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                               September 25, 2007

   DA 07-4036

   VIA CERTIFIED MAIL 

   RETURN RECEIPT REQUESTED AND E-MAIL

   Mr. Richard E. Brown

   c/o Douglas McNabb, Esq.

   McNabb Associates PC

   JP Morgan Chase Tower

   600 Travis Street, Suite 7070

   Houston, TX 77002

   Re: Notice of Suspension and Initiation of Debarment Proceedings,

   File No. EB-07-IH-5369

   Dear Mr. Brown:

   The Federal Communications Commission ("FCC" or "Commission") has received
   notice of your conviction for mail fraud in violation of 18 U.S.C. S: 1341
   in connection with your participation in the schools and libraries
   universal service support mechanism ("E-Rate program"). Consequently,
   pursuant to 47 C.F.R. S: 54.521, this letter constitutes official notice
   of your suspension from the E-Rate program. In addition, the Enforcement
   Bureau ("Bureau") hereby notifies you that we are commencing debarment
   proceedings against you.

   I. Notice of Suspension

   The Commission has established procedures to prevent persons who have
   "defrauded the government or engaged in similar acts through activities
   associated with or related to the schools and libraries support mechanism"
   from receiving the benefits associated with that program. You pled guilty
   to three counts of mail fraud for activities in connection with your
   participation in the E-Rate program involving telecommunications upgrade
   projects in four Connecticut school districts. While employed at
   Southwestern Bell Communications ("SBC"), the prime contractor servicing
   these school districts, you recommended subcontractors to perform
   telecommunications upgrades in four Connecticut school districts. You also
   reviewed invoices submitted by the subcontractors to SBC for payment that
   SBC then submitted to the Universal Service Administrative Company
   ("USAC") for reimbursement from the E-Rate fund. You admitted to
   participating in schemes to defraud the E-Rate program where fictitious
   bills for upgrades that were never performed were submitted to USAC for
   reimbursement from the E-Rate fund. In another fraudulent scheme in which
   you admitted to being a participant, engineering services for upgrade
   projects were billed at inflated rates and the associated invoices were
   also submitted to USAC for E-Rate reimbursement. In sum, these schemes
   generated approximately $1,564,768 in fictitious expenses and
   approximately $956,203 of these expenses ultimately were submitted to the
   USAC for reimbursement from E-Rate fund.

   Pursuant to section 54.521(a)(4) of the Commission's rules, your
   conviction requires the Bureau to suspend you from participating in any
   activities associated with or related to the schools and libraries fund
   mechanism, including the receipt of funds or discounted services through
   the schools and libraries fund mechanism, or consulting with, assisting,
   or advising applicants or service providers regarding the schools and
   libraries support mechanism. Your suspension becomes effective upon the
   earlier of your receipt of this letter or publication of notice in the
   Federal Register.

   Suspension is immediate pending the Bureau's final debarment
   determination. In accordance with the Commission's debarment rules, you
   may contest this suspension or the scope of this suspension by filing
   arguments in opposition to the suspension, with any relevant
   documentation. Your request must be received within 30 days after you
   receive this letter or after notice is published in the Federal Register,
   whichever comes first. Such requests, however, will not ordinarily be
   granted. The Bureau may reverse or limit the scope of suspension only upon
   a finding of extraordinary circumstances. Absent extraordinary
   circumstances, the Bureau will decide any request for reversal or
   modification of suspension within 90 days of its receipt of such request.

   II. Initiation of Debarment Proceedings

   Your guilty plea to criminal conduct in connection with the E-Rate
   program, in addition to serving as a basis for immediate suspension from
   the program, also serves as a basis for the initiation of debarment
   proceedings against you. Your conviction falls within the categories of
   causes for debarment defined in section 54.521(c) of the Commission's
   rules. Therefore, pursuant to section 54.521(a)(4) of the Commission's
   rules, your conviction requires the Bureau to commence debarment
   proceedings against you.

