NOV, 22. 2010 11:21AM F A A kbGlONAL COUNSEL, AEA-7 NO. 2731 P. 2/ 8 

U.S. DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

OFFICE OF HEARINGS 

WASHINGTON, D.C. 

In the Matter of Cenogenics Corporation. 

FAA Docket No. CPl 0EA0007 

(Civil Penalty Action) 

FDMS No. FAA-2010-0786 

The Honotable Ronnie A. Yoder 

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COMPLAINANT'S SUPPLEMENTAL REPLY TO RESPONDENT'S 

INTERROGATORIES AND NOTICE TO PRODUCE 

COMES NOW the Complainant, by and through its designated 

representative, the Regional Counsel for the Eastern Region and Ms designated and 

authorized agents, in accordance with 14 C.F.R. 13.220 and Rules 33 and 34 of the Federal 

Rules of Civil Procedure, and submits its supplemental responses to Respondent's 

Intenogalories and Notice to Produce documents as follows: 

INTERROGATORIES 

3. Set forth the name and address of all proposed expert vsdtnesses whom you expect 

to call at trial, and as to eocli, state: 

(e) the expert's job title or position, educational background, work, history, 

experience, employer, and membership in professional and/or trade 

organi2ation5; and 

Supplemental Answer; 

See Special Agent's curriculum vitae, attached. 

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COMPLAINANT'S SUPPLEMENTAL RESPONSE TO RESPONDENT'S NOTICE TO 

PRODUCE 

9. A copy of tlie resume, ciuriculum vitae, and/or training records of any and all 

FAA agents, investigators or employees involved in the subject matter. 

Answer: See Special Agent Odum's curriculum viiae attachedComplainant reserves the right to amend responses in keeping with the ongoing 

nature of discovery. 

Respectfiilly submitted, 

Alfred K Johnson, Jr, 

Regional Counsel 

By: fVCO^^J-^^^^^ Date: ( - 1 ^ M 

Jeaiiine C. Gotimer 

Attorney 

Federal Aviation Administration 

1 Aviation Plaza 

Jamaica, NY 11434 

Telephone: 718 553-3272 

Facsimile: 718 995-5699 

D 

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CERTIFICATE OF SERVICE 

I hereby certify that on this day copies of the foregoing Complainant's Supplemental Reply 

to Respondent's Interrogatories and Notice to Produce documents were sent via Certilied 

Mail - Return Receipt Requested addressed as follows: 

Aj)d Via Facsimile 

Chief Adimnistrative Law Judge Ronnie A. Yoder 

Office of Administrative Law Judges 

OfBce of Hearings, M-20, 

U.S. Department of Transportation 

1200 New Jersey Avenue, S.E. 

East Building Ground Floor 

Room El2-320 

Wasliington, D.C 20590 

FAX 202-366-7536 

Ai:>d Via Facsimile 

Federal Aviation Administration (Original and one copy) 

800 Independence Avenue, S.W. 

Washington, D.C. 20591 

Attn: Hearing Docket Clerk, AGC-430 

WUbur Wright Building - Room 2014 

FAX 202-493-5142 

John P. Bcycl 

McElroy, Deutsch, Mulvancy & Carpenter, LLP 

Attorneys at Law 

1300 Mount Kemble Avenue 

PO Box 2075 

Moirisiown, New Jersey 07962-2075 

Da,e: NOV 2 1 2010 [ A f-J JT -

MariannaPerero 

Paralegal Specialist 

Federal Aviation Administration 

Oflice of Regional Counsel 

1 Aviation Plaza 

Room 561 

Jamaica, NY 11434 

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lOWoodbridgc Center Drive 

Suite 100 

Woodbridge, NJ 07095 

CbarleS OaUHl chnrles.odumi'a)faa.gov 

Department of Transportation, Federal Aviation Administration 

Security Specialist (Hazmat), SV-UOM 

Special Agent 

FEDERAL AVIATION ADMINISTRATION 09/2007 - Present 

10 Woodbridge Center Drive, Suite 100 Woodbridge, NJ 07095 

Supervisor: Joe Ballas. (732) 634-1045 xt. 201 

Special Agem - Haznua 

Responsible for conducting liazaidous materials compliance inspections of regulated parties that 

introduce hazardous materials into the air transportation system. Evaluates air carrier training programs 

for compliance vith Federal Air Regulations and mvcstigates incidents, discrepancies, and regulatory 

compliance violations. Performs critical observations, surveillance, records review and conducti: 

interviews to determine a regulated party's knowledge of the hazardous materials procedures, policies, 

and regulations. 

