ALTHOUGH NO CHARACTER RELATED ISSUES HAVE BEEN RAISED IN THE CONTEXT OF A SPECIFIC CITADEL APPLICATION, OUT OF AN ABUNDANCE OF CAUTION, CITADEL HEREBY REPORTS THAT CHARACTER RELATED ALLEGATIONS HAVE BEEN RAISED BY JOHN J. FULLER AGAINST CITADEL IN AN EMERGENCY MOTION FOR EXPEDITED ACTION AND COMPLAINT FILED ON JUNE 9, 2004 AND IN A FIRST SUPPLEMENT FILED ON JUNE 14, 2004 WITH RESPECT TO CITADEL'S STATIONS WQGN-FM AND WSUB(AM), GROTON, CT; IN A COMPLAINT FILED ON JUNE 16, 2004 WITH RESPECT TO WQGN-FM, WSUB(AM), AND WSKO-FM, WAKEFIELD-PEACEDALE, RI; AND IN A REPLY FILED ON AUGUST 2, 2004 WITH RESPECT TO WQGN-FM, WSUB(AM), AND WSKO-FM. FULLER IS SOLE SHAREHOLDER OF RED WOLF BROADCASTING CORPORATION, AN FCC LICENSEE. RED WOLF RAISED SIMILAR CHARACTER RELATED ALLEGATIONS AGAINST CITADEL IN AN OPPOSITION TO INFORMAL OBJECTION FILED ON JUNE 21, 2004; IN A COMPLAINT FILED ON JULY 20, 2004 WITH RESPECT TO WQGN-FM, WSUB(AM), AND WSKO-FM; AND IN A SUPPLEMENT TO REPLY FILED ON SEPTEMBER 27, 2004. RED WOLF FILED AN ADDITIONAL COMPLAINT ON JANUARY 31, 2005, A REPLY ON FEBRUARY 15, 2005, AND A FIRST SUPPLEMENT TO COMPLAINT ON FEBRUARY 18, 2005. FULLER'S AND RED WOLF'S ALLEGATIONS STEM FROM AN INFORMAL OBJECTION THAT CITADEL FILED ON MAY 26, 2004 AGAINST RED WOLF'S APPLICATION FOR A NEW FM TRANSLATOR STATION, FCC FILE NO. BNPFT-20030827AMA, NEW LONDON, CT, AND FROM CITADEL'S ACTIVITIES IN CONSTRUCTING A NEW BROADCAST TOWER FOR WQGN-FM AND WSUB(AM). CITADEL HAS RESPONDED, AND WILL BE FURTHER RESPONDING, TO THESE ALLEGATIONS IN THE APPROPRIATE CONTEXT, AND BELIEVES THAT THEY ARE MERITLESS.