A top telecommunications lawyer has filed papers with the Federal Communications Commission that take the hardest line ever against the proposed merger of Sirius and XM satellite radio. Attorney Julian R. Shepard's heavily redacted statement offers "Highly Confidential Documents," he says, that "call into question the truthfulness and candor of both Sirius and XM with respect to their dealings with the Commission as licensees during this proceeding." Shepard files as counsel for the Consumer Coalition for Competition in Satellite Radio, or "C3SR" as it calls itself for short.

Not surprisingly, the filing urges the FCC to reject Sirius and XM's merger application. But C3SR goes further, suggesting that the companies have been "less than candid" before the government, and that "this conduct raises serious questions that must be investigated." In fact, the agency should consider revoking Sirius and XM's licenses, the 25-page comment concludes.

Shepard is no lone crank, firing a shot in the dark. His résumé includes a term as vice president and general counsel of the Association for Maximum Service Television, senior policy advisor at the National Telecommunications and Information Administration, and attorney for the National Association of Broadcasters (NAB).

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