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6273
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF LOUISIANA
***************************************************************
IN RE: OIL SPILL BY THE OILRIG DEEPWATER HORIZON IN THEGULF OF MEXICO ON APRIL 20,2010
CIVIL ACTION NO. 10-MD-2179 "J"NEW ORLEANS, LOUISIANA
WEDNESDAY, MARCH 27, 2013, 8:00 A.M.
THIS DOCUMENT RELATES TO:
CASE NO. 2:10-CV-02771,IN RE: THE COMPLAINT ANDPETITION OF TRITON ASSETLEASING GmbH, ET AL
CASE NO. 2:10-CV-4536,
UNITED STATES OF AMERICA V.BP EXPLORATION & PRODUCTION,INC., ET AL
***************************************************************
DAY 19 MORNING SESSION
TRANSCRIPT OF NONJURY TRIAL PROCEEDINGSHEARD BEFORE THE HONORABLE CARL J. BARBIER
UNITED STATES DISTRICT JUDGE
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APPEARANCES:
FOR THE PLAINTIFFS: DOMENGEAUX WRIGHT ROY & EDWARDSBY: JAMES P. ROY, ESQ.556 JEFFERSON STREET, SUITE 500POST OFFICE BOX 3668LAFAYETTE, LA 70502
HERMAN HERMAN & KATZBY: STEPHEN J. HERMAN, ESQ.820 O'KEEFE AVENUENEW ORLEANS, LA 70113
CUNNINGHAM BOUNDSBY: ROBERT T. CUNNINGHAM, ESQ.1601 DAUPHIN STREETMOBILE, AL 36604
LEWIS, KULLMAN, STERBCOW & ABRAMSONBY: PAUL M. STERBCOW, ESQ.
PAN AMERICAN LIFE BUILDING601 POYDRAS STREET, SUITE 2615NEW ORLEANS, LA 70130
BREIT DRESCHER IMPREVENTO & WALKERBY: JEFFREY A. BREIT, ESQ.600 22ND STREET, SUITE 402VIRGINIA BEACH, VA 23451
LEGER & SHAWBY: WALTER J. LEGER, JR., ESQ.600 CARONDELET STREET, 9TH FLOORNEW ORLEANS, LA 70130
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6275
APPEARANCES CONTINUED:
WILLIAMS LAW GROUPBY: CONRAD S. P. WILLIAMS, ESQ.435 CORPORATE DRIVE, SUITE 101HOUMA, LA 70360
THORNHILL LAW FIRMBY: THOMAS THORNHILL, ESQ.1308 NINTH STREETSLIDELL, LA 70458
DEGRAVELLES PALMINTIER HOLTHAUS & FRUGEBY: JOHN W. DEGRAVELLES, ESQ.618 MAIN STREETBATON ROUGE, LA 70801
WILLIAMSON & RUSNAKBY: JIMMY WILLIAMSON, ESQ.4310 YOAKUM BOULEVARD
HOUSTON, TX 77006
IRPINO LAW FIRMBY: ANTHONY IRPINO, ESQ.2216 MAGAZINE STREETNEW ORLEANS, LA 70130
FOR THE UNITED STATESOF AMERICA: U.S. DEPARTMENT OF JUSTICETORTS BRANCH, CIVIL DIVISIONBY: R. MICHAEL UNDERHILL, ESQ.450 GOLDEN GATE AVENUE7TH FLOOR, ROOM 5395SAN FRANCISCO, CA 94102
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6276
APPEARANCES CONTINUED:
U.S. DEPARTMENT OF JUSTICEENVIRONMENT & NATURAL RESOURCES DIVISIONENVIRONMENTAL ENFORCEMENT SECTIONBY: STEVEN O'ROURKE, ESQ.
SCOTT CERNICH, ESQ.DEANNA CHANG, ESQ.RACHEL HANKEY, ESQ.A. NATHANIEL CHAKERES, ESQ.
P.O. BOX 7611WASHINGTON, DC 20044
U.S. DEPARTMENT OF JUSTICETORTS BRANCH, CIVIL DIVISIONBY: JESSICA McCLELLAN, ESQ.
MICHELLE DELEMARRE, ESQ.JESSICA SULLIVAN, ESQ.SHARON SHUTLER, ESQ.MALINDA LAWRENCE, ESQ.
POST OFFICE BOX 14271WASHINGTON, DC 20044
U.S. DEPARTMENT OF JUSTICEFRAUD SECTIONCOMMERCIAL LITIGATION BRANCHBY: DANIEL SPIRO, ESQ.
KELLEY HAUSER, ESQ.ELIZABETH YOUNG, ESQ.
BEN FRANKLIN STATIONWASHINGTON, DC 20044
FOR THE STATE OFALABAMA: ALABAMA ATTORNEY GENERAL'S OFFICEBY: LUTHER STRANGE, ATTORNEY GENERAL
COREY L. MAZE, ESQ.WINFIELD J. SINCLAIR, ESQ.
500 DEXTER AVENUEMONTGOMERY, AL 36130
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6277
APPEARANCES CONTINUED:
FOR THE STATE OFLOUISIANA OFFICEOF THE ATTORNEYGENERAL:
STATE OF LOUISIANABY: JAMES D. CALDWELL,ATTORNEY GENERAL1885 NORTH THIRD STREETPOST OFFICE BOX 94005BATON ROUGE, LA 70804
KANNER & WHITELEYBY: ALLAN KANNER, ESQ.
DOUGLAS R. KRAUS, ESQ.701 CAMP STREETNEW ORLEANS, LA 70130
FOR BP EXPLORATION &PRODUCTION INC.,BP AMERICA PRODUCTION
COMPANY, BP PLC: LISKOW & LEWISBY: DON K. HAYCRAFT, ESQ.ONE SHELL SQUARE701 POYDRAS STREETSUITE 5000NEW ORLEANS, LA 70139
COVINGTON & BURLINGBY: ROBERT C. MIKE BROCK, ESQ.1201 PENNSYLVANIA AVENUE, NW
WASHINGTON, DC 20004
KIRKLAND & ELLISBY: J. ANDREW LANGAN, ESQ.
HARIKLIA "CARRIE" KARIS, ESQ.MATTHEW T. REGAN, ESQ.
300 N. LASALLECHICAGO, IL 60654
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6278
APPEARANCES CONTINUED:
FOR TRANSOCEAN HOLDINGSLLC, TRANSOCEANOFFSHORE DEEPWATERDRILLING INC., ANDTRANSOCEAN DEEPWATERINC.: FRILOT
BY: KERRY J. MILLER, ESQ.ENERGY CENTRE1100 POYDRAS STREET, SUITE 3700NEW ORLEANS, LA 70163
SUTHERLAND ASBILL & BRENNANBY: STEVEN L. ROBERTS, ESQ.
