Free Application for Access to Protected Material - District Court of Federal Claims - federal

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FORM 10
APPLICATION FOR ACCESS TO INFORMATION UNDER
PROTECTIVE ORDER BY EXPERT CONULTANT OR WITNESS


I1niteb ~tate.6'
SDS INTERNATIONAL, INC., Plaintiff,

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THE UNITED STATES OF AMERICA,

Demndant
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HiPK, Inc., Intervenor.
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APPLICATION FOR ACCESS TO INFORMATION UNDER
PROTECTIVE ORDER BY EXPERT CONSULTANT OR WITNESS

1. I, the undersigned, am a retired business development consultant with N/A

and hereby apply for access to protected information covered by the Protective Order issued in connection with this proceeding. 2. I have been retained by SOS International, Inc. ("SOS") and will, under the direction and control of Christopher Johnson, Esq. assist in the representation of SOS in this proceeding. 3. I hereby certify that I am not involved in competitive decision making as discussed in U.S. Steel Corp. v. United States, 730 F.2d 1465 (Fed. Cir. 1984), for or on behalf of any party to this proceeding or any other firm that might gain a competitive advantage from access to the information disclosed under the protective order. Neither I nor my employer provides advise or participates in any decisions of such parties in matters involving

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similar or corresponding information about a cornpEititor. This means, for example, that neither I nor my employer provides advice concerning, or participates in decisions about, marketing or advertising strategies, product research and development, product design or competitive structuring and composition of bids, offers, or proposals with re:3pe~t to which the use of protected information could provide a competitive advance. 4. My professional relationship with the part.y for whom I am retained in this proceeding and its personnel is strictly as a consultant on issues relevant to the proceeding. Neither I nor any m'amber of my immediate family holds office or a management position in anv company that is a party in this proceeding or in any competitor or ';:Jotential competitor of a party. 5. , have attached the following information: a. a current resume describing my educ:atie,n and employment experience to date; b. a list of all clients for whom I have performed work within the two years prior to the date of this applicaJ/ioll and a brief description of the work performed; c. a statement of the services I am expl:~c1:E:,d to perform in connection with this proceeding; d. a description of the -financial interest::; that 1, my spouse, and/or my family has in any entity that is an intE!rested party in this proceeding or whose protected inforrnat'on will be reviewed; if none, I have so stated; e. a list identifying by name of forum, case number, date, and circumstances all instances in which I have been granted admission or been denied admission to a protective order, had a protective order admission revoked, or have been found to have violated a protective order issued by an administrative or judicial tribunal; if none, I have so stated; and f. a list of the professional association~:) to which I belong, including my identification numbers. 6. I have read a copy of the Protective Order issued by the court in this proceeding. I will comply in all respects with all terms and conditions of that order in handling any protected information pl"Oduced in connection with the proceeding. I will not disclose any protected information to any individual who has not been admitted under the P'rotective Order by the court. 7. For a period of two years after the date this application is granted, I
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will not engage or assist in the preparation of a proposal to be submitted to any agency of the United States government for training in support of the DoD Joint Tactical Air Operations interface training program when I know or have reason to know that any party to this proceeding, or any successor entity, will be a competitor, subcontractor, or teaming member. 8, For a period of two years after the date this application is granted, I will not engage or assist in the preparation of a proposal or sUbmission to Army Contracting Agency nor willi have any personal involvement in any such activity, 9., J acknowledge that a violatIon of the terms 0" the Protective Order

may result in the imposition of such ~.:;anctlon$ as l'y'sy be deemed appropriate by the court and in possible eMf and GrimlnalliabiHty.

fa.y my :3ignatl$fe, f certify that, to the best of my knowledge, the
repreSEH'llations set fol1h above (including aUBel'!@e: statell1ents) aTe true


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BRIAN E. WAGES
67 Pepper Tree Road Chula Vista, CA 91910 Home: (619) 422-2123 Mobile: (858) 948-3013 [email protected]
EXPERIENCE SUMMARY

Business development program and proposal manager, author, and analyst with expertise in unmanned aerial vehicles (UAV) , international military affairs, military training, and aviation safety. Military background includes operational experience in the Middle East, Europe, and Asia; over 675 aerial combat missions (1,300 combat hours); and service on USAF, joint, and multinational staffs.
EDUCATIONITRAINING

Olmsted Scholar (International Relations), Hebrew University of Jerusalem, Israel B.Sc. (Civil-Military Affairs), US Air Force Academy, Colorado Royal College of Aerial Warfare, Royal Air Force (RAF) Cranwell, United Kingdom Armed Forces Staff College, Norfolk, Virginia
. SECURITY CLEARANCE