Conducts on-site inspections of regulated air carriers, shippers and repair stations to determine 

compliance with Hazardous Materials Regulations and advises of any violations requiring immediate 

corrective action and potential enforcement actions(s) that may be taken for non-compliance. Executes 

authority co order immediate cessation of an activity found to be in violation of the Hazardous Materials 

Regulations that pose aji imminent danger to the life, health, and/or safety of the public or employees 

involved In tlie transportation of such materials. Determines whether an administrative or civil penalty 

enforcement action is appropriate when a violation occurs. 

Conducts outreach to the industry based upon regional trend analysis and hazardous material inspections 

to improve compliance with Federal Air Regulations, Hazardous Materials Regulations, and ICAO 

Ttichniciil Instruction. Provides technical advice to industry pursuunel, assigned organizations, aiid tlic lo 

the general public. Invesdgates hazardous materials incidents and makes findings of fact. Draws 

conclusions regarding the propriety of advisability of the action(s) at issue based on hazardous materials 

policy re<]uirements and recommends corrective action. Presents these analyses, conclusions, and 

recommendations in written report of findings lO a manager. 

U.S.NAVY 04/2006-07/2007 

Naval Station Norfolk, VA 23511 

Supervisor: Lt Commander Reid, (757) 444-9600 

Master at Arms, (Independent Duty), E-5 

Serve in force protectioii/antiterrorism leadership role, providing military airport and base infrasoncnire 

HEizmat safety, law enforcement, investigation and security support for up to 150,000 personnel. Train, 

supervise and evaluate junior security staff. Plan reviews and inspect facilities, equipment, firearms, and 

security processes regularly to monitor compliance to military policies and regulations. Analyze security 

systems and processes to ensure adequate protection. Document any discoveries of vulnerabilities or 

personnel disregard for safety, citing specific threat and/or code violation. Enforce appropriate orders and 

regulations, make apprehensions, conduct investigations and prepare required records and reports. 

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Charles Odum 

• Selected as one of two enlisted personnel to serve on Chambers Field Anti-terrorism Committee 

tasked with assessing and improving airport security, facilitating personnel training and providing 

long-term security solutions for cat X equivalent airport. 

• Reseaich, interpret and apply Navy physical Security Program and Operating Manual For 

Explosives in order to fiilfiH law enforcement, Hazmat safety and base security functions. Provide 

foimal training in hazardous materials and airport security Standard Operating Procedures (SOP). 

• Instruct personnel in decontamination procedui^s for hazardous materials as well as Chemical, 

Biological, Radiological, Nuclear and Explosive (CBRNE) tlireats/Weapons of Mass Destruction 

(WT»4D), minimizing threat to immediate area while ensuring safety of emergency response team. 

• Monitor adherence to all security procedures at perimeter and base checkpoints, including 

positive control regarding access to sterile areas, ED display of all employees/visitors and cargo 

movement thi'ough checkpoints. 

U.S. NAV Y 07/2002 - 04/2006 

Weapons Station Earle, Colts Neck, NJ 07722 

Supervisor: Gary Caldwell, (732) 866-2291 

Command Armorer /Harbor Platoon Leader 

Progressed through increasingly responsible positions providing law enforcement, security and 

investigative services tor major weapons station. Assessed and applied physical security requirements, 

crime prevention, military and civil law, antiterrorism procedures, physical fitness training, interpersonal 

communications, first aid, firearms and physical restraint. Trained, supervised and evaluated up to 500 

security peisonnel. Served as Hazmat Petty Officer for two years. 

• Successfully reorganized and restructured a failing Armory and small arms program to achieve a 

"Satisfactory" rating on the annual explosive safety inspection in less than five mondis following 

initial unsatisfactory rating. 

• Managed a small arms program for 100 Active Duty personnel and upwards of 75 Reserve 

personnel frojn two separate units wliile maintaining perfect safety and accountability, resulting 

in the qualification of 100% of all personne). 

• Collaborated with local and national law enforcement agencies (TSA, FBI, Homeland SectJrity, 

Middletown Police Department and NJ State Police) to provide critical training in both 

classroom environments and cross agency joint training drills. 

Patrolled base, ensuring security of restricted areas and responding to incidents of suspected or 

probable hostile action, isolating the area, searching, seizing evidence, controlling the personnel 

and neutralizing tlireats to priority resources. 