RACHEL G. CLINGMAN, ESQ.1001 FANNIN STREET, SUITE 3700HOUSTON, TX 77002
MUNGER TOLLES & OLSONBY: MICHAEL R. DOYEN, ESQ.
BRAD D. BRIAN, ESQ.
LUIS LI, ESQ.355 SOUTH GRAND AVENUE, 35TH FLOORLOS ANGELES, CA 90071
MAHTOOK & LAFLEURBY: RICHARD J. HYMEL, ESQ.1000 CHASE TOWER600 JEFFERSON STREETLAFAYETTE, LA 70502
HUGHES ARRELL KINCHENBY: JOHN KINCHEN, ESQ.2211 NORFOLK, SUITE 1110HOUSTON, TX 77098
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6279
APPEARANCES CONTINUED:
FOR CAMERON INTERNATIONALCORPORATION: STONE PIGMAN WALTHER WITTMANNBY: PHILLIP A. WITTMANN, ESQ.546 CARONDELET STREETNEW ORLEANS, LA 70130
BECK REDDEN & SECRESTBY: DAVID J. BECK, ESQ.
DAVID W. JONES, ESQ.GEOFFREY GANNAWAY, ESQ.
ALEX B. ROBERTS, ESQ.ONE HOUSTON CENTER1221 MCKINNEY STREET, SUITE 4500HOUSTON, TX 77010
FOR HALLIBURTONENERGY SERVICES,INC.: GODWIN LEWIS
BY: DONALD E. GODWIN, ESQ.
FLOYD R. HARTLEY, JR., ESQ.GAVIN HILL, ESQ.RENAISSANCE TOWER
1201 ELM STREET, SUITE 1700DALLAS, TX 75270.
GODWIN LEWISBY: JERRY C. VON STERNBERG, ESQ.1331 LAMAR, SUITE 1665HOUSTON, TX 77010.
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6280
APPEARANCES CONTINUED:
OFFICIAL COURT REPORTER: CATHY PEPPER, CRR, RMR, CCRCERTIFIED REALTIME REPORTERREGISTERED MERIT REPORTER500 POYDRAS STREET, ROOM HB406NEW ORLEANS, LA 70130(504) 589-7779Cathy_Pepper@laed.uscourts.gov
PROCEEDINGS RECORDED BY MECHANICAL STENOGRAPHY. TRANSCRIPTPRODUCED BY COMPUTER.
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6281
I N D E X
EXAMINATIONS PAGE
NATHANIEL CHAISSON................................... 6288
DIRECT EXAMINATION BY MR. BOWMAN..................... 6289
CROSS-EXAMINATION BY MR. BREIT....................... 6330
CROSS-EXAMINATION BY MR. UNDERHILL................... 6341
CROSS-EXAMINATION BY MR. LI......................... 6354
CROSS-EXAMINATION BY MR. BROCK....................... 6364REDIRECT EXAMINATION BY MR. BOWMAN................... 6403
RICHARD STRICKLAND, Ph.D............................. 6409
VOIR DIRE EXAMINATION BY MR. HILL.................... 6410
DIRECT EXAMINATION BY MR. HILL....................... 6418
E X H I B I T S
DESCRIPTION PAGE
EXHIBITS TREX-51133, TREX-1144, TREX-4514,
TREX-52664, AND TREX-4112 WERE ADMITTED..............
6284
EXHIBIT TREX-60083 WAS ADMITTED...................... 6422
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08:05:55
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OFFICIAL TRANSCRIPT
6282
P-R-O-C-E-E-D-I-N-G-S
WEDNESDAY, MARCH 27, 2013
M O R N I N G S E S S I O N(COURT CALLED TO ORDER)
THE DEPUTY CLERK: All rise.
THE COURT: Good morning, everyone.
VOICES: Good morning, Your Honor.THE COURT: Please be seated.
All right. Do we have any preliminary matters?
MR. BRIAN: We do, Your Honor.
Brad Brian for Transocean.
I have two thumb drives that I would offer and
file and ask to be admitted.The first, Your Honor, is dated -- it says, "TO
Video Played 3/20/2013, 3/21/2013." Those were the depo clips
for Leo Lindner, Buddy Trahan, and Murray Sepulvado.
May those be admitted, Your Honor?
THE COURT: These are the clips that have been played
already, correct?MR. BRIAN: Yes.
THE COURT: Okay, those are admitted.
(WHEREUPON, the above-mentioned exhibits were
admitted.)
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MR. BRIAN: The second one, Your Honor, that I would
offer, file and ask to be admitted, the thumb drive states, "TO
Video Played 3/26/2013." That's yesterday. That's the onethat contains Mr. McKay and Mr. Johnson.
They were subject to the rulings Your Honor made,
so they were redacted per Your Honor's ruling.
So I would ask that they be admitted.
THE COURT: Very well. Those are admitted.
(WHEREUPON, the above-mentioned exhibits wereadmitted.)
MR. BRIAN: Secondly, Your Honor, we took your
admonition to heart. We went back last night, and we looked at
our exhibits to see if we would offer any complete exhibits,
and we have -- well, we circulated a list of five documents.
They are TREX-51133, TREX-1144, TREX-4514, TREX-52664, andTREX-4112.
Two of those -- well, three of those are -- one
of them is a signed statement, which we used as a cull out of
Mr. Vidrine and Mr. Kaluza. I understand there is no objection
to that. That's 51133.
The next two, TREX-1144 and 4514, are theMr. Guide e-mail that has been displayed several times and the
Mr. Cocales e-mail. We just couldn't see that they had been
admitted.
THE COURT: Are any of those voluminous?
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MR. BRIAN: No. The only one -- you had asked --
TREX-4112 that was used with Mr. Perkin on cross-examination,
it's 20 pages of a multi-length contract, so we excerpted the20 pages. So none of these would be voluminous.
THE COURT: That's fine. I don't like to put in a
voluminous document of hundreds of pages, where only a handful
of pages are necessary or used during the trial. That's all.
MR. BRIAN: I think there were some manuals and stuff
that would come in with the bundling, Your Honor, but we hadyour admonition in mind.
So I would move those five exhibits in.
THE COURT: Very well. Those are admitted.
(WHEREUPON, Exhibits TREX-51133, TREX-1144, TREX-4514,
TREX-52664, and TREX-4112 were admitted.)
MR. BRIAN: Finally, Your Honor, last evening, latelast evening we circulated our exhibits to offer for
Mr. Ambrose and a revised list for Mr. Wolfe, after meeting and
conferring with the PSC.
I think those are still under consideration by
the parties. We were not able to get that out until pretty
late.I know that the PSC has offered some exhibits,
which we're still conferring on, with respect to Mr. Young,
their cross-exam of Mr. Young.