None (Formerly Top Secret as of 21 June 2001 w/SSBI of 8 Jun 01)
PROFESSIONAL CREDENTIALS

Business and Strategy Development, Northrop Grumman Corporation (NGC), Rancho Bernardo, CA Conducted Business and Strategy Development (B&SD) activities for the Advanced Systems Development and Aerial Targets integrated product/process teams (IPT) at the NGC Unmanned Systems (LlMS) facility in Rancho Bernardo, CA. Developed marketing plans/strategies, advertising and pUblic briefing materials, and contact plans. Interfaced with customers and media personnel, supervised/supported proposal preparation, assisted with program management reviews and other customer meetings, and represented the organization at trade shows, conferences, and other domestic and international promotional venues. Helped grow B&SD organization from 9 to 30+ personnel. Proposal manager for Winning Responsive Access, Small Cargo, Affordable Launch (RASCAL)--Phase I and Unmanned Combat Armed Rotorcraft (UCAR)--Phases I and II proposals. Worked Hunter-Killer program in addition to four Targets programs (BQM-34, BQM-74E/Chukar, and BQM-74F). Retired in 2005. 2001-2002 Consultant, Cardiff, CA Established Wages Consulting as a California-certified Small and Disabled Veteran Business Enterprise. As a subcontractor to Northrop Grumman UMS, prepared contract proposals and program modification documents related to the organization's Miniature Air Launched Decoy and derivatives, RASCAL, and other advanced and developmental systems. Under subcontract to SDS International, researched and updated the Joint Strike Fighter (JSF) Production Facility Cost-Effectiveness Study originally prepared for the State of California in 1999.

2002-2005

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E. WAGES
Director of Program Development, SDS International, Inc., Arlington, VA Managed preparation of company contract proposals: identified, assessed, and
tracked bidding opportunities in view of corporate expertise and growth objectives;
coordinated teaming arrangements; developed proposal production schedules and
assigned writing tasks; organized blue, pink, red, and gold teams; edited final
products; and supervised proposal assembly. Coordinated responses to
Government Evaluation Notices (EN) and requests for Best and Final Offer (BAFO).
Took Government post-award debriefings. Supervised company support for
preparation of proposals by teaming partners when SDS was not primary contractor.
Provided guidance for program management and execution of contracts.
Conducted contracted studies and analyses. Marketed commercial vendors.
Senior Analyst and Planner, SDS International Conducted and published weapon system evaluations and program assessments for commercial and military clients, including comparison of direct-delivered ordnance with cruise missiles and comprehensive assessment of Maverick Missile program. Prepared annual posture statements delivered to Congress by Chief, National Guard Bureau. Performed extensive research on role of bombers in evolution of USAF doctrine. Developed or helped develop and edited most SDS contract proposals. 1998-2001

1996- 1998

1992- 1996 Analyst and Planner, SDS International Analyzed US defense issues such as power projection capabilities/limitations, weapon system development, force structure, budgets, base closure activity, and defense industrial base. Conducted research; directed studies; wrote articles for publication; edited documents and reports. Developed contract proposals and execution plans. Prepared marketing plans for new products and services.
1990-1991 Advisor to Commander of Allied Naval Forces USAF Advisor to Commander of Coalition Naval Forces aboard the USS Blue Ridge during the war with Iraq. Coordinated integration of Navy air assets into DESERT STORM air war plans. Director of Safety, Headquarters 12th Air Force, Bergstrom Air Force Base, Texas Directed design and execution of flight, ground, and explosive safety programs for over 40 active/reserve tactical fighter units (1,400 aircraft, 40,000 personnel, and 70,000 vehicles). Supervised over 30 major aircraft accident investigations. Deputy Director of 1992 Team that examined Reserve air operations in wake of rash of F-16 accidents; wrote Team's final report, and prepared briefing for the US Air Force Chief of Staff (CSAF). CinCPACAF Chief of Staff, Headquarters Pacific Air Forces, Hickam Air Force Base, Hawaii Orchestrated the activities of a 1,SOO-person staff controlling USAF operations and facilities in the Pacific and Asia. Monitored command involvement in all phases of daily operations and long-term planning. Authored action plan adopted by US Government officials in Washington and Manila as cornerstone for successful preliminary negotiations on US-Philippine facilities agreement. 1987-1989 1989-1990

