My name is Charles D. Carter. I am the owner President and CEO of the National Emergency Communications Institute, referred to as NECI, in Atlanta.

I am also a 9-1-1 Litigation Specialist who specializes in investigations of alleged wrongdoing by 9-1-1 employees in civil lawsuits in several states.

I am a former police officer, investigator, and Chief Deputy Sheriff near Atlanta.

For the past twenty-four years, NECI has provided 9-1-1 certification courses to many state and local 9-1-1 boards and commissions.
NECI was selected by the Mississippi Board of Emergency Telecommunications Standards and Training (BETST), a state agency under the Mississippi Department of Public Safety, as one of the training companies to meet the statutory requirements of the Mississippi 9-1-1 Act in 1993.

In 1995, NECI contracted Robert Graham to teach conduct the 9-1-1 instructor course for individuals who would return to their agencies and certify all the other 9-1-1 employees with the NECI 9-1-1 Basic Certification and other programs.
NECI allows certified 9-1-1 instructors to form a private training company and conduct course using training manuals developed by NECI and to charge a fee for training 9-1-1 employees from agencies other than their own as long as they were not on duty.
In addition to being a contract instructor for NECI, Robert Graham also began purchasing 9-1-1 training manuals to conduct training courses around the state. He conducted many courses at the Jackson Police Academy and many other locations in Mississippi. Beginning in 1999, Graham stopped ordering all but a few manuals from NECI.

In 2006, NECI received a call from the Mississippi Board of Emergency Telecommunications Standards and Training (BETST) wanting to know if we had changed the appearance of our certificates. We advised we had not and inquired as to the reason for the question. We were told that the courses conducted by Robert Graham for NECI were being certified using a different certificate. We requested copies of the certificate and some course student rosters to compare to our records. When the course rosters arrived, we began a thorough review of NECI records and compared them with information received from BETST and other sources.

From our review of those sources of information, we have formed the clear opinion that Robert Graham had been conducting courses and falsely representing them to 9-1-1- instructors, their employers and the 9-1-1- board as NECI courses. In addition, he was using training materials not purchased from NECI. Then, he was charging $495.00 per student, an amount for which the state 9-1-1 board was reimbursing the 9-1-1 agencies. (Funds for these reimbursements come from charges paid by customers of telephone companies, collected on each monthly bill paid by telephone customers and dedicated toward the costs 9-1-1- service.)

We notified the state 9-1-1 board of this and requested to come to their office in Jackson and conduct a more formal investigation to determine how long and how frequently this had been going on. In addition, I notified the Mississippi Attorney General in writing and alleged my opinion that this conduct amounted to fraud by a City of Jackson civilian employee, Robert Graham.

I travelled to the state 9-1-1 board and inspected many records provided by the staff. I was allowed to make copies of the records so I could compare with NECI records in Atlanta.
One of the documents we obtained was a letter from Robert Graham listing his private training company address as 3000 St. Charles Street, the address of the Jackson Police Academy. I’m not sure if he was paying rent to the City of Jackson for using their police academy as a for-profit business. This is the location in which Graham was conducting courses when the double-dipping actions alleged by the State Auditor occurred.

Upon my return to Atlanta, NECI personnel inspected all the course rosters submitted by Robert Graham and determined that this conduct had been going on for several years.

NECI immediately de-certified Robert Graham as a 9-1-1 instructor.

NECI sent a letter to every police chief, sheriff, and 9-1-1 director in Mississippi to make them aware of this situation and concerns that our materials had been presented in an unauthorized, pirated manner. We advised them of our opinion that their employees might not be certified legally that they might be working unlawfully according to Mississippi law. They were also invited to contact NECI to determine whether or not their employees were duly certified by an organization which was duly authorized by the State of Mississippi to present courses and certify completion.
I notified the state 9-1-1 board and requested permission to return to inspect “all the records” of courses conducted by Robert Graham.

After a more thorough investigation, I was able to document Robert Graham had submitted false claims for conducting many NECI course which entitled 9-1-1 agencies to reimbursement by the state 9-1-1 board.

Aside from my company, NECI, we have obtained a copy of the course manual from another training company, Professional Pride©, which Robert Graham has pirated for use by his company without authorization. Graham obtained the manual from this company and disassembled, reassembled with a new cover page, and distributed it to individuals who work for a police department, sheriff’s department, or 9-1-1 agency, this manual, and he misrepresented the training program as a BETST-approved program and eligible for reimbursement as described above.
Sue Pivetta, owner of Professional Pride© has advised me in writing that Robert Graham did not have permission to use their training manuals unless purchased individually, which they were not. She stated, “Under no circumstances did he have permission to disassemble, reassemble, and put his own cover on them and charge a fee.” She has also advised she is more than willing to assist in this investigation against Graham. Her number in Washington State is 253.891.9084.

Graham also created certificates for students to submit to BETST for reimbursements which were unauthorized by NECI and which were misleading to students, their employers and BETST. Graham submitted these documents to BETST to complete the process for reimbursement of training costs.

I met with investigator at the State Auditor’s and reported my findings and opinions and submitted the documentary evidence to support my claims. Using these documents, the State Auditor was able to find Robert Graham guilty of conducting training courses and accepting in excess of $45,000 in violation of state law and he demanded repayment in May of this year.

At the end of their investigation, the State Auditor turned the documentary evidence over to the District Attorney, to determine what criminal charges are in order.

I have not filed a civil action in this matter, since it might have made my motive in reporting this fraud subject to question by the investigative agencies. I have come to Jackson today to provide additional information and documents I have received since this investigation began. My sole purpose is to see that Robert Graham is held fully accountable for his multiple misdeeds which, in my opinion, involve defrauding state and federal agencies, mail fraud, misuse of public funds, theft of intellectual property, and copyright infringement.
In addition, I have previously met with the City of Jackson and provided an official with the Department of Finance documentary evidence of when Robert Graham used a Jackson Police Department Purchase Order for $2500 to purchase NECI manuals to train employees of 9-1-1 agencies other than the City of Jackson. He then used the manuals to conduct training courses. In addition to the other charges, Graham should be held accountable for committing actions which, in my opinion, amount to fraud against the public entity that paid his salary and which contributed public funds to the Public Employees Retirement System of Mississippi for his benefit.

Charles D. Carter
President, CEO
NECI
www.NECI911.com

Press Release from NECI
10/24/11