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4668

UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF LOUISIANA

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IN RE: OIL SPILL BY THE OIL RIG


DEEPWATER HORIZON IN THE
GULF OF MEXICO ON APRIL 20, 2010

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Applies to:
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Docket 10-CV-02771,
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IN RE: THE COMPLAINT AND
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PETITION OF TRITON ASSET
LEASING GmbH, et al
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Docket 10-CV-4536,
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UNITED STATES OF AMERICA v.
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BP EXPLORATION & PRODUCTION,
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INC., et al
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* * * * * * * * * * * * * * * * * *

Docket 10-MD-2179
Section J
New Orleans, Louisiana
March 19, 2013

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DAY 14, AFTERNOON SESSION


TRANSCRIPT OF NONJURY TRIAL
BEFORE THE HONORABLE CARL J. BARBIER
UNITED STATES DISTRICT JUDGE

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Appearances:

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For the Plaintiffs:

Domengeaux Wright Roy


& Edwards, LLC
BY: JAMES P. ROY, ESQ.
556 Jefferson Street, Suite 500
Post Office Box 3668
Lafayette, Louisiana 70502

For the Plaintiffs:

Herman Herman & Katz, LLC


BY: STEPHEN J. HERMAN, ESQ.
820 O'Keefe Avenue
New Orleans, Louisiana 70113

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OFFICIAL TRANSCRIPT

4669

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Appearances:
For the Plaintiffs:

Cunningham Bounds, LLC


BY: ROBERT T. CUNNINGHAM, ESQ.
1601 Dauphin Street
Mobile, Alabama 36604

For the Plaintiffs:

Lewis Kullman Sterbcow & Abramson


BY: PAUL M. STERBCOW, ESQ.
601 Poydras Street, Suite 2615
New Orleans, Louisiana 70130

For the Plaintiffs:

Breit Drescher Imprevento


& Walker, PC
BY: JEFFREY A. BREIT, ESQ.
600 22nd Street, Suite 402
Virginia Beach, Virginia 23451

For the Plaintiffs:

Leger & Shaw


BY: WALTER J. LEGER JR., ESQ.
600 Carondelet Street, 9th Floor
New Orleans, Louisiana 70130

For the Plaintiffs:

Williams Law Group, LLC


BY: CONRAD "DUKE" WILLIAMS, ESQ.
435 Corporate Drive, Suite 101
Houma, Louisiana 70360

For the Plaintiffs:

Thornhill Law Firm


BY: TOM THORNHILL, ESQ.
1308 Ninth Street
Slidell, Louisiana 70458

For the Plaintiffs:

deGravelles Palmintier Holthaus


& Frug, LLP
BY: JOHN W. DEGRAVELLES, ESQ.
618 Main Street
Baton Rouge, Louisiana 70801

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OFFICIAL TRANSCRIPT

4670

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Appearances:
For the Plaintiffs:

Williamson & Rusnak


BY: JIMMY WILLIAMSON, ESQ.
4310 Yoakum Boulevard
Houston, Texas 77006

For the Plaintiffs:

Irpino Law Firm


BY: ANTHONY IRPINO, ESQ.
2216 Magazine Street
New Orleans, Louisiana 70130

For the United States


of America:

U.S. Department of Justice


Torts Branch, Civil Division
BY: R. MICHAEL UNDERHILL, ESQ.
450 Golden Gate Avenue
7-5395 Federal Bldg., Box 36028
San Francisco, California 94102

For the United States


of America:

U.S. Department of Justice


Environment & Natural Resources
Environmental Enforcement Section
BY: STEVEN O'ROURKE, ESQ.
SCOTT CERNICH, ESQ.
DEANNA CHANG, ESQ.
RACHEL HANKEY, ESQ.
A. NATHANIEL CHAKERES, ESQ.
Post Office Box 7611
Washington, D.C. 20044

For the United States


of America:

U.S. Department of Justice


Torts Branch, Civil Division
BY: JESSICA McCLELLAN, ESQ.
MICHELLE DELEMARRE, ESQ.
JESSICA SULLIVAN, ESQ.
SHARON SHUTLER, ESQ.
MALINDA LAWRENCE, ESQ.
Post Office Box 14271
Washington, D.C. 20004

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OFFICIAL TRANSCRIPT

4671

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Appearances:
For the United States
of America:

U.S. Department of Justice


Fraud Section
Commercial Litigation Branch
BY: DANIEL SPIRO, ESQ.
KELLEY HAUSER, ESQ.
ELIZABETH YOUNG, ESQ.
Ben Franklin Station
Washington, D.C. 20044

For the State of


Alabama:

Attorney General of Alabama


BY: LUTHER STRANGE, ESQ.
COREY L. MAZE, ESQ.
WINFIELD J. SINCLAIR, ESQ.
500 Dexter Avenue
Montgomery, Alabama 36130

For the State of


Louisiana:

Attorney General of Louisiana


BY: JAMES D. CALDWELL, ESQ.
1885 North Third Street
Post Office Box 94005
Baton Rouge, Louisiana 70804

For the State of


Louisiana:

Kanner & Whiteley, LLC


BY: ALLAN KANNER, ESQ.
DOUGLAS R. KRAUS, ESQ.
701 Camp Street
New Orleans, Louisiana 70130

For BP Exploration &


Production Inc.,
BP America Production
Company, BP PLC:

Liskow & Lewis, APLC


BY: DON K. HAYCRAFT, ESQ.
701 Poydras Street, Suite 5000
New Orleans, Louisiana 70139

For BP Exploration &


Production Inc.,
BP America Production
Company, BP PLC:

Kirkland & Ellis, LLP


BY: J. ANDREW LANGAN, ESQ.
HARIKLIA "CARRIE" KARIS, ESQ.
MATTHEW T. REGAN, ESQ.
300 N. Lasalle
Chicago, Illinois 60654

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OFFICIAL TRANSCRIPT

4672

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Appearances:
For BP Exploration &
Production Inc.,
BP America Production
Company, BP PLC:

Covington & Burling, LLP


BY: ROBERT C. "MIKE" BROCK, ESQ.
1201 Pennsylvania Avenue, NW
Washington, D.C. 20004

For Transocean Holdings


LLC, Transocean Offshore
Deepwater Drilling Inc.,
Transocean Deepwater Inc.:

Frilot, LLC
BY: KERRY J. MILLER, ESQ.
1100 Poydras Street, Suite 3700
New Orleans, Louisiana 70163

For Transocean Holdings


LLC, Transocean Offshore
Deepwater Drilling Inc.,
Transocean Deepwater Inc.:

Sutherland Asbill & Brennan, LLP


BY: STEVEN L. ROBERTS, ESQ.
RACHEL G. CLINGMAN, ESQ.
1001 Fannin Street, Suite 3700
Houston, Texas 77002

For Transocean Holdings


LLC, Transocean Offshore
Deepwater Drilling Inc.,
Transocean Deepwater Inc.:

Munger Tolles & Olson, LLP


BY: MICHAEL R. DOYEN, ESQ.
BRAD D. BRIAN, ESQ.
LUIS LI, ESQ.
355 S. Grand Avenue, 35th Floor
Los Angeles, California 90071

For Transocean Holdings


LLC, Transocean Offshore
Deepwater Drilling Inc.,
Transocean Deepwater Inc.:

Mahtook & Lafleur


BY: RICHARD J. HYMEL, ESQ.
600 Jefferson Street, Suite 1000
Post Office Box 3089
Lafayette, Louisiana 70501

For Transocean Holdings


LLC, Transocean Offshore
Deepwater Drilling Inc.,
Transocean Deepwater Inc.:

Hughes Arrell Kinchen, LLP


BY: JOHN KINCHEN, ESQ.
2211 Norfolk, Suite 1110
Houston, Texas 77098

For Cameron International


Corporation:

Stone Pigman Walther Wittmann, LLC


BY: PHILLIP A. WITTMANN, ESQ.
546 Carondelet Street
New Orleans, Louisiana 70130

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OFFICIAL TRANSCRIPT

4673

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Appearances:
For Cameron International
Corporation:

Beck Redden & Secrest, LLP


BY: DAVID J. BECK, ESQ.
DAVID W. JONES, ESQ.
GEOFFREY GANNAWAY, ESQ.
ALEX B. ROBERTS, ESQ.
1221 McKinney Street, Suite 4500
Houston, Texas 77010

For Halliburton Energy


Services, Inc.:

Godwin Lewis, PC
BY: DONALD E. GODWIN, ESQ.
BRUCE W. BOWMAN JR., ESQ.
FLOYD R. HARTLEY JR., ESQ.
GAVIN HILL, ESQ.
1201 Elm Street, Suite 1700
Dallas, Texas 75270

For Halliburton Energy:


Services, Inc.:

Godwin Lewis, PC
BY: JERRY C. VON STERNBERG, ESQ.
1331 Lamar, Suite 1665
Houston, Texas 77010

For M-I, LLC:

Morgan Lewis & Bockius


BY: HUGH E. TANNER, ESQ.
DENISE SCOFIELD, ESQ.
JOHN C. FUNDERBURK, ESQ.
1000 Louisiana Street, Suite 4000
Houston, Texas 77002

Official Court Reporter:

Jodi Simcox, RMR, FCRR


500 Poydras Street, Room HB-406
New Orleans, Louisiana 70130
(504) 589-7780
[email protected]

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Proceedings recorded by mechanical stenography using


computer-aided transcription software.

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OFFICIAL TRANSCRIPT

4674

I N D E X

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Page
Steven Newman
Cross-Examination By Mr. Regan:
Redirect Examination By Mr. Brian:

4677
4743

Timothy Leo Quirk


Direct Examination Mr. Breit
Cross-Examination By Ms. McClellan:
Cross-Examination By Mr. Maze:
Direct Examination By Mr. Hill:

4753
4808
4824
4843

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OFFICIAL TRANSCRIPT

4675

* * *

AFTERNOON SESSION

(March 19, 2013)

* * * * *

13:22

THE DEPUTY CLERK:

13:34

THE COURT:

13:34

13:34

13:34

13:34

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THE COURT:

13:34

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MR. GODWIN:

13:34

12

THE COURT:

13:34

13

MR. WILLIAMS:

13:35

14

13:35

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THE COURT:

13:35

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MR. WILLIAMS:

13:35

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13:35

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exhibits used with Mr. Webster's testimony, Your Honor.

13:35

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circulated the requisite list, have had -- or heard no

13:35

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objections and thus would like to move formally for their

13:35

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introduction into evidence.

13:35

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13:35

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objections to the plaintiffs' list of exhibits in conjunction

13:35

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with Mr. Webster's testimony?

13:35

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Please be seated, everyone.

All right.
MR. GODWIN:

All rise.

Let's see.

Halliburton?

Yes, Your Honor.

Halliburton has no

questions of this witness, Your Honor.


Thank you.
You're welcome.
BP?
Your Honor, do you want to do -- just

to finish up the Webster exhibits?


We can do that.
Okay.

Thank you.

We would formally offer and introduce the

THE COURT:

All right.

We've

Does anyone have any

Hearing none, those are admitted.


OFFICIAL TRANSCRIPT

4676

13:35

13:35

a list of exhibits that we wish to move into evidence used

13:35

during Mr. Webster's deposition -- during Webster's

13:35

examination.

13:35

13:35

13:35

13:35

Transocean would also like to formally move to introduce the

13:36

exhibits that were referenced in cross-examination of Geoff

13:36

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Webster.

13:36

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objections.

13:36

12

13:36

13

13:36

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13:36

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also have our list of exhibits used in connection with

13:36

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Mr. Barnhill's testimony.

13:36

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no --

13:36

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13:36

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yet.

13:36

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Okay.

13:36

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MR. IRPINO:

13:36

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THE COURT:

13:36

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13:36

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MR. REGAN:

09:20

25

(WHEREUPON, STEVEN NEWMAN, having been previously

MR. HAYCRAFT:

THE COURT:

Your Honor, BP does the same.

We have

Any objections?

Without any objections, those are admitted.


MR. KINCHEN:

Your Honor, John Kinchen, Transocean.

We've distributed that list and have received no

THE COURT:

Any objections to Transocean?

Hearing none, those are admitted.


MR. IRPINO:

THE COURT:

Okay.

Judge, Anthony Irpino for the PSC.

We

We've sent those around and received

We've not finished with his testimony

Why don't you wait and we'll do those all together.

Sure.
Anything else before we resume?

All right.

Mr. Regan.

Thank you, Your Honor.

OFFICIAL TRANSCRIPT

4677
STEVEN NEWMAN - CROSS

09:20

duly sworn, testified as follows.)

13:36

13:36

BY MR. REGAN:

13:36

Q.

13:36

I represent BP, and I have you on cross-examination.

13:36

13:36

anything that we've repeated earlier today.

13:36

that, hopefully.

13:36

13:36

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is in the business -- you say you own rigs and you have a crew

13:36

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to operate them.

13:36

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A.

Yes.

13:37

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Q.

And you believe Transocean is the best in the world when

13:37

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it comes to drilling of complex offshore wells; correct?

13:37

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A.

I do.

13:37

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Q.

And the capabilities of Transocean people, to you, they

13:37

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are capable of drilling in some of the world's most difficult

13:37

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and harsh environments; correct?

13:37

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A.

I believe that.

13:37

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Q.

And you have confidence in them to not only do those

13:37

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things, but to do them well; correct?

13:37

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A.

13:37

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13:37

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BY MR. REGAN:

13:37

25

Q.

CROSS-EXAMINATION

Good afternoon, Mr. Newman.

Again, my name is Matt Regan.

Mr. Newman, I'm going to endeavor to try not to cover


I'll do my best on

But with respect to Transocean's business, Transocean

Is that fair?

That's the basis of our business.

I do, yes.
MR. REGAN:

I'd like to pull up TREX-5642.

Which is a letter dated March 24th, 2010, to shareholders.


OFFICIAL TRANSCRIPT

4678
STEVEN NEWMAN - CROSS

13:37

That must have been about a month into your time as CEO.

13:37

is the cover page on the proxy statement, the annual report.

13:37

13:37

BY MR. REGAN:

13:37

Q.

13:37

13:37

went to -- as the cover to Transocean's annual report in late

13:37

March 2010?

13:37

A.

I do.

13:37

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Q.

Okay.

13:38

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correct?

13:38

12

A.

Yes.

13:38

13

Q.

All right.

13:38

14

13:38

15

TREX-5642.2.1.

13:38

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BY MR. REGAN:

13:38

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Q.

13:38

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Transocean Limited.

13:38

19

A.

Yes.

13:38

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Q.

"Transocean Limited is the world's largest offshore

13:38

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drilling contractor and leading provider of drilling management

13:38

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services worldwide."

13:38

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13:38

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A.

That's what the document says.

13:38

25

Q.

As of that time, Transocean had a fleet of 140 mobile

MR. REGAN:

This

If we go to TREX-5642.5.1.

I'll just show you your signature on there.


Do you recall writing and signing this letter that

So this is about a month before April 20th;

MR. REGAN:

If we could turn to page 2,

Just to see if this is fair, there's a description about


Do you see it there?

Correct?

OFFICIAL TRANSCRIPT

4679
STEVEN NEWMAN - CROSS

13:38

offshore drilling units, plus three newbuild units; correct?

13:38

A.

That's what the document says.

13:38

Q.

And Transocean believes that its fleet was one of the most

13:38

modern and versatile in the world due to its emphasis on

13:38

technically demanding sectors of the offshore drilling

13:38

business; correct?

13:38

A.

That's what the document says.

13:38

Q.

And it also highlights the fact that Transocean has

13:38

achieved a long history of firsts, in the words of the

13:38

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document; correct?

13:38

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A.

That's what the document says.

13:38

12

Q.

Including the first dynamically positioned drillship, and

13:38

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some other firsts; right?

13:38

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A.

Yes.

13:38

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Q.

And at the bottom, it says:

13:39

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Lead."

13:39

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13:39

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March of 2010?

13:39

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A.

13:39

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our 2010 proxy statement.

13:39

21

Q.

13:39

22

the Deepwater Horizon's expertise amongst all of those

13:39

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140 rigs; correct?

13:39

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A.

13:39

25

rig had drilled in 2009 with BP.

"Transocean:

Positioned to

Was that one of the models of the company there in

We used that as the theme for our 2009 annual report and

And in this proxy statement, you specifically highlighted

I think that was on the basis of the type of well that the

OFFICIAL TRANSCRIPT

4680
STEVEN NEWMAN - CROSS

13:39

Q.

Go to 5642.4.4.

So again on March 24th, 2010, your letter

13:39

stated that "Transocean continues to be the industry leader in

13:39

technology, which gives us a strong competitive advantage.

13:39

expertise in helping customers drill complex and challenging

13:39

wells is well-documented in deepwater and harsh environments,

13:39

and the latest example in 2009 was our ultradeepwater

13:39

semisubmersible drilling rig, Deepwater Horizon, which drilled

13:40

the deepest oil and gas wells ever while working for BP in the

13:40

U.S. Gulf of Mexico.

13:40

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13:40

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13:40

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A.

That's what the document says.

13:40

13

Q.

That was a historic achievement, was it not?

13:40

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A.

It was.

13:40

15

Q.

It was one that Transocean shared with BP; correct?

13:40

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A.

We did, yes.

13:40

17

Q.

That was a well that was designed by BP engineers;

13:40

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correct?

13:40

19

A.

That's correct.

13:40

20

Q.

That well was drilled by the Transocean Deepwater Horizon

13:40

21

crew; correct?

13:40

22

A.

Yes.

13:40

23

Q.

And there were BP well site leaders onboard when that well

13:40

24

was drilled; correct?

13:40

25

A.

Our

The well was drilled to a record depth of

35,050 feet, including 4,130 feet of water."


Correct?

I believe so.

That would be the normal circumstances,


OFFICIAL TRANSCRIPT

4681
STEVEN NEWMAN - CROSS

13:40

yes.

13:40

Q.

That was the team?

13:40

A.

Yes.

13:40

Q.

And I recall that in one of your investor speeches, you

13:40

said:

13:40

achievements, we've been there and done that."

13:40

13:40

A.

I have used those words in the past.

13:40

Q.

And the Transocean Deepwater Horizon, it had been there

13:40

10

and it had done that.

13:40

11

A.

13:41

12

had done some pretty amazing things.

13:41

13

Q.

13:41

14

provides the safest, most effective and efficient drilling at

13:41

15

all water depths."

13:41

16

13:41

17

A.

I have probably used those words in the past, yes.

13:41

18

Q.

And you would agree it would be fair for both the public

13:41

19

and for the operators, like BP, to rely on those type of

13:41

20

statements; that is, to rely on "Transocean will be providing

13:41

21

the safest, most effective and efficient drilling"?

13:41

22

A.

13:41

23

on me making those statements?

13:41

24

Q.

Just the statements themselves.

13:41

25

A.

Yes.

"With respect to Transocean's people and their

Do you recall using those words?

The Deepwater Horizon had an exemplary track record and

Now, you've also said in the past that "Transocean

Do you recall using those words?