• Detained suspects, gathered information, documented identification of involved parties and 

wimesses, and reported suspicious vehicles and actLvities. Searched computer databases, 

organizing all findings into cohesive investigative reports for distribution to military atloracys. 

-'^^::'""".^:te:. •-:•::- .:'f":" :-i!ai';^ 'm^i^f^^^ : 'k;. '::;•;:'';::.:. ~^ ^ T" 

TIDEWATER COMMUNITY COLLEGEMOFSTRA UNIVERSITY 

(Virginia Beach, VA~Hempstead, NY) 

Green Run High School, Virginia Beach, VA, diploma, 1986 

FEDERAL AVIATION ADMINISTRATION TRAINING 

Hazardous Materials NationaL Training Program, 2007 

Air Transportation of Dangerous Goodls - Basic Course, 2008 

Hazardous Materials Safely Program Training CoDference, 2009 

FAA Compliance and Enforcement, 3007 

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Charles Odum 

US DOT Hazardous Maieriab Transportation Training 5.1, 2007 

ADG Regulatory and Operational Update Briefing, 2009 

Newark International Airport Air Cargo Carriers - Contributor Monthly 

U-S.NAVYTPA^^ING 

Operational Risk Management, 2007 

Hazmat Safety and Inspection, 2006 

Joint Antiterrorism, 2005 

Dynamic Decision Making, 2005 

Dynamics of Leadership, 2005 

Small Arms Marksmanship Instructor, 2005 

Basics of Naval Explosives Hazards Control, 2005 

Mastei^At-Arms Course, 2005 

Counterdrug Risk Management, 2004 

Counterdrug Analytical Investigative Toola, 2004 

First Line Leadership Pragrani, 2004 

National Law Enforcement Academy, 2003 

E£0 , Diversity Awareness Training, re-occarring annually 

"Weapons Safety, re-occurring annually 

National Law Enforcement Academy (U.S. Navy), 2003 

SELECT COURSEWOiaC 

• Arrest Procedures • Defense Tactics * Counterinsurgcncy 

• Evidence Handling • Emergency First Aid * Physical Security 

• Criminallnvestigations • HAZMATTraining * Entry Control 

• Firearms Safety/Usage > Criminal Law • Shore Patrol 

OTHER 

XL2000 Leadership Workshop, Ford Motor Compjuiy, 1998 

EXCEL Training - The "Satnniization" of Oldsmobile, General Moiors Corporation, 1996 

Management "Disney Style," 1995 

Dealer Operations and Ownership Program, NAD A Dealer Candidate Academy, 1994 

Participated in over 50 workshops and training programs through various manvfactxercrs in sales 

achievement leadership, customer service and employee satisfaction 

,;;."•'!ii,,„,,_ ;*-'V•; , "''i;i,i<,i.„,; •^>"'-';,iii.,,,'.]i''tJtiK^im^^&^'\ \ V IIIIIN ,., , 

Single-Engine Aircraft Pilot License 

Licensed Small Arms Instructor 

Military Explosive Transportation License 

Tirr 

Microsoft Word/Excel/PowerPoint^Outlook 

Military classified and unclassified data management systems 

FEDERAL AVIATION ADMINISTRATION 

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Charles Odum 

Certificate of Appreciation - EWR Cargo Strike - Transportation Security Administration, 2010 

Letter uf Appreciation - Presentation - Curtiss-Wright Composite Squadron - Civil Air Patrol, 2009 

Letter of Appreciation - Presentation - The Raritan Traffic Club, Inc., 2009 

U.S. NAVY 

Honorable Discharge-US >Javy Reserve, 2010 

Navy Achievement Medal - Third Award for professional achievement, 2007 

Junior Sailor of the Quarter - Last quarter, 2006 

Letter of Appreciation - Honorable Service of Commanding Officer, 2006 

Outstanding Volunteer Service Medal - "Make Peace with Animals" and Special Olympics, 2006 

Navy Achievement Medal - Second Award for professional achievement, 2006 

Navy Achievement Medal - First Award for profiessional achievement, 2005 

Good Conduct Award - Outstanding dedication to maintaining miliiary discipline, 2005 

Navy Expert Rifle Medal - Marksmansliip Ex,cellence, 2004 

Navy Expert Pistol Medal - MaricsmonshJp Excellence, 2004 

Global War on Terrorism Medal - Service of Comitry, 2003 

Meritorious Unit Commendation - First Award for unit achievement, 2003 

Letter of Commendation - Honor Graduate from Navy Basic Training, 2002 

National Defense Service Medal- Serving in time of conflict, 2002 

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