General pleading requirements. Complaint proceedings under this part are generally resolved on a written record consisting of a complaint, answer, and reply, but may also include other written submissions such as briefs and written interrogatories. All written submissions, both substantive and procedural, must conform to the following standard: (1) Pleadings must be clear, concise, and explicit. All matters concerning a claim, defense or requested remedy, should be pleaded fully and with specificity; (2) Pleadings must contain facts which, if true, are sufficient to constitute a violation of the Communications Act or of a Commission regulation or order, or a defense to such alleged violation; (3) Facts must be supported by relevant documentation or affidavit; (4) Legal arguments must be supported by appropriate judicial, Commission, or statutory authority; (5) Opposing authorities must be distinguished; (6) Copies must be provided of all non-Commission authorities relied upon which are not routinely available in national reporting systems, such as unpublished decisions or slip opinions of courts or administrative agencies; and (7) Parties are responsible for the continuing accuracy and completeness of all information and supporting authority furnished in a pending complaint proceeding. Information submitted, as well as relevant legal authorities, must be current and updated as necessary and in a timely manner at any time before a decision is rendered on the merits of the complaint. (e) Complaint. (1) A complaint filed under this part shall contain: (i) The name of the complainant and each defendant; (ii) The type of entity that describes complainant (e.g., individual, private association, partnership, or corporation), the address and telephone number of the complainant, and the address and telephone number of each defendant; (iii) The name, address and telephone number of complainant's attorney, if complainant is represented by counsel; (iv) Citation to the section of the Communications Act and/or the Commission regulation or order alleged to have been violated; (v) A complete statement of facts, which, if proven true, would constitute such a violation; (vi) Any evidence that supports the truth or accuracy of the alleged facts; (vii) Evidence that the open video system operator's conduct at issue violated a section of the Communications Act and/or Commission regulation or order. (viii) If discrimination in rates, terms, and conditions of carriage is alleged, documentary evidence shall b...