If you're -- are you asking me whether the public can rely

As CEO, you know, I'm taught not to make public


OFFICIAL TRANSCRIPT

4682
STEVEN NEWMAN - CROSS

13:41

statements that I don't believe are true; and so, yeah, I

13:41

believe those statements.

13:41

Q.

13:41

drilling contractors; is that right?

13:41

A.

Yes.

13:41

Q.

And the Deepwater Horizon was top of the market at

13:41

Transocean?

13:41

A.

13:42

13:42

10

41215.1.2.

13:42

11

BY MR. REGAN:

13:42

12

Q.

13:42

13

from your testimony in Congress on May 18th, 2010.

13:42

14

13:42

15

.1.1 then.

13:42

16

BY MR. REGAN:

13:42

17

Q.

13:42

18

respect to that testimony; is that right?

13:42

19

A.

13:42

20

MR. REGAN:

13:42

21

Nope.

13:42

22

BY MR. REGAN:

13:42

23

Q.

13:42

24

in a statement saying that "The well construction process was a

13:42

25

collaborative effort involving various entities and many

So we have Transocean being top of the market amongst

The Deepwater Horizon was one of our best-performing rigs.


MR. REGAN:

If we could pull up TREX-41215,

And what I have here, Mr. Newman, is your -- an excerpt

MR. REGAN:

I think if we go to the -- try .1.2.

Or

Now, this is a written statement that you gave with

I believe so, yes.


Now, if we can go to .1.3.
All right.

Well, do you recall, Mr. Newman, as we're pulling it up,

OFFICIAL TRANSCRIPT

4683
STEVEN NEWMAN - CROSS

13:42

personnel, the well operator, government officials, the

13:43

drilling contractor, the mud contractor, the casing contractor,

13:43

the cement contractor, and others"?

13:43

13:43

A.

That's what the document says, yes.

13:43

Q.

All right.

13:43

believed these words when you said them; right?

13:43

A.

Yes.

13:43

Q.

And you believe them to be true today?

13:43

10

A.

Yes.

13:43

11

13:43

12

4341.1.

13:43

13

BY MR. REGAN:

13:43

14

Q.

13:43

15

think Transocean has a similar one, but really about the

13:43

16

history of the Deepwater Horizon's drilling from the time it

13:43

17

went into service through 2010.

13:43

18

13:43

19

that rig, you're aware that the operator for all of the wells

13:43

20

that were drilled by the Deepwater Horizon was BP; correct?

13:43

21

A.

13:43

22

operator, yes.

13:43

23

Q.

13:43

24

talked about Tiber already, but we had Walker Ridge, the

13:44

25

deepest water depth that had been drilled back in 200 -- end of

Do you recall using those words?

I know that's what the document says, but you

MR. REGAN:

Now, if I could pull up D-4341.1.

This is a demonstrative that we have put together.

And with the exception of one well in the life of

As you said, with the exception of one well, BP was the

And what we have here are a few of the successes.

OFFICIAL TRANSCRIPT

We

4684
STEVEN NEWMAN - CROSS

13:44

'04 into '05; right?

13:44

A.

Yes.

13:44

Q.

And these wells -- these wells that we see on D-4341,

13:44

these wells had losses; right?

13:44

when they were being drilled?

13:44

A.

13:44

those wells.

13:44

Q.

So whether they had losses or kicks, you don't know?

13:44

A.

I do not know.

13:44

10

Q.

But you do know they were successfully completed?

13:44

11

A.

I --

13:44

12

Q.

As far as you know?

13:44

13

A.

As far as I know, but...

13:44

14

Q.

The -- you said earlier you considered the Deepwater

13:44

15

Horizon's performance to be exemplary; correct?

13:44

16

A.

Yes.

13:44

17

Q.

And that performance is also a testament to the successful

13:44

18

collaboration that had taken place amongst all of the various

13:44

19

entities involved with the wells that were drilled here on this

13:44

20

page?

13:44

21

A.

13:44

22

record like that, is if you had a well-performing team.

13:45

23

Q.

13:45

24

be hard to choose a better rig than the Deepwater Horizon,

13:45

25

wouldn't it?

I don't know.

Did these wells have losses

I haven't reviewed the well reports for all

I think that's the only way you could deliver a track

If you had to pick a rig in 2010 to drill a well, it would

OFFICIAL TRANSCRIPT

4685
STEVEN NEWMAN - CROSS

13:45

A.

13:45

yes.

13:45

Q.

13:45

well, as of January 2010, that met or exceeded industry

13:45

standard for a MODU drilling deepwater wells; correct?

13:45

A.

I believe so, yes.

13:45

Q.

And the crew, the people on that rig, they met or exceeded

13:45

industry standard for drilling deepwater wells; is that

13:45

correct?

13:45

10

13:45

11

13:45

12

chart, D-4594.

13:45

13

BY MR. REGAN:

13:45

14

Q.

13:45

15

every Transocean employee, but just to try to orient our

13:45

16

examination and for the Court, I just wanted to highlight a few

13:45

17

of the individuals that are either going to be testifying or

13:45

18

that have documents that have been shown already this morning

13:46

19

or on prior examinations.

13:46

20

13:46

21

president, Mr. Newman?

13:46

22

A.

Yes.

13:46

23

Q.

And that was your position as of April 20th, 2010;

13:46

24

correct?

13:46

25

A.

A.

The Deepwater Horizon was one of our best-performing rigs,

The equipment on the Deepwater Horizon, as of April --

I believe so, yes.


MR. REGAN:

I'd like to pull up an organizational

Mr. Newman, this is not a complete organization chart of

Do you see yourself on this chart as CEO and

Yes.
OFFICIAL TRANSCRIPT

4686
STEVEN NEWMAN - CROSS

13:46

Q.

Again, this is D-4594, if I didn't say that for the

13:46

record.

13:46

13:46

Moore; is that right?

13:46

A.

Yes.

13:46

Q.

Is that the HSE side of the house for Transocean?

13:46

A.

It is.

13:46

Q.

And then you have underneath -- we have Mr. McMahan.

13:46

you see him, vice president of performance?

13:46

10

A.

I do.

13:46

11

Q.

And you talked about Mr. McMahan at some length earlier

13:46

12

today; is that right?

13:46

13

A.

Yes.

13:46

14

Q.

Over on the far left underneath VP of engineering and

13:46

15

technology, we see Bill Ambrose.

13:46

16

maintenance and technical support as of that time.

13:46

17

sound about right?

13:46

18

A.

Yes.

13:46

19

Q.

If we follow the line down from Mr. McMahan, we then have

13:46

20

Keelan Adamson, division manager.

13:46

21

name today.

13:46

22

A.

Yes.

13:46

23

Q.

Is he now on the board of directors?

13:46

24

A.

Keelan?

13:46

25

Q.

Yes.

And underneath you, you have Adrian Rose and Jimmy

Do

He's the director of


Does that

Do you know?

I think you mentioned his

Is that right?

OFFICIAL TRANSCRIPT

4687
STEVEN NEWMAN - CROSS

13:46

A.

No.

Keelan -- today Keelan is our vice president of human

13:47

resources.

13:47

Q.

13:47

13:47

A.

Yes.

13:47

Q.

We know him.

13:47

13:47

A.

Yes.

13:47

Q.

Daun Winslow, Buddy Trahan, and Jerry Canducci.

13:47

10

see them?

13:47

11

A.

Yes.

13:47

12

Q.

All right.

13:47

13

13:47

14

Mr. Kent and Mr. Johnson.

13:47

15

A.

13:47

16

was the asset rig manager.

13:47

17

13:47

18

Q.

Please do.

13:47

19

A.

On this chart you have depicted Keelan Adamson as working

13:47

20

for Larry McMahan.

13:47

21

Q.

Yes.

13:47

22

A.

That's not accurate.

13:47

23

Q.

Is there a different person I have on the chart where he

13:47

24

works, or do I have it wrong?

13:47

25

A.

Okay.
You have Steve Hand underneath Mr. McMahan; correct?

We have Mr. Braniff?

Do you

Now we get to the bottom of the left side with


What were their roles, if you know?

Mr. Johnson was the performance rig manager, and Mr. Kent

If I could just point out --

The line would have gone straight up from Keelan Adamson


OFFICIAL TRANSCRIPT

4688
STEVEN NEWMAN - CROSS

13:47

up through the business unit performance and directly up that

13:47

way.

13:47

Q.

Okay.

13:47

A.

Yes.

13:47

individual, not a line management.

13:47

Q.

13:48

Deepwater Horizon; right?

13:48

A.

He was the onshore rig manager/performance.

13:48

Q.

The job you had -- similar to the job you had when you

13:48

10

were in Brazil and some other places?

13:48

11

A.

13:48

12

really have two individuals filling the role of rig manager.

13:48

13

Back when I did it, the company was organized in a way that you

13:48

14

only had one individual filling the role of rig manager.

13:48

15

here we have two.

13:48

16

Q.

13:48

17

were doing the job where they were the first contact onshore

13:48

18

for the rig; right?

13:48

19

A.

Yes, that's correct.

13:48

20

Q.

And as we go to the right side of the page, on the rig, we

13:48

21

have Jimmy Harrell.

13:48

22

A.

Yes.

13:48

23

Q.

Then we have a maintenance group underneath Mr. Bertone?

13:48

24

A.

Yes.

13:48

25

Q.

And you talked about them earlier today; correct?

So if I just drew that line straight to there?


That's correct.

Larry McMahan was a staff

And Mr. Johnson, he was the onshore rig manager for the

Sort of.

Okay.

If you look at the way this -- this is drawn, we

But it's the same concept.

So

Those two gentlemen

He was the OIM; correct?

OFFICIAL TRANSCRIPT

4689
STEVEN NEWMAN - CROSS

13:48

A.

Yes.

13:48

Q.

Then we have the drilling group underneath Mr. Harrell

13:48

with Mr. Ezell, Mr. Wheeler, Mr. Anderson, and some others?

13:48

A.

Yes.

13:48

Q.

Again, it's not fully complete, but those are the key

13:48

players; correct?

13:48

A.

Yes.

13:48

Q.

And then we have a maritime group, where Curt --

13:49

Captain Kuchta; David Young, the chief mate; Andrea Fleytas,

13:49

10

the DP operator; and Yancy Keplinger, the DP operator?

13:49

11

A.

Yes.

13:49

12

Q.

All right.

13:49

13

chart just to make sure that we stay oriented as to who had

13:49

14

which jobs and where they might be situated.

13:49

15

A.

Okay.

13:49

16

Q.

You talked on your direct about Transocean having -- I

13:49

17

think you used the phrase "narrow slice."

13:49

18

up D-4275, which is a POB list, "persons onboard" of the

13:49

19

Deepwater Horizon.

13:49

20

detail today about some of the roles and responsibilities,

13:49

21

generally, like the questions you've already been asked.

13:49

22

13:49

23

justice, would it surprise you that the vast majority of the

13:49

24

people on the rig would be Transocean employees?

13:49

25

A.

Okay?

I may refer back and forth to this little

I just want to pull

I'm going to ask you some questions in some

But with respect to the people on the rig, rough

I think that's typically the case on our rigs around the


OFFICIAL TRANSCRIPT

4690
STEVEN NEWMAN - CROSS

13:49

world.

13:49

Q.

13:50

be, of the actual people on the rig, generally speaking, the

13:50

drilling contractor's going to have the majority, if not

13:50

75 percent, of the people on the rig?

13:50

A.

13:50

a drilling rig than there are operator personnel or operator

13:50

subcontractor personnel.

13:50

Q.

13:50

10

correct?

13:50

11

A.

13:50

12

Mr. Regan, yes.

13:50

13

Q.

There are no tourists?

13:50

14

A.

No, there are no tourists.

13:50

15

Q.

I'd now like to change to -- there were some questions

13:50

16

about Transocean and BP's contractual relationship, and I just

13:50

17

want to ask you a few questions about that, if I might.

13:50

18

13:50

19

Transocean and BP?

13:50

20

A.

Yes.

13:50

21

Q.

And I'd like to pull up just a few provisions of it and

13:50

22

just confirm that they are consistent with your understanding.

13:50

23

If we could pull up TREX-1356A.20.4.

13:51

24

13:51

25

So in term of the slice, however narrow or broad it might

There are typically more drilling contractor personnel on

And people are on the rig because they have jobs to do;

That's the only reason for them to be out there,

Now, you understand there is a contract between


You understand that?

What I've pulled up, Mr. Newman, is Article 15 of


that contract, which is TREX-1356A under "Performance of
OFFICIAL TRANSCRIPT

4691
STEVEN NEWMAN - CROSS

13:51

Drilling Operations," and the contract states -- 15.1,

13:51

"Operations of Drilling Unit:

13:51

case is Transocean -- "shall be solely responsible for the

13:51

operations of the drilling rig."

13:51

13:51

A.

I do.

13:51

Q.

And it continues on and it says:

13:51

onboard the drilling unit as may be necessary or desirable for

13:51

the safety of the drilling unit."

13:51

10

13:51

11

A.

I do.

13:51

12

Q.

And that's your understanding of one of the terms of the

13:51

13

agreement between BP and TO; correct?

13:51

14

A.

13:51

15

drilling contract, yes.

13:51

16

13:51

17

Section 15, which is "Performance of Drilling Operations."

13:51

18

BY MR. REGAN:

13:51

19

Q.

13:51

20

understanding, I should say, Mr. Newman, that there is a

13:51

21

provision in the contract with respect to prevention of fire

13:52

22

and blowouts?

13:52

23

A.

Yes, that would be consistent with my understanding.

13:52

24

Q.

And it states:

13:52

25

"shall maintain well control equipment in accordance with good

The contractor" -- which in this

Do you see that?

"Including operations

Do you see that?

I think that's -- I think that's an article from the

MR. REGAN:

We'll pull up 1356A.20.4, also in

Are you understanding -- is it consistent with your

"Contractor" -- again, Transocean --

OFFICIAL TRANSCRIPT

4692
STEVEN NEWMAN - CROSS

13:52

oilfield practices at all times and shall use all reasonable

13:52

means to control and prevent fire and blowouts and to protect

13:52

the hole and all of the property of the company" -- in this

13:52

case BP.

13:52

13:52

the terms of the contract?

13:52

A.

Generally consistent, yes.

13:52

Q.

You're not aware of any amendment of that term, are you?

13:52

A.

I'm not aware of, no.

13:52

10

13:52

11

BY MR. REGAN:

13:52

12

Q.

13:52

13

which is entitled "Safety," that contractually Transocean

13:52

14

agreed in 17.1 that "Contractor" -- Transocean -- "shall have

13:52

15

the primary responsibility for the safety of all its

13:52

16

operations, shall take all measures necessary or proper to

13:52

17

protect the personnel and facilities, and in addition, shall

13:53

18

observe all safety rules and regulations of any governmental

13:53

19

agency having jurisdiction over operations conducted hereunder.

13:53

20

Contractor shall place the highest priority on safety while

13:53

21

performing the work.

13:53

22

company's safety rules and guidelines as set forth in safety

13:53

23

and health manual of Vastar Resources and the requirements

13:53

24

contained in Exhibit D" -- and it continues:

13:53

25

also have its own safety manual" -- we can go to the next page,

Is that consistent with your understanding of one of

MR. REGAN:

Let me pull up one more, 1356A.22.2.

Again, Mr. Newman, are you aware that, under Article 17,

Contractor shall observe all of the

OFFICIAL TRANSCRIPT

"Contractor may

4693
STEVEN NEWMAN - CROSS

13:53

at the very top -- "and when contractor's and company's safety

13:53

manuals conflict, contractor's safety manual shall control."

13:53

13:53

the agreement between BP and Transocean?

13:53

A.

These are provisions right out of that contract.

13:53

Q.

And so you understand that under the contract, if there's

13:53

a conflict between Transocean and BP's safety manual,

13:54

Transocean's manual controls?

13:54

A.

That's what the contract says.

13:54

10

Q.

We talked about a bridging document -- I'm done with that.

13:54

11

13:54

12

said you have the same arrangement with every customer you

13:54

13

worked for; that is, Transocean has a safety system, the

13:54

14

operator or customer has a safety system, and you look at the

13:54

15

two of them and determine whether or not you need to bridge.

13:54

16

Is that fair?

13:54

17

A.

That's a general approach, yes.

13:54

18

Q.

All around the world?

13:54

19

A.

Yes.

13:54

20

Q.

Including the Gulf of Mexico?

13:54

21

A.

Including the Gulf of Mexico, yes.

13:54

22

Q.

Now, the concept of a bridging document, just to be clear

13:54

23

for the Court, that, in concept, is, if you identify a

13:54

24

difference between the policies, you need to bridge between

13:54

25

them.

Are those terms consistent with your understanding of

We talked about a bridging document, and I think you

Is that fair?
OFFICIAL TRANSCRIPT

4694
STEVEN NEWMAN - CROSS

13:54

A.

That's the general purpose of the bridging document, yes.

13:54

Q.

But if you both -- if the operator has a consistent policy

13:54

and you have a consistent policy, there's no need for a bridge;

13:54

correct?

13:54

A.

That's correct.

13:54

Q.

And again, that's how it happens every day of the week in

13:54

your business, regardless of who the operators are, all around

13:55

the world?

13:55

A.

That is our general approach to business, yes.

13:55

10

Q.

You also understand that there are regulations that apply,

13:55

11

not just to the operators under United States law, not just to

13:55

12

the operator, but also to the contractor with respect to steps

13:55

13

needed to be taken to keep wells under control.

13:55

14

familiar with that?

13:55

15

A.

Yes.

13:55

16

Q.

Okay.

13:55

17

talked a little bit already about it, but Transocean is

13:55

18

responsible for maintenance of any of the equipment that it

13:55

19

owns on the rig; correct?

13:55

20

A.

Yes, that's true.

13:55

21

Q.

And Transocean provides the maintenance crew, we've

13:55

22

already talked about; correct?

13:55

23

A.

Yes.

13:55

24

Q.

Transocean is responsible for the maintenance of the BOP

13:55

25

on the Deepwater Horizon; correct?

All right.

You're

With respect to the equipment, you

OFFICIAL TRANSCRIPT

4695
STEVEN NEWMAN - CROSS

13:55

A.

Yes.

13:55

Q.

Transocean is responsible for training the drilling crew

13:55

on the Deepwater Horizon; correct?

13:55

A.

Yes.

13:55

Q.

Transocean is responsible for providing well control

13:55

training, specifically, to the members of the rig crew to whom

13:56

it pertains; correct?

13:56

A.

For the members -- yeah, for Transocean's employees, yes.

13:56

Q.

On the maritime side, Transocean is responsible for

13:56

10

providing the maritime crew; correct?

13:56

11

A.

Yes.

13:56

12

Q.

And Transocean is responsible for training the maritime

13:56

13

crew; correct?

13:56

14

A.

Yes.

13:56

15

Q.

