the Commission.  S(-  lx22. None of the materials produced, nor the contents thereof, may be used for any purpose other  xLthan the prosecution of the instant complaint. Each individual who is provided access to these materials  S- xyis hereby required to certify in writing that he or she has personally reviewed this Order and understands  S- xthe limitations imposed on the signing party. No copies of materials protected by this Order may be made  xexcept copies to be used by the persons identified in paragraph 25. Each party shall maintain a log recording the number of copies made of all proprietary material and the persons to whom the copies have " a ,-(-(ZZV""Ԍ  xbeen provided. Upon termination of this proceeding, including any appeals, petitions or settlement, all  xoriginals and reproductions of any protected materials, along with the log recording persons who received copies of such materials, shall be provided to the producing party. In addition, upon final termination of  xjthe proceeding, any notes or other work product derived in whole or in part from the protected materials of an opposing party shall be destroyed.  S-  x23. The parties may agree to additional reasonable measures to protect the confidentiality of  xinformation as the circumstances may warrant. Such agreement should be confirmed in writing and a copy  Sp- x\provided to the Bureau. As noted in the Declaratory Ruling, any failure to abide by the terms of this  xprotective order may result in the imposition of sanctions, including dismissal of the complaint or censure, suspension, or disbarment of the attorneys involved. See 47 C.F.R.  1.24.  S -  x24. Extensions of the discovery period (Appendix C) will be granted only where extraordinary  xcircumstances exist and the parties agree to the extension, or both parties submit declarations that serious  xsettlement discussions are ongoing. Any deadlines within the discovery period may be changed by mutual  xyagreement, with notification to the Bureau, as long as all discovery is completed within the required time.  xService of documents, discovery requests, and any pleading which requires a ruling by the Bureau is to  xoccur by the dates set in Appendix C, unless modified by the Bureau or by mutual agreement of the parties.  S-  x25. Within 30 days after completion of discovery, Complainants must file an amended complaint,  x=alleging specific facts based on the information discovered, stating the nature of the  315(b)(1) violation  xand the amounts said to be owed. After WALB has filed its answer, the parties shall file with the Bureau their election to have the complaint resolved either by the Bureau or by Alternative Dispute Resolution.  S-  x26. Settlement of lowest unit charge claims is strongly encouraged. Although the Commission  xyretains its discretion to determine whether additional sanctions are warranted, the Commission is inclined  Sx- xto look with favor upon a settlement in making that determination. See Declaratory Ruling, at 7521, n. 52. " S-  "x27. ACCORDINGLY, we find that a prima facie case of a violation of the LUC requirements of  x.Section 315(b)(1) of the Communications Act has been established by Complainants in connection with  xadvertising aired on WALBTV on their behalf during the sixty days preceding the November 8, 1994,  xgeneral election. The parties are hereby ORDERED to follow the procedures and timetable for discovery,  S`-postdiscovery, and election of a complaint resolution procedure established herein. xx x  S -  Ox28. We find that Complainants have failed to establish a prima facie case of an LUC violation  xby WALBTV during the period before the July 19, 1994, primary and the August 9, 1994, runoff election. Thus, their claims as to the 1994 primary and runoff elections against WALBTV are "& ,-(-(ZZn("Ԍ  xDISMISSED in their entirety. Finally, we DISMISS Complainants claims with regard to public file violations as those allegations are not properly considered here.  S`- x` `  hhFEDERAL COMMUNICATIONS COMMISSION x` `  hhRoy J. Stewart x` `  hhChief, Mass Media Bureau  SH - " ,-(-(ZZ "  S-x` `  hh APPENDIX A    DOCUMENTS TO BE PRODUCED TO COMPLAINANTS  S-  xjTo the extent not already produced to Bureau and Complainants, certain documents shall be produced to  xComplainants Zell Miller and Guy Millner by WALB by delivering them to the offices of Barnes,  xBrowning, Tanksley & Casurella, 166 Anderson Street, Suite 225, Marietta, Georgia 30060 in accordance with the procedures outlined in this Order. The documents to be produced are as follows:  x1) All advertising contracts executed by or on behalf of candidates for public office in connection with the 1994 general election.  xz2) All invoices, logs or other documents recording time, duration, or class of advertising time for each  xpolitical advertisement ordered and/or aired on behalf of candidates for public office in connection with the 1994 general election.  