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E. WAGES
Vice Wing Commander, 58th Tactical Training Wing, Luke Air Force Base, Arizona Assisted Commander in supervising activities at USAF's major F-16 training establishment ($2 billion in assets; $10 million annual budget; 2,500 personnel). Conducted personnel and maintenance programs. Served as unit ombudsman. Selected by the CSAF as Deputy Director of first post-WW II US military training team sent to People's Republic of China. F-16 Instructor Pilot. Deputy Commander for Operations, 479th Tactical Training Wing, Holloman Air Force Base, New Mexico Managed operational functions of the world's largest fighter training program: over 200 instructors conducting 35,000 sorties and graduating 1,100 students annually.. Directed five squadrons and five staff divisions. Developed training programs, flying schedules, airspace utilization plans. AT-38 Instructor Pilot. 1981-1983 Exchange Officer with British Forces Completed Air Warfare Course at Royal Air War College and subsequently served as platform instructor in Joint Warfare Wing of British National Defense College, Latimer, England. Taught NATO organization and joint warfare procedures to officers from all NATO nations and military services. Developed British positions on NATO doctrine. Lectured throughout Europe and Asia on joint warfare. Pre-1981 USAF Operational and Staff Positions Served in numerous staff and flying positions, including tours in Spain, Laos, Thailand, and the Middle East, and duty as Middle East Plans and Policy staff officer at Headquarters USAF. Combat service in Southeast Asia as F-4 aircraft commander and 0-1/T-28 Raven forward air controller. 1983-1985 1985-1987

PROFESSIONAL AFFILIATIONS AND MILITARY AWARDS

Order of Daedalians
RAF Air Warfare and Flying Colleges Association
Air Force Association
Air Force Academy Association of Graduates
Legion of Merit
Distinguished Flying Cross (four awards)
Bronze Star Medal
Air Medal (thirty-two awards)
National Defense Service Medal (two awards)
Southwest Asia Service Medal (two stars)
Vietnam Service Medal (seven stars)
Saudi Arabian Medal for the Liberation of Kuwait
Kuwaiti Medal for the Liberation of Kuwait

OTHER

Attachment 1 Attachment 2

Studies and Publications
Corporate Contract Awards


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BRIAN E. WAGES ATTACHMENT

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1-

STUDIES AND PUBLICATIONS

JSF Production Facility Cost-Effectiveness Study Update, Contract Study, October 2001, 98 pp. Draft Operational Requirements Document (ORO) for the Miniaturized Munitions Capability Requirement, CAF 304-97-1A; SDS Contract Study, November 1999, 10 pp. JSF Production Facility Cost-Effectiveness Study, SDS Contract Study, May 1999, 96 pp. Marketing Flight ControJTMfor Use at Civil and Military Airports: Feasibility Assessment and Preliminary Marketing Plan, SDS Contract Study, August 1998. 175 pp. Chief, National Guard Bureau FY 99 Posture Statement, testimony by Lieutenant General
Edward D. Baca delivered to the US Senate Defense Appropriations Subcommittee, 105th
Congress of the United States, 18 March 1998.
Program Assessment Review of the AGM-65 Maverick Missile; SDS Contract Study for Air Combat Command, February 1998. 32 pp. Chief, National Guard Bureau FY 98 Posture Statement, testimony by Lieutenant General
Edward D. Baca delivered to the US Senate Defense Appropriations Subcommittee, 105th
Congress of the United States, 30 April 1997.
Bombers and Doctrine-The Place of Long-Range Aviation in the Evolution of USAF Airpower Doctrine, SDS Contract Study, March 1997. 420 pp. Putting Cruise Missiles In Perspective --- A Comparison of Direct-Delivered Ordnance and Cruise . Missiles in Illustrative Combat Scenarios, SDS Contract StUdy, December 1996. 200 pp.

"The First With the Most," printed in Armed Forces Journal International [AFJI] , September 1996.
The Plant 42 Alliance: Setting New Standards of Cooperation and Competition for the Aerospace Industry, SDS Contract Study, March 1996. 40 pp.

"DoD's Free Thinkers -- Is the Air Force Surrendering Its Visionary Role?", AFJI, November 1995.
Assessment of FY96 000 Budget With Emphasis on Air Force Elements, SDS Contract Study, October 1995. 52 pp. Alleviating Anxiety: Promoting Depot Operations at Palmdale By Enhancing Customer/User Comfort with B-2 Support Plan, SDS Contract Study, July 1995. 20 pp.

"Circle the Carriers -- Why Does 'Virtual Presence' Scare the Navy?", AFJI, July 1995.

Making Palmdale the Model "Private Depot": Options/Strategies for Increasing Work and
Cutting Cost, SDS Contract Study, May 1995. 30 pp.
1995 Depot Handbook: A Guide to USAF Air Logistics Centers, SDS Contract Study, April 1995. 72 pp.