And with respect to the BOP in specific, we've had some

13:56

16

testimony already about BOP pods and batteries in BOP pods.

13:56

17

Would you agree that the batteries in the BOP and

13:56

18

whether they were charged or not charged, that question and

13:56

19

that maintenance issue is a Transocean responsibility?

13:56

20

A.

13:56

21

ours and the pods are ours and the batteries within those pods

13:56

22

are ours, that's our responsibility to maintain and operate

13:56

23

that equipment.

13:56

24

Q.

13:56

25

Transocean was responsible for complying with MMS regulations

Yeah.

I think earlier I said that, because the BOP is

And more broadly, as the supplier and owner of the BOP,

OFFICIAL TRANSCRIPT

4696
STEVEN NEWMAN - CROSS

13:57

with respect to the BOP; correct?

13:57

A.

13:57

supplier of the BOP.

13:57

Q.

13:57

owner --

13:57

A.

Yes.

13:57

Q.

-- Transocean was responsible for complying with MMS

13:57

regulations as to the BOP; correct?

13:57

A.

Yes.

13:57

10

Q.

Now, there were modifications that were made to the BP --

13:57

11

or Deepwater Horizon's BOP over the course of its ten-year

13:57

12

history?

13:57

13

A.

Yes.

13:57

14

Q.

You have general knowledge?

13:57

15

A.

General knowledge, yes.

13:57

16

Q.

With respect to drawings or other recordations of those

13:57

17

modifications, that would have been a Transocean responsibility

13:57

18

to keep that information; correct?

13:57

19

A.

Yes, yes.

13:57

20

Q.

I'd like to now turn to the safety management system.

13:57

21

had a fair number of questions about that.

13:57

22

13:57

23

you have trust in BP's safety management system and the

13:57

24

relationship between Transocean and BP.

13:57

25

generally?

We were certainly the owner.

Cameron was the original

We were the owner.

But my question was a little more specific.

As the

You

Now, you were asked about the idea of trust, whether

Do you recall that

OFFICIAL TRANSCRIPT

4697
STEVEN NEWMAN - CROSS

13:58

A.

Yes.

13:58

Q.

Okay.

13:58

safety system for what you control.

13:58

words.

13:58

A.

Yes.

13:58

Q.

And that's true for BP and for Transocean; correct?

13:58

A.

Yes.

13:58

Q.

And so there's mutual trust on those issues; correct?

13:58

A.

I think so, yes.

13:58

10

Q.

It's a two-way street?

13:58

11

A.

Yes.

13:58

12

Q.

BP puts its trust it Transocean for its safety policies

13:58

13

for what Transocean controls; and Transocean may put trust in

13:58

14

BP for BP's policies for what BP controls?

13:58

15

A.

Yes.

13:58

16

Q.

And again, is that consistent with the way it works all

13:58

17

around the world?

13:58

18

A.

Yes.

13:58

19

Q.

Now, you were -- I just want to do this right off the bat.

13:58

20

You were shown some deposition testimony from Mr. John Baxter.

13:58

21

Do you recall that?

13:58

22

A.

13:58

23

13:58

24

Now, I think you said you have -- you should have a


I think those were your

Does that sound fair?

Fair?

Generally, yes.

I do.
MR. REGAN:

If we could put up Mr. Baxter's

testimony, deposition, page 175.

25
OFFICIAL TRANSCRIPT

4698
STEVEN NEWMAN - CROSS

13:58

BY MR. REGAN:

13:58

Q.

13:58

You were shown lines 14 and 15.

13:59

13:59

for the State of Alabama?

13:59

A.

Yes.

13:59

Q.

I'd like to show you the question and answers that precede

13:59

this.

13:59

13:59

10

13:59

11

leased continuously since its creation in the Gulf of

13:59

12

Mexico.

13:59

13

13:59

14

did not have the OMS system apply to it?

13:59

15

true?"

13:59

16

13:59

17

line 19?

13:59

18

A.

Yes.

13:59

19

Q.

And he says:

13:59

20

"ANSWER:

13:59

21

I take that back.

13:59

22

contracting any service which is -- and I can't recall the

13:59

23

words, but they're not on a BP entity -- then the business

14:00

24

which is contracting in that service reviews the safety

14:00

25

management system that the contractor is using.

I think you were shown two lines from that deposition.

Do you recall being shown those two lines by counsel

So if we could start with page 174, line 13.


Now, the question starts on line 13:
"QUESTION:

Now, so BP is using this MODU that it has

"Is it your testimony that the Deepwater Horizon


First of all, is that

And do you see Mr. Baxter's answer starting at

There was no requirement to apply -- sorry,


OMS requires that where BP is

OFFICIAL TRANSCRIPT

And the

4699
STEVEN NEWMAN - CROSS

14:00

question then is, is that safety" -- go to the next

14:00

page -- "management system -- will it deliver the same --

14:00

let me remember the words.

14:00

deliver the same intent as OMS.'

14:00

14:00

kind of gap assessment.

14:00

then what, if anything, additional should be applied?

14:00

14:00

14:00

10

14:00

11

14:00

12

A.

Yes.

14:00

13

Q.

And were you shown that by the counsel for the State of

14:00

14

Alabama?

14:00

15

A.

No.

14:00

16

Q.

And that conflict that's described by Mr. Baxter, that an

14:00

17

operator will look at the contractor's safety management

14:00

18

system, determine if there are any gaps, determine if there

14:00

19

needs to be a bridge, and then proceed forward with mutual

14:01

20

trust of each other, that's what you see every day in your

14:01

21

business; correct?

14:01

22

A.

14:01

23

globe.

14:01

24

Q.

That's industry standard, isn't it?

14:01

25

A.

It is general industry standard for the operator to have a

It's something like 'it will

"The BP business is then required to carry out some


And the point is that the question is

"And, of course, MAR is an element of OMS, taking an


isolation, one, may not be the right thing to do.

The other

thing is that MAR is a very high-level risk assessment."


Do you see that question and do you see that answer?

That is a -- that's not an uncommon occurrence across the

OFFICIAL TRANSCRIPT

4700
STEVEN NEWMAN - CROSS

14:01

safety management system and the contractor to have a safety

14:01

management system, and for there to be a pretty thorough

14:01

comparison of those two safety management systems.

14:01

there are gaps or differences, those need to be bridged.

14:01

Q.

And if there are no gaps, then you proceed at peace?

14:01

A.

Yes.

14:01

Q.

Now, I want to talk about your safety management system.

14:01

14:01

14:01

10

14:01

11

14:01

12

14:02

13

from Senator Murkowski, who asked you if you have any

14:02

14

additional safety measures or modification procedures as a

14:02

15

result of incident, you said:

14:02

16

consistent standard of policies and procedures, maintenance

14:02

17

practices, and operating practices across the Transocean fleet

14:02

18

throughout the world."

14:02

19

I'm going to stop there.

14:02

20

Do you recall giving that answer?

14:02

21

A.

It's helpful to read it.

14:02

22

Q.

Okay.

14:02

23

as to that.

14:02

24

company management system; is that right?

14:02

25

A.

MR. REGAN:

And if

If we could pull up 216.71.1 --

2016.7D-1.1.
This is an excerpt from your testimony on May 11th,
2010.
Mr. Newman, do you recall, in response to a question

"Senator, we operate a

Yes.

I just -- that's all I wanted, to just refresh you


The system you are referring to is the Transocean

Yes.
OFFICIAL TRANSCRIPT

4701
STEVEN NEWMAN - CROSS

14:02

Q.

And that CMS system at Transocean serves as a governing

14:02

document.

14:02

various functional policies and procedures that are part of the

14:02

overall system?

14:02

A.

Yes.

14:02

Q.

And it's Transocean's general practice to have its CMS

14:02

govern on its rigs rather than an operator -- operating

14:03

management system; correct?

14:03

A.

14:03

10

our people to our safety management system, and we expect them

14:03

11

to operate our safety management system.

14:03

12

rigs that are changing contracts frequently, they're not having

14:03

13

it change every time we change a contract.

14:03

14

consistent set of policies and procedures.

14:03

15

Q.

14:03

16

sure that they know "We're working under Transocean's system"?

14:03

17

A.

14:03

18

safety management is independent of the customer we work for;

14:03

19

it's independent of the operator -- of the area we operate in;

14:03

20

it's independent of the type of rig we operate on.

14:03

21

14:03

22

procedures that comprise our safety management system.

14:03

23

Q.

14:03

24

Exhibit 5474.102.1.

14:04

25

And then there's -- below it, or underneath it, are

Yeah.

That's our preference because, you know, we train

And consequently, on

They're operating a

You find it less confusing for your employees, to make

Yes.

What I tell our people is that our approach to

We have a standard -- standard set of policies and

Let's turn to that, and just be brief.

But

This is TREX-5474.

This is a work chart that comes out of the


OFFICIAL TRANSCRIPT

4702
STEVEN NEWMAN - CROSS

14:04

Deepwater Horizon operations integrity case.

I think you might

14:04

be able to see those words at the top.

14:04

A.

Yes.

14:04

Q.

And you know what an operations integrity case is; right?

14:04

A.

Yes.

14:04

Q.

And that's one of the documents that's put together as

14:04

part of Transocean's assessments of conducting safe operations?

14:04

A.

It is part of our safety management system.

14:04

Q.

I just want to briefly describe.

14:04

10

14:04

11

14:04

12

A.

Yes.

14:04

13

Q.

And, in fact, I think I have a demonstrative that's easier

14:04

14

to read than this.

14:04

15

14:04

16

14:04

17

14:04

18

BY MR. REGAN:

14:04

19

Q.

14:04

20

company management system.

14:04

21

A.

14:05

22

comprehensive company management system.

14:05

23

Q.

14:05

24

to the top, those are worldwide, companywide policies; right?

14:05

25

A.

You see "Levels," this

"hierarchy of risk management documents."


Do you see that on the right side?

MR. REGAN:

So, Diane, could we pull up D-4595.

hope it's easier to read.


There, I can read that better.

This is the hierarchy within Transocean, correct, of the

Yeah.

Right?

I think this is a graphical depiction of our

And Level 1 and 1B, these ones here, kind of half the page

Between Level 1, Level 1A, and Level 1B, those are the
OFFICIAL TRANSCRIPT

4703
STEVEN NEWMAN - CROSS

14:05

worldwide documents.

14:05

Q.

Level 2A and 2B, those are regional-type policies; right?

14:05

A.

Yes.

14:05

Q.

And then Level 3, down here at the bottom, those would be

14:05

location-specific or rig-specific policies; correct?

14:05

A.

Yes.

14:05

Q.

So this is the Transocean Deepwater Horizon operations

14:05

integrity case.

14:05

"Deepwater Horizon," and then the various manuals or policies

14:05

10

and procedures, they're in Level 3; right?

14:05

11

A.

Yes.

14:05

12

Q.

Okay.

14:05

13

Transocean to ensure that management expectations are

14:05

14

communicated, understood, and implemented effectively; right?

14:05

15

A.

Yes.

14:05

16

Q.

Okay.

14:06

17

corner.

14:06

18

14:06

19

Level 1A, do you see that box?

14:06

20

A.

Yes.

14:06

21

Q.

All right.

14:06

22

14:06

23

14:06

24

14:06

25

So we see at Level 3 they all say

Now, this system is prepared or maintained by

I want to just focus just briefly on the top left

I think you talked about it.


But this health and safety policies and procedures,

That's TREX-1449.

And forgive me, before I get do that, let me do one


other thing.
With respect to the Macondo well, did you see the
drilling program where it expressly said which safety policy
OFFICIAL TRANSCRIPT

4704
STEVEN NEWMAN - CROSS

14:06

was going to apply for drilling this well?

Did you see that?

14:06

A.

No.

14:06

Q.

Have you seen that?

14:06

A.

No.

14:06

Q.

Let me pull it up, 41222.31.1.

14:06

All right.

14:06

And then I'll bring up 7685.1.4, which is the

14:07

transmission of that drilling program to the OIM in February of

14:07

2010 to the Horizon.

14:07

10

Do you see that there on the screen?

14:07

11

Let me now go to the first page of that program,

14:07

12

14:07

13

14:07

14

the exhibit and go to -- sorry -- 7685.4.1.

14:07

15

it right here.

14:07

16

BY MR. REGAN:

14:07

17

Q.

14:07

18

for the Macondo well.

14:07

19

under "Well information and well objectives, our H, S and E

14:07

20

objective is zero incidents, no harm to people, environment, or

14:07

21

equipment.

14:07

22

14:07

23

Transocean's health and safety management system on the

14:07

24

Horizon."

14:07

25

A.

This is the drilling program.

which I think is -MR. REGAN:

All right.

Diane, if we could just come back into


Pardon me.

I have

7685.4.1.

This is the first page of the drilling program


And do you see there on the first page,

We will accomplish this by:"

And the first bullet is:

"Fully implementing

Do you see that?

Yes.
OFFICIAL TRANSCRIPT

4705
STEVEN NEWMAN - CROSS

14:07

Q.

And that's consistent with what we've been talking about

14:07

in the last ten minutes.

14:08

A.

Broadly speaking, I think so, yes.

14:08

Q.

Let's go back now to that policy document I had up a

14:08

minute ago, which is 1449.5.3 -- 1449.

14:08

14:08

stop-the-job authority, and the Court has heard about

14:08

stop-the-job authority.

14:08

helpful to hear it from you.

14:08

10

14:08

11

Transocean's safety management system; correct?

14:08

12

A.

Yes.

14:08

13

Q.

It's something that you talk about with your employees

14:08

14

every time you're out there around them; right?

14:08

15

A.

Yes.

14:08

16

Q.

It's both they have the right to stop the job, but they

14:08

17

have the obligation to exercise that authority if they see

14:08

18

something that they don't understand or they think is unsafe or

14:08

19

they think shouldn't proceed; correct?

14:08

20

A.

Yes.

14:08

21

Q.

And that's a fundamental part of the safety management

14:08

22

system; right?

14:08

23

A.

It is.

14:08

24

Q.

So if a well site leader tried to direct a Transocean rig

14:08

25

hand to do something that the rig hand thought was unsafe or

Fair?

Now, you were asked a few questions about

But just -- I think it would be

Stop-the-job authority is a key component in

OFFICIAL TRANSCRIPT

4706
STEVEN NEWMAN - CROSS

14:09

didn't understand, it doesn't matter who asked the rig hand to

14:09

do it, he's entitled and obligated to stop that job; is that

14:09

right?

14:09

A.

Absolutely.

14:09

Q.

And that's not just a Transocean policy; that's the way

14:09

the oil and gas business works.

14:09

A.

Yes.

14:09

Q.

You've heard about that policy on your competitors' rigs;

14:09

right?

14:09

10

A.

14:09

11

the general approach taken across the industry.

14:09

12

Q.

14:09

13

policy statement that you signed.

14:09

14

there what we just said.

14:09

15

interrupt an operation to prevent an incident from occurring";

14:09

16

correct?

14:09

17

A.

That's what the document says.

14:09

18

Q.

And there's been no change in that policy; right?

14:09

19

A.

No.

14:09

20

Q.

Similarly, if a Transocean employee feels like he doesn't

14:09

21

have enough information about the job he's about to do,

14:09

22

stop-the-job authority would kick in; correct?

14:10

23

A.

Yes.

14:10

24

Q.

All right.

14:10

25

think by Mr. Brian, about what your role is for safety.

Right?

Maybe not.

I would agree with your prior statement, which is that's

All right.

And in 1449.5.4 there's health and safety


And it expressly says in

"Each employee has the obligation to

With respect to safety, you were asked, I

OFFICIAL TRANSCRIPT

And

4707
STEVEN NEWMAN - CROSS

14:10

you described three things:

Make sure that a system exists;

14:10

make sure that the people that you hire understand the system

14:10

and execute against it; and set expectations to make sure

14:10

people are meeting them.

14:10

Number 4, which is "intervene where necessary."

14:10

A.

Yes.

14:10

Q.

Do I have it right?

14:10

A.

Yes.

14:10

Q.

Good.

14:10

10

actually has some specific obligations for the chief executive

14:10

11

officer; correct?

14:10

12

A.

I believe it probably does, yes.

14:10

13

Q.

First, let me show you 1449.20.1.

14:10

14

Mr. Cunningham's drawing, but I did note in the document that

14:10

15

there was a drawing in there that actually had a description

14:10

16

of -- from the OIM to the CEO, how the line management for HSE,

14:10

17

or for safety, works at Transocean.

14:10

18

14:11

19

A.

Yes.

14:11

20

Q.

And is that a fair depiction of how you would get from the

14:11

21

OIM through the various levels of management up to the CEO with

14:11

22

respect to safety?

14:11

23

A.

Yes.

14:11

24

Q.

Let me now go to 1449.15.1.

14:11

25

And I think sometimes you threw in a

But within the health and safety policy, it

And I didn't get to see

Do you see that depicted on the screen?

Again, we're in that Level 1 document.


OFFICIAL TRANSCRIPT

Do you see

4708
STEVEN NEWMAN - CROSS

14:11

it?

There's a provision about the chief executive officer?

14:11

A.

Yes.

14:11

Q.

And it says:

14:11

responsible for the health, safety, and welfare of all

14:11

personnel working at company installations, facilities, and

14:11

offices."

14:11

14:11

correct?

14:11

A.

That's what the document says.

14:11

10

Q.

And you understand that to be the case.

14:11

11

role, are ultimately responsible for the health, safety, and

14:11

12

welfare of all personnel working at Transocean installations,

14:11

13

facilities, and offices; correct?

14:11

14

A.

As CEO, I'm ultimately responsible for a lot of things --

14:11

15

Q.

And the way you --

14:11

16

A.

-- including health, safety, and welfare.

14:12

17

Q.

And the way you discharge that ultimate responsibility

14:12

18

that you own, as per the policy, is you clarify expectations,

14:12

19

you hire competent people to carry them out, you track their

14:12

20

performance, and you intervene where necessary.

14:12

21

A.

14:12

22

management.

14:12

23

Q.

14:12

24

the work of the people below you, the 19,000 people at

14:12

25

Transocean; correct?

"The chief executive officer is ultimately

And then it details some specific responsibilities;

That you, in that

Is that fair?

Yeah, I think that's a good description of an approach to

You have ultimate responsibility, but you're not doing all

OFFICIAL TRANSCRIPT

4709
STEVEN NEWMAN - CROSS

14:12

A.

No.

14:12

Q.

You can't do everything --

14:12

A.

Yes, that is correct.

14:12

Q.

Right.

14:12

responsibility through expectations, through hiring competent

14:12

people, tracking their performance, and intervening where

14:12

necessary; right?

14:12

A.

Yes.

14:12

Q.

Let me show you 1449.123.1.

14:12

10

saw in this document.

14:13

11

START programs, Task Risk Assessment, MAHRAs.

14:13

12

about operations integrity case.

14:13

13

14:13

14

conversation here and for the Court.

14:13

15

TREX-1449, page 123.

14:13

16

14:13

17

the levels of risk management within Transocean?

14:13

18

A.

