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                                 August 7, 2008

   DA 08-1862

   VIA CERTIFIED MAIL

   RETURN RECEIPT REQUESTED AND E-MAIL

   Mr. Allan Green

   c/o Mark Rosenbush, Esq.

   Attorney at Law

   214 Duboce Avenue

   San Francisco, CA 94103

   Re: Notice of Debarment, File No. EB-08-IH-1141

   Dear Mr. Green:

   Pursuant to section 54.8 of the rules of the Federal Communications
   Commission (the "Commission"), by this Notice of Debarment you are
   debarred from the schools and libraries universal service support
   mechanism (or "E-Rate program") for a period of three years.

   On May 19, 2008, the Enforcement Bureau (the "Bureau") sent you a Notice
   of Suspension and Initiation of Debarment Proceedings (the "Notice of
   Suspension"). That Notice of Suspension was published in the Federal
   Register on June 9, 2008. The Notice of Suspension suspended you from the
   schools and libraries universal service support mechanism and described
   the basis for initiation of debarment proceedings against you, the
   applicable debarment procedures, and the effect of debarment.

   Pursuant to the Commission's rules, any opposition to your suspension or
   its scope or to your proposed debarment or its scope had to be filed with
   the Commission no later than thirty (30) calendar days from the earlier
   date of your receipt of the Notice of Suspension or publication of the
   Notice of Suspension in the Federal Register. The Commission did not
   receive any such opposition.

   As discussed in the Notice of Suspension, you pled guilty to and were
   convicted of conspiracy to commit mail fraud, in violation of 18 U.S.C. S:
   371, in connection with your participation in the Philadelphia Academy
   ("Academy") E-Rate project ("Project"). You admitted to participating in a
   conspiracy whereby you and others (collectively "co-conspirators"), among
   other things, misrepresented to Academy employees that co-conspirators
   would be able to obtain a grant to cover the Academy's share of the cost
   of the Project, provided false and misleading documents to the Universal
   Service Administrative Company ("USAC") indicating the Academy has secured
   access to funding from an independent source, and misrepresented to USAC
   the share of the Project's costs that USAC would be paying. Such conduct
   constitutes the basis for your debarment, and your conviction falls within
   the categories of causes for debarment under section 54.8(c) of the
   Commission's rules. For the foregoing reasons, you are hereby debarred for
   a period of three years from the debarment date, i.e., the earlier date of
   your receipt of this Notice of Debarment or its publication date in the
   Federal Register. Debarment excludes you, for the debarment period, from
   activities "associated with or related to the schools and libraries
   support mechanism," including "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 the
   schools and libraries support mechanism."

   Sincerely,

   Hillary S. DeNigro

   Chief

   Investigations and Hearings Division

   Enforcement Bureau

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

   Michael Wood, Antitrust Division, United States Department of Justice (via
   mail)

                                  May 19, 2008

   DA 08-1179

   VIA CERTIFIED MAIL

   RETURN RECEIPT REQUESTED AND E-MAIL

   Mr. Allan Green

   c/o Mark Rosenbush, Esq.

   Attorney at Law

   214 Duboce Avenue

   San Francisco, CA 94103

   Re: Notice of Suspension and Initiation of Debarment Proceedings,

   File No. EB-08-IH-1141

   Dear Mr. Green:

   The Federal Communications Commission ("FCC" or "Commission") has received
   notice of your conviction of conspiracy to commit mail fraud, in violation
   of 18 U.S.C. S: 371, 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: 54.8, 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 conspiracy to commit mail fraud through your activities as a principal
   of ADJ Consultants, Inc. ("ADJ") in relation to the Philadelphia Academy
   ("the Academy") E-Rate project (the "Project"). Specifically, you admitted
   that you and others (collectively "co-conspirators") met with Academy
   employees, obtained their agreement to utilize ADJ services for the
   Project, and told Academy employees that co-conspirators would be able to
   obtain a grant to cover the Academy's share of the Project's costs. You
   admitted that the co-conspirators further agreed and submitted to the
   Universal Service Administrative Company "(USAC") false and misleading
   documents indicating that the Academy had secured access to funding from
   an independent foundation and that the co-conspirators also misrepresented
   the share of the Project's costs that USAC would be paying.

   Pursuant to section 54.8(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 and conviction of 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 54.8(c) of the Commission's rules.
   Therefore, pursuant to section 54.8(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: Kristy Carroll, Esq., Universal Service Administrative Company (via
   e-mail)

   Michael Wood, Antitrust Division, United States Department of Justice (via
   mail)

   See 47 C.F.R. S:S: 0.111(a), 54.8.

   Letter from Hillary S. DeNigro, Chief, Investigations and Hearings
   Division, Enforcement Bureau, Federal Communications Commission, to Mr.
   Allan Green, Notice of Suspension and Initiation of Debarment Proceedings,
   23 FCC Rcd 8211 (Inv. & Hearings Div., Enf. Bur. 2008) (Attachment 1).

   73 Fed. Reg. 32579  (June 9, 2008).

   See Notice of Suspension, 23 FCC Rcd at 8212-14.