   As with your suspension, you may contest debarment or the scope of the
   proposed debarment by filing arguments and any relevant documentation
   within 30 calendar days of the earlier of the receipt of this letter or of
   publication in the Federal Register. Absent extraordinary circumstances,
   the Bureau will debar you. Within 90 days of receipt of any opposition to
   your suspension and proposed debarment, the Bureau, in the absence of
   extraordinary circumstances, will provide you with notice of its decision
   to debar. If the Bureau decides to debar you, its decision will become
   effective upon the earlier of your receipt of a debarment notice or
   publication of the decision in the Federal Register.

   If and when your debarment becomes effective, you will be prohibited from
   participating in activities associated with or related to the schools and
   libraries support mechanism for three years from the date of debarment.
   The Bureau may, if necessary to protect the public interest, extend the
   debarment period.

   Please direct any response, if by messenger or hand delivery, to Marlene
   H. Dortch, Secretary, Federal Communications Commission, 236 Massachusetts
   Avenue, N.E., Suite 110, Washington, D.C. 20002, to the attention of Diana
   Lee, Attorney Advisor, Investigations and Hearings Division, Enforcement
   Bureau, Room 4-C330, with a copy to Vickie Robinson, Assistant Chief,
   Investigations and Hearings Division, Enforcement Bureau, Room 4-C330,
   Federal Communications Commission. If sent by commercial overnight mail
   (other than U.S. Postal Service Express Mail and Priority Mail), the
   response should be sent to the Federal Communications Commission, 9300
   East Hampton Drive, Capitol Heights, Maryland 20743. If sent by
   first-class, Express, or Priority mail, the response should be sent to
   Diana Lee, Attorney Advisor, Investigations and Hearings Division,
   Enforcement Bureau, Federal Communications Commission, 445 12th Street,
   S.W., Room 4-C330, Washington, DC, 20554, with a copy to Vickie Robinson,
   Assistant Chief, Investigations and Hearings Division, Enforcement Bureau,
   Federal Communications Commission, 445 12th Street, S.W., Room 4-C330,
   Washington, DC, 20554. You shall also transmit a copy of the response via
   email to diana.lee@fcc.gov and to vickie.robinson@fcc.gov.

   If you have any questions, please contact Ms. Lee via mail, by telephone
   at (202) 418-1420 or by e-mail at diana.lee@fcc.gov. If Ms. Lee is
   unavailable, you may contact Ms. Vickie Robinson, Assistant Chief,
   Investigations and Hearings Division, by telephone at (202) 418-1420 and
   by e-mail at vickie.robinson@fcc.gov.

   Sincerely yours,

   Hillary S. DeNigro

   Chief

   Investigations and Hearings Division

   Enforcement Bureau

   cc: Calvin B. Kurimai, Esq., Assistant United States Attorney

   Kristy Carroll, Esq., Universal Service Administrative Company (via
   e-mail)

   Any further reference in this letter to "your conviction" refers to your
   February 13, 2007 guilty plea and subsequent conviction of three counts of
   mail fraud. United States v. Richard E. Brown, Criminal Docket No.
   3:07-CR-29 (RNC), Plea Agreement (D.Conn. filed Feb. 13, 2007 and entered
   Feb. 14, 2007) ("Brown Plea Agreement"); United States v. Richard E.
   Brown, 3:07-CR-29 (RNC), Judgment (D.Conn. filed Sept. 6, 2007 and entered
   Sept. 7, 2007) ("Brown Judgment").

   47 C.F.R. S: 54.521; 47 C.F.R. S: 0.111(a)(14) (delegating to the
   Enforcement Bureau authority to resolve universal service suspension and
   debarment proceedings pursuant to 47 C.F.R. S: 54.521).

   See Schools and Libraries Universal Service Support Mechanism, Second
   Report and Order and Further Notice of Proposed Rulemaking, 18 FCC Rcd
   9202, 9225, P: 66 (2003) ("Second Report and Order"). The Commission's
   debarment rules define a "person" as "[a]ny individual, group of
   individuals, corporation, partnership, association, unit of government or
   legal entity, however, organized." 47 C.F.R. S: 54.521(a)(6).