Yes.

14:13

19

Q.

We see here the pencil on the side, "increasing complexity

14:13

20

and severity of risk," up the side; right?

14:13

21

A.

Yes.

14:13

22

Q.

The THINK procedures that are written here, both verbal,

14:13

23

individual, written, that's what we talked about earlier today;

14:13

24

correct?

14:13

25

A.

So you try to discharge that ultimate

This is another chart that I

You were asked about THINK procedures,


I just asked you

I was hoping that this chart might organize our


This is from the document

Do you see this as a representation, graphically, of

You used the word "procedures."

I think what that says is

OFFICIAL TRANSCRIPT

4710
STEVEN NEWMAN - CROSS

14:13

"process"; "THINK planning process, individual, verbal, and

14:13

written."

14:13

Q.

All right.

14:13

A.

And then you get to task-specific THINK procedures.

14:13

Q.

Okay.

14:13

14:13

and then some things above the line; correct?

14:13

A.

Yes.

14:13

Q.

And the things above the line include the operations

14:13

10

integrity case -- that's at the very top; right?

14:14

11

A.

Yes.

14:14

12

Q.

There was an operations integrity case done for the

14:14

13

Deepwater Horizon; correct?

14:14

14

A.

Yes.

14:14

15

Q.

There's an issue of a safety case.

14:14

16

refers to?

14:14

17

A.

14:14

18

there is a requirement for an analysis of safety on the rig,

14:14

19

and that document is referred to as a safety case.

14:14

20

Q.

14:14

21

assessment; correct?

14:14

22

A.

Yes.

14:14

23

Q.

And then there's HAZOP or HAZID.

14:14

24

studies you've done; correct?

14:14

25

A.

Yes.

I skipped that one.

You're right.

Then we have a line here, "shore-based resources,"

Yes.

Okay.

Do you know what that

In some highly regulated regimes around the world

There's the MAHRA, or major accident hazard risk

Those are other types of

Yeah, hazard identification and hazard operability


OFFICIAL TRANSCRIPT

4711
STEVEN NEWMAN - CROSS

14:14

analysis.

14:14

Q.

14:14

only just an OIC, but it also had a MAHRA done; correct?

14:14

A.

Yes.

14:14

Q.

Just a couple questions about the THINK procedures, then I

14:14

want to turn to that MAHRA.

14:14

14:14

a THINK procedure might work.

14:14

about sling lockers.

14:15

10

discussing?

14:15

11

A.

14:15

12

you might apply the THINK planning process at the individual

14:15

13

level.

14:15

14

Q.

14:15

15

conducting a negative test; correct?

14:15

16

A.

There would be a THINK plan.

14:15

17

Q.

There would be a THINK plan.

14:15

18

maybe it would be written, but there would be a THINK plan for

14:15

19

conducting a negative test; correct?

14:15

20

A.

I would expect there to be, yes.

14:15

21

Q.

You would expect there to be a THINK plan for displacing

14:15

22

the riser; correct?

14:15

23

A.

14:15

24

that's undertaken on our drilling rigs.

14:15

25

Q.

So for the Deepwater Horizon, though, we know it had not

You gave an example, I think to Mr. Brian, about how

Yeah.

And I think you were talking

I think that was what you were

I mean, that was a simplified task to describe how

Understood.

There also would be a THINK procedure for

Maybe it would be verbal,

I would expect there to be a THINK plan for every task

So you would expect for the positive test, the negative


OFFICIAL TRANSCRIPT

4712
STEVEN NEWMAN - CROSS

14:15

test, displacing the riser, and on down the line?

14:15

A.

14:15

task.

14:15

Q.

14:15

for the Deepwater Horizon with respect to negative tests?

14:15

you seen those?

14:15

A.

As a result of the litigation, I believe I have, yes.

14:16

Q.

And have you seen THINK plans that were prepared for

14:16

displacement of the riser?

14:16

10

A.

I don't recall.

14:16

11

Q.

But fundamentally, that procedure, the THINK procedure, is

14:16

12

designed to have people stop before they take action, think

14:16

13

about what they're going to do, talk to the people they're

14:16

14

going to do it with, make sure they're clear on what's going to

14:16

15

happen, consider the risks, and only then proceed?

14:16

16

A.

14:16

17

THINK planning process, is that before the crew or any

14:16

18

individual in the crew undertake a task, they conduct a THINK

14:16

19

plan to make sure that they can carry out that task safely and

14:16

20

efficiently.

14:16

21

Q.

14:16

22

accident hazard risk assessment.

14:16

23

14:16

24

14:17

25

I would expect a THINK plan to be undertaken for every

And have you seen written THINK plans that were prepared
Have

That is the -- that's the fundamental expectation of the

Okay.

I'd like to now turn to the Transocean major

Now, still on this same document, 1449, let me pull


1449.132.1.
Now, a few preliminary questions, Mr. Newman.
OFFICIAL TRANSCRIPT

You

4713
STEVEN NEWMAN - CROSS

14:17

were shown some testimony from Dr. Bea.

Do you remember seeing

14:17

that on your direct examination?

14:17

A.

I do.

14:17

Q.

And I think you were asked about whether Transocean could

14:17

do a risk assessment about all risks inherent in the well.

14:17

you remember that?

14:17

A.

I do.

14:17

Q.

And I think you said you couldn't.

14:17

risk assessment for the things that Transocean controls and the

14:17

10

things Transocean does; correct?

14:17

11

A.

Yes.

14:17

12

Q.

All right.

14:17

13

that's applicable to your own activities; right?

14:17

14

A.

Yes.

14:17

15

Q.

Okay.

14:17

16

of a -- under the policy is -- let me just read it.

14:17

17

14:17

18

14:17

19

One, "the Major Hazard Risk Assessment, MHRA."

14:18

20

Two, "the HSE (or safety) Case."

14:18

21

And three, "the Operations Integrity Case (OIC).

14:18

22

"Every vessel on the Transocean fleet must have a

14:18

23

14:18

24

14:18

25

You could only do a

So it applies -- you can do a risk assessment

And this is what a risk assessment -- the purpose

It says:

"Transocean has three processes to provide

assurance that major hazards are effectively managed.

current version of a MHRA, Safety Case, or OIC."


Do you see that?
A.

Do

Yes.
OFFICIAL TRANSCRIPT

4714
STEVEN NEWMAN - CROSS

14:18

Q.

And the Deepwater Horizon had two of them.

It had a MHRA

14:18

and an OIC; correct?

14:18

A.

I believe that's true, yes.

14:18

Q.

And then for definitions, to make sure we're all on the

14:18

same page, it's defined.

14:18

(MHRA) shows that major hazards have been identified, the risk

14:18

associated with those hazards has been qualitatively assessed,

14:18

and the preventive and mitigating controls necessary to reduce

14:18

the risk to ALARP have been identified."

14:18

10

14:18

11

A.

As low as reasonably practical.

14:18

12

Q.

And that's a term that comes out of both the safety case

14:18

13

concept and also some of the process safety discussions; right?

14:18

14

A.

14:18

15

14:19

16

major accident hazard risk assessment for the Horizon.

14:19

17

like to go to .2.1 in the same exhibit, TREX-2187.

14:19

18

BY MR. REGAN:

14:19

19

Q.

14:19

20

for 2004 signed by John Keeton?

14:19

21

A.

I do.

14:19

22

Q.

And he is confirming that this major accident hazard risk

14:19

23

assessment has been performed and that it identified the

14:19

24

reasonably foreseeable hazards that might lead to a major

14:19

25

accident; correct?

"A Major Hazard Risk Assessment

ALARP stands for?

Yes.
MR. REGAN:

Let me pull up 2187.1.2.

This is the
I'd

Do you see there's a statement of approval of the document

OFFICIAL TRANSCRIPT

4715
STEVEN NEWMAN - CROSS

14:19

A.

That's what the document says, yes.

14:19

Q.

And Mr. Keeton is confirming, by virtue of his signature,

14:19

that it has been demonstrated that adequate controls are in

14:19

place so that HSE risks on the Horizon can be considered both

14:19

tolerable and ALARP, as low as reasonably practicable; correct?

14:19

A.

That's what the document says.

14:19

Q.

And then he goes on to approve it; correct?

14:19

A.

He has signed the document, yes.

14:19

14:20

10

BY MR. REGAN:

14:20

11

Q.

14:20

12

concentrated on identifying major accident hazards.

14:20

13

following is a list of the possible hazards for

14:20

14

semisubmersibles engaged in exploration or development

14:20

15

drilling."

14:20

16

14:20

17

A.

Yes.

14:20

18

Q.

And that list of hazards applies to any MODU operated by

14:20

19

Transocean in the oceans of the world.

14:20

20

A.

Yes.

14:20

21

Q.

I want to focus on just a couple of them because a couple

14:20

22

have already been covered.

14:20

23

blowout at drill floor."

14:20

24

14:20

25

MR. REGAN:

Now let's go to 2187.5.

There's a list of scenarios, and it says:

"The study
The

Do you see that?

Is that fair?

I want to focus on "reservoir

Do you see that?


A.

Yes.
OFFICIAL TRANSCRIPT

4716
STEVEN NEWMAN - CROSS

14:20

Q.

Let's turn to 2817.178.1.

This is the chart similar to

14:20

what you went through, I think, with Mr. Cunningham,

14:20

identifying the hazards.

14:20

do you see that?

14:20

A.

Yes.

14:20

Q.

It also identifies the consequences of that event:

14:20

environmental impact.

14:20

fatalities.

14:20

vessel."

14:20

10

14:21

11

A.

I do.

14:21

12

Q.

And then it lists the preventions; correct?

14:21

13

A.

Yes.

14:21

14

Q.

And the first prevention listed to avoid the hazard of a

14:21

15

reservoir blowout at the drill floor is "well control

14:21

16

procedures and training of drill crew in well control";

14:21

17

correct?

14:21

18

A.

That's what the document says.

14:21

19

Q.

The well control procedures and the training of the drill

14:21

20

crew in well control is a Transocean responsibility; correct?

14:21

21

A.

Yes.

14:21

22

Q.

The second prevention of a reservoir blowout is

14:21

23

"maintenance and testing of BOPs and other subsea and well

14:21

24

control equipment"; correct?

14:21

25

A.

"Reservoir blowout (at drill floor),"

"Major

Multiple personnel injuries and/or

Major structural damage and possible loss of

Do you see that?

That's what the document say also.


OFFICIAL TRANSCRIPT

4717
STEVEN NEWMAN - CROSS

14:21

Q.

Maintenance and testing of BOPs and other subsea and well

14:21

control equipment, that's a Transocean responsibility; correct?

14:21

A.

Yes.

14:21

Q.

The third prevention of a reservoir blowout at the drill

14:21

floor is "instrumentation and indication of well status";

14:21

correct?

14:21

A.

That's what the document says.

14:21

Q.

And that's referring to the HITEC system, or it could be,

14:21

in the olden days, just more rotary-type gauges --

14:22

10

A.

The geolograph.

14:22

11

Q.

Literally the gauges, the computer screens, the data, the

14:22

12

things that are used by people to understand what's going on in

14:22

13

the well; correct?

14:22

14

A.

I think that's what that would refer to, yes.

14:22

15

Q.

And instrumentation and indication of well status, that's

14:22

16

a Transocean responsibility; correct?

14:22

17

A.

14:22

18

status, in addition to other companies out there doing that as

14:22

19

well.

14:22

20

Q.

14:22

21

the well are the drillers; correct?

14:22

22

A.

Correct.

14:22

23

Q.

And the driller works in the driller's cabin or driller's

14:22

24

shack or doghouse; correct?

14:22

25

A.

We do have instrumentation and indication of the well

But the person with the primary responsibility to watch

Yeah, that what we call it.


OFFICIAL TRANSCRIPT

4718
STEVEN NEWMAN - CROSS

14:22

Q.

The epicenter of instrumentation and the indication of

14:22

well status is that doghouse or driller's shack or driller's

14:22

cabin; correct?

14:22

is --

14:22

A.

14:22

indication of well status.

14:22

Q.

14:22

floor is "hydrocarbon combustible gas detection system";

14:23

correct?

14:23

10

A.

That's what the document says.

14:23

11

Q.

And that detection system on the Horizon, that's a

14:23

12

Transocean responsibility; correct?

14:23

13

A.

14:23

14

is Transocean's system, yes.

14:23

15

Q.

14:23

16

drill floor is "redundant BOP controls"; correct?

14:23

17

A.

That's what the document says.

14:23

18

Q.

And we've already agreed that the BOP controls are a

14:23

19

Transocean responsibility?

14:23

20

A.

Yes.

14:23

21

Q.

Those preventions that we've just listed, the five

14:23

22

preventions of a reservoir blowout at the drill floor, those

14:23

23

are the same types of preventions you would expect to see,

14:23

24

frankly, on any of your rigs with respect to this risk;

14:23

25

correct?

Yes.

That's where the bulk of that information

The driller has access to the instrumentation and

The fourth prevention for a reservoir blowout at the drill

The system that was installed permanently on the Horizon

And the fifth prevention of a reservoir blowout at the

OFFICIAL TRANSCRIPT

4719
STEVEN NEWMAN - CROSS

14:23

A.

Yes.

14:23

Q.

Those are industry standard preventions for reservoir

14:23

blowouts; correct?

14:23

A.

Yes.

14:23

Q.

Then with respect to mitigations, do you see, as listed

14:23

there in the column Emergency Response Procedures, "ability to

14:23

move off station; firefighting capabilities; ability to

14:23

evacuate the rig; availability of medical treatment, including

14:23

medivac; redundant BOP controls; passive fire protection in

14:24

10

highly populated areas of vessel; and EX-rated equipment to

14:24

11

prevent ignition of blowout"?

14:24

12

14:24

13

primarily Transocean responsibilities; correct?

14:24

14

A.

No.

14:24

15

Q.

Which are not?

14:24

16

A.

Availability of medical treatment, including medivac.

14:24

17

Typically, the medivac element of it would be provided by the

14:24

18

customer.

14:24

19

Q.

14:24

20

Transocean responsibilities?

14:24

21

A.

Yes.

14:24

22

Q.

Again, are those standard mitigations in the industry for

14:24

23

this risk?

14:24

24

A.

Yes.

14:24

25

Q.

Okay.

All of those mitigations are Transocean -- are

Excluding the medivac, are the rest of the mitigations

Generally standard, yes.


Mr. Cunningham showed you a similar page for gas in
OFFICIAL TRANSCRIPT

4720
STEVEN NEWMAN - CROSS

14:24

the riser.

14:24

14:24

BY MR. REGAN:

14:24

Q.

14:24

failure.

14:24

A.

I do.

14:24

Q.

And the prevention -- it indicates consequences.

14:24

prevention is testing, inspection, and maintenance; correct?

14:24

A.

That's what the document says.

14:24

10

Q.

Also, failure of hydraulic supply.

14:25

11

A.

I do.

14:25

12

Q.

The same preventions; correct?

14:25

13

A.

That's what the document says.

14:25

14

Q.

And those testing, inspections, and maintenance, again,

14:25

15

would be led by Transocean; correct?

14:25

16

A.

Yes.

14:25

17

Q.

All right.

14:25

18

chain of command on the Deepwater Horizon.

14:25

19

topics.

14:25

20

14:25

21

control or authority between the OIM and the master.

14:25

22

are you able to tell us, Mr. Newman, with respect to that chain

14:25

23

of command, when authority was transitioned from the OIM to the

14:25

24

master?

14:25

25

A.

MR. REGAN:

I'd like to turn to 2187.212.1.

There's also identified -- hazards of BOP component


Do you see that?

And the

Do you see that?

With respect to -- I'll ask you about the


I'm going to change

Okay?
We heard some testimony about the transition of
Do you --

Well, under the statutory framework, the master always,


OFFICIAL TRANSCRIPT

4721
STEVEN NEWMAN - CROSS

14:25

always has overriding authority, particularly in the event of

14:25

an emergency, such as what occurred.

14:25

Q.

14:25

that -- of the handover?

14:25

A.

When the emergency response team musters on the bridge.

14:26

Q.

So visually seeing the muster would then be the evidence

14:26

that there had been a transition from a drilling issue of the

14:26

OIM to the master -- from a maritime issue to the master?

14:26

A.

14:26

10

center, the captain would understand that he has overriding

14:26

11

authority.

14:26

12

Q.

14:26

13

sorry -- 5643.

14:26

14

you recognize this?

14:26

15

A.

Yes.

14:26

16

Q.

And it was something that you authorized; correct?

14:26

17

A.

Yes.

14:26

18

Q.

It was in connection with a merger that had taken place

14:26

19

in -- earlier in 2007; correct?

14:27

20

A.

The merger took place at the end of November 2007.

14:27

21

Q.

Okay.

14:27

22

entity would operate on day one going forward; correct?

14:27

23

A.

Yes.

14:27

24

Q.

Okay.

14:27

25

document; is that right?

Okay.

And what constitutes an emergency for purposes of

Well, as individuals gathered in the emergency response

Let me put up TREX-5643.

This is a November 20th, 2007 --

This is a November 20th, 2007 memorandum.

Do

So it was preparations for how the new combined

Again, you were one of the approvers of this

OFFICIAL TRANSCRIPT

4722
STEVEN NEWMAN - CROSS

14:27

14:27

14:27

page, Diane, I think we might have Mr. Newman's name.

14:27

BY MR. REGAN:

14:27

Q.

Do you see your name there as an approver?

14:27

A.

Yes.

14:27

14:27

BY MR. REGAN:

14:27

Q.

14:27

10

command, "There will be no changes to the current chain of

14:27

11

command and rig organization on Transocean or GlobalSantaFe

14:27

12

rigs on Day 1"?

14:27

13

14:27

14

manager will remain overall responsible for the health, safety,

14:27

15

and welfare of all persons and all activities conducted

14:27

16

on board their respective rig.

14:27

17

obligated to take whatever actions he considers necessary to

14:27

18

prevent injury, loss of life, damage to equipment/structure,

14:28

19

and/or loss of rig and well operation integrity."

14:28

20

14:28

21

A.

Yes, you did.

14:28

22

Q.

And was that statement true when you approved the

14:28

23

document?

14:28

24

A.

Yes.

14:28

25

Q.

Well control.

A.

I recall seeing it, yes.


MR. REGAN:

MR. REGAN:

If you just go down to the bottom of the

If we can go to 5643.4.1.

Now, in this memorandum, did you write, for rig chain of

And as we've highlighted:

"The offshore installation

The OIM is authorized and

Do I read that correctly?

To you, well control, in terms of


OFFICIAL TRANSCRIPT

4723
STEVEN NEWMAN - CROSS

14:28

maintaining well control, requires awareness and vigilance,

14:28

identification and recognition of an indication of a loss of

14:28

well control, and the requirement to then take prompt and

14:28

appropriate action; is that right?

14:28

A.

Yes.

14:28

Q.

Now, kicks -- I think you might have been asked this, but

14:28

kicks themselves in an exploration well are not a surprising

14:28

event, are they?

