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                                  May 9, 2012

                                                                    DA 12-733

   SENT  VIA CERTIFIED MAIL, RETURN RECEIPT REQUESTED

   AND EMAIL

   Mr. Jonathan M. Slaughter

   c/o William R. Blanchard, Jr.

   Blanchard Law Offices

   505 South Perry Street

   Montgomery, AL 36104

   Re: Notice of Suspension and Initiation of Debarment Proceeding

   File No. EB-12-IH-0050

   Dear Mr. Slaughter:

   The Federal Communications Commission (Commission or FCC) 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 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 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 Commission's rules are designed
   to ensure that all E-Rate funds are used for their intended purpose. For
   example, schools and libraries must apply and meet certain qualifications
   to be eligible to receive E-Rate funds. Additionally, services purchased
   at a discount under the E-Rate program cannot be "sold, resold, or
   transferred . . . [for] money or any other thing of value."

   On September 29, 2011, you pled guilty to committing fraudulent activities
   associated with the E-Rate program while you were owner and president of
   E-Rate Consulting Services, LLC (ECS) in Montgomery, Alabama. ECS assisted
   schools and school districts in their efforts to qualify for E-Rate
   funding. ECS arranged to receive through the mail its clients' E-Rate
   checks, and was supposed to forward those checks to the clients. Between
   May 2006 and January 2009, however, you converted approximately $892,000
   in E-Rate funds to your personal use without your clients' knowledge.
   Specifically, you deposited E-Rate checks payable to your clients into an
   ECS bank account and, instead of transmitting the E-Rate funds to your
   clients, kept the money and used it largely for your personal expenses.
   Your fraudulent scheme affected six schools and 14 school districts
   located in 13 states.

   On January 6, 2012, the United States District Court for the Middle
   District of Alabama sentenced you to serve 51 months in prison followed by
   three years of supervised release. The court also ordered you to pay a
   $100 special assessment.

   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-A236, with a copy to Theresa Z. Cavanaugh,
   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, 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 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)

   Andrew O. Schiff, Assistant United States Attorney, United States
   Department of Justice (via e-mail)

                                                                     Appendix


             ECS' CLIENTS               STATE        TOTAL AMOUNT CONVERTED  


     Dermott Public School             Arkansas                   $6,809.24  
     District                                                                

     Citrus County School              Florida                  $678,288.69  
     District                                                                

     Eckerd Halfway House/E-Ku         Florida                       $5,670  
     Sumee                                                                   

     Hendry County School              Florida                   $39,031.19  
     District                                                                

     Kuna Joint School District         Idaho                     $3,523.67  

     Middleton School District          Idaho                     $4,299.25  
     #134                                                                    

     The Winchendon School          Massachusetts                 $8,316.00  

     Northwood Children's             Minnesota                  $24,797.66  
     Services                                                                

     Prairie Academy                  Minnesota                   $4,673.99  

     Poplar Bluff School District      Missouri                   $7,672.77  

     Red Cloud Community School        Nebraska                   $2,254.52  
     District                                                                

     SAU 41-Hollis Brookline        New Hampshire                 $1,765.18  
     Schools                                                                 

     Beaufort County School         North Carolina                $9,730.00  
     District                                                                

     Middle Ohio Education               Ohio                        $23.01  

     Penns Valley Area School        Pennsylvania                $10,966.83  
     District                                                                

     Bedford County School            Tennessee                  $23,215.94  
     District                                                                

     Banquete Independent School        Texas                    $18,655.72  
     District                                                                

     Cleburne Independent School        Texas                     $7,231.32  
     District                                                                

     Leander Independent School         Texas                    $31,872.31  
     District                                                                

     Teague Independent School          Texas                     $3,190.56  
     District                                                                


     TOTAL                                                      $891,987.85  


   Any further reference in this letter to "your conviction" refers to your
   guilty plea and subsequent sentencing for mail fraud in United States v.
   Jonathan Michael Slaughter, Criminal Case No. 2:11cr162-MEF-01, Judgment
   (M.D. Ala. 2012) (Judgment).

   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).

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

   47 C.F.R. S: 54.501.

   Id. S: 54.513(a).

   United States v. Jonathan Slaughter, Case No. 2:11cr162-MEF-01, Plea
   Agreement at 3-4 (M.D. Ala. 2011) (Plea Agreement).

   Id. at 4.

   Id.; Justice News, Dep't of Justice, Montgomery Man Pleads Guilty to
   Stealing $892,000 from Schools in 13 States, Sept. 29, 2011,
   http://www.justice.gov/usao/alm/press/current_press/2011_09_29_slaughter.pdf
   (Press Release).

   Plea Agreement at 4-5.

   Id.

   Id. See Appendix.

   Judgment  at 2-3.

   Id. at 5.

   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.

   Jonathan M. Slaughter

   May 9, 2012

   Page 3

   WASHINGTON, DC 20554

                       FEDERAL COMMUNICATIONS COMMISSION

                               Enforcement Bureau

                      Investigations and Hearings Division