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November 29, 2012
DA 12-1912
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 Debarment, File No. EB-12-IH-0847
Dear Mr. Lanham:
The Federal Communications Commission (Commission) hereby notifies you
that, pursuant to Section 54.8 of its rules, you are prohibited from
participating in activities associated with or relating to the schools and
libraries universal service support mechanism (E-Rate program) for three
years from either the date of your receipt of this Notice of Debarment or
of its publication in the Federal Register, whichever is earlier in time
(Debarment Date).
On July 27, 2012, the Commission's Enforcement Bureau (Bureau) sent you a
Notice of Suspension and Initiation of Debarment Proceeding (Notice of
Suspension) that was published in the Federal Register on August 13, 2012.
The Notice of Suspension suspended you from participating in activities
associated with or relating to the E-Rate program. It also described the
basis for initiating debarment proceedings against you, the applicable
debarment procedures, and the effect of debarment.
As discussed in the Notice of Suspension, in March 2012 you were convicted
of one count of theft of federal funds and three counts of mail fraud in
connection with your activities as a consultant for the New York City
Department of Education (DOE), which included managing Project Connect, an
E-Rate funded project. As a DOE consultant, you defrauded the E-Rate
program by, among other things, inflating consultant fees and bundling
those charges with eligible services on invoices billed to DOE for work
unrelated to Project Connect. As a result of your scheme, DOE was
fraudulently billed more than $3.6 million for Project Connect between
2002 and 2008, of which you profited approximately $1.7 million. Pursuant
to Section 54.8(c) of the Commission's rules, your conviction of criminal
conduct in connection with the E-Rate program is the basis for this
debarment.
In accordance with the Commission's debarment rules, you were required to
file with the Commission any opposition to your suspension or its scope,
or to your proposed debarment or its scope, no later than 30 calendar days
from either the date of your receipt of the Notice of Suspension or of its
publication in the Federal Register, whichever date occurred first. The
Commission did not receive any such opposition from you.
For the foregoing reasons, you are debarred from participating in
activities associated with or related to the E-Rate program for three
years from the Debarment Date. During this debarment period, you are
excluded 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.
Sincerely,
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)
47 C.F.R. S: 54.8(g); see also 47 C.F.R. S: 0.111 (delegating authority to
the Enforcement Bureau to resolve universal service suspension and
debarment proceedings).
Letter from Theresa Z. Cavanaugh, Chief, Investigations and Hearings
Division, Enforcement Bureau, Federal Communications Commission to Willard
Ross Lanham, Notice of Suspension and Initiation of Debarment Proceeding,
27 FCC Rcd 8384 (Enf. Bur. 2012) (Attachment 1).
77 Fed. Reg. 48154 (Aug. 13, 2012).
Supra n. 2 at 2.
Id. at 3.
Id.
47 C.F.R. S: 54.8(c).
47 C.F.R. S:S: 54.8 (e)(3), (4). Any opposition had to be filed no later
than August 26, 2012.
Id. S:S: 54.8(e)(5), (g).
Id. S:S: 54.8(a)(1), (5), (d).
Willard Ross Lanham
November 29, 2012
Page 2
WASHINGTON, DC 20554
FEDERAL COMMUNICATIONS COMMISSION
Enforcement Bureau
Investigations and Hearings Division