14:28

A.

They're not uncommon.

14:28

10

Q.

Right.

14:28

11

they're going to happen, but you prepare for them because you

14:28

12

know it's a possibility; correct?

14:28

13

A.

14:28

14

prompt, appropriate action, the awareness part is to remain

14:29

15

vigilant.

14:29

16

Q.

14:29

17

gas wells, regardless of what the plan is, regardless of what

14:29

18

the prognosis is, regardless of what the engineering is,

14:29

19

there's always one -- or in this case two people whose job it

14:29

20

is to, in essence, assume everything's going to go wrong, we're

14:29

21

going to have a situation that we're going to need to respond

14:29

22

to quickly.

14:29

23

A.

14:29

24

a need for that high level of awareness, understanding, and

14:29

25

recognition and the prompt, appropriate action.

They're unanticipated, meaning you don't know when

Under this framework of awareness, recognition, and

Right.

And in this business in drilling deepwater oil and

Is that right?

I don't think that's unique to deepwater.

OFFICIAL TRANSCRIPT

I think there's

4724
STEVEN NEWMAN - CROSS

14:29

Q.

That's because drilling wells is a dynamic process.

14:29

you have to be ready for something that's unanticipated.

14:29

That's why drillers constantly monitor the well; right?

14:29

A.

Yes.

14:29

Q.

Loss returns, loss return events, in your experience,

14:29

Mr. Newman, are those rare things in drilling deepwater wells?

14:29

A.

No, they're not uncommon.

14:30

Q.

Use of loss circulation material, is that a rare thing to

14:30

happen?

14:30

10

A.

That's the general approach to curing loss returns.

14:30

11

Q.

With respect to the well control manual itself --

14:30

12

14:30

13

BY MR. REGAN:

14:30

14

Q.

14:30

15

10 minutes ago, we see the well control handbook is Level 1B;

14:30

16

correct?

14:30

17

A.

Yes.

14:30

18

Q.

It applies wordwide; correct?

14:30

19

A.

Yes, it does.

14:30

20

Q.

The Horizon didn't have its own well control manual, and

14:30

21

the Nautilus has its own, and the DD3 has its own.

14:30

22

control handbook for Transocean is a global policy; correct?

14:30

23

A.

It is.

14:30

24

Q.

Irrespective of the operator, irrespective of the

14:30

25

location; correct?

MR. REGAN:

If we could pull up D-4595.1.

It's

D-4595.1.

In this hierarchy of documents that we talked about

OFFICIAL TRANSCRIPT

The well

4725
STEVEN NEWMAN - CROSS

14:30

A.

That's correct.

14:30

Q.

Now, with respect to -- the judge has heard a fair amount

14:30

about this.

14:31

person with responsibility on Transocean rigs to constantly

14:31

monitor the well and shut it in if they believe it's flowing is

14:31

the driller; correct?

14:31

A.

Our driller has that responsibility, yes.

14:31

Q.

And the driller has the responsibility to shut it in if he

14:31

has any indication that something's happening that may not be

14:31

10

right?

14:31

11

A.

I think that's part of the prompt, appropriate action.

14:31

12

Q.

And it's the policy of Transocean that the driller or the

14:31

13

person doing the driller's function has to shut the well in as

14:31

14

quickly as possible if a kick is detected or suspected;

14:31

15

correct?

14:31

16

A.

14:31

17

action.

14:31

18

Q.

14:31

19

tours, that's true on all of your rigs; correct?

14:31

20

A.

Yes.

14:31

21

Q.

And when you were in Brazil on the Petrobras work, and the

14:31

22

rig manager drilling wells for Texaco on the TO97, the driller

14:31

23

was the person with the responsibility to watch the well;

14:32

24

correct?

14:32

25

A.

Yes.

But with respect to monitoring the well, the

I think that's part of the prompt, appropriate

And when you visit the five or six Transocean rigs in your

Trinidad.
OFFICIAL TRANSCRIPT

4726
STEVEN NEWMAN - CROSS

14:32

Q.

Oh, Trinidad?

14:32

A.

Yes, yes.

14:32

Q.

And we saw your chart of the -- I think it was D-6730,

14:32

D-6730.

14:32

14:32

A.

That's what the chart says, yes.

14:32

Q.

On every single one of those wells, who had responsibility

14:32

to watch the well?

14:32

A.

From Transocean's perspective, the driller does.

14:32

10

Q.

And that idea, well monitoring, that's something that's

14:32

11

totally under the control of Transocean; correct?

14:32

12

A.

14:32

13

that responsibility.

14:32

14

that do that same thing.

14:33

15

Q.

14:33

16

driller has to understand.

14:33

17

monitoring function, is it contingent in any way on the type of

14:33

18

cement that's being used in a well, this well-monitoring

14:33

19

responsibility?

14:33

20

A.

No.

14:33

21

Q.

Is it contingent in any way on the type of casing that's

14:33

22

being run in the hole?

14:33

23

A.

No.

14:33

24

Q.

Is the well-monitoring responsibility of the driller

14:33

25

contingent on the jewelry that's being used on the casing or

6,795 wells around the world, 2005 to 2009; correct?

We have an individual, the driller, who is tasked with

Okay.

The customer has a number of other folks

You used a phrase on your direct about things a


With respect to this well

OFFICIAL TRANSCRIPT

4727
STEVEN NEWMAN - CROSS

14:33

centralizers or liner or long string or any of those things?

14:33

A.

No.

14:33

Q.

Is it contingent in any way on the pore pressure frac

14:33

gradient analysis or assessments?

14:33

A.

No.

14:33

Q.

Is it contingent on any stage in the operation in between

14:33

the time a BOP goes on the well and the time a BOP comes off?

14:33

A.

14:33

14:34

10

BY MR. REGAN:

14:34

11

Q.

14:34

12

is not a document that you would have received, but I'd just

14:34

13

like to use it for my question.

14:34

14

Exhibit 7651.

14:34

15

14:34

16

Steve Woelfel?

14:34

17

A.

I do.

14:34

18

Q.

Do you know John Keeton and Dan Reudelhuber, who received

14:34

19

it?

14:34

20

A.

I do.

14:34

21

Q.

And Mr. Woelfel wrote:

14:34

22

control - one of more important aspects of our business and one

14:34

23

that we are 100 percent responsible/accountable for when the

14:34

24

sh*t hits the fan.

14:34

25

that the toolpusher, OIM, you, me, Jurgen [sic], and on up to

No.
MR. REGAN:

Let me pull up 7651.1.3.

This is a document -- in fairness to you, Mr. Newman, this

This is a document from 2004,

Do you know the gentleman that wrote this document,

"Core Drilling Competence.

Well

Do the drillers/ADs know in their hearts

OFFICIAL TRANSCRIPT

4728
STEVEN NEWMAN - CROSS

14:34

Bob Long expects/100 percent supports them to SI if there are

14:34

any questions/doubts?

14:35

the company man wants to do."

14:35

14:35

A.

Yes.

14:35

Q.

And Bob Long is the CEO of Transocean in 2004; correct?

14:35

A.

Yes.

14:35

Q.

You are the CEO of Transocean today and you were in April

14:35

of 2010; correct?

14:35

10

A.

Yes.

14:35

11

Q.

Do you expect 100 percent support for drillers and ADs to

14:35

12

shut in if there are any questions or doubts?

14:35

13

A.

Absolutely.

14:35

14

Q.

I'd like to turn now to TREX-4255.

14:35

15

questions about a summary document that Transocean had put

14:35

16

together.

14:35

17

14:35

18

the third.

14:35

19

BY MR. REGAN:

14:35

20

Q.

14:35

21

14:35

22

A.

Yes.

14:35

23

Q.

And I'm going to try not to repeat some of the questions

14:35

24

that were asked before.

14:35

25

Not an area where we wait to see what

Do you see what I just read?

MR. REGAN:

You were asked some

Go to the second page there.

Maybe it's

I apologize.

It's the summary of well control events from 2005 to 2009.


Do you see that?

MR. REGAN:

But if I could pull up D-4418.1, which I


OFFICIAL TRANSCRIPT

4729
STEVEN NEWMAN - CROSS

14:36

guess is a demonstrative taken out of this exhibit.

14:36

BY MR. REGAN:

14:36

Q.

14:36

5,000 wells.

14:36

that?

14:36

A.

Yes.

14:36

Q.

329 kicks; correct?

14:36

A.

That's what the document says, yes.

14:36

Q.

142 that were ballooning, and you explained to the Court

14:36

10

what "ballooning" is; right?

14:36

11

A.

Yes.

14:36

12

Q.

Okay.

14:36

13

correct?

14:36

14

A.

14:36

15

14:36

16

BY MR. REGAN:

14:36

17

Q.

14:36

18

this earlier.

14:36

19

you had a demonstrative up.

14:37

20

kicks below and above 20 barrels.

14:37

21

A.

Yes.

14:37

22

Q.

And Transocean refers to above 20 barrels as a red zone

14:37

23

kick; correct?

14:37

24

A.

Yeah.

14:37

25

Q.

And then there's a reference by Mr. Cunningham to six rigs

Again, statistically, from 2005 to 2009, almost


There were 556 well control events.

Do you see

And 306 of those kicks were on exploration wells;

That's what the document says.


MR. REGAN:

If we could turn to 4255.20.3.

Just briefly, this is -- talks about -- you were shown


Percentage 84 percent and 14 percent, I think
It talked about the difference of
Do you recall that?

OFFICIAL TRANSCRIPT

4730
STEVEN NEWMAN - CROSS

14:37

in 2009 having unloaded their drilling risers.

Do you recall

14:37

those questions?

14:37

A.

I do.

14:37

Q.

Those six rigs, the 711, the M. G. Hulme, Jr., the DAS,

14:37

the DD1, the 702, and the ATN, those were not rigs drilling

14:37

wells for BP, were they?

14:37

A.

14:37

DD1 works for BHP, the Hulme works for E&I.

14:37

Shell.

14:37

10

14:37

11

14:37

12

BY MR. REGAN:

14:37

13

Q.

14:38

14

representation from 2005 to 2009 of kick events in the red

14:38

15

zone; correct?

14:38

16

A.

That's what the document says.

14:38

17

Q.

Correct.

14:38

18

on a Transocean rig in that four-year period, it would be on

14:38

19

this chart.

14:38

20

A.

That's what the document says, yes.

14:38

21

Q.

And it represents the year, the rig, the client, and then

14:38

22

the size of the kick; right?

14:38

23

A.

Yes.

14:38

24

Q.

And in that four-year period, Mr. Newman, there was not a

14:38

25

single red zone kick on a Transocean rig drilling a well for

711 works for Shell, the Americas works for Statoil, the
702 works for

The Actinia was not working for BP, but I can't

remember who it was working for.


MR. REGAN:

I'd like to now turn to 4255.44.3.

This is from the same document, and this is a graphical

So if there was a kick greater than 20 barrels

That's what it represents; correct?

OFFICIAL TRANSCRIPT

4731
STEVEN NEWMAN - CROSS

14:38

BP; correct?

14:38

A.

That's what the document says.

14:38

Q.

We have got Shell, Petrobras, Total, TTT, RIL, which is

14:38

Reliance, Anadarko, the oil -- the Chinese company, CNOOC.

14:39

Those are major operators; correct?

14:39

A.

Some of them are, yes.

14:39

Q.

But during that time period, BP was one of Transocean's

14:39

largest clients, was it not?

14:39

A.

Yes.

14:39

10

Q.

And as one of its largest clients, using a large

14:39

11

proportion of Transocean rigs relative to its competitors, not

14:39

12

a single red zone kick; right?

14:39

13

A.

Not according to this chart.

14:39

14

Q.

Now, you also tracked things called "precautionary

14:39

15

shut-ins."

14:39

16

earlier today.

14:39

17

A.

14:39

18

14:39

19

BY MR. REGAN:

14:39

20

Q.

14:39

21

this would be all events, red zone or otherwise; is that

14:39

22

correct?

14:39

23

A.

I think so, yes.

14:40

24

Q.

And we do see BP on this chart, again, the same four-year

14:40

25

period.

I think you mentioned that briefly to the Court


Do you recall that?

Yes.
MR. REGAN:

Let's go to 4255.62.4.

This is a summary of well control events by client.

They're listed right here in the fifth line?


OFFICIAL TRANSCRIPT

So

4732
STEVEN NEWMAN - CROSS

14:40

A.

Yes.

14:40

Q.

So over that four-year period, 17 kicks, 10 loss/gain

14:40

events.

14:40

A.

Yes.

14:40

Q.

Which client of Transocean led the way in having the

14:40

highest number of precautionary shut-ins in that four-year

14:40

period?

14:40

A.

14:40

shut-ins conducted on BP operations than any other customer.

14:40

10

Q.

14:40

11

something, I think you said, they shut it in, but it turns out

14:40

12

it was a false alarm, they were being extra cautious?

14:40

13

A.

14:40

14

precautionary shut-in.

14:40

15

Q.

14:40

16

over the four-year period of 2005 to 2009, as one of the

14:40

17

largest clients of Transocean, BP wells, BP rigs working with

14:41

18

TO, not a single kick over 20 barrels, with the highest number

14:41

19

of precautionary shut-ins; correct?

14:41

20

A.

I think that's what the data says.

14:41

21

Q.

And that data is consistent with safe operation, isn't it?

14:41

22

A.

It's an element of safe operations, yes.

14:41

23

Q.

In this same document there was a phrase, a section shown

14:41

24

to you with respect to the riser unloading events about --

14:41

25

And over here we have precautionary shut-ins; right?

According to this document, there were more precautionary

And a precautionary shut-in is where someone sees

Yes.

Generally, that's an accurate description of a

And so if we put this chart together with the last one,

MR. REGAN:

Let's go to 4255.21.3.
OFFICIAL TRANSCRIPT

4733
STEVEN NEWMAN - CROSS

14:41

BY MR. REGAN:

14:41

Q.

14:41

it again.

14:41

14:41

14:41

14:41

A.

That's what the document says.

14:41

Q.

Okay.

14:41

to avoid a riser unloading event, was there?

14:42

10

A.

I don't think so, no.

14:42

11

Q.

The same would be true with respect to April 20th.

14:42

12

riser unloading event that happened on April 20th could have

14:42

13

been avoided "through the application of fundamental well

14:42

14

control practices, such as treating every positive indicator as

14:42

15

a kick, shutting in quickly, and taking returns through the

14:42

16

choke whenever in any doubt whatsoever"; correct?

14:42

17

A.

14:42

18

recognition, and prompt action.

14:42

19

Q.

14:42

20

riser unloading event that took place on April 20th could have

14:42

21

been avoided through the application of fundamental well

14:42

22

control practices?

14:42

23

A.

14:42

24

there's recognition and prompt appropriate action.

14:42

25

me, is fundamental well control.

Mr. Cunningham asked you about this.

I just want to ask

This is about the riser unloading event.


It says:

"These can be avoided through the

application of fundamental well control practices."


Do you see that?

There was not a need for a new policy or procedure

The

I think that falls into the category of vigilance,

But you agree with me that the events of April 20th -- the

I characterize fundamental well control practices when

OFFICIAL TRANSCRIPT

That, for

4734
STEVEN NEWMAN - CROSS

14:42

Q.

TREX-48093.1.1.

You were asked about M.G. Hulme, Jr.

14:42

just wanted to ask you about one document that came out of that

14:43

investigation from Mr. Hand.

14:43

A.

Mr. Hand worked in your well construction group.

14:43

Q.

And here do you see, with respect to the M.G. Hulme --

14:43

have you seen this document before, Mr. Newman?

14:43

A.

I think so, in the context of all the litigation.

14:43

Q.

Just briefly, he says:

14:43

problems on the MGH were:

14:43

10

14:43

11

14:43

12

14:43

13

14:43

14

14:43

15

procedures to shut in would have resulted in a standard well

14:43

16

control operation."

14:43

17

14:43

18

A.

Yes.

14:43

19

Q.

And is that the same thing we just talked about, that

14:43

20

again, the idea of recognizing a kick when the pump's off,

14:43

21

there are standard well control procedures that are already in

14:43

22

place that are designed to avoid that from happening?

14:44

23

A.

Yes.

14:44

24

Q.

Do you know if -- the investigations done on the

14:44

25

M.G. Hulme, Jr. or the Sedco 711 incident, do you know if those

Who is Mr. Hand?

Do you know?

"Unless I'm missing something, the

"They expected to drill into a gas zone and did not


pick up any indicators, and so did not flow-check.
"Number two, took a kick when the pumps were off and
didn't notice it.
"If they had recognized the kick, then following the

Do you see that?

OFFICIAL TRANSCRIPT

4735
STEVEN NEWMAN - CROSS

14:44

were ever provided to BP?

14:44

A.

I don't.

14:44

Q.

With respect to Sedco 711, just a few questions.

14:44

agree that in that incident in December of 2009, the BOP was

14:44

activated and worked effectively to provide a barrier and stop

14:44

the flow of oil?

14:44

A.

Yes.

14:44

Q.

Do you agree that if the BOP there had not shut in the

14:44

well, that for the Sedco 711 there was a possibility for a

14:44

10

blowout that would result in potential for escalation of that

14:44

11

incident?

14:44

12

A.

Yeah.

14:44

13

Q.

You, Mr. Newman, have not done any assessments about the

14:45

14

level of collaboration or communication that occurred between

14:45

15

BP and Transocean on the Deepwater Horizon, have you?

14:45

16

A.

I have not, no.

14:45

17

Q.

So you're readily familiar with the generic process that

14:45

18

happens on a rig, the idea of twice daily meetings, pre-job

14:45

19

meeting, etc.; correct?

14:45

20

A.

Yeah.

14:45

21

Q.

But as to the content of any such meeting, what was

14:45

22

discussed by whom, you're not the witness for that; correct?

14:45

23

A.

No.

14:45

24

Q.

With respect to any pre-spud analysis that was done by

14:45

25

Transocean on the Macondo well, you would not be the witness

Do you

I agree with that hypothetical statement, yes.

That's a standard approach around the world.

OFFICIAL TRANSCRIPT

4736
STEVEN NEWMAN - CROSS

14:45

for that; correct?

14:45

A.

No.

14:45

Q.

You are aware that Transocean does have policies that

14:45

require pre-spud meetings?

14:45

A.

Yes.

14:45

Q.

With respect to any pre-spud checklist, again, that would

14:45

not be you; correct?

14:45

A.

Correct.

14:45

Q.

The well advisor program, are you familiar with that?

14:45

10

A.

Yes.

14:46

11

advisor program.

14:46

12

Q.

14:46

13

14:46

14

Transocean well advisor program was used by the Deepwater

14:46

15

Horizon to review the well as it was being drilled, do you have

14:46

16

any firsthand knowledge as to the use of that well advisor

14:46

17

program?

14:46

18

A.

No.

14:46

19

Q.

Do you know what the purpose of the well advisor program

14:46

20

is?

14:46

21

A.

