Brendan Parets
Chief Counsel
Lindsey Graham 2016
1555 King Street, Suite 300
Alexandria, Virginia 22314
Dale R. Woods
General Manager
WHO-TV
1801 Grand Ave.
Des Moines, Iowa 50309
November 13, 2015
Via FedEx and Electronic Mail
Re: Equal Time Request
Dear Mr. Woods:
I represent Lindsey Graham 2016, Senator Lindsey Graham’s presidential campaign
committee, and am writing to request an equal opportunity for Senator Graham to appear on
WHO-TV for 12 minutes and five seconds in light of presidential candidate Donald Trump’s
appearance on Saturday Night Live.1
Federal Communications Commission regulations require station licensees that permit a
“legally qualified candidate for public office . . . to use its facilities” to “afford equal
opportunities to all other candidates for that office to use such facilities .”2 Both Senator
Graham and Mr. Trump can make a “substantial showing of a bona fide candidacy” for the
Republican presidential nomination in Iowa and are therefore “legally qualified
candidate[s]” for president in the state. Accordingly, Senator Graham is due an equal
opportunity to appear on your station after Mr. Trump’s appearance. 3
A candidate makes a “substantial showing of a bona fide candidacy” by providing evidence
that he or she “engaged to a substantial degree in activities commonly associated with
political campaigning,” including by “making campaign speeches, distributing campaign
I have enclosed with this correspondence your station’s November 9, 2015 notice that states in
relevant part: “Donald Trump, a candidate for the Republican nomination for President in the
2016 national election, appeared without charge on NBC's ‘Saturday Night Live’ for a total
period of 12:05 (12 minutes and 5 seconds) commencing at 10:39:11 PM MT on November 7 and
ending at 12:01:01 AM MT on November 8, 2015. Station WHO-TV, Des Moines, is affiliated
with the NBC Television Network and broadcast the November 7 episode of ‘Saturday Night
Live,’ including the segments in which Mr. Trump appeared.”
1

2

47 C.F.R § 73.1941.

3

Id. §§ 73.1941, 73.1940(e)(2).

 literature, issuing press releases, maintaining a campaign committee, and establishing
campaign headquarters.” 4 As you probably know, both Senator Graham and Mr. Trump are
actively campaigning in Iowa for the Republican presidential nomination. Both campaigns
have multiple Iowa staff members and issue numerous press releases detailing their
candidates’ Iowa activities.5 Mr. Trump and Senator Graham frequently appear at events in
the state in support of their presidential candidacies. 6
Please contact Brittany Bramell by email at bbramell@grahamhq.com or by telephone at
703-542-3282 x 6 to schedule Senator Graham’s appearance on WHO-TV. Additionally, I
can be reached by email at bparets@grahamhq.com and by telephone at 703-542-3282 x 9 if
you have any questions about this matter or wish to discuss it further.
Thank you very much for your prompt attention to this matter, and Ms. Bramell and I look
forward to hearing from you.
Sincerely,

Brendan Parets
Enclosure

4

Id. § 73.1940.

See, e.g., Lindsey Graham 2016, Graham 2016 Announces the Endorsement of Iowa State
Senator Tim Kapucian, Nov. 9, 2015,
http://lg2016.cmail2.com/t/ViewEmail/j/224EA6EDF1318A9D/B7666C2758E0874FF039C52
3302FD418; Donald J. Trump for President, Inc., Donald J. Trump Receives Endorsement of
Iowa State Senator Brad Zaun, Oct. 15, 2015, https://www.donaldjtrump.com/pressreleases/donald-j-trump-receives-endorsement-of-iowa-state-senator-brad-zaun.
5

See, e.g., Kim Norvell, The Des Moines Register, Lindsey Graham promises to 'destroy' U.S.
enemies, Oct. 31, 2015,
http://www.desmoinesregister.com/story/news/elections/presidential/caucus/2015/10/31/lind
sey-graham-promises-destroy-us-enemies-gop-growth-opportunity-party/74853508; Katy Tur,
NBC News, Trump Machine Ups Its Ground Game in Iowa, Oct. 22, 2015,
http://www.nbcnews.com/politics/2016-election/trump-machine-ups-its-ground-game-iowan448931; Jason Noble, The Des Moines Register, Lindsey Graham returns to Iowa Friday and
Saturday, Sept. 15, 2015,
http://www.desmoinesregister.com/story/news/elections/presidential/caucus/2015/09/15/lin
dsey-graham-returns-iowa-friday-and-saturday/72324922; C-SPAN, Senator Lindsey Graham
at the Iowa State Fair, Aug. 17, 2015, http://www.c-span.org/video/?327574-4/senator-lindseygraham-iowa-state-fair.
6