   See generally United States v. Richard E. Brown, Criminal Docket No.
   3:07-CR-29 (RNC), Information (D.Conn. filed and entered Jul. 28, 2006)
   ("Information"); Brown Plea Agreement  at 1; Brown Judgment at 1.

   See Information at 2-3.

   See Information at 1-8.

   See Information at 8-10.

   See Information at 3, 5, 8;
   http://www.usdoj.gov/usao/ct/Press2007/20070829-3.html (Department of
   Justice Press Release dated August 29, 2007) (last accessed September 12,
   2007) ("DOJ August 29 Press Release"). See also Letter from Hillary S.
   DeNigro, Chief, Investigations and Hearings Division, Enforcement Bureau,
   Federal Communications Commission, to Scott A. Federowicz, c/o Paul H.D.
   Stoughton, Conway & Stoughton, LLP, Notice of Suspension and Initiation of
   Debarment Proceedings, File No. EB-07-IH-5171, (rel. June 27, 2007)
   ("Federowicz Suspension Letter"); 72 Fed. Reg. 39425 (Jul. 18, 2007).

   47 C.F.R. S: 54.521(a)(4). See Second Report and Order, 18 FCC Rcd at
   9225-9227, P:P: 67-74 (2003).

   Second Report and Order, 18 FCC Rcd at 9225, P: 67; 47 U.S.C. S: 254; 47
   C.F.R S:S: 54.502-54.503; 47 C.F.R. S: 54.521(a)(4).

   Second Report and Order, 18 FCC Rcd at 9226, P: 69; 47 C.F.R. S:
   54.521(e)(1).

   Second Report and Order, 18 FCC Rcd at 9226, P: 70; 47 C.F.R. S:
   54.521(e)(4).

   Second Report and Order, 18 FCC Rcd at 9226, P: 70.

   47 C.F.R. S: 54.521(e)(5).

   See Second Report and Order, 18 FCC Rcd at 9226, P: 70; 47 C.F.R. S:S:
   54.521(e)(5), 54.521(f).

   "Causes for suspension and debarment are the conviction of or civil
   judgment for attempt or commission of criminal fraud, theft, embezzlement,
   forgery, bribery, falsification or destruction of records, making false
   statements, receiving stolen property, making false claims, obstruction of
   justice and other fraud or criminal offense arising out of activities
   associated with or related to the schools and libraries support
   mechanism." 47 C.F.R. S: 54.521(c). Such activities "include the receipt
   of funds or discounted services through the schools and libraries support
   mechanism, or consulting with, assisting, or advising applicants or
   service providers regarding schools and libraries support mechanism
   described in this section ([47 C.F. R.] S: 54.500 et seq.)." 47 C.F.R. S:
   54.521(a)(1).

   See Second Report and Order, 18 FCC Rcd at 9226, P: 70; 47 C.F.R. S:S:
   54.521(e)(2)(i), 54.521(e)(3).

   Second Report and Order, 18 FCC Rcd at 9227, P: 74.

   See id., 18 FCC Rcd at 9226, P: 70; 47 C.F.R. S: 54.521(e)(5).

   Id. The Commission may reverse a debarment, or may limit the scope or
   period of debarment upon a finding of extraordinary circumstances,
   following the filing of a petition by you or an interested party or upon
   motion by the Commission. 47 C.F.R. S: 54.521(f).

   Second Report and Order, 18 FCC Rcd at 9225, P: 67; 47 C.F.R. S:S:
   54.521(d), 54.521(g).

   Id.

   Richard E. Brown

   September 25, 2007

   Page 3 of 5

                       Federal Communications Commission

                               Enforcement Bureau

                      Investigations and Hearings Division

                       445 12th Street, SW, Suite 4-C330

                             Washington, D.C. 20554