14:46

22

program is to provide our people, who don't have a lot of

14:46

23

drilling/engineering experience, with a simplified approach to

14:46

24

identifying wells along sort of the continuum of complexity.

14:46

25

So well advisor will tell you whether this is a simple,

Sort of generically.

Yes, I know we have a well

I took that from the look you just gave me.


But again, with respect to whether or not the

Generally speaking, yeah.

The purpose of the well advisor

OFFICIAL TRANSCRIPT

4737
STEVEN NEWMAN - CROSS

14:46

straightforward well or a more challenging and complex well.

14:46

That's the purpose, is just to alert our people.

14:46

Q.

14:46

they understand the activities that are going to be taking

14:47

place on that well?

14:47

A.

14:47

said, well advisor is designed to alert our people when the

14:47

well they're preparing to drill for the customer is a little

14:47

bit more complex.

14:47

10

14:47

11

what you indicated as an objective.

14:47

12

Q.

14:47

13

that are used on rigs?

14:47

14

A.

Yes.

14:47

15

Q.

Forward plans?

14:47

16

A.

Generally, yes.

14:47

17

Q.

You have not looked at five-day planners, the forward

14:47

18

plans that were exchanged between Transocean and BP during the

14:47

19

drilling of the MC252 No. 1 well, have you?

14:47

20

A.

No.

14:47

21

Q.

You were asked some questions about the negative test, or

14:47

22

you discussed it, both generically and the concept in

14:48

23

connection with Transocean's criminal plea.

14:48

24

questions on that.

14:48

25

It's a way that the Transocean crew can make sure that

I'm not sure that's the purpose of well advisor.

As I

I think there are other mechanisms for accomplishing

You're familiar with five-day planners, daily planners

I just have a few

Again, just to confirm, Mr. Newman, you obviously


OFFICIAL TRANSCRIPT

4738
STEVEN NEWMAN - CROSS

14:48

were not on the Horizon on April 20th; correct?

14:48

A.

I was not.

14:48

Q.

You were not a witness to the activity that took place

14:48

during the negative test; correct?

14:48

A.

That is correct.

14:48

Q.

Do you understand that there are gentlemen who will be

14:48

testifying in this trial who were present and who did witness

14:48

those activities?

14:48

MR. BRIAN:

Objection, argumentative.

14:48

10

THE COURT:

Sustained.

14:48

11

BY MR. REGAN:

14:48

12

Q.

14:48

13

who were percipient witnesses of the negative tests as to what

14:48

14

took place?

14:48

15

A.

What was the term you used?

14:48

16

Q.

"Percipient," people that saw it, heard it, touched it,

14:48

17

tasted it --

14:48

18

A.

No, I was not there.

14:48

19

Q.

You did receive an e-mail on April 21st with respect to

14:48

20

the -- from Keelan Adamson; correct?

14:49

21

14:49

22

you received, Mr. Newman, on April 21st, around 1:00 in the

14:49

23

afternoon, 2010; correct?

14:49

24

A.

That's what the document says.

14:49

25

Q.

Okay.

Cumulative.

Would you defer, Mr. Newman, to the testimony of people

Do you defer to that?

Do you recall that?

Let me pull it up, 1472.1.3.

This is an e-mail that

And in this e-mail that was sent to you, you were


OFFICIAL TRANSCRIPT

4739
STEVEN NEWMAN - CROSS

14:49

advised by Mr. Adamson:

"We have spoken to Jimmy Harrell, OIM.

14:49

He advises that he was very aware of the rig operations.

14:49

had only spoken with TP, Randy Ezell, ten minutes before the

14:49

incident.

14:49

test.

14:49

riser over to water in preparation to set P & A plug."

14:49

14:49

A.

Yes.

14:49

Q.

You received that at about 1:00 in the afternoon the day

14:50

10

after the Horizon blew up; correct?

14:50

11

A.

14:50

12

afternoon Houston time or 1:00 in the afternoon Geneva time.

14:50

13

Q.

14:50

14

14:50

15

questions about Transocean's allocution.

14:50

16

No. is 63213.

14:50

17

you approved and recommended to be approved by Transocean;

14:50

18

correct?

14:50

19

A.

Yes.

14:50

20

Q.

And I just wanted to ask you a few questions.

14:50

21

14:50

22

negative test, I'd like to pull up 63213.13.1.

14:50

23

BY MR. REGAN:

14:50

24

Q.

14:50

25

duties, "Transocean and BP were required to monitor the well

He

They had conducted successful inflow test/pressure

No flow on the flow check.

They had turned the well and

Do you see that?

Yes.

To be clear, I don't know whether that's 1:00 in the

All right.

Well, we're familiar with that issue.

Lastly, with respect to -- you were asked some


I think the exhibit

Again, just to confirm, this is a document that

MR. REGAN:

With respect to the paragraphs on the

In the allocution, Transocean agreed that as part of its

OFFICIAL TRANSCRIPT

4740
STEVEN NEWMAN - CROSS

14:50

and take appropriate action during the negative test in

14:51

accordance with the standard of care applicable in the

14:51

deepwater oil exploration industry"; correct?

14:51

A.

14:51

14:51

BY MR. REGAN:

14:51

Q.

14:51

line Transocean agreed that "Transocean and BP observed

14:51

pressure buildup on the drill pipe multiple times.

14:51

10

commenced, but did not complete, investigation of the pressure

14:51

11

anomalies."

14:51

12

A.

14:51

13

14:51

14

BY MR. REGAN:

14:51

15

Q.

14:51

16

line says, "BP's well site leaders eventually instructed

14:51

17

defendant Transocean, and defendant Transocean agreed, to begin

14:51

18

monitoring the negative testing on the kill line instead of the

14:51

19

drill pipe"; correct?

14:51

20

A.

That's what the document says.

14:51

21

Q.

Next sentence says that "Both BP and defendant Transocean

14:51

22

continued to observe abnormal pressure on the drill pipe while

14:51

23

monitoring the kill line for flow"; correct?

14:51

24

A.

That's that the document says.

14:51

25

Q.

Transocean agreed that "Based on the lack of flow in the

That's what the document says.


MR. REGAN:

Go to .13.2.

You can read the whole paragraph.

But again, in the last

The crew

Correct?

That's what the document says.


MR. REGAN:

Go to .13.3.

I think you might have been shown this one, but the top

OFFICIAL TRANSCRIPT

4741
STEVEN NEWMAN - CROSS

14:51

kill line, the negative testing ultimately was deemed

14:52

successful, notwithstanding the continuing abnormal pressure on

14:52

the drill pipe"; correct?

14:52

A.

That's what the document says.

14:52

Q.

Transocean agreed that "BP and defendant Transocean did

14:52

not take further steps to investigate the source of the

14:52

abnormal drill pipe pressure, which was neither correctly

14:52

explained nor remediated"; correct?

14:52

A.

14:52

10

MR. BRIAN:

14:52

11

He misread the third sentence.

14:52

12

He said that Transocean agreed that it was deemed successful.

14:52

13

That's not what it states.

14:52

14

MR. REGAN:

I didn't mean to misread it.

14:52

15

MR. BRIAN:

It says:

14:52

16

the kill line, the negative testing ultimately was deemed

14:52

17

successful, notwithstanding the continued abnormal pressure on

14:52

18

the drill pipe."

14:52

19

BY MR. REGAN:

14:52

20

Q.

14:52

21

Mr. Brian just read, is it true that Transocean agreed in its

14:52

22

allocution to the sentence that Mr. Brian just read, which

14:52

23

says, "Based on the lack of flow in the kill line, the negative

14:52

24

testing ultimately was deemed successful, notwithstanding the

14:52

25

continued abnormal pressure on the drill pipe"?

That's what the document says.


Your Honor, I'm actually going to object.
I ask that that be read again.

"Based on the lack of flow in

It does not say that --

Let me clarify it.

With respect to the sentence that

OFFICIAL TRANSCRIPT

4742
STEVEN NEWMAN - CROSS

14:52

A.

We agreed with the document.

14:53

Q.

Thank you.

14:53

14:53

Transocean agreed with these provisions as well, that is, that

14:53

"Transocean's conduct violated its duty to exercise well

14:53

control in accordance with the standard of care applicable in

14:53

the deepwater oil exploration industry"; correct?

14:53

A.

That's what the document says.

14:53

Q.

And Transocean agreed to that; correct?

14:53

10

A.

We did agree to the document, yes.

14:53

11

Q.

And you also agreed to paragraph 15, which reads,

14:53

12

"Transocean's negligent conduct, together with the negligent

14:53

13

conduct of others, was a proximate cause of the blowout and the

14:53

14

discharge of certain quantities of oil and natural gas from the

14:53

15

Macondo well into the Gulf of Mexico"; correct?

14:53

16

A.

That's what the document says.

14:53

17

Q.

Now, the blowout that took place, after the blowout there

14:53

18

was then gas in the rig, fire, and explosion; correct?

14:53

19

A.

Yeah.

14:53

20

Q.

And after the fire and explosion, the rig burned for two

14:54

21

days; correct?

14:54

22

A.

For about two days, yeah.

14:54

23

Q.

And then it sank on April 22nd; correct?

14:54

24

A.

Yes.

14:54

25

And with respect to 63213.14.1, paragraphs 14 and 15,

MR. REGAN:

Thank you, Mr. Newman.


OFFICIAL TRANSCRIPT

Those are the

4743
STEVEN NEWMAN - CROSS

14:54

questions I have.

14:54

THE COURT:

Cameron?

14:54

MR. JONES:

Cameron has no questions of Mr. Newman.

14:54

THE COURT:

M-I.

14:54

MR. TANNER:

14:54

THE COURT:

14:54

14:54

BY MR. BRIAN:

14:54

Q.

14:54

10

14:54

11

be very brief.

14:54

12

BY MR. BRIAN:

14:54

13

Q.

14:54

14

Mr. Cunningham about the 2009 well control event report.

14:55

15

you have that document in mind?

14:55

16

A.

Yes.

14:55

17

Q.

And specifically about something called a "riser unloading

14:55

18

event."

14:55

19

A.

Yes.

14:55

20

Q.

What is a riser unloading event?

14:55

21

A.

Simply speaking, a riser unloading event is when the

14:55

22

influx -- it only happens on -- first of all, it only happens

14:55

23

on a floating drilling operation when you have a riser above

14:55

24

the BOP, between the BOP and the rig.

14:55

25

event happens when the influx is allowed to migrate above the

No questions, Your Honor.


Back to Transocean.
REDIRECT EXAMINATION

Good afternoon, Mr. Newman.


MR. BRIAN:

Good afternoon, Your Honor.

I'm going to

You were asked this morning by myself and then by


Do

Do you have that in mind?

And a riser unloading

OFFICIAL TRANSCRIPT

4744
STEVE NEWMAN - REDIRECT

14:55

BOP.

So the driller shuts the BOP in but doesn't catch all of

14:55

the influx that can be above the BOP.

14:55

14:55

riser, it expands as it migrates; and so you can have a

14:55

situation with a riser unloading event where you have some

14:55

amount of hydrocarbons on the rig floor or exiting through the

14:56

diverter lines.

14:56

Q.

Is a riser unloading event the same as a blowout?

14:56

A.

No.

14:56

10

Q.

How are they different?

14:56

11

A.

A blowout is uncontrolled flow from the reservoir.

14:56

12

means the well is not closed in.

14:56

13

14:56

14

but you didn't catch it quick enough, and so you have influx in

14:56

15

the riser that unloads the riser.

14:56

16

riser.

14:56

17

Q.

14:56

18

Mr. Cunningham, about the M.G. Hulme, Jr. incident.

14:56

19

have that in mind?

14:56

20

A.

Yes.

14:56

21

Q.

And you were asked about changes in the well control

14:56

22

manual that occurred as a result of that.

14:56

23

mind?

14:56

24

A.

14:56

25

And then as that influx continues to migrate up the

That

A riser unloading event means the well is closed in

It relates solely to the

You were asked this morning, both by myself and

Do you have that in

Yes.
MR. BRIAN:

Let's pull up TREX-5650, 5650.


OFFICIAL TRANSCRIPT

Do you

4745
STEVE NEWMAN - REDIRECT

14:56

BY MR. BRIAN:

14:56

Q.

Is that the first page of the M.G. Hulme incident report?

14:56

A.

Yes.

14:56

Q.

And do you recall that that incident took place on --

14:56

occurred on February 20th, 2009?

14:57

A.

14:57

can certainly say that that's what the document says.

14:57

remember that the incident took place on February --

14:57

Q.

14:57

10

14:57

11

BY MR. BRIAN:

14:57

12

Q.

14:57

13

manual, is it not?

14:57

14

A.

Yes.

14:57

15

Q.

And can you see down in the corner, right there, the date

14:57

16

of that?

14:57

17

A.

Yes.

14:57

18

Q.

That's March -- is that March 31st, 2008?

14:57

19

A.

Yes, that's what the document says.

14:57

20

14:57

21

BY MR. BRIAN:

14:57

22

Q.

14:57

23

manual; correct?

14:57

24

A.

Yes.

14:57

25

Q.

And that date is what?

If you -- if you turn to the page where that date is, I


I don't

The document will be in evidence.


MR. BRIAN:

Let's pull up TREX-52545.

Now, that's a portion of the Transocean well control

MR. BRIAN:

Now, let's pull up TREX-52546.

This appears to be a later revision of the well control

OFFICIAL TRANSCRIPT

4746
STEVE NEWMAN - REDIRECT

14:57

A.

March 31st, 2009.

14:57

Q.

Prior to the April 20th, 2010 incident; correct?

14:58

A.

Yes.

14:58

14:58

BY MR. BRIAN:

14:58

Q.

14:58

compares the first two pages of two versions of the well

14:58

control manual we just looked at, does it not?

14:58

A.

14:58

10

14:58

11

BY MR. BRIAN:

14:58

12

Q.

Do you see that?

14:58

13

A.

Yes.

14:58

14

Q.

And the language "Once the BOP is closed, monitor the

14:58

15

riser for flow and be prepared to divert if necessary," was

14:58

16

that added to the well control manual on or about March 31st,

14:58

17

2009?

14:58

18

A.

Yes.

14:58

19

Q.

And that's as a result of incident of the MG Hulme, is it

14:59

20

not?

14:59

21

A.

Yes.

14:59

22

Q.

About a month or so after the incident took place?

14:59

23

A.

Yes.

14:59

24

MR. BRIAN:

So let's pull up D-6726.1.

This is a demonstrative that we prepared.

This simply

Yes.
MR. BRIAN:

Let's pull up D-6726.2.

According to the revisions, yes.

MR. BRIAN:

Let's go to D-6726.3.

25
OFFICIAL TRANSCRIPT

4747
STEVE NEWMAN - REDIRECT

14:59

BY MR. BRIAN:

14:59

Q.

14:59

Section 8, Subsection 4, Items 9 and 9.3," that language was

14:59

also added to the manual on or about March 31st, 2009, was it

14:59

not?

14:59

A.

14:59

"flow."

14:59

Q.

14:59

14:59

10

BY MR. BRIAN:

14:59

11

Q.

14:59

12

be prepared to divert if necessary."

14:59

13

14:59

14

of approximately March 31st, 2009?

14:59

15

A.

That's what the document says.

14:59

16

Q.

Now, I want to pull up --

14:59

17

14:59

18

TREX-52658.1.

15:00

19

BY MR. BRIAN:

15:00

20

Q.

15:00

21

Bridge Crew Members Aboard the Deepwater Horizon on April 20th,

15:00

22

2010."

15:00

23

15:00

24

That language -- "monitor the riser for flowing, refer to

Yes.

I think you said "flowing."

The document says

I'm sorry.
MR. BRIAN:

This language:

Now, let's pull up D-6726.4.

"Subsea BOPs.

Monitor riser for flow and

Was that language added to the well control manual as

MR. BRIAN:

Which is in evidence, Your Honor --

This is a summary chart, "Training of Well Control and

MR. BRIAN:

Can we -- Mr. Nickels, can you pull up,

first, page 4 of the TREX-52658.4, Miles Ezell.

25
OFFICIAL TRANSCRIPT

4748
STEVE NEWMAN - REDIRECT

15:00

BY MR. BRIAN:

15:00

Q.

15:00

training on December 4th, 2009?

15:00

A.

That's what the document says.

15:00

Q.

And is it the practice of Transocean to train pursuant to

15:00

the manual, as revised, that's in effect as of the date of the

15:00

training?

15:00

A.

Yes.

15:00

Q.

So if the manual was revised in March of 2009, would that

15:01

10

revised version have been the basis for the training that

15:01

11

Mr. Ezell received on December 4th, 2009?

15:01

12

A.

Yes.

15:01

13

Q.

Let's now turn to TREX-52658.12.

15:01

14

training for Dewey Revette.

15:01

15

on April 20th, 2010, wasn't he, sir?

15:01

16

A.

Yes.

15:01

17

Q.

And he received IADC WellCAP supervisor training on

15:01

18

February 12th, 2010.

15:01

19

A.

Yes.

15:01

20

Q.

And again, that would have been pursuant to the manual as

15:01

21

revised in March of 2009; correct?

15:01

22

A.

Yes.

15:01

23

Q.

Now, let's turn to TREX-52658.16, Stephen Curtis.

15:02

24

the assistant driller that evening on the Deepwater Horizon,

15:02

25

was he not?

Do you see where he received IADC WellCAP supervisor


Do you see that?

This summarizes the

He was the driller, unfortunately,

Do you see that?

OFFICIAL TRANSCRIPT

He was

4749
STEVE NEWMAN - REDIRECT

15:02

A.

Yes.

15:02

Q.

And according to this document, he received IADC WellCAP

15:02

fundamental training on October 2nd, 2009, did he not?

15:02

A.

That's what the document says.

15:02

Q.

Again, with the same well control manual, as amended and

15:02

revised to add that language that came in as a result of the

15:02

MG Hulme incident; correct?

15:02

A.

Yes.

15:02

Q.

Let me turn to another subject quickly.

15:02

10

15:02

11

BY MR. BRIAN:

15:02

12

Q.

15:02

13

shown this by Mr. Cunningham, perceived weaknesses.

15:02

14

"Supervisors felt that younger crews weren't good at hazard

15:02

15

awareness.

15:02

16

15:02

17

A.

Yes.

15:02

18

Q.

Let's go now back to TREX-5482.1.1.TO, the cover page of

15:03

19

this document.

15:03

20

This was the Lloyd's Register slide report pertaining

15:03

21

not specifically to Deepwater Horizon, but to the North America

15:03

22

division; correct?

15:03

23

A.

Yes.

15:03

24

Q.

And the crew aboard the Deepwater Horizon in the driller's

15:03

25

shack that night -- Jason Anderson, Dewey Revette, Stephen

MR. BRIAN:

I'd like to pull up TREX-5482.10.1.TO.

Do you see that language at the top?

I think you were

Younger crews thought they were competent."

Do you see that?

According to the document, yes.

