Attachment question37

This document pretains to SES-MOD-20130128-00105 for Modification on a Satellite Earth Station filing.

IBFS_SESMOD2013012800105_982150

Question 37

37. Has the applicant, or any party to this application or amendment, or any party directly or indirectly
controlling the applicant ever been convicted of a felony by any state or federal court? If Yes, attach as an
exhibit, an explanation of circumstances.

         “On March 1, 2005, Titan pled guilty to three felony counts related to its former overseas
         operations. These counts consist of violations of the anti-bribery and the books and records
         provisions of the Foreign Corrupt Practices Act (FCPA) and aiding and assisting in the
         preparation of a false tax return. On March 2, 2005, Titan and the debarring official for the
         U.S. Navy entered into an administrative settlement agreement which evidences that, after
         reviewing Titan's enhanced ethics and compliance program and other remedial measures,
         the cognizant Government debarring official has determined that Titan is presently
         responsible and will not be suspended or debarred as a consequence of the guilty plea.”



Document Created: 2010-07-27 16:37:23
Document Modified: 2010-07-27 16:37:23

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