So, subject to our offering the exhibits from
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Mr. Wolfe and Mr. Ambrose, we would rest -- we would like to
keep the record open for that purpose; but, subject to that, we
would rest our case.THE COURT: Very well, thank you.
MS. KARIS: Good morning, Your Honor.
THE COURT: Good morning.
MS. KARIS: Hariklia Karis on behalf of BP.
We have circulated and not received any
objections to the exhibits that we used with Mr. Ambrose, andso we would tender that list and offer them into the record.
THE COURT: All right. Any objections?
Without objection, those are admitted.
(WHEREUPON, the above-mentioned exhibits were
admitted.)
MS. KARIS: Thank you, Your Honor.THE COURT: Sure.
MR. IRPINO: Good morning, Your Honor. Anthony Irpino
for the PSC.
The same. We have our list of exhibits used in
connection with our examination of Mr. Ambrose yesterday. We
have circulated that list and have received no objections.MR. BRIAN: I'm informed we're fine. We have no
objection, Your Honor.
THE COURT: Any other objections?
Without objection, those are admitted.
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(WHEREUPON, the above-mentioned exhibits were
admitted.)
MR. IRPINO: We are still meeting and conferring withTransocean on Mr. Young's list. We had three or four exhibits.
We should be able to do that after the break.
MR. GODWIN: Good morning, Your Honor. Don Godwin for
Halliburton.
We have our exhibits, as well, that were used in
the cross-examination of Mr. Bill Ambrose. We have circulatedthose, Judge, and to my knowledge, no objections. We'd offer
them at this time.
THE COURT: Any objections?
All right. Without objection, those are
admitted.
(WHEREUPON, the above-mentioned exhibits wereadmitted.)
MR. GODWIN: Thank you, Judge.
MR. BROCK: Good morning, Your Honor.
THE COURT: Good morning.
MR. BROCK: We, as Your Honor knows, now have briefed
in response to our motion for sanctions positions taken by theUnited States, the states and the PSC.
We wanted to ask permission to file a short, five
pages or less, response to the various submissions to address a
few substantive points.
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THE COURT: I'll allow that. How much time do you
need?
MR. BROCK: 5 o'clock today.THE COURT: Fine.
MR. BROCK: Thank you.
MR. GODWIN: Judge, if I might briefly --
This is Don Godwin.
-- just since Mike has brought that up, we join
in the PSC's request of Your Honor that this matter notinterrupt the trial, that it be carried --
THE COURT: I don't plan to let it interrupt the trial,
so you can be assured of that.
MR. GODWIN: In terms of a hearing or whatever, we'd
ask that it be carried to the end, Your Honor.
THE COURT: I have not decided how I'm going toproceed. I wanted to wait to allow everyone to weigh in first,
and then I'll consider it.
This will allow me time over this extended break
to at least, you know, consider how to go forward, and then
we'll talk about it next week.
MR. GODWIN: Okay, Judge. Thank you, sir.THE COURT: All right. Anything else?
Let's see, where are we?
MR. BOWMAN: I think we're at our first witness. I'm
trying to get hooked up here.
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THE COURT: Right. Who is your first witness?
MR. BOWMAN: Bruce Bowman for Halliburton on direct
calling Nathaniel Chaisson.THE DEPUTY CLERK: Please raise your right hand. Do
you solemnly swear that the testimony you are about to give is
the truth, the whole truth and nothing but the truth, so help
you God?
THE WITNESS: I do.
NATHANIEL CHAISSON
was called as a witness and, after being first duly sworn by
the Clerk, was examined and testified on his oath as follows:
THE DEPUTY CLERK: Please take a seat, and if you'd
state and spell your name for the record.
THE WITNESS: Nathaniel, N-A-T-H-A-N-I-E-L, James,
J-A-M-E-S, Chaisson, C-H-A-I-S-S-O-N.THE COURT: Mr. Bowman, I thought it was Chaisson, not
Chaisson, okay.
MR. BOWMAN: Okay.
THE COURT: I wanted to hear it from him, though, to
make sure. That's how I would pronounce it.
MR. BOWMAN: I believe both of you two can pronounce itmuch better than I can.
With your permission, can I call you Nate?
THE COURT: Okay.
MR. BOWMAN: Okay.
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6289
Your Honor, what we're going to try to do is to
have Nate say what he was supposed to do out there, what he
did, and then the results.THE COURT: That's fine.
DIRECT EXAMINATION
BY MR. BOWMAN:
Q. Now, again, you just stated your name.
Where do you live?
A. Currently living in Church Point, Louisiana.Q. Who do you work for?
A. Halliburton.
Q. What do you do?
A. I'm currently a cementing service coordinator.
Q. What does that mean?
A. Basically, I monitor day-to-day operations of variousoffshore rigs and platforms and coordinate the movement of
personnel, materials, and equipment to location.
Q. Going back to the April 20, 2010, time period, what were
you doing?
A. I was currently a -- well, then I was a technical
professional for Halliburton, which is essentially a cementingengineer. I was in charge of designing cement slurries and
testing, going out on the various jobs and monitoring jobs to
ensure that they were executed as designed.
Q. Okay. Now, as far as this particular slurry and this
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6290
particular job, you did not design it, right?
A. No, I did not.
Q. You were supposed to be doing what with it?
A. Going out to the job and, once again, ensuring that the
job was performed and executed as it has been -- as it had been
designed.
Q. Okay. By the way, how did you get the educational
background, how did you learn how to do something like that?
A. Well, most of it came from on-the-job training. I do havea degree in civil engineering, which aided me in converting
over to the petroleum side; but, most of it was on-the-job
training and training within Halliburton.
Q. How long did that go on before you actually went out to
the Horizon in April?
A. Let's see. That was in 2010. I believe I started withHalliburton midway through '07, give or take. But the actual
training period was plus or minus a year.
Q. Okay. Where did you grow up? Are you from Louisiana?
A. I'm from Lafayette, born and raised, yes.
Q. You say you have a civil engineering degree. Where did
you get that from?A. The University of Louisiana at Lafayette.
Q. All right. Now, what were you supposed to do on the
Macondo well?
A. I was going out, once again, to monitor the execution of
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6291
the job, ensure that the proper chemicals and cement volumes
were pumped.
Basically, as I stated previously, just ensure thatthe job was pumped as designed.
Q. Okay. How many other -- how many people were there? In
other words, you weren't going to do this all by yourself?
A. No.
Q. So kind of tell the Judge, if you would, the process, how
many people were going to be involved.A. Okay. Well, as far as Halliburton personnel?
Q. Yes, sir.
A. There were two cementers on location, which, I believe we
have two cementers on location at all times.
There was myself, a foam team leader. There was also
two individuals in control of the nitrogen equipment as well.So it was a team effort, basically.
