Attachment Felony Letter

This document pretains to SES-STA-INTR2017-03371 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTAINTR201703371_1311654

                                           Exhibit

                        Summary of Boeing Felony Convictions

Past Boeine: Convictions: The Boeing Company has pled guilty to felonies on two occasions. In
November 1989, Boeing pled guilty in federal court to two counts of violating 18 U.S.C. § 641
and § 642 (unlawful conveyance). These convictions relate to the activity of a Boeing employee
in its Washington D.C. office who improperly conveyed two government documents.

In June 1982, Boeing pled guilty in federal court to forty counts of violating 18 V.S.C. §§ 1001
and 1002 (false statements). These convictions relate to false statements that Boeing made in
applications to the Exim Bank as to whether payments were made to non regular agents in
connection with sales of commercial aircraft.

Past Rockwell Convictions .In December 1996, The Boeing Company completed the
acquisition of the aerospaceunits of Rockwell International Corporation. The acquired units
became a wholly owned subsidiary of Boeing, named Boeing North American, Inc. The
acquired units had the following felony convictions, all of them prior to the acquisition.

In March 1989, Rockwell pled guilty in federal court to one count of violating 18 U.S.C. § 371
(conspiracy to commit a fraud against the United States), one count of violating 18 U.S.C. § 401
(criminal contempt) and one count of violating 18 U.S.C § 1001 (false statements). These
convictions arose out of activity by the Satellite and Space Electronics Division of Rockwell
which was performing work under contracts for the United States government on the Global
Positioning System program. The convictions were due to failure to disclose facts relating to a
subcontract the disclosure of which were required by the Truth in Negotiations Act, and
submission of false claims for payment under a Global Positioning System contract in violation
of a prior court injunction.

In March 1992, Rockwell agreedto plead guilty in federal court to five felony and five
misdemeanorcounts of violating the ResourceConservationand RecoveryAct, 42 V.S.C. §§
6901 ~~,     andthe CleanWaterAct, 33 V.S.C. §§ 1251~ ~   Theseconvictionsaroseout of
activity performed by Rockwell in managingthe Rocky Flats Nuclear WeaponsPlant under
contractto the Departmentof Energy.

In April 1996,Rockwell pled guilty in federalcourtto threecountsof violating 42 V.S.C. § 6928
(for unlawful storageand disposalof hazardouswaste). Theseconvictionsresultedfrom activity
by employeesof the Rockwell Rocketdynedivision testsite in Simi Hills, California.

Past McDonnell Douf!las Convictions: In August 1997, Boeing completed the acquisition of
McDonnell Douglas Corporation, now a wholly owned subsidiary of Boeing. McDonnell
Douglas Corporation had the following felony convictions, all of them prior to the acquisition.

In September1981,McDonnell Douglas Corporationpled guilty in federal court to five counts
of violating 18 V.S.C. § 1001 (false statements),three countsof violating V.S.C. § 1341 (fraud
by mail) and two countsof violating 18 V.S.C. § 1343(fraud by wire). Theseconvictionsrelate
to false or incomplete statementsmade in Exim Bank filings concerning commission sales
representativesusedin the saleof commercialaircraft in five countries.



Document Created: 2017-09-18 15:01:10
Document Modified: 2017-09-18 15:01:10

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