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                                 July 27, 2012

                                                                   DA 12-1211

   SENT  VIA CERTIFIED MAIL, RETURN RECEIPT REQUESTED

   AND EMAIL

   Mr. Willard Ross Lanham

   c/o Stephen N. Preziosi

   Law Office of Stephen N. Preziosi P.C.

   570 Seventh Avenue, Ninth Floor

   New York, NY 10018

   Re: Notice of Suspension and Initiation of Debarment Proceeding

   File No. EB-12-IH-0847

   Dear Mr. Lanham:

   The Federal Communications Commission (Commission or FCC) has received
   notice of your conviction for theft of federal education funds in
   violation of 18 U.S.C. S: 666(a)(1), and mail fraud in violation of 18
   U.S.C. S: 1341, in connection with 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 participating in activities associated with the
   E-Rate program. In addition, the Enforcement Bureau (Bureau) hereby
   notifies you that it 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 [E-Rate program]" from receiving the
   benefits associated with that program. The statutory provisions and
   Commission rules relating to the E-Rate program are designed to ensure
   that all E-Rate funds are used for their intended purpose. For example,
   Section 254(h)(1)(B) of the Communications Act of 1934, as amended,
   requires E-Rate program applicants to make bona fide requests for services
   intended for educational purposes in order to receive E-Rate discounts.
   Further, the Commission has stated that "[a] funding request may not be
   bona fide where a service provider has charged the beneficiary an inflated
   price." The Commission also limits E-Rate funding to certain eligible
   services, which does not include consulting services.

   On March 5, 2012, a jury rendered a guilty verdict convicting you on one
   count of theft of federal funds and three counts of mail fraud in
   connection with your activities as an E-Rate consultant for the New York
   City Department of Education (DOE). Your responsibilities as a DOE
   consultant included overseeing Project Connect, a project designed to
   bring Internet connectivity to New York City schools. On April 28, 2011,
   the Special Commissioner of Investigation for the New York City School
   District (SCI) released a report alleging, among other matters, that you
   had orchestrated a fraudulent invoicing and billing scheme using DOE
   vendors and subcontractors to overcharge DOE for Project Connect.

   Testimony and documentary evidence admitted during your trial corroborates
   SCI's allegations. Specifically, witnesses testified that you: 1) arranged
   for employees of your company, Lanham Enterprises, Inc., to work as
   consultants for DOE, 2) inflated their hourly rates far above their
   salaries, and 3) arranged for Project Connect subcontractors to bill those
   inflated rates to a Project Connect contractor using invoices that
   misstated the true nature of the charges. Witnesses further testified you
   directed employees of that contractor to "bundle" the consultant charges
   with services eligible for E-Rate funding on invoices and billing
   spreadsheets sent to DOE in order to make it appear that the consultants
   were doing work associated with wiring the schools for Internet access
   service. Your scheme resulted in DOE being fraudulently billed more than
   $3.6 million for Project Connect between 2002 and 2008, of which you
   profited approximately $1.7 million. The DOE included at least a portion
   of these overcharges in its E-Rate funding requests for Project Connect.

   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 E-Rate program, including the
   receipt of funds or discounted services through the E-Rate program, or
   consulting with, assisting, or advising applicants or service providers
   regarding the E-Rate program. Your suspension becomes effective upon
   receipt of this letter or its publication in the Federal Register,
   whichever comes first.

   In accordance with the Commission's suspension and debarment rules, you
   may contest this suspension or the scope of this suspension by filing
   arguments, with any relevant documents, within thirty (30) calendar days
   of receipt of this letter or its publication 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. The Bureau will decide any
   request to reverse or modify a suspension within ninety (90) calendar days
   of its receipt of such request.

   II. Initiation of Debarment Proceedings

   In addition to requiring your immediate suspension from the E-Rate
   program, your conviction is 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 proposed debarment or
   the scope of the proposed debarment by filing arguments and any relevant
   documentation within thirty (30) calendar days of receipt of this letter
   or its 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 ninety (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 E-Rate
   program for three years from the date of debarment. The Bureau may set a
   longer debarment period or extend an existing debarment period if
   necessary to protect the public interest.

   Please direct any response, if sent 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-C330, with a copy to Theresa Z. Cavanaugh,
   Chief, Investigations and Hearings Division, Enforcement Bureau, Room
   4-C330, 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-C330, Washington, D.C. 20554, with a copy to
   Theresa Z. Cavanaugh, Chief, Investigations and Hearings Division,
   Enforcement Bureau, Federal Communications Commission, 445 12th Street,
   S.W., Room 4-C330, Washington, D.C. 20554. You shall also transmit a copy
   of your response via e-mail 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 by telephone at (202) 418-1697. You may contact me at
   (202) 418-1553 or at the e-mail address noted above if Ms. Ragsdale is
   unavailable.

   Sincerely yours,

   Theresa Z. Cavanaugh

   Chief

   Investigations and Hearings Division

   Enforcement Bureau

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

   Rashann Duvall, Universal Service Administrative Company (via e-mail)

   Brian A. Jacobs, U. S. Attorney's Office, Southern District of New York
   (via e-mail)

   Alvin L. Bragg, Jr., U. S. Attorney's Office, Southern District of New
   York (via e-mail)

   Paul M. Krieger, U. S. Attorney's Office, Southern District of New York
   (via e-mail)

   Any further reference in this letter to "your conviction" refers to the
   jury's verdict finding you guilty on one count of theft of federal funds
   and three counts of mail fraud. Trial Transcript at 887, United States v.
   Willard Lanham, Jury Trial,  No. 11 CR 548 GBD (S.D.N.Y. 2012) (Trial
   Tr.); United States v. Willard Lanham, No. 11 CR 548 GBD, Order (S.D.N.Y.
   June 13) (order denying motions for judgment of acquittal and for a new
   trial).