Q. Okay. Do you recall about when you first arrived?
A. I arrived on the 16th, about 8:00 a.m., if I remember
correctly.
Q. April 16th?
A. Yes, sir.Q. We're going to show you your tally book in a minute and go
through some stuff --
By the way, what is a tally book?
A. My tally book is somewhat of a personal journal, I guess,
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6292
would be the best way to describe it. I use it just to jot
down notes as the days progress out on the rig, capture any
modifications or deviations from the plan, capture anysignificant points that I may witness.
Q. As far as the execution of the job, was there a plan --
A. Yes.
Q. -- a written plan?
Rob, can you go to TREX-00737 and Bates numbers, last
three, 303.Now, Nate, you have seen this before, have you not?
A. Yes, I have.
Q. What did you have to do with it?
A. Well, I typed up this particular document.
Q. So you actually typed this document?
A. Yes, sir.Q. And how did you know what to put down?
A. This was a combination of the -- actually, the plan I had
received from Jesse Gagliano, the cement procedure, as well as
a meeting that had taken place on the night of the 17th, I
believe, to discuss the cement job out on the rig.
Q. A meeting. Who was at that meeting?A. Various BP personnel. Company man, who would have been
Bob Kaluza. I believe Brian Morel was also present, a BP
Drilling Engineer. Myself. Foam team leader, Paul Anderson.
The nitrogen personnel were there, as well, Jack Abey and --
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6293
I'm sorry, I can't remember the second individual's name.
There were some TO personnel present, as well. I'm
not sure who those individuals were.
Q. What was the purpose of that meeting?
A. To discuss the execution of the cement job.
Q. It was discussed, I presume?
A. Yes, it was.
Q. Well, do you remember -- let's go to -- you see Item
Number 2? It talks about how much is going to be circulated.Do you see that?
A. Yes, sir.
Q. All right. Now, when it says, "per company man," why did
you insert that?
A. Well, if you read this particular line item, with rig
pumps, pump and circulate 1100 barrels at one barrel perminute, and then 150 barrels at four barrels per minute, that
was specifically dictated to myself and the other individuals
in the room by Bob Kaluza, who was the BP company man on
location.
Q. Did you know that was nowhere close to being at
bottoms-up?A. Yes. Correct. This was not -- based upon Halliburton's
recommendation, this is not sufficient, correct.
Q. Was there some discussion at this meeting as to whether
there would be a bottoms-up or just do this?
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6294
A. Yes, there was some discussion. It was brought up that
this particular volume did not meet Halliburton's best practice
of to bottoms-up.Once again, the company man, who was Bob Kaluza at
the time, stated, this is what we're going to circulate, and
this is what we're going to move forward with.
Q. All right. Pump rates, where did the pump rates come
from?
A. This was also dictated by Bob Kaluza.Q. All right. Just generally, for Your Honor's benefit, if
you pump faster versus slower, does that have any effect on the
quality of what you're pumping down?
A. It does have an effect on the cement job, yes.
Q. How?
A. Basically, the faster you circulate a fluid or the fasteryou pump, the more -- I guess you can say the closer you get to
turbulent flow in the annulus, which helps clean out the
wellbore, helps remove some of the mud that's been in the
annulus, so that the cement can be placed correctly or placed
efficiently.
Q. Just like if you're squirting something -- you have somemud on, say, the wall, and you squirt it very lightly, it might
not knock it off; but if you squirt it really fast, it will
knock it off? Is that a decent analogy?
A. That's a good analogy, yes.
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6295
Q. You're kind of squinting, so maybe it's not too good.
Well, going one step further, what's the purpose,
what does a bottoms-up do a versus a few hundred barrels?
A. It allows you to, once again, remove some of the mud
that's been built up in the annulus.
As we all know, fluid will take the path of least
resistance. So it's in your best interest or it's in the best
interest of the cement job to remove any mud that's been
sitting there in the annulus and gelling up over time.The faster you circulate, the more -- or closer to
turbulent flow you can achieve, and better mud displacement
you'll achieve.
By displacing that mud, you allow your cement to be
placed correctly and hopefully not contaminated.
Q. I'm following the words. I want to make sure that Iunderstand it and, more importantly, the Judge does.
So you clean it out. When you say you want the
cement hopefully not to be contaminated, what are you saying?
A. Hopefully, you remove all of the previous gel mud, which
will allow your cement to be placed without being contaminated
by any of that mud that's been left in the annulus.Not only are you concerned with contamination, but as
well as channel. As I stated, fluid will take the path of
least resistance. So, if there is mud remaining in the
wellbore, in the annulus, it's a possibility that cement will
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6296
just simply pump around it, which in case will not allow you to
achieve zonal isolation, which is ultimately the goal of a
cement job.
Q. I understand. Now, if there had been a bottoms-up, full
bottoms-up or cleaning on, I think, the 16th or something of
April, why would you also need to do it before the cement job
on the 19th?
A. Simply because of the time period. That mud has been
sitting in the annulus over a matter of days or hours. As mudsits static, it begins to gel. As those gels increase, it's
just that much harder to remove that mud from the annulus.
Q. Why don't we now go to TREX-00718, starting at page 515.
Now, you recognize this document?
A. Yes, I do. This is from my tally book -- or this is my
tally book.Q. This is your tally book.
It shows, 4/16, arrive on rig. Is that when you
arrived?
A. Yes, sir. 8 o'clock a.m.
Q. All right. Now, right below that, when it says rig is
currently -- what does that say right here?A. Rig is currently on bottom -- that's abbreviated, BTTM --
circulating, getting gas back.
Q. What does it mean, getting gas back?
A. That means that as they are circulating and the mud is
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6297
being brought back to surface, there is some encapsulated gas
in that mud. That typically comes from the formation.
Q. Why did you then think it was important enough to write itdown?
A. At this particular time, I happened to walk into the
company man's office. I was just going through orientation and
introducing myself to him. I heard this being mentioned, and I
just jotted it down, just as a side note.
Q. Okay. I understand.Let's go to the other side of the page, over here. I
think this will be all the people.
Why did you write these names?
A. Honestly, it's because I got in the habit of doing this on
every job. I'm not real well with remembering names, so just
as a personal benefit to myself. I just jot down the name ofevery individual that I need to familiarize myself with for
that particular job.
Q. Okay. Company men, Don Vidrine and Bob Kaluza. Had you
ever met them before?
A. No, I have not.
Q. But you obviously met them --A. Had not.
Q. --- when you were out there, right?
A. Yes.
Q. Cementers, Mr. Tabler, Mr. Cupit, had you met them before?
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6298
A. No, I had not.
Q. Had not. First time.
Then we have Mr. Jack Elmo. Is that the person youcouldn't remember his name?