   See 47 C.F.R. S:S: 54.8(e)(3) and (4). That date occurred no later than
   July 9, 2008. See supra note 3.

   See Notice of Suspension, 23 FCC Rcd at 8211-12.

   See id. at 8212.

   47 C.F.R. S: 54.8(c).

   See 47 C.F.R S:54.8(g). See also Notice of Suspension, 23 FCC Rcd at 8213.

   See 47 C.F.R. S:S: 54.8(a)(1), 54.8(a)(5), 54.8(d); Notice of Suspension,
   23 FCC Rcd at 8214.

   Any further reference in this letter to "your conviction" refers to your
   guilty plea and subsequent conviction of conspiracy to commit mail fraud.
   See United States v. Allan Green, Criminal Docket No.
   3:05-CR-00208-CRB-009, Judgment (N.D.Cal. filed and entered Apr. 10, 2008)
   ("Allan Green Judgment"), Substitute Information (N.D.Cal. filed Apr. 9,
   2007 and entered Apr. 10, 2007) ("Allan Green Substitute Information").
   See United States v. Video Network Communications, Inc. et al., Criminal
   Docket No. 3:05-CR-00208-CRB, Superseding Indictment (N.D.Cal. filed Dec.
   8, 2005 and entered Dec. 12, 2005);
   http://www.usdoj.gov/atr/cases/f213600/213626.htm (accessed May 1, 2008)
   ("VNCI Superseding Indictment").

   47 C.F.R. S: 54.8; 47 C.F.R. S: 0.111 (delegating to the Enforcement
   Bureau authority to resolve universal service suspension and debarment
   proceedings). The Commission adopted debarment rules for the schools and
   libraries universal service support mechanism in 2003. See Schools and
   Libraries Universal Service Support Mechanism, Second Report and Order and
   Further Notice of Proposed Rulemaking, 18 FCC Rcd 9202 (2003) ("Second
   Report and Order")  (adopting section 54.521 to suspend and debar parties
   from the E-rate program). In 2007, the Commission extended the debarment
   rules to apply to all of the Federal universal service support mechanisms.
   Comprehensive Review of the Universal Service Fund Management,
   Administration, and Oversight; Federal-State Joint Board on Universal
   Service; Schools and Libraries Universal Service Support Mechanism;
   Lifeline and Link Up; Changes to the Board of Directors for the National
   Exchange Carrier Association, Inc., Report and Order, 22 FCC Rcd 16372,
   16410-12 (2007) (Program Management Order) (renumbering section 54.521 of
   the universal service debarment rules as section 54.8 and amending
   subsections (a)(1), (5), (c), (d), (e)(2)(i), (3), (e)(4), and (g)).

   See Second Report and Order, 18 FCC Rcd at 9225, P: 66; Program Management
   Order, 22 FCC Rcd at 16387, P: 32. 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: 54.8(a)(6).

   See Allan Green Substitute Information at P:P: 2, 6. The following four
   individuals, who were also charged in the VNCI Superseding Indictment,
   have pled guilty or been found guilty, and subsequently have been
   sentenced: Judy Green, George Marchelos, Earl Nelson, and William Holman.
   We are sending separate notices of suspension and initiation of debarment
   proceedings to these individuals. VNCI and ADJ are now defunct; charges
   against the companies have been dropped.

   See Allan Green Substitute Information at P: 5.

   See id.

   47 C.F.R. S: 54.8(a)(4). See Second Report and Order, 18 FCC Rcd at
   9225-9227, P:P: 67-74.

   47 C.F.R. S:S: 54.8(a)(1), (d).

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

   47 C.F.R. S: 54.8(e)(4).

   Id.

   47 C.F.R. S: 54.8(e)(5).

   See Second Report and Order, 18 FCC Rcd at 9226, P: 70; 47 C.F.R. S:S:
   54.8(e)(5), 54.8(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,
   the high-cost support mechanism, the rural healthcare support mechanism,
   and the low-income support mechanism." 47 C.F.R. S: 54.8(c). Such
   activities "include the receipt of funds or discounted services through
   [the Federal universal service] support mechanisms, or consulting with,
   assisting, or advising applicants or service providers regarding [the
   Federal universal service] support mechanisms." 47 C.F.R. S: 54.8(a)(1).

   See Second Report and Order, 18 FCC Rcd at 9226, P: 70; 47 C.F.R. S:
   54.8(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: 54.8(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: 54.8(f).

   Second Report and Order, 18 FCC Rcd at 9225, P: 67; 47 C.F.R. S:S:
   54.8(d), 54.8(g).

   Id.

   Mr. Allan Green

   August 7, 2008

   Page 2 of 2

                       Federal Communications Commission

                               Enforcement Bureau

                      Investigations and Hearings Division

                       445 12th Street, SW, Suite 4-C330

                             Washington, D.C. 20554

   Mr. Allan Green

   May 19, 2008

   Page 4 of 4

                                  Attachment 1

                       Federal Communications Commission

                               Enforcement Bureau

                      Investigations and Hearings Division

                       445 12th Street, SW, Suite 4-C330

                             Washington, D.C. 20554