"Back to Basics -- The Defense Americans Want," AFJI, February 1995.

1994 Elections -- Implications for the Military Establishment, SDS Contract Study, December
1994. 20 pp.
Privatizing Depot Maintenance, SDS Contract Study, November 1994. 20 pp..


"Look to Bombers for Power Projection," AFJI, September 1994.

Estimate Of 000 Out-Year Power Projection Forces Based on the FY95 Defense Budget, SDS
Contract Study, September 1994. 50 pp.
The Gulf War -- An Airman's Perspective, SDS Contract Study, 1993. [Translated into
Mandarin Chinese and Spanish for publication in Taiwan, China, and Latin America.] 180 pp.

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ATTACHMENT

2-

CORPORATE CONTRACT AWARDS

NORTHROP GRUMMAN CORPORATION

2004 2003 2002

Response to USAF Hunter-Killer Remotely Operated Aircraft (ROA) Request for Information (RFI); BQM-74E FY05/06 Production (USN/PMA-208). Unmanned Combat Armed Rotorcraft, Phase II (DARPA/TTO); Extended Range BQIVI 34 (USAF Targets Program Office) Responsive Access, Small Cargo, Affordable Launch (RASCAL), Phase I (DARPAlTTO); Unmanned Combat Armed Rotorcraft, Phase I (DARPA/TTO); Counter Underground Facilities (CUGF) Technology (DARPA/SPO).

SDS INTERNATIONAL, INC.

2001

Contracted Advisory and Assistance Services Recompete (CMS II) (ACC); Scientific, Engineering, and Technical Assistance (SETA) to the US Army Joint Interoperability Test Command (Fort Huachuca); Technical Services and Space Operations Support Program (USAF Space Warfare Center); Ballistic Missile Defense Organization (BMDO) Services Support Program (GSA Schedule); NAS Indian Head Engineering, Analytical, and Technical Services (Naval Sea Systems Command [NAVSEA]); Joint Strike Fighter Project Consultant (State of California); Multi-Award Contract (NAVSEA). 17th Test Squadron Support (USAF Space Warfare Center); Advisory & Assistance Services II (Air National Guard); Professional Engineering Services (GSA Schedule); Chief Information Officer Solutions and Partners (CI0-SP2) Program (National Institutes of Health); OSD Joint Test & Evaluation Program Office Support (OSD); US Army Simulation, Training and Instrumentation Command (STRICOM) Omnibus Contract (STOC) Lots I, II, III, and IV; Future Total Force Project (Headquarters USAF) (Headquarters ACC); Distributed Mission Training Operations and Integration Phase I (Air Force Materiel Command); Support to the Air Force Weapons Center Director of Test and Training; Support to PMA-233 for the Tactical Automated Mission Planning System (TAMPS) (NAS Patuxent River); Support for the Development of a Miniaturized Munitions Capability (Raytheon); Design and Engineering Support Program (DESP) (Ogden Air Logistics Center); Support for the Air Force Operational Requirements Directorate; Support for the 000 Weapon Systems Technology Information and Analysis Center (WSTIAC) (Defense Information Systems Agency); Support for the Joint Theater Air and Missile Defense Organization (JTAMDO); Management, Organizational, and Business Improvement Services (MOBIS) (GSA Schedule)

2000

1999 Staff Support for the Combined Aerospace Operations Center-Experimental (CAOC-X)

1998 AF Weapons School Contract Aircrew Training/Courseware Development; Internal
Revenue Service (IRS) Training and Performance Development

1997 Joint Air-to-Surface Standoff Missile (JASSM) Program Support (Headquarters ACC
under CMS I; converted to GSA Schedule in 2000)

1996 Cockpit/Crewmember Resource Management (CRM) Contract Aircrew Training and
Courseware Development (ACC and United States Air Forces Europe); Technical Support and Management Assistance (TSMA) for the National Guard Bureau/Air National Guard; Contracted Advisory and Assistance Services (CMS I) (Headquarters ACC)

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Attachment 5.b. None- Retired since July 2005 5.c.- Review and analysis of proposals submitted by SOS International, Inc. and HiPK, Inc. in response to Solicitation No. W911 SE-07-R-0016 issued by the Army Contracting Agency. Assistance to counsel retained by SOS. 5.d.-None. I have no financial interests in either SOS or HiPK 5.e.-None 5.f.- See attached resume
· · · · Order of Daedalians (member # 7716) RAF Air Warfare and Flying Colleges Association Air Force Association Air Force Academy Association of Graduates