A. Yes, Elmo is the second nitrogen operator.
Q. Mr. Paul Anderson, what was his job?
A. He was the foam team leader, abbreviated FTO.
Q. What does it mean to be the foam team leader?
A. The foam team leader is the lead on location of thatparticular operation. He oversees the execution of all facets
of that particular job.
Q. He's the one sort of in charge to make sure that the foam
gets foamed and down the hole?
A. Correct. He may also help out with the actual cementing
equipment, nitrogen equipment. Those guys tend to have aknowledge of all facets of that job.
Q. All right. Then we have Mr. Jesse Gagliano.
A. Yes.
Q. You had both his cell and his home number?
A. Correct.
Q. Had you worked with him before?A. I honestly don't recall if I had worked with Jesse prior
to this job. I don't remember working with Jesse, but I'm not
sure if I had met him prior to this job.
Q. You had worked with him, but not sure you had met him?
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6299
A. I'm not sure I had worked with him, but I had met him
before.
Q. What's this last thing mean?
A. This says, "BP engineer, Brian."
Q. Brian, is that Brian Morel?
A. Yes.
Q. Is that the first time you met him?
A. Yes.
Q. Can we now go to 516. And if we can focus in on thisfirst item right there.
The Dril-Quip tool, what does that mean? What are
you saying there?
A. "Dril-Quip tool didn't shear properly. Have to RIH," run
in hole, it's an abbreviation, "and retrieve."
Q. All right. And why did you put that down?A. This is a 7:00 a.m. entry. That's typically the 7:00 a.m.
morning meeting. It's something that may have been mentioned
in the morning meeting that I noted.
Q. As far as you know, that got resolved?
A. To my knowledge, yes.
Q. Now, let's go to 517. And focus on this entry.How do you know what to write down in your book, by
the way?
A. Once again, it's -- every engineer will typically have
different ways of documenting in the tally book. I tend to
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6300
write down anything that's significant in my mind.
Q. This entry at 1800, what's that, 6 o'clock at night?
A. Yes.
Q. "May have retrieved part of Dril-Quip assembly that was
left in the hole."
What's that all about?
A. Apparently I had heard that they had retrieved what was
left in the hole, whatever part of the tool had not sheared
properly. And POOH is a abbreviation for pull out of hole.Q. All right. These things just normally happen during
cement jobs or is this a little unusual? Why did you write
this down?
A. This is prior to the cement job. Actually, the days prior
to the job, myself and the rest of the Halliburton team, we're
preparing for the actual pumping of the cement, so we'retesting equipment and checking calibrations. And as I hear any
significant points that may be going on with the well, I'll jot
them down.
Q. Let's now go to 518 of the same exhibit.
And you'll notice this date is 4/18. I want to ask
you about what's above, so what are these figures?A. Those seem to be mud volumes. Those are significant
during displacement. I was jotting those down. It seems like
I was doing calculations on when pressure indications may be
seen.
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6301
"120 barrels to diverter plus 9 barrels to DTD,"
diverter test device, "plus an additional 9 barrels to the
plug."
Q. All right. By the way, do you know at this time if you
knew whether y'all were going with eight or nine gallons of
retarder?
A. I would say no, simply because of the note I have with an
asterisk right on top, longer pump time.
Q. Yeah. What does that indicate?A. If I put an asterisk by something, that's a bit of
information I don't have at that particular time, something I
need to discuss with someone or get a clear answer on.
Q. Let's now go to 520.
And this stars on 4/19. Is this the day that you
actually did the cement job?A. Yes.
Q. Now, there is -- if we come down to the right here, this
is, what, 13 -- what does that say, 1390?
A. Looks like 1340.
Q. 1340. What are you talking about right there?
A. "Landed casing at 18,218 feet," which would have beenmeasured. Took a 10K -- "Took 10K," which basically means took
10,000 pounds of weight.
Q. What does that mean?
A. It means you may have bumped into something. Just
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6302
basically means the casing is seeing some resistance to hitting
bottom.
Q. And this is a casing that is coming down from the top thatyou're eventually going to be cementing around?
A. Yes, sir.
Q. So as that casing is coming down, it bumps into something
that cause it to take a 10K?
MR. BROCK: Your Honor, I'm going to object to that on
foundation. He's not been tendered as an expert, and I don'tthink a foundation has been established on this.
MR. BOWMAN: I'll rephrase it.
THE COURT: Okay.
BY MR. BOWMAN:
Q. As the casing is coming down, when you wrote "10K," what
did that mean?A. It means that it took an additional 10,000 pounds of
weight to get the casing to continue or get the casing to where
it needed to be.
THE COURT: Let me ask, one thing I'm not clear on,
Mr. Chaisson, is this something you're -- with this note here,
for example, you're being told or you're hearing somebody elsesay or is this something you're doing yourself or what?
THE WITNESS: This particular note I would have heard
someone say this. I did not witness this actual event.
THE COURT: Okay.
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6303
BY MR. BOWMAN:
Q. Do you know who you would have heard it from?
A. No. I do not recall.
Q. Now, let's go back to this whole page at 520, and without
zeroing in, we have a one, we have a two, and we go on to the
next page, which is 521, then we have a series of numbers going
up through nine. What does all that represent?
A. Okay, I was actually up on the rig floor at this
particular time.Q. What time is that?
A. And this is previous to the cement job. Myself and the
rest of the Halliburton team, and all the individuals involved
in the cement job, had been called up to the rig floor for
what's called a re-job safety meeting.
And we walked up to the rig floor. At thatparticular time, they were going into -- attempting to convert
the float collar. And what you see here, one through nine, are
the nine various attempts of trying -- attempting to convert
that float collar while we're on the rig floor.
Q. So you were actually physically on the rig floor watching
who?A. Yes, we were on the rig floor. And there was TO personnel
operating the rig, and there was also -- Bob Kaluza was on the
rig floor as well.
Q. All right. So all of this information that you're writing
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6304
down, where did you get that from?
A. This is information that I'm hearing. It's being read
from the various monitors and sensors in the actual drill shackon the rig floor.
Q. All right. And I think the judge certainly realizes that
it took nine attempts to convert the collar, right?
A. Right.
Q. Did you have anything to do with actually converting the
collar or were you just watching?A. I was just watching.
Q. All right. Let's go to page 522, which, unfortunately, is
hard to read, but I think if we can blow up this part right
here, that says what?
THE COURT: Can I ask, does he have his actual book
here?MR. BOWMAN: I don't believe so, Your Honor, sorry.
THE COURT: I was just going to suggest it might be
easier for him to read.
MR. BOWMAN: I think this is the only page like this,
Your Honor.
BY MR. BOWMAN:Q. And the entry right there has what, 1621?
A. Correct.
Q. And that says, "Floats converted."
Now, why did you write down, "Floats converted"?