xj3) Copies of invoices and contracts for, and program logs related to: all commercial time run on WALB S0- x=TV beginning on September 9, 1994, and running through November 8, 1994, (the 60 days preceding the general election). xThis should include:   Xxa) All invoices, logs or other documents recording time, duration, or class of advertising time for   each commercial spot aired, and, if not apparent from the preceding, documents reflecting all agency discounts provided by the station;(#   Xxb) All long term contracts that pertain to commercial spots, including make goods and bonus spots, that aired during this period;(#   {Xxc) All addenda or memoranda relating to these invoices or contracts that alter or otherwise address   Pthe terms or provisions of any document subject to production pursuant to this document production order;(#   Xxd) All orders for commercial spots aired during this period, including confirmation orders or contracts;(#   !Xxe) All orders for bonus spots, public service announcements, or any other type of free spots, for any of the commercial advertisers who purchased time that ran during this period;(#   Xxf) All documents that describe the rate and other relevant terms (those that affect price or have   a direct bearing on the characteristics, such as class of time, or any priorities against preemption,   of each spot) of discount packages sold to commercial advertisers that included spots that aired during this period;(# xg) All documents regarding make goods provided to any commercial advertiser; and "& ,-(-(ZZn("ԌXxh) All documents that reflect promises of certain audience delivery to any commercial advertiser.(#  x/4) All documents used by WALBTV to explain to its sales personnel or other employees or agents  xdealing with political campaigns, or the agents of political campaigns, the application of the lowest unit  xjcharge provisions of Section 315(b) of the Communications Act. This should include any written policy  x/statement(s) used by WALBTV in 1994 which directly or indirectly related to WALBTV's pricing policies during the 1994 general election LUC period.  x5) All documents reflecting the existence, implementation, and results of any audit of rates charged to  xpolitical advertisers performed by or on behalf of WALBTV with respect to the 1994 general election,  xMincluding any provision of rebates to such political advertisers, as well as all documents explaining or detailing the methodology used by in performing any such audit or providing any such rebates. " ,-(-(ZZ "  S- ` `   APPENDIX B  S-  S-uADDITIONAL INFORMATION TO BE PROVIDED TO COMPLAINANTS ĐTP  x[Answers to the following interrogatories shall be provided to Complainants Zell Miller and Guy Millner in accordance with the procedures set forth in this Order: 1) Describe how WALBTV arrived at its LUC for the 1994 general election period.  x2) Detail any actions taken by WALBTV to ensure that political advertisers were, in fact, charged the  x[lowest unit rate for the same class and amount of time during the same time periods which ran during the  xjsixty days preceding the 1994 general election. This should include the identities of all individuals taking  xor participating in such action, identifying their position at WALBTV, and should identify all documents which refer to or formed a part of WALBTV's efforts to ensure that candidates received the LUC.  x3) Provide a statement that indicates the class and length of each commercial spot, if not apparent from the program logs, invoices or contracts, that aired during the relevant time period.  x4) Provide a statement that explains any codes used by WALBTV or its sales representatives to indicate  xthe rate, section or class of spot identified in confirmation contracts, program logs, affidavits of actual broadcast or other documents relating to advertising rates.  x5) Provide a statement that explains to what extent, if any, WALBTV accorded any priorities against  xpreemption to commercial advertisers who purchased time relevant to the 1994 general election period.  xLTo the extent that such priorities against preemption were given, explain whether this priority treatment was known to any commercial advertiser when the time was contracted for. " ,-(-(ZZ"  S-+ APPENDIX C  S-i TIMETABLE FOR DISCOVERY AND POSTDISCOVERY ă First day of discovery period (30  S8-days after release of this Order):hh@hpp  Day 1 Documents in Appendix A and Answers to  S-Written Interrogatories in Appendix B due:@hpp  Day 1 Request by Complainants for further discovery (production of additional documents, answers to additional written interrogatories, and/or for the taking  S -of depositions) due: hh@hpp  Day 15 Opposition by WALB to Complainants  SX-request for further discovery due:hh@hpp  Day 20 WALB's request for discovery (production of documents, answers to written interrogatories,  S-and/or for the taking of depositions) due: @hpp  Day 20 Opposition by Complainants  S@-to WALB's request for discovery due: hh@hpp  Day 27 Documents and answers to written interrogatories (if allowed by Bureau) pursuant to  S-WALB's request for discovery due:hh@hpp  Day 45 Production of additional documents and/or answers to additional written interrogatories (if allowed by Bureau) pursuant to Complainants request for  S-further discovery due: hh@hpp  Day 60  S-Final day of discovery period:hh@hpp  Day 60 x Complainants  S -amended complaint due:hh@hpp  Day 90  S!-WALB's answer to amended complaint due:@ hpp  Day 105 Joint notice of election of complaint resolution  SH$-procedure due:` `  hh@hpp  Day 116