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                                 July 27, 2011

                                                                   DA 11-1270

   VIA CERTIFIED MAIL, RETURN RECEIPT REQUESTED

   AND FACSIMILE

   Mr. Barrett C. White

   c/o Mr. H. Thomas Murphy III

   H. Thomas Murphy, LLC

   1029 Milan Street

   New Orleans, LA 70115

   Re: Notice of Suspension and Initiation of Debarment Proceedings,

   File No. EB-11-IH-1075

   Dear Mr. White:

   The Federal Communications Commission ("FCC" or "Commission") has received
   notice of your conviction of conspiracy to defraud the United States in
   violation of 18 U.S.C S: 371 in connection with your participation in the
   federal 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 the
   Bureau will commence 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. On March 3,
   2011, you entered a plea agreement and pleaded guilty to intentionally
   conspiring with others to defraud and obtain money from the federal E-Rate
   Program. Specifically, on behalf of your co-conspirators' company, Global
   Network Technologies, Inc. ("GNT"), beginning approximately February 2004
   through August 2005 you offered and delivered $28,500 in bribes and
   kickbacks to various school officials in exchange for ceding control of
   the schools' E-Rate program to GNT and CTA. You also accepted fraudulent
   billing invoices from a school employee for services never provided by the
   employee, and concealed the source of your payments to school officials by
   paying them from a bank account not readily associated with your
   co-conspirators or their companies. These actions constitute the conduct
   or transactions upon which this suspension notice and proposed debarment
   proceeding is based.

   On June 9, 2011, you were sentenced to serve one year and one day in
   prison, followed by a two year period of supervised release, for
   conspiring to defraud the federal E-Rate program in multiple states. You
   also were ordered to pay a $4,000 fine for your role in the conspiracy
   scheme.

   Pursuant to section 54.8(b) of the Commission's rules, upon your
   conviction, the Bureau is required to suspend you from participating in
   any 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 fund mechanism, or consulting with,
   assisting, or advising applicants or service providers regarding the
   schools and libraries support mechanism. Your suspension becomes effective
   upon receipt of this letter, or publication of the notice in the Federal
   Register, whichever comes first.

   In accordance with the Commission's debarment rules, you may contest this
   suspension or the scope of this suspension by filing arguments, along with
   any relevant documents, within 30 calendar days after receipt of 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 to reverse or modify a suspension within 90
   calendar days of its receipt of such request.

   II. Initiation of Debarment Proceedings

   As discussed above, your guilty plea and conviction of criminal conduct in
   connection with the E-Rate program serves as a basis for immediate
   suspension from the program, as well as a basis to commence debarment
   proceedings against you. Conviction of criminal fraud is a cause for
   debarment as defined in section 54.8(c) of the Commission's rules.
   Therefore, pursuant to section 54.8(b) of the rules, your conviction
   requires the Bureau to commence debarment proceedings against you.

   As with the suspension process, you may contest the debarment or the scope
   of the proposed debarment by filing arguments and any relevant
   documentation within 30 calendar days of receipt of this letter or
   publication in the Federal Register, whichever comes first. The Bureau, in
   the absence of extraordinary circumstances, will notify you of its
   decision to debar within 90 calendar days of receiving any information you
   may have filed. If the Bureau decides to debar you, its decision will
   become effective upon either your receipt of a debarment notice or
   publication of the decision in the Federal Register, whichever comes
   first.

   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 set a longer debarment period if necessary to protect the
   public interest.