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6305
A. It seems at 1621 everyone was under the impression that
the floats had converted and the rig was able to circulate
fluid, circulate mud.
Q. How did you hear that?
A. Once again, just sitting -- standing back on the rig floor
and monitoring and listening to what's going on and jotting
down notes.
Q. All right. Now, did you hear anyone talk about, after the
conversion, anything unusual?A. Yes. It was noted that the circulating pressure, once the
floats had converted, or once the rig was able to circulate,
circulating pressure seemed to be low.
And I heard Bob Kaluza mention after witnessing --
after monitoring the circulating pressure, he made the
statement that, you know, "I need to make a phone call. We mayhave blown something higher up in the casing."
Q. Now, was he asking you that or is that something you just
heard?
A. That was just something I heard.
Q. And so what happened after that?
A. At that time, there were phone calls made. Thecirculating pressure continued to be monitored at various
rates. At one point they switched mud pumps, from one rig pump
to the other, monitored pressure as well at various rates. And
more phone calls were made.
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6306
Ultimately, walked back up on the rig floor and we
were told, "Hey, let's move forward with the cement job. We're
going to circulate and move forward with the cement job."
Q. Can we put this whole page back up for a second. And I
think we can blow this up.
Different pump?
A. Yes.
Q. That's an indication of what you were just telling the
judge that --A. Correct.
Q. -- everybody was trying to see if they went to a different
pump if the pressure would be higher?
A. Correct. At that point in time, they attempted to use --
to circulate with a different rig pump and monitored and
recorded pressures and rates to see if it would be anydifferent from the original rig pump they used.
Q. Did it make any difference?
A. Not -- not much of a difference, as I recall.
Q. All right. Did you call anybody during this period of
time?
A. I did speak with Jesse Gagliano at some point in time inthis process.
Q. What did you tell him?
A. Just informed him of what was going on, just to keep him
in the loop of activities prior to the cement job.
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6307
Q. And what did he tell you?
A. Basically just, "Okay, just keep me informed. Continue to
document what's going on. If anything else drastic occurs, youknow, just give me a call."
Q. All right. Let's go to page 523.
Is this when you start the cement job?
A. This is the circulation prior to the cement job.
Q. Circulation prior to it. All right.
And who told you to circulate?A. Well, Halliburton didn't actually perform the circulation.
After phone calls had been made, or in the process of, I'm
assuming, company men and Brian Morel making phone calls,
myself and the rest of the Halliburton team walked off the rig
floor for a minute.
Upon returning to the rig floor, I was told byDon Vidrine, "Look, we're going to circulate 110 barrels, and
then we're going to go into performing the cement job."
Q. So Mr. Vidrine is the one that told you, you were going to
be doing the job?
A. Correct.
THE COURT: Mr. Bowman, it's just been noted thatyou've been -- you're calling out, apparently, the Bates page
numbers.
MR. BOWMAN: What I've been calling out is, yes,
Your Honor, the last three digits.
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6308
THE COURT: The problem is, that's not the way we have
been doing it. We're trying to be consistent throughout this
trial. I think it's better if you use the TREX number and --that one that's on the screen now appears to be TREX-718-009.
MR. BOWMAN: Yes.
THE COURT: So it might be helpful to use that. If you
also want to refer to the Bates number, that's fine, but we
have to go back and retrace our steps here.
MR. BOWMAN: All right. Okay. Thank you, Your Honor.BY MR. BOWMAN:
Q. So now, you're staring -- when do you actually start the
cement job?
A. I would have to look at the -- later on in the tally book.
Q. All right. Can we show the whole page. See if that helps
you.A. It seems near 1928, third entry.
Q. Here?
A. We're blowing through nitrogen lines to pressure test
nitrogen lines. Typically the official start of a cement job
is with a pressure test of lines, so I would say 1928 would be
the -- officially the start of the cement job.Q. All right. There is a -- can we go back to the page, full
page.
And there is indication about bumping a plug. Do you
see that?
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6309
A. No, this is actually, once again, attempting to pressure
test the nitrogen lines. On the first attempt, there was a --
the line was plugged somehow, so they broke the line down,cleared it out and pressure tested again to 5,000 psi.
Q. Okay. Let's go to -- Rob, if you can give me 526, and
I'll call out the correct number. This is TREX-00718-012.
If we go to an entry, 29, what does that say?
A. Here I'm documenting the actual pumping of mud to displace
the cement. And here at 029, this entry says, "Bump bottomplug."
Q. What does that mean?
A. This means that the bottom plug -- we're assuming the
bottom plug has landed onto the float collar.
Q. How do you know that?
A. By pressure indication.Q. So show the whole page again, if you would.
And at 019, it says, "Got returns."
How do you know that?
A. Any information on returns I would have had to have
received from another individual because my equipment doesn't
have the capability of monitoring mud returns.Q. So who would have told you that?
A. That would have either come from the person working for
Sperry, who was Cathleenia Williams. Or during the cement job,
everyone has radios, basically walkie-talkies, and there is one
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6310
on the rig floor, and on occasion I would call to the rig floor
and ask, "Hey, are you guys getting returns? Are you seeing
full returns?" And I would get a response. Can't be certainwho was on the other side of the radio, but the radio was on
rig floor.
Q. All right. And I forgot to ask you one other item. Let's
to go the whole page again.
And right here, what does this say? "Bump top plug."
A. "Bump top plug."Q. What that does that mean?
A. Once again, a pressure indication that the top plug has
landed on the float collar, which is, for all intents and
purposes, the end of the cement job.
Q. What time was that?
A. This is -- I don't know. I need you to display the fulltally book again.
It seems to be between 037 and 043.
Q. All right. So, basically, that's the end of the cement
job?
A. Correct. The cement is in place. You can no longer
circulate through the casing and up the annulus at this point.Q. And what do you do then?
A. Depending on the job type, this particular job, if it's a
liner, then you go through the process of pulling the running
tool and circulating, etcetera.
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6311
Q. Let's go to page 527, which is TREX-00718-013.
And this is the -- seems to be the last entry. What
does this say?
A. This is the last entry at 0730. This is at the morning
meeting of that particular morning. It says -- I jotted down a
note here that the rig is going to be testing casing at
9:15 a.m. They're saying that's the 500 psi time on cement.
Q. Who told you that?
A. This was just said in the particular meeting. I'm notsure who made the comment.
Q. You didn't make the comment, did you?
A. No, I did not.
Q. So who was at this meeting?
A. The morning meetings typically included the company men,
the BP engineer, Brian Morel, TO personnel, Halliburtonpersonnel, and also individuals on the call. They would call
in to this meeting from town. I'm not sure who would call in.
Q. All right. So do you know who actually made this -- who
actually said 500 psi by 9:15?
A. No, I do not.
Q. We know it wasn't you?A. Correct.
Q. And you don't remember it being anyone else with
Halliburton, do you?