OFFICIAL TRANSCRIPT

4750
STEVE NEWMAN - REDIRECT

15:03

Curtis -- was this what you would characterize as a younger

15:03

crew?

15:03

A.

No.

15:03

Q.

How much experience, if you know, did they have on the

15:03

Deepwater Horizon?

15:03

A.

15:03

nine or ten years.

15:03

years.

15:03

15:04

10

15:04

11

TREX number?

15:04

12

BY MR. BRIAN:

15:04

13

Q.

15:04

14

have TREX-4942.20.

15:04

15

15:04

16

his questioning of you, sir?

15:04

17

A.

Yes.

15:04

18

Q.

And you see there's from the OIMs all the way up to the

15:04

19

chief executive officer, where you sit.

15:04

20

A.

Yes.

15:04

21

Q.

Now, there's been a lot of testimony in this trial

15:04

22

about -- a lot of questioning of you about GMS and OIMs and

15:04

23

THINK and starts.

15:04

24

your core.

15:04

25

I think those three guys had been on the rig for eight or
I think Jason had been on the rig for ten

MR. BRIAN:

I now want to pull up TREX-1429.20.1.

I think it's actually -- is this a different

So it's a copy of the same document you were shown.

We

Is that the chart that Mr. Regan showed you during

Do you see that?

I want to ask you a question that goes to

And that is, how often do you think about the 11 men
OFFICIAL TRANSCRIPT

4751
STEVE NEWMAN - REDIRECT

15:05

who died that night on the Deepwater Horizon?

15:05

A.

Every day.

15:05

Q.

Why?

15:05

A.

Because I ask myself if there isn't something -- I ask

15:05

myself if there isn't something more I could have done.

15:05

15:05

15:05

15:05

15:05

10

15:05

11

15:05

12

finish up Mr. Barnhill.

15:05

13

Mr. Quirk is available, we're happy to interrupt our case and

15:05

14

go with Mr. Quirk.

15:06

15

would like to play two deposition video clips.

15:06

16

15:06

17

available.

15:06

18

whatever is your pleasure.

15:06

19

15:06

20

15:06

21

15:06

22

finished today, Your Honor, and go back, as we discussed was

15:06

23

the plan.

15:06

24

15:06

25

MR. BRIAN:

Thank you.

No further questions,

All right.

Thank you, Mr. Newman.

Your Honor.
THE COURT:

All right.
witness?

Who's going to be Transocean's next

Are we going back to Mr. Barnhill?


MR. BRIAN:

We are, Your Honor.

I thought we would

And then as we discussed yesterday, if

And then if we have additional time, we

MR. GODWIN:

Mr. Quirk is here, Your Honor, and

He can go now or he can go after Mr. Barnhill,

THE COURT:

What do the plaintiffs want to do?

Do

you want to take him now or finish Barnhill?


MR. GODWIN:

Mr. Quirk would like to be able to be

But if it looks like -THE COURT:

Well, I don't know.

The way we've been

going, I don't know if that's going to be possible, regardless.


OFFICIAL TRANSCRIPT

4752
STEVE NEWMAN - REDIRECT

15:06

It's already 3:00.

15:06

MR. GODWIN:

15:06

MR. WILLIAMS:

15:06

15:06

15:06

15:06

15:06

15:06

15:06

10

MR. BREIT:

45 to 55 minutes, Judge.

15:06

11

MR. BRIAN:

I don't think, Your Honor, we have that

15:06

12

much more of Mr. Barnhill.

15:06

13

30 minutes.

15:06

14

short redirect.

15:07

15

is available, so whatever is convenient for yourself and the

15:07

16

other parties.

15:07

17

15:07

18

I'm going to be here regardless.

15:07

19

listening to.

15:07

20

15:07

21

minutes.

15:07

22

now, he's ready.

15:07

23

THE COURT:

15:07

24

MR. WILLIAMS:

15:07

25

THE COURT:

I understand, judge.
Your Honor, I think we called --

Mr. Breit is not in the courtroom -- there he is.


But we're prepared to take Mr. Quirk, and we had
hoped to be able to do that today because he's got -THE COURT:

How long do we expect this examination to

be?
MR. WILLIAMS:

How long is your exam going to take?

I think Mr. Brock said he had 20 or

And then there will be, I think, a relatively


But we'll defer to Your Honor.

THE COURT:

MR. GODWIN:

Mr. Barnhill

It doesn't make any difference to me.


It doesn't matter who I'm

He will be here in three or four

He's here in the building.

If you want him to go

Do you want a quick break?


Sure.

Do you think there's a chance we can get


OFFICIAL TRANSCRIPT

4753
STEVE NEWMAN - REDIRECT

15:07

15:07

15:07

15:07

him out of here by 6:00 altogether?


MR. BREIT:

I'll be finished, Judge.

I can tell you

THE COURT:

By 6:00?

15:07

MR. BREIT:

By 4:00.

15:07

THE COURT:

Let's take about a 15-minute recess.

15:07

THE DEPUTY CLERK:

15:09

(WHEREUPON, the Court took a recess.)

15:23

THE DEPUTY CLERK:

15:23

10

15:23

11

15:23

12

MR. BREIT:

15:23

13

(WHEREUPON, TIMOTHY QUIRK, having been duly sworn,

15:23

14

15:23

15

15:23

16

correct spelling for the record.

15:23

17

THE WITNESS:

15:23

18

T-I-M-O-T-H-Y, L-E-O, Q-U-I-R-K.

15:23

19

15:23

20

15:23

21

plaintiffs' case in chief, slightly out of order.

15:23

22

Breit for the Plaintiffs' Steering Committee, and this would be

15:23

23

cross-examination of Mr. Quirk.

15:23

24

that.

THE COURT:

All rise.

All rise.

Please be seated, everyone.

Mr. Breit, call your next witness.


Next witness is Timothy Quirk.

testified as follows.)
THE DEPUTY CLERK:

Please state your full name and

My name is Timothy Leo Quirk,

DIRECT EXAMINATION
MR. BREIT:

THE COURT:

If Your Honor remembers, this is the

All right.

25
OFFICIAL TRANSCRIPT

Jeffrey

4754
TIMOTHY QUIRK - DIRECT

15:23

BY MR. BREIT:

15:23

Q.

15:24

Broussard lab, in 2008; is that correct?

15:24

A.

Yes, sir.

15:24

Q.

And before that time --

15:24

15:24

15:24

15:24

15:24

10

Q.

15:24

11

primary chemist at Halliburton Broussard lab; is that correct?

15:24

12

A.

Yes, cement lab manager.

15:24

13

Q.

And in April of 2010, you were responsible for the four

15:24

14

labs that were at Broussard, were you not?

15:24

15

A.

Yes, sir.

15:24

16

Q.

Now, just above you in the chain of hierarchy at

15:24

17

Halliburton was Ron Faul; is that right?

15:24

18

A.

Ronnie Faul.

15:24

19

Q.

And Ronnie Faul was based in the Houston office of

15:24

20

Halliburton?

15:24

21

A.

Yes, sir.

15:24

22

Q.

And you were in charge of the lab itself, and there was no

15:24

23

one at the lab above you; is that correct?

15:24

24

A.

That's correct.

15:24

25

Q.

If you had a problem at your lab, you would contact Ronnie

Mr. Quirk, you were the lab manager at Halliburton,

THE COURT:
minute.

Wait a minute, wait a minute, wait a

Pull the microphone a little closer to you.


There you go.

Try that.

Okay.

BY MR. BREIT:
And prior to becoming the lab manager, you had been the

OFFICIAL TRANSCRIPT

4755
TIMOTHY QUIRK - DIRECT

15:24

Faul?

15:24

A.

That's correct.

15:25

Q.

Now, immediately -- after this explosion on April 20th,

15:25

2010, you received a phone call from Ronnie Faul within weeks

15:25

of that explosion?

15:25

A.

Yes.

15:25

Q.

And by the time he had called you, you had already taken a

15:25

look at the cement slurry that Jesse Gagliano had used in the

15:25

Deepwater Horizon well, had you not?

15:25

10

A.

Yes.

15:25

11

Q.

You found that slurry by looking it up on Viking -- the

15:25

12

Viking system -- to see what had been used?

15:25

13

A.

15:25

14

the folder of data.

15:25

15

Q.

15:25

16

or folder at Broussard, or it was on the Viking system, or it

15:25

17

was both?

15:25

18

A.

That's correct.

15:25

19

Q.

And that's how you, as a lab manager, would look to find

15:25

20

out what chemicals were used, what additives were used, what

15:25

21

cement slurry had been used by Mr. Gagliano in the last time

15:26

22

before the well had cement dumped down it; right?

15:26

23

A.

Yes, right.

15:26

24

Q.

Now, when you were contacted by Mr. Faul, you knew by that

15:26

25

time that there had been a preservation order put in place by

I don't recall if it was the Viking system or looking at

One of the two.

There was either a written documentation

OFFICIAL TRANSCRIPT

4756
TIMOTHY QUIRK - DIRECT

15:26

at least one court asking that the products that had been used

15:26

on the Deepwater Horizon be secured and put aside so that no

15:26

one would touch them; is that right?

15:26

A.

15:26

to gather the material and put it in a secure --

15:26

Q.

Was that Ron Faul?

15:26

A.

That was Tony Angelle.

15:26

Q.

So Tony Angelle, who, again, was another Halliburton

15:26

employee --

15:26

10

A.

He's in Lafayette.

15:26

11

Q.

He's in Lafayette.

15:26

12

15:26

13

find related to the Macondo well, and secure it"?

15:26

14

A.

15:26

15

recall -- "the Horizon rig" is what I remember.

15:26

16

Q.

15:27

17

Mr. Angelle that anything from the Horizon rig was to be

15:27

18

gathered up and put into a locked, air-conditioned locker?

15:27

19

A.

15:27

20

from the Horizon rig.

15:27

21

Q.

And then -- I'm sorry.

15:27

22

A.

And -- that's correct.

15:27

23

Q.

So you went around looking for things from the Horizon rig

15:27

24

that had been marked "Horizon rig" so that you could put them

15:27

25

in a location?

I was not aware of a preservation order.

I was instructed

-- he told you, "Gather up everything that you can

He said -- originally, he said the Horizon rig.

And, basically, you understood that directive from

No.

He asked me initially just to gather up the material

OFFICIAL TRANSCRIPT

4757
TIMOTHY QUIRK - DIRECT

15:27

A.

In my office, right.

15:27

Q.

So initially when you gathered up everything from the

15:27

Horizon rig, you put all of that stuff in your office?

15:27

A.

That's correct.

15:27

Q.

In fact, you are the one who helped collect it?

15:27

A.

I was a part of -- yes.

15:27

Q.

Now, when Mr. Faul called you initially, he told you at

15:27

that time that there had been tests in the Duncan, Oklahoma,

15:27

lab on the cement slurry design from the Macondo well, did he

15:28

10

not?

15:28

11

A.

Yes.

15:28

12

Q.

So when you got the first phone call about gathering up

15:28

13

products for your office, you already knew someone in Oklahoma

15:28

14

had done some testing on the cement slurry from the Macondo

15:28

15

well.

15:28

16

someone had done testing in Oklahoma?

15:28

17

A.

Around that same time period.

15:28

18

Q.

In fact, when Mr. Faul called you and told you about the

15:28

19

slurry testing in Duncan, Oklahoma, he wanted to compare what

15:28

20

had happened in Duncan, Oklahoma, with what you were going to

15:28

21

do in the Broussard lab?

15:28

22

were seeing in Duncan?

15:28

23

A.

He wanted to repeat the tests.

15:28

24

Q.

And --

15:28

25

A.

Go ahead.

Whether it's the design or some other part of it,

He wanted to compare what you-all

He was --

OFFICIAL TRANSCRIPT

4758
TIMOTHY QUIRK - DIRECT

15:28

Q.

I'm sorry.

Go ahead.

I don't mean to interrupt you.

15:28

I've been guilty of that before.

15:28

A.

15:29

ingredients.

15:29

Q.

15:29

Duncan with whatever you were going to see in Broussard; is

15:29

that right?

15:29

A.

15:29

him asking me to repeat the test.

15:29

10

15:29

11

15:29

12

deposition of Mr. Quirk, page 89, lines 11 through 18, please.

15:29

13

11 through 18.

15:29

14

BY MR. BREIT:

15:29

15

Q.

15:29

16

15:29

17

BY MR. BREIT:

15:29

18

Q.

15:29

19

15:29

20

15:29

21

15:29

22

Duncan, Oklahoma, and they wanted -- and that he wanted me

15:29

23

to mix the slurry up and see if, you know, to see how it

15:29

24

compared to what they were seeing up there."

15:30

25

He wanted to repeat the test using the off-the-shelf lab

But he wanted you to compare what they were seeing in

I don't recall exactly the conversation.

I just remember

That's what I recall right

now.
MR. BREIT:

Let me see TREX-63141, which would be the

And did he give you -MR. BREIT:

Thank you very much.

(Reading):
"QUESTION:

And did he give you a reason why he

wanted you to foam the slurry using lab stock additives?


"ANSWER:

He said that they had performed a test in

Does that refresh your recollection?


OFFICIAL TRANSCRIPT

4759
TIMOTHY QUIRK - DIRECT

15:30

A.

Can you go further down, please?

15:30

Q.

You mean below line 18?

15:30

A.

Yes.

15:30

15:30

that page.

15:30

BY MR. BREIT:

15:30

Q.

15:30

THE COURT:

15:30

THE WITNESS:

15:30

10

perform the stability test."

15:30

11

BY MR. BREIT:

15:30

12

Q.

15:30

13

seeing in Oklahoma; correct?

15:30

14

A.

15:30

15

conversation.

15:30

16

Q.

15:30

17

or two years ago, do you?

15:30

18

A.

No, I don't deny saying that.

15:30

19

Q.

All right.

15:31

20

couple weeks after April 20th, and he asked you and wanted you

15:31

21

to use Macondo lab stock additives, didn't he?

15:31

22

A.

I'm sorry, could you repeat the question?

15:31

23

Q.

When Mr. Faul called you, he asked you to use Macondo lab

15:31

24

stock additives, didn't he?

15:31

25

A.

MR. BREIT:

Just to the page 94 -- I'm sorry, just on

Can you just give us the full page?

Right there, is that what you're talking about?

Right.

You can read it on your screen.


Okay.

"Mix it up -- mix it up and

But he wanted you to compare to what they were

I'm sorry.

I just don't recall exactly that part of the

You don't deny saying that under oath about a year ago --

Now, when Mr. Faul called you, that was a

I'm not aware of any Macondo lab stock additives.


OFFICIAL TRANSCRIPT

4760
TIMOTHY QUIRK - DIRECT

15:31

Q.

But he wanted you to use them.

15:31

A.

Macondo lab stock additives?

15:31

Q.

Lab stock additives that were used on the Macondo well.

15:31

A.

I'm not aware of any lab stock additives used on the

15:31

Macondo well.

15:31

15:31

Carl.

15:31

BY MR. BREIT:

15:31

Q.

15:31

10

15:31

11

asked you to look at the slurry design and use what you

15:31

12

have at your lab to recreate the slurry that was being

15:31

13

used offshore?"

15:31

14

15:31

15

15:32

16

15:32

17

Do you understand that that now?

15:32

18

A.

Yes, not the Macondo lab stock additives.

15:32

19

Q.

But he was trying to get you, at that time, to re-create

15:32

20

the slurry that was being used offshore that would be on the

15:32

21

Macondo well, and he asked you to use the lab stock additives.

15:32

22

Did he not ask you that?

15:32

23

A.

Lab stock additives, that's correct.

15:32

24

Q.

Thank you.

15:32

25

MR. BREIT:

Didn't he tell you that?

TREX-63141, page 39, lines 9 through 21,

Thank you.

(Reading):
"QUESTION:

So both Mr. Faul and these two gentlemen

Initially, this is your answer:

"Well, Mr. Faul

asked that I, you know, use the lab stock additives."


Now, did he ask you to use the lab stock additives?

Now, Mr. Faul told you that the tests at Duncan, when
OFFICIAL TRANSCRIPT

4761
TIMOTHY QUIRK - DIRECT

15:32

they had done those tests, it looked thin, didn't it?

15:32

A.

Yes.

15:32

Q.

In fact, after they completed the first test at Duncan

15:32

that showed that the slurry was thin, either someone at

15:32

Oklahoma or you called each other to discuss what had been done

15:32

in the test?

15:32

A.

That's correct.

15:32

Q.

You remember that, don't you?

15:32

A.

Yes.

15:32

10

15:32

11

here?

15:32

12

BY MR. BREIT:

15:32

13

Q.

We're talking a couple weeks after April 20th, are we not?

15:32

14

A.

Yes, somewhere in that time period.

15:32

15

15:32

16

BY MR. BREIT:

15:32

17

Q.

15:33

18

test in Duncan that had been thin, and the person in Duncan who

15:33

19

you don't remember -- do you remember it now being Mr. Morgan?

15:33

20

A.

Yes.

15:33

21

Q.

And Mr. Morgan said to you, "It looks thin.

15:33

22

do when you tested it?"

15:33

23

A.

That's correct.

15:33

24

Q.

So when Mr. Morgan called you before he did this second

15:33

25

test --

THE COURT:

THE COURT:

What time frame are we talking about

Okay.

And a couple weeks after April 20th, there had been one

What did you

Is that right?

OFFICIAL TRANSCRIPT

4762
TIMOTHY QUIRK - DIRECT

15:33

A.

When you asked me when I tested it, are you talking about

15:33

the lab test, that it's pre-incident?

15:33

Q.

15:33

done on the testing with regard to conditioning.

15:33

right?

15:33

A.

Pre-incident.

15:33

Q.

Okay.

15:33

A.

No.

15:33

Q.

Mr. Morgan was about to do his second test?

15:33

10

A.

Well, I don't know -- I don't know if there was a second

15:33

11

test.

15:33

12

Q.

15:33

13

another one?

15:33

14

A.

15:33

15

that he was about ready to do another one.

15:33

16

part of it.

15:33

17

Q.

15:33

18

time, did he not?

15:33

19

A.

Yes.

15:33

20

Q.

Okay.

15:33

21

test?

15:33

22

A.

Right.

15:33

23

Q.

Now, Mr. Faul told you, when he asked you to re-create the

15:34

24

slurry testing, that there had been settling in Duncan when

15:34

25

Rickey Morgan had done his test; isn't that right?

My impression was that Mr. Morgan asked you what had been
Is that

So you had not done your test yet?

I don't know.

At least one had been thin already, and he was about to do

I can -- I can understand that one was done.

I don't know

I don't recall that

Well, he asked you what had happened with the conditioning

So you don't know whether or not he did another

OFFICIAL TRANSCRIPT

4763
TIMOTHY QUIRK - DIRECT

15:34

A.

Right.

Upon miscibility.

15:34

Q.

But, again, on a testing trying to re-create the slurry

15:34

that had been used at the last time in the well, on

15:34

April 19th and April 20th, that Mr. Morgan's testing of that

15:34

slurry, however it was done, it showed settling; is that right?