   Please direct any response, if by messenger or hand delivery, to Marlene
   H. Dortch, Secretary, Federal Communications Commission, 445 12th Street,
   S.W., Room TW-A325, Washington, D.C. 20554, to the attention of Joy M.
   Ragsdale, Attorney Advisor, Investigations and Hearings Division,
   Enforcement Bureau, Room 4-A236, with a copy to Theresa Z. Cavanaugh,
   Acting Division Chief, Investigations and Hearings Division, Enforcement
   Bureau, Room 4-C322, Federal Communications Commission. All messenger or
   hand-delivery filings must be submitted without envelopes. If sent by
   commercial overnight mail (other than U.S. Postal Service (USPS) Express
   Mail and Priority Mail), the response must be sent to the Federal
   Communications Commission, 9300 East Hampton Drive, Capitol Heights,
   Maryland 20743. If sent by USPS First Class, Express Mail, or Priority
   Mail, the response should be addressed to Joy Ragsdale, Attorney Advisor,
   Investigations and Hearings Division, Enforcement Bureau, Federal
   Communications Commission, 445 12th Street, S.W., Room 4-A236, Washington,
   D.C. 20554, with a copy to Theresa Z. Cavanaugh, Acting Division Chief,
   Investigations and Hearings Division, Enforcement Bureau, Federal
   Communications Commission, 445 12th Street, S.W., Room 4-C322, Washington,
   D.C. 20554. You shall also, to the extent practicable, transmit a copy of
   the response via email to Joy M. Ragsdale, joy.ragsdale@fcc.gov  and to
   Theresa Z. Cavanaugh, Terry.Cavanaugh@fcc.gov.

   If you have any questions, please contact Ms. Ragsdale via U.S. postal
   mail, e-mail, or telephone at (202) 418-7931. You may contact me at (202)
   418-1420 or at the email addressed noted above if Ms. Ragsdale is
   unavailable.

   Sincerely yours,

   Theresa Z. Cavanaugh

   Acting Chief

   Investigations and Hearings Division

   Enforcement Bureau

   cc: Johnnay Schrieber, Universal Service Administrative Company (via
   e-mail)

   Rashann Duvall, Universal Service Administrative Company (via email)

   Juan Rodriguez, Antitrust Division, United States Department of Justice
   (via e-mail)

   Stephanie Toussaint, Antitrust Division, United States Department of
   Justice (via e-mail)

   Any further reference in this letter to "your conviction" refers to your
   conviction of count one in Case No. 10-324-L. United States v. Barrett C.
   White, Criminal Docket No. 10-324-L, Judgment (E.D.LA. filed June 9, 2011)
   ("Judgment").

   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; Rural
   Health Care 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")
   (section 54.521 of the universal service debarment rules was renumbered as
   section 54.8 and subsections (a)(1), (5), (c), (d), (e)(2)(i), (3),
   (e)(4), and (g) were amended.)

   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).

   United States v. Barrett C. White, Criminal Case No. 10-324-L,  Judgment
   at 2 (E.D.LA. filed June 9, 2011).

   By letter, the Bureau will serve notice of suspension and initiation of
   debarment proceedings to Tyrone D. Pipkin, a partner in CTA, who pleaded
   guilty and was convicted on June 21, 2011 for his role in the conspiracy.
   The Bureau will also serve notice of suspension and initiation of
   debarment proceedings to Gloria F. Harper, who pleaded guilty to
   conspiracy on June 2, 2011, and awaits sentencing. See Justice News, Dep't
   of Justice, Owner of Illinois Technology Company Sentenced to Serve 12
   Months and a Day in Prison for Role in Conspiracy to Defraud the Federal
   E-Rate Program, June 9, 2011, at
   http://www.justice.gov/opa/pr/2011/June/11-at-755.html ("Press Release").

   United States v. Barrett C. White, Criminal Case No. 10-324-L,  Factual
   Basis at 2 (E.D.LA. filed Mar. 3, 2011) ("Factual Basis"). CTA and GNT
   marketed and provided E-Rate services to schools in Arkansas and
   Louisiana. Id.; United States v. Barrett C. White, Criminal Case No.
   10-324-L,  Information at 2 (E.D.LA. filed Nov. 18, 2011) ("Information").

   Information at 4.

   Factual Basis at 2-3.

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

   Press Release at 1; Judgment at 3.

   Judgment at 5. You were also ordered to immediately pay a Special
   Assessment of $100. Id.

   47 C.F.R. S: 54.8(b). 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(f).

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

   "Causes for suspension and debarment are 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). Associated 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).

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

   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), (g).

   Id.

   See FCC Public Notice, DA 09-2529 for further filing instructions (rel.
   Dec. 3, 2009).

   Barrett C. White

   July 27, 2011

   Page 5 of 5

                       Federal Communications Commission

                               Enforcement Bureau

                      Investigations and Hearings Division

                       445 12th Street, SW, Suite 4-C330

                             Washington, D.C. 20554