A. No, sir.
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6312
Q. By the way, did anyone, Mr. Morel, Mr. Kaluza, anyone ever
ask you how long they should wait on cement?
A. No. They did not, no.
Q. Did you ever hear them asking anyone from Halliburton how
long they should wait on cement?
A. No, I did not.
Q. Did you ever hear that discussed at all?
A. No, sir.
Q. Now, later on -- and this is, what, 7:30 meeting in themorning of the 20th?
A. Yes.
Q. And what did you do later that day?
A. After this particular meeting, I went back into the room,
continued to pack my bag and wait on the helicopter flight to
fly back in.Q. And you got on a helicopter flight so you were not on the
rig when it exploded.
A. Correct. If I recall correctly, we flew out sometime
around noon, and we were back home for -- about 1:00 p.m. that
day on the 20th.
Q. Were there Schlumberger people that were going to run theCDL on the same flight that you were on?
A. I don't recall.
Q. You don't recall?
A. No, sir.
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6313
Q. Actually, before the cement job, was there ever any
discussion with anyone on the rig about centralizers?
A. Yes.
Q. And who was that discussion with?
A. I personally had a discussion with Brian Morel and
Don Vidrine.
Q. Concerning what about centralizers?
A. In this case, the decision not to run 21 centralizers. I
was under the impression going out to the rig that there wereto be 21 centralizers on the casing. I later learned, while
being on the rig, that a decision had been made not to
run 15 additional centralizers and only run six.
Q. Did that concern you?
A. Yes, it did.
Q. All right. And did you voice that concern to someone fromBP?
A. I did have a conversation with Brian and Don Vidrine, yes.
Q. What did they tell you?
A. They simply informed me that, yes, that decision had been
made not to run the 15 additional centralizers, and they were
going to move forward with only six.Q. And did you let anyone know that decision?
A. Yes. I did make a call to Jesse Gagliano.
Q. And what did he say?
A. He seemed a bit upset about the decision. He said there
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6314
had been some previous talks during the design phase of the
job, and that individuals within BP were aware of, I guess, the
impact on the cement job.
Q. And what's the possible impact when you say impact?
MR. BROCK: Your Honor, I'm going to object to this as
being hearsay. I think Mr. Gagliano will be appearing, I
think, next week to testify and we can hear what he said at
that point.
THE COURT: You're asking this witness to say whatMr. Gagliano said to somebody else?
MR. BOWMAN: No. The question, I think, was: What
would be the effect of not having the right number of
centralizers?
MR. BROCK: On that one he said that he does not have
an opinion on that for this particular job because he was notinvolved in that, so I object on foundation.
MR. BOWMAN: That's not what he said at all.
THE COURT: Go ahead and reask the question, and let's
see what it is.
BY MR. BOWMAN:
Q. All right. Nate, what would the effect of not having the21 centralizers have been on this job?
MR. BROCK: I object on foundation.
THE WITNESS: On this particular job, based solely upon
looking at the simulations with and without the additional
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6315
centralizers, without the additional centralizers or the lack
of the additional 15 centralizers, would result in channeling.
BY MR. BOWMAN:
Q. If we go to TREX-00717-421, then I'll call out the correct
number. And this is TREX-00717.
All right. And have you seen this before?
A. Yes, I have.
Q. And what is it?
A. This is an e-mail which was sent out by Jesse Gaglianothat contained lab tests and an ISM report.
Q. We will look at those lab tests and the ISM report. Can
we blow up all of this. Make it a little bigger.
All right. Now, first one is Anthony Cupit,
Brett Cocales.
Do you know who Brett Cocales is?A. No, I do not.
Q. Don Vidrine, you know who he was, right?
A. Yes, sir.
Q. John Guide, do you know who John Guide was?
A. No, I did not.
Q. Murray Sepulvado, do you know who he was?A. I did not know at the time. No, I did not.
Q. And Ronald Sepulvado?
A. No, I did not.
Q. Mark Hafle, do you know who he was?
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6316
A. No.
Q. Greg Walz?
A. No.
Q. Let's look at the next page, which is 467, and this is
TREX-00717-002.
And what is this?
A. This is a lab test.
Q. Lab test. Okay. So this was sent to you and all those
other people, right?A. Correct.
Q. And the date of the e-mail, of course, was April 18th, on
Sunday, right?
A. Correct.
Q. And this lab test is actually two pages, the next page
being 467, which is TREX-00717-003.And that lab test shows a series of tests on the
particular slurry, right?
A. That is correct.
Q. And can we go back to 002.
And this shows a nine-gallon retarder. Do you see
that?A. Yes. Nine gallons of SCR-100L, which is the retarder
used.
Q. Do you recall when it was that you learned that it would
be nine versus eight gallons?
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6317
A. No. I do not recall the specific date. I want to say it
was the 17th or 18th.
Q. How did you find out?
A. I remember Brian Morel having some question about the pump
time and he didn't feel comfortable with the amount of pump
time on the eight-gallon test, so he asked about a nine-gallon
test.
Q. Did he tell you then they were going to use the
nine gallons?A. I did, at some point, find out that nine gallons of
SCR-100L was going to be used on this particular job, yes.
Q. And this particular page has a thickening time. You don't
need to blow it up. You can see that thickening time.
What is thickening time for the Court?
A. That is the time in which the cement is no longer deemedpumpable. It's ultimately the longest time period you have to
get the cement in place.
Q. That's the 7:37?
A. That is correct, 7 hours and 37 minutes.
Q. All right. Now, I notice -- let's go to the second page
now, which is 003, and it shows a series of tests.Then, unfortunately, it has a graph that is not
legible right now. Do you remember what that graph was?
A. Yes. This seems to be the thickening time test. The
graph of the actual -- of the actual pump time test itself.
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6318
Q. And let's go to the next page. That would be 004. That's
another graph. This one you can actually read a little bit.
What's this graph?
A. This is the graph of the compressive strength test, the
UCA chart --
Q. Yes, sir.
A. -- as we call it. It shows the compressive strength
development over time of this particular cement slurry.
Q. All right. So could you read this graph?A. I could make it out. I can't read it.
Q. When you actually received it, was it in a form that you
could read?
A. Yes.
Q. Now, what's the importance of a UCA test?
A. Once again, it shows the compressive strength developmentover time of the cement slurry being pumped.
Q. All right. Now, I noticed that there is not -- you have
all these tests here. There is not a foam stability test, is
there?
A. No, there is not.
Q. So all the people receiving this showed these tests, butno foam stability test.
A. Correct.
Q. You knew this was a foam job. Did you ask anybody about a
foam test?
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6319
A. No, I did not.
Q. Why was that?
A. I relied on Jesse Gagliano's testing, and I assumed thathe had tested for foam stability. That's typically the first
test that is performed when pumping a foam job.
