EXHIBIT A

AFFIDAVIT OF JAMES A. WASHINGTON, JR.

I, JAMES A. WASHINGTON, JR., being first sworn according to law, depose and state as follows:

1. That I was the Chairman of the Public Service Commission of the District of Columbia from October 1961 to October 1966.

2. That between the years September 1963 and August 1965 I presided at the hearings regarding the Chesapeake and Potomac Telephone Company's application for a $10,500,000 increase in rates.

3. That I participated in the writing of the opinion in the case which was entered by the Commission in December 1964. The Commission denied a rate increase in the amount of $10,500,000 but granted an increase of $2,300,000.

4. That one of the intervenors in the case was The Telephone Users Association, Inc., whose President and attorney is Mr. Arthur S. Curtis.

5. That Mr. Arthur S. Curtis participated in the hearing of the case pro se and as an attorney for his association.

6. That during the course of the hearings but before the preparation of the opinion referred to above, Mr. Arthur S. Curtis approached me in my office at the Commission and stated that he had heard a rumor to the effect that I had a daughter who was employed at the Telephone Company. In response, I stated that is was not a rumor but a fact. I then asked the reason for his inquiry and indicated to him that, if he was intimating that the fact of her employment would have some effect upon my impartiality, he should raise this on motion before the Commission. He indicated that he did not care to do so and that he would drop the matter. He then left the office.

7. That I informed Commissioner Edgar H. Berstein of this matter shortly thereafter and also reported my conversation with Mr. Curtis to the Executive Secretary, Mr. Joseph S. Greco.

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8. That I was not aware of my daughter's employment by the Telephone Company at the time she was employed and I made no contact with any executive or other person in the Telephone Company concerning her employment.

9. Then, at the request of my son, Stephen C. Washington, then age 17, I contacted an executive of the Telephone Company in July 1963 to ascertain whether youths could be hired under the Telephone Company summer program for youth at that date and I was informed that it was possible to apply for summer employment. I have been informed by Stephen C. Washington that he went to the Telephone Company, took an examination, passed the examination and was employed during the summer months in 1963 at an initial gross salary of $66.50 per week. The next year Stephen C. Washington went to the Telephone Company and was employed during the summer months of 1964 at a salary of $72.00 per week. I have been informed by my Son, Stephen C. Washington, that he again went to the Telephone Company in the early part of the summer of 1965 seeking temporary employment and was advised that the program had been discontinued.

10. At the time referred to immediately above I also inquired if my son, James A Washington, III, could make application after his summer school work and was told that he could apply. I have been informed by my son, James A. Washington, III, that he went to the Telephone Company, took the examination, passed the examination and on this basis he was employed for a period of three weeks.

11. That the Court should be fully advised that during the latter part of the year 1962 the Public Service Commission held a conference with executives of the Telephone Company, the Gas Company and the Electric Company for the purpose of determining ways and means of removing the racial imbalance in employment in public utilities of the District of Columbia. At that meeting the conferees discussed recruiting within the negro community by advertising, by visits to Howard University and by references from the

Commission to the utilities of persons seeking employment. This activity was continued after this initial conference, with the first three meetings at six month intervals. As a result of these discussions the Chairman and others within the Commission referred persons to the Telephone Company, the Gas Company and the Electric Company for employment. It was a common understanding of all that reference did not mean employment and that any person referred would have to qualify by taking the required examination and by meeting the other qualifying criteria. [Many of the persons referred by me to the Telephone Company were not personally known to me.] Some of the persons referred by me to the Telephone Company were employed after qualifying. Others failed to quality and were rejected.

/s/ James A. Washington, Jr.

Subscribed and sworn to before me this 14th day of May

1969.

/s/ Dorothy M. Rainey

Notary Public, D.C.

EXHIBIT B

AFFIDAVIT OF J. HILLMAN ZAHN

CITY OF WASHINGTON)

DISTRICT OF COLUMBIA)

) SS:

I, J. Hillman Zahn, being duly sworn according to law, depose and say:

1. I am the J. Hillman Zahn referred to in the motion of the petitioner in this case to remand or for other appropriate relief. I am a Vice President of The Chesapeake and Potomac Telephone Company ("the Company"), a respondent in this case. I am now on loan to and serving as Deputy Executive Vice Chairman of the National Alliance of Businessmen, a national organization of businessmen formed to encourage private business to hire and train chronically unemployed persons. From March 1, 1962 to April 30, 1966 I was Vice President in charge of operations of the Company, with headquarters in Washington.

2. The records of the Company disclose that Grace Charlotte Alexander, the daughter of James A. Washington, Jr., was employed by the Company from December 1962 to November 1965. Mrs. Alexander was initially employed at a salary of $80.00 a week, which was increased by stages until at the end of her employment she was being paid at the rate of approximately $115.00 per week.

3. James A. Washington, Jr. did not at any time request or suggest to me that the Company should employ Grace Charlotte Alexander nor did he at any time give me the name of his daughter as a person qualified for employment. In fact I was not aware that his daughter was working for the Company until some time after she had been employed.

4. The records of the Company show that James A. Washington, III, a son of James A. Washington, Jr., then 18 years old, was employed on a temporary basis by the Company from August 12, to August 30, 1963, at a salary of $69.00 a week and worked as a helper in installing tele

phone equipment. The records of the Company also show that Stephen C. Washington, a son of James A. Washington, Jr., then 17 years old, was employed by the Company on a temporary basis from July 8 to August 31, 1963, at a salary of $66.50 a week which on July 21 was raised in accordance with a union contract to $69.00 a week, and from June 15 to September 4, 1964, at a salary of $72.00 a week. Stephen C. Washington was employed as a helper in the installation of telephone equipment. In each instance, these boys were employed under the same standards and were paid at the same rates generally applicable to such employment.

5. In 1963 and 1964 the Company engaged in a program of employing on a temporary basis qualified younger persons for work during the summer months. Pursuant to

this program the Company hired 416 temporary employees in the summer of 1963 and 360 in the summer of 1964. James A. Washington, III and Stephen C. Washington were employed by the Company pursuant to this program. Mr. Washington did not at any time speak to me about the employment of his two sons. I am informed and believe that in July 1963 he inquired of a representative of the Company whether temporary employment opportunities were still available for that summer and in that conversation mentioned the names of his two sons. I am also informed and believe that the applications of James A. Washington, III and Stephen C. Washington for employment were handled by the Company under the normal procedure governing such applications and that they were employed only after it had been determined that they possessed the necessary qualifications.

6. Between 1962 and 1964 when I was Vice President of the Company in charge of operations I was directly involved in the employment practices and policies of the Company. Throughout this period of time the Company was in need of qualified employees. The extent of this need is indicated by the fact that the Company employed 2404 persons in 1962, 3007 in 1963, and 3503 in 1964.