   See 47 C.F.R. S: 0.111 (delegating authority to the Bureau to resolve
   universal service suspension and debarment proceedings). The Commission
   adopted debarment rules for the E-Rate program 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 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, app. C at 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), (a)(5), (c), (d),
   (e)(2)(i), (e)(3), (e)(4), and (g)).

   Second Report and Order, 18 FCC Rcd at 9225, para. 66; Program Management
   Order, 22 FCC Rcd at 16387, para. 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).

   NEC-Business Network Solutions, Inc., Notice of Debarment and Order
   Denying Waiver Petition, 21 FCC Rcd 7491, 7493, para. 7 (2006).

   47 U.S.C. S: 245(h)(1)(B); Request for Review by Ysleta Independent School
   District of the Decision of the Universal Service Administrator, CC Docket
   Nos. 96-45, 97-21, Order, 18 FCC Rcd 26407, 26409, para. 5 (2003), (citing
   Federal-State Joint Board on Universal Service, CC Docket No. 96-45,
   Report and Order, 12 FCC Rcd 8776, 9076, para. 570 (1997)).

   Schools and Libraries Universal Service Support Mechanism, Fifth Report
   and Order and Order, 19 FCC Rcd 15808, 15818, para. 30 (2004). The
   Commission has taken enforcement action against service providers who
   inflated their rates and subsequently requested E-Rate funding for those
   associated costs. See Letter from William H. Davenport, Chief,
   Investigations and Hearings Division, Enforcement Bureau, Federal
   Communications Commission, to Steven G. Mihaylo, Notice of Suspension and
   of Proposed Debarment, 20 FCC Rcd 1372 (Enf. Bur. 2005); see also Letter
   from Hillary S. DeNigro, Chief, Investigations and Hearings Division,
   Enforcement Bureau, Federal Communications Commission, to Richard E.
   Brown, Notice of Debarment, 22 FCC Rcd 20569 (Enf. Bur. 2007) (debarment
   of service provider who inflated costs in an attempt to defraud the E-Rate
   program).

   Federal-State Joint Board on Universal Service, Total Communications,
   Inc., Site Link Communications, Inc., Requests for Review of Decisions of
   the Universal Service Administrator, Order, 16 FCC Rcd 14020, 14023-24,
   para. 9 & n.23 (Com. Car. Bur. 2001) (Site Link Order).

   Trial Tr. at 887.

   See Trial Testimony of Tom Kambouras; Trial Tr. at 34-36; Testimony of
   Stephen Vigilante, Trial Tr. at 274-75.

   Special Commissioner of Investigation Report to Hon. Dennis M. Walcott,
   Chancellor New York City Public Schools, Dep't of Education from Richard
   J. Condon, Special Commissioner of Investigation for the New York City
   School District, SCI Case No. 2008-4446, at 1 (Apr. 28, 2011), at
   http://www.nycsci.org/reports/04-11%20Lanham%20Rpt.pdf (SCI Report).

   Testimony of Michael Pizza, Trial Tr. at 162-66; Testimony of Stephen
   Vigilante, Trial Tr. at 289-96. These consultants also worked on a second
   project that you managed for DOE that involved reviewing, paying, and
   centralizing DOE's telephone bills. Testimony of Stephen Vigilante, Trial
   Tr. at 282, 290.

   Testimony of Tamika Stevenson, Trial Tr. at 218; see also SCI Report at 6
   & n.18 (stating three of the consultants who were paid $30 to $70 per hour
   had their services billed to DOE at $290 an hour or more).

   Testimony of Christopher Louridas, Trial Tr. at 124-38; see also SCI
   Report at 7 & n.20.

   Testimony of Christopher Louridas, Trial Tr. at 124-26; Testimony of
   Joseph Iacoviello, Trial Tr. at 81-82; Testimony of Stephen Vigilante,
   Trial Tr. at 294-96; Testimony of Willard Lanham, Trial Tr. at 613,
   616-18, 636-38, 702-12, 735-38.

   See Testimony of Valerie Batista, Trial Tr. at 453-54 (testifying that
   Verizon billed DOE $3.9 million for the telecommunications consultants'
   work); SCI Report at 1 (stating that DOE paid Mr. Lanham approximately
   $3.6 million for the consultants' work).

   See Testimony of Stephen Vigilante, Trial Tr. at 274-75; see also News
   Release, Representative Charles B. Rangel, Ranking Democrat, Committee on
   Ways and Means, Chancellor Harold O. Levy and Congressman Charles Rangel
   Announce Utilization of Federal Assistance for School Modernization (Jan.
   8, 2002), at
   http://www.house.gov/apps/list/speech/ny15_rangel/pr.wm.schoolsqzab.html
   (News Release) (stating Project Connect would be "largely financed through
   the federal E-[R]ate program").

   47 C.F.R. S: 54.8(b); see Second Report and Order, 18 FCC Rcd at 9225-27,
   paras. 67-74.

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

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

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

   Id.

   Id. S: 54.8(f).

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

   "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." Id. S: 54.8(a)(1).

   Id. S: 54.8(b).

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

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

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

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

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

   See FCC Announces Change in Filing Location for Paper Documents, Public
   Notice, 24 FCC Rcd 14312 (2009) for further filing instructions.

   Willard Ross Lanham

   July 27, 2012

   Page 2

   WASHINGTON, DC 20554

                       FEDERAL COMMUNICATIONS COMMISSION

                               Enforcement Bureau

                      Investigations and Hearings Division