Q. Okay, let's go now to 005. What is it?
A. This is OptiCem report, a simulation report.
Q. Yes, sir. That was attached to this e-mail, also. Did
you look at it?A. Yes, I did.
Q. Can we go to Bates Number 434.
MR. BROCK: Can you call a page on that, also?
MR. BOWMAN: Page 18.
MR. BROCK: Thank you.
BY MR. BOWMAN:Q. This is TREX-00717-008 -- no, let's see. Let's go to --
it's 434, sorry. You know, I'm looking at it -- I have a lot
of 434's here. Sorry, Rob.
Well, let's look at this. One place in that is on
page 18, there is something that shows gas flow potential.
739.18, thank you. Let's try that, Rob.Okay, you see that?
A. Yes.
Q. It shows a 10.29. What does that mean to you?
A. 10.29 gas flow potential means that it's in a severe range
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6320
of the probability of gas or hydrocarbon being able to flow
through the cement once it's in place.
Q. Is foam cement used in part when you want to try tocontrol a high gas flow potential?
A. Yes. It is.
Q. Did this particular OptiCem also show a high likelihood of
channeling, do you recall?
A. Is this the particular OptiCem with the six centralizers?
Q. This is one of the --A. I believe it is, yes. Yes, with the high gas flow
potential. Yes, this OptiCem does show channeling.
Q. You got this right before the cement job, correct?
A. Correct.
Q. Mr. Vidrine, Mr. Sepulvado and all those other people
would have received it at the same time, as far as you know?A. As far as I know, yes.
Q. Of course, Mr. Vidrine is the one that told you, go ahead
and pump the job, right?
A. That is correct.
Q. Now, after the job, what do you do? Or is that too open a
question? What are you supposed to do after the job?A. Immediately after a cement job is done, I'll complete the
post-job report. I'll then send it to the Account Rep, who was
Jesse Gagliano in this case. He reviews it and makes changes
and sends it on to his customer.
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6321
At that point, you know, the job is complete.
Q. Okay. We'll look at the post-job report in just a second.
You actually did two here?
A. Yes.
Q. Explain to the Court why.
A. Well, the first version of the post-job report was done
prior to me leaving the rig on the 20th.
The second version occurred, I believe, on the 21st.
I was called back into the office to -- really notmake modifications, but make an addition to my job log because
of the event, the blowout.
The blowout had taken place. My supervisor,
Michael Serio, asked me to come in and include every detail
from my tally book that I could possibly include in the
post-job report.Q. I'm just going to ask you about the -- I'll say the second
one. Someone else can ask you about the first, if they want.
Can we go to TREX-00713.
This is an e-mail from you to Jesse Gagliano and
Mr. Serio. You just mentioned Mr. Serio. Who was he?
A. Michael Serio was the lead technical professional inLafayette at the time. He was my manager at that time.
Q. All right. Let's go to page 646.
This is your event, right? You're writing down --
what all are you writing down there?
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6322
A. Yes, this is my job log, basically writing down
significant points.
It tends to pretty match up with -- it tends to matchup pretty much with the tally book. It's just significant
points throughout each day and things that pertain to the
cement job.
Q. All right.
MR. BOWMAN: Your Honor, may I have one second to
confer with my videographer because we have a lot of duplicatenumbers here?
MR. BROCK: I was going to mention, they all have
646 --
MR. BOWMAN: That's what I just noticed.
MR. BROCK: -- but call the page number.
MR. BOWMAN: That's what I just noticed.THE AUDIO/VIDEO TECHNICIAN: Just call the page number.
BY MR. BOWMAN:
Q. Okay, so let's go to page 2.
All right. Now, I want to ask you, first of all,
what is this whole page supposed to indicate?
A. Here, it's just a -- I guess, a -- just a sheet filledwith data of fluids being pumped, wellbore geometry
information, circulation data, etcetera.
Q. Let me ask you about this one thing. It says, estimated
TOC. That's top of cement?
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6323
A. Yes, estimated top of cement.
Q. Why does it say estimated?
A. This is the planned top of cement based upon the plannedjob in the proposal.
Q. All right. Because is there any way you can actually know
what the top of cement is?
A. In this particular case, no. It's estimated based on
fluids being pumped, volumes being pumped.
Q. In other words, if it was all pumped the way it wassupposed to, it would come all the way down, then it would go
up the annulus, and it would go up to that height?
A. Correct. That's assuming it pumps out the bottom of the
casing, up the annulus.
This is assuming you have a perfectly gauged -- I
guess, a perfect hole size, hole diameter, one hole diameter.This is assuming you've estimated the correct excess amount.
It's an estimated calculation.
Q. All right. There is no way -- well, is there any way you
can actually know for sure how high the cement was?
A. Yes.
Q. How do you know?A. You'd have to perform a cement bond log to do so.
Q. We all know one wasn't performed. So was there any way,
without performing one, anyone would know actually how high the
cement was?
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6324
A. Not to my knowledge, no.
Q. Let's go to page 6. Could we just blow this up.
MR. BROCK: Could we read the number into the record?MR. BOWMAN: This is 00713-007, Your Honor.
BY MR. BOWMAN:
Q. This is looking like it's pretty close to the end of the
job; is it?
A. Yes. This is on the 20th, correct. The morning of the
20th.Q. This is where you say, bottom plug bumped, top plug
bumped, right?
A. Correct.
Q. We've already seen those notations in your tally book?
A. That is correct.
Q. This last entry says, "check floats, bled back fivebarrels, floats held."
Now, what does it mean, bled back five barrels?
A. In order to check the floats -- after the top plug bumps,
you still have -- you're holding -- and the rig's holding
pressure on the casing, that pressure is bled back, released.
In releasing that pressure, you're going to get someflow back of volume. That flow back is typically taken back to
the cementing unit into the measuring tanks, where that volume
can be measured.
In this particular case, five barrels was measured
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6325
back to the cementing measuring tanks. It was then deemed that
the floats were holding as they were supposed to, and the
cement job was done.
Q. Now, how was it deemed the floats were holding? Did you
go look at them?
A. No, I did not witness this event. No, I did not.
Q. Who did?
A. Outside of the -- I can't be certain who was up there
because I was not in the cementing room when that occurred.Q. That's what someone told you; is that basically it?
A. Yes.
Q. Let's now go to page 7, which is TREX-00713-008.
Is this basically your conclusion?
A. Yes, it is. It's significant points from the job.
Q. Okay. It was pumped as planned. Full returns.That says full returns. Were you measuring returns?
A. No, I was not. I would have --
Q. Who was looking at that?
A. I would have gotten this data, once again, from
Cathleenia, who works for Sperry, as well as individuals on the
rig floor who were monitoring ret