15:34

A.

15:34

remember.

15:34

Q.

15:34

Morgan and no one in Oklahoma wrote down any of the testing

15:34

10

that happened in Oklahoma?

15:34

11

A.

15:34

12

At the time, I wasn't aware of that.

15:34

13

Q.

15:34

14

lab after April 20th, 2010?

15:34

15

A.

Up until August 24th of last year.

15:35

16

Q.

So up until August of 2012, did you ever go and ask if

15:35

17

someone in Oklahoma could show you any written tests, any

15:35

18

Viking tests, any notes of anything Rickey Morgan did a couple

15:35

19

of weeks after this incident so that you could see what kind of

15:35

20

slurry he used and what kind of testing he was doing after this

15:35

21

incident?

15:35

22

A.

I don't recall requesting that at all.

15:35

23

Q.

So is it safe to say that at no time after April 20th of

15:35

24

2010, until August of 2012, when you left the Broussard lab,

15:35

25

you never even asked anyone to show you any of those tests?

What I remember is the point of miscibility, is what I

Well, do you know now -- or did you know that Rickey

I've heard that over the last couple of years, you know.

Well, how long did you remain the manager of the Broussard

OFFICIAL TRANSCRIPT

4764
TIMOTHY QUIRK - DIRECT

15:35

A.

I never asked anyone to show me that.

15:35

Q.

Did you look on the Viking system?

15:35

A.

I did not, not specifically looking for that.

15:35

Q.

Well, did you look on the Viking system at any time to see

15:35

whether or not there was any testing in Oklahoma that someone

15:35

had put on the record?

15:35

A.

I did not.

15:35

Q.

And you understand there were at least two tests done in

15:36

Duncan now, both of which showed that the slurry was thin?

15:36

10

understand that now, don't you?

15:36

11

A.

As we're -- today, yes.

15:36

12

Q.

Now, you were asked by Mr. Faul to do these tests; is that

15:36

13

correct?

15:36

14

A.

That's correct.

15:36

15

Q.

Anyone one up, higher up?

15:36

16

you to do any testing in April or May of 2010?

15:36

17

A.

No, sir.

15:36

18

Q.

Now, you were to perform a foam stability, foam slurry

15:36

19

test?

15:36

20

A.

Foam stability, right.

15:36

21

Q.

And, in fact, that's not part of your habit, to perform

15:36

22

that test at Broussard lab back in May of 2010, was it?

15:36

23

A.

Me, personally?

15:36

24

Q.

Yes, you personally.

15:36

25

A.

Not on a regular basis, no.

You

Any lawyers, anyone else ask

Wasn't that your intention initially?

No.

OFFICIAL TRANSCRIPT

4765
TIMOTHY QUIRK - DIRECT

15:36

Q.

In fact, it had been years since you had run a test like

15:36

that prior to May of 2010?

15:36

A.

It could have been.

15:36

Q.

You don't remember, do you?

15:36

A.

Right.

15:36

Q.

In fact, before this phone call from Mr. Faul, he had

15:36

never asked you orally to do any kind of testing at Broussard,

15:37

you, yourself?

15:37

A.

I don't recall.

15:37

10

Q.

Well, didn't you testify before today that, in fact, he

15:37

11

had never called you orally prior to that day to ask you to

15:37

12

perform tests?

15:37

13

A.

15:37

14

answer.

15:37

15

Q.

15:37

16

18, please.

15:37

17

15:37

18

15:37

19

"ANSWER:

15:37

20

"QUESTION:

15:37

21

other than this one?

15:37

22

15:37

23

15:37

24

15:37

25

I don't --

I just don't recall that part of it.

I can't remember my

I'm sorry.

Well, let's look.

"QUESTION:

TREX-63141, page 318, lines 8 through

Has he -- does he frequently ask you to

do tests or similar projects orally without in writing?

"ANSWER:

No.
Has he ever asked you to do one before

I don't recall at this time -- I don't --

not related to lab testing."


So does that help refresh your memory as to him never
calling you prior to this date?
OFFICIAL TRANSCRIPT

4766
TIMOTHY QUIRK - DIRECT

15:37

A.

Yes.

15:37

Q.

Thank you.

15:37

15:37

this incident and asked you to perform these tests, he

15:38

specifically told you not to report your results, didn't he?

15:38

A.

He asked me to phone the results to him.

15:38

Q.

But he asked you not to report the results?

15:38

question, please.

15:38

A.

15:38

10

system.

15:38

11

Q.

15:38

12

record any of your results anywhere, didn't he?

15:38

13

A.

He just asked me to phone the results to him.

15:38

14

Q.

And he did not want you to report them, not on Viking and

15:38

15

not anywhere else?

15:38

16

A.

He didn't want a report.

15:38

17

Q.

That meant not on Viking and not to write up a written

15:38

18

report --

15:38

19

A.

Right.

15:38

20

Q.

-- just like the ones that Mr. Gagliano's reports would

15:38

21

have shown from the April 17th; is that correct?

15:38

22

A.

Right.

15:38

23

Q.

So you didn't prepare a lab work sheet?

15:38

24

A.

I didn't prepare a lab work sheet.

15:38

25

Q.

You didn't prepare any notes, did you?

Now, when Mr. Faul called you a couple of weeks after

Listen to my

He asked me not to report the results in the Viking

He also told you not to put anything in Viking and not to

OFFICIAL TRANSCRIPT

4767
TIMOTHY QUIRK - DIRECT

15:38

A.

Prepare any notes?

No, I just -- no.

15:38

Q.

In fact, you had written notes, didn't you, after this

15:38

incident, but you got rid of them, didn't you?

15:39

A.

I discarded my notes.

15:39

Q.

You threw them in the trash, didn't you?

15:39

A.

I -- yes.

15:39

Q.

Now, was that on directions of Mr. Faul that you threw

15:39

your notes from this test, a couple of weeks after April 20th,

15:39

in the trash; or is that something that you decided on your

15:39

10

own?

15:39

11

A.

15:39

12

reported the results to him over the phone and I didn't see any

15:39

13

need to hang on to my notes.

15:39

14

Q.

15:39

15

knew at that time that the Deepwater Horizon was in the bottom

15:39

16

of the Gulf, 11 men had perished, that you didn't think it was

15:39

17

important --

15:39

18

MR. UNDERHILL:

15:39

19

MR. BREIT:

15:39

20

15:39

21

15:39

22

BY MR. BREIT:

15:39

23

Q.

15:39

24

15:39

25

I -- based on the way he requested that I run the tests, I

You're telling this Court that after April 20th, when you

Objection, argumentative.

I don't think it's argumentative at all,

Your Honor.
THE COURT:

Overrule the objection.

Let me restart my question.


April 20th, by the time you get this phone call, the

Deepwater Horizon is at the bottom of the Gulf, 11 men have


OFFICIAL TRANSCRIPT

4768
TIMOTHY QUIRK - DIRECT

15:39

perished, and you know that there's being testing done by

15:39

Halliburton personnel and they ask you to do testing of the

15:40

cement stability and you don't think it's important to hold on

15:40

to any of your notes showing what your results would have

15:40

shown?

15:40

A.

15:40

asked me to use off-the-shelf lab stock ingredients, and I

15:40

didn't -- in the past I performed experiments in using lab

15:40

stock ingredients and was not using the samples that were from

15:40

10

15:40

11

15:40

12

it now, I can understand the importance of it, but back then I

15:40

13

just didn't see it that way.

15:40

14

run -- go in the lab and run today or I could have run it the

15:40

15

very next day.

15:40

16

Q.

15:40

17

think it was so important then, one of the important things is

15:41

18

what are the densities that you found when you did your

15:41

19

testing; isn't that right?

15:41

20

A.

Right.

15:41

21

Q.

You didn't write that down, did you, the densities?

15:41

22

A.

No.

15:41

23

Q.

You don't remember what the densities are, do you?

15:41

24

A.

I don't.

15:41

25

Q.

You didn't remember them two years ago when your

At the time that this happened, I didn't -- my view was he

the location.
I know that -- I mean, hindsight, looking way back at

I mean, it's a test that I could

It's all additives off the shelf.

Well, let me ask you this question because you didn't

OFFICIAL TRANSCRIPT

4769
TIMOTHY QUIRK - DIRECT

15:41

deposition was taken, do you?

15:41

A.

That's correct.

15:41

Q.

So you don't think it's important, with 11 men perished,

15:41

that you save the results of the density as to whether or not

15:41

this cement was stable?

15:41

A.

15:41

test again.

15:41

Q.

15:41

the cement that you had tested and you threw them away too,

15:41

10

didn't you?

15:41

11

A.

As we do with all the other testing.

15:41

12

Q.

Do you have that much testing done after 11 men perished

15:41

13

and a rig sinks to the bottom of the Gulf?

15:41

14

A.

No, sir.

15:41

15

Q.

Now, Mr. Faul asked you specifically to do these tests off

15:41

16

the side, didn't he?

15:41

17

A.

15:41

18

that.

15:41

19

15:42

20

15:42

21

15:42

22

side.

15:42

23

BY MR. BREIT:

15:42

24

Q.

15:42

25

Just run it again.

That's all we had to do was run the

In fact, after you did this test, you took the pieces of

Do you?

I don't remember exactly his exact words, something like

MR. BREIT:

Let's look at TREX-63141, page 316,

lines 19 to the top of page 317, line 4, please.


316, 19, see if you can get 316 and 317 side by
Thank you.

(Reading:)
"QUESTION:

So did he just ask you to do it in this


OFFICIAL TRANSCRIPT

4770
TIMOTHY QUIRK - DIRECT

15:42

case because there were problems with the well, the

15:42

litigation?

15:42

separate test?

15:42

15:42

15:42

A.

Okay.

15:42

Q.

When you say "off the side," that means not record it.

15:42

he asked you to do this off the side, didn't he?

15:42

A.

I guess so.

15:42

10

Q.

Didn't you think it was strange with so many people

15:42

11

wondering what happened on the Deepwater Horizon -- the United

15:42

12

States Government, BP, Transocean -- that he would ask you to

15:42

13

do testing on the side and not write down or record a single

15:42

14

word?

15:42

15

A.

It's -- it was a little unusual.

15:43

16

Q.

Now, in addition to that test, Mr. Faul asked you to

15:43

17

perform four or five contamination tests, checking the foam

15:43

18

stability, didn't he?

15:43

19

A.

That's correct.

15:43

20

Q.

You didn't save any notes yourself from those

15:43

21

contamination tests, did you?

15:43

22

A.

No, sir.

15:43

23

Q.

Now, you also received a call from Simon Turton and

15:43

24

Anthony Badalamenti.

15:43

25

or where are they?

I mean, is that why he asked you to do this

"ANSWER:

Well, I can't speak for him.

He just asked

me to do it off the side and give him the results."

So

That's my --

Didn't you think that was strange?

Both of those gentlemen are in Houston,

OFFICIAL TRANSCRIPT

4771
TIMOTHY QUIRK - DIRECT

15:43

A.

Now I'm not sure where they're at.

They were in Houston

15:43

at the time.

15:43

Q.

15:43

they called you after Mr. Faul's test, they, too, had tests for

15:43

you to do?

15:43

A.

Yes.

15:43

Q.

They wanted you to perform static gel strength and

15:43

transitioning time tests, didn't they?

15:43

A.

That's correct.

15:43

10

Q.

And you used the weigh-up --

15:43

11

A.

It's the same test.

15:43

12

Q.

I'm sorry, sir?

15:43

13

A.

It's the same test.

15:43

14

Q.

The same test done almost at the same time, or is it the

15:43

15

exact same test?

15:43

16

A.

It's the exact same test.

15:43

17

Q.

Thank you.

15:43

18

Now, you used the weigh-up sheets so that you would

15:43

19

know what was the proper amount of additives to weigh out for

15:44

20

the testing, didn't you?

15:44

21

A.

The weigh-up sheets were used.

15:44

22

Q.

You were trying to reconfigure the slurry that Jesse

15:44

23

Gagliano had asked for testing on April 17th, weren't you?

15:44

24

A.

15:44

25

Right.

In April of 2010 when they called you, or May 2010 when

It was a generated sheet.

It was -- it was the slurry that was pumped, I think.

OFFICIAL TRANSCRIPT

4772
TIMOTHY QUIRK - DIRECT

15:44

Q.

And the weigh-up sheet that you went to was the cement

15:44

weigh-up sheet that Gagliano had used and made up on

15:44

April 17th, 2010, the last weigh-up sheet of the cement that

15:44

was used?

15:44

A.

On the transition time?

15:44

Q.

No, no, no.

15:44

weigh-up sheet so that you could reconfigure the slurry like

15:44

the slurry that Jesse Gagliano had tested or asked to be tested

15:44

on April 17th; isn't that right?

15:44

10

A.

That --

15:44

11

Q.

You had to look somewhere to find out what to do --

15:44

12

A.

That makes sense, yes.

15:44

13

Q.

Now, let's look at the TREX-4566, which is the April 17th,

15:45

14

2010.

15:45

15

15:45

16

[verbatim], 2010, Jesse Gagliano, engineer, and this is the

15:45

17

last weigh-up sheet of the cement slurry that was tested before

15:45

18

they did the pumping of the cement on the Macondo well.

15:45

19

15:45

20

A.

15:45

21

one.

15:45

22

Q.

15:45

23

testimony in the last three weeks, the April 17th, 2010 cement

15:45

24

weigh-up sheet is -- the cement weigh-up sheet, as the lawyer

15:45

25

for Halliburton has indicated, is the only cement weigh-up

You were looking at the April 17th, 2010

That makes sense.

First, let me look at the top of that sheet.


This is the cement lab weigh-up sheet, April 7th

Do you see that?


I don't think it was -- I don't think that was the last

Well, I'll represent to you there's been plenty of

OFFICIAL TRANSCRIPT

4773
TIMOTHY QUIRK - DIRECT

15:45

sheet that is important because this is the last one that they

15:45

were relying on for the testing for purposes of pumping down

15:45

the well.

15:45

A.

I understood that there was a part two to that.

15:46

Q.

Let's look at the April 17th, 2010 weigh-up sheet.

15:46

look at some of the material.

15:46

to the SCR-100L.

15:46

A.

Yes.

15:46

Q.

And the lot number, which is 6264, that's an indication

15:46

10

that the lot of SCR-100L came from the Deepwater Horizon, does

15:46

11

it not?

15:46

12

A.

It could be.

15:46

13

Q.

I'm going to represent to you from other testimony that

15:46

14

the 6264 is, in fact, from Tank No. 8 of the Deepwater Horizon

15:46

15

and that other witnesses, whose testimony is in the record,

15:46

16

indicated 6264 was the Deepwater Horizon.

15:46

17

15:46

18

sample ID.

15:46

19

Broussard, not only is there a lot number showing from where a

15:46

20

particular chemical, in this case SCR-100L, comes from, it also

15:46

21

has a specific ID showing what was used specifically from that

15:47

22

lot.

15:47

23

15:47

24

A.

Yes.

15:47

25

Q.

And so in this case, if the cement lab weigh-up sheet of

I'll represent that to you.

Let's

And specifically I want to look

Now, if you see to the right of that, there is a


And the sample ID, as I understand your lab in

Is that right?

OFFICIAL TRANSCRIPT

4774
TIMOTHY QUIRK - DIRECT

15:47

April 17th is, in fact, the correct one, the SCR-100L, which

15:47

was dated October 22nd, 2009 -- that's another marking you-all

15:47

use to date your lab samples; correct?

15:47

A.

Yes.

15:47

Q.

-- was specifically 54573, which shows that that is a

15:47

specific ID of a specific SCR-100L used for that test; correct?

15:47

A.

Okay.

15:47

Q.

Am I correct on that?

15:47

A.

Based on what I see here.

15:47

10

Q.

Thank you.

15:47

11

15:47

12

A.

15:47

13

the lab tech is supposed to weigh up.

15:47

14

Q.

Correct.

15:47

15

A.

Okay.

15:47

16

Q.

And what's supposed to be used for purposes of Jesse

15:47

17

Gagliano testing --

15:47

18

A.

Right.

15:47

19

Q.

-- is this specific 54573 ID, SCR-100L?

15:48

20

A.

Right.

15:48

21

Q.

And you understand, of course, by this time, when you're

15:48

22

looking at this sheet, you've already received a phone call

15:48

23

asking for the materials that were used on the Deepwater

15:48

24

Horizon to be secured in your office.

15:48

25

right?

Now, again, you were trying to -Now, I want to just point out something.

This shows what

You understand that;

OFFICIAL TRANSCRIPT

4775
TIMOTHY QUIRK - DIRECT

15:48

A.

Yes.

15:48

Q.

Now, when you were going to do this second group of

15:48

testing for Mr. Badalamenti and Mr. Turton, you needed to

15:48

figure out what to look at for purposes of making up your

15:48

slurry.

15:48

15:48

April 17th lab weigh-up sheet, which would be TREX-05593,

15:48

please.

15:48

So this shows that on May 20th, 2010, this particular

15:49

10

cement lab weigh-up sheet was printed out and it's the same one

15:49

11

that Jesse Gagliano had used, except the only difference is

15:49

12

it's got a .09 SCR-100L; right?

15:49

13

A.

Uh-huh.

15:49

14

Q.

And you understand, of course, now, having stayed at the

15:49

15

lab until August of 2012, that Jesse Gagliano had tested the

15:49

16

.08 SCR-100L, but he had never tested the .9 [verbatim].

15:49

17

you understand that, or does that come to your knowledge?

15:49

18

A.

Well, the records that I've looked at, he tested the .09.

15:49

19

Q.

Are you sure you didn't look at those records and find out

15:49

20

that he had canceled that test?

15:49

21

A.

Well, I see results on the test when I look at it.

15:49

22

Q.

All right.

15:49

23

15:49

24

the SCR-100L.

15:49

25

the lot number, 6264, Deepwater Horizon, the date, 10/22/09,

And so on May 20th, 2010, you pulled up the

If we could look at the top, please.

Do

We'll get to those in a second.

Now, let's look at your lab weigh-up and notice again


Notice the date.

First of all, let's look at

OFFICIAL TRANSCRIPT

4776
TIMOTHY QUIRK - DIRECT

15:49

and again the sample ID, 54573.

15:50

15:50

that part?

15:50

A.

15:50

so --

15:50

Q.

I'm going to represent to you that it's the exact same.

15:50

A.

Okay.

15:50

Q.

Now, let's look at your tests, which I believe you then

15:50

tried to do on May 28th.

15:50

10

A.

Are you saying that I used that to perform a test?

15:50

11

Q.

No.

15:50

12

May 28th, 2010.

15:50

13

A.

That right there?

15:50

14

Q.

This is what you printed out.

15:50

15

A.

I don't recall printing that.

15:50

16

Q.

Okay.

15:50

17

used to guide yourself.

15:50

18

A.

Okay.

15:50

19

Q.

You do remember performing these tests that these

15:50

20

gentlemen from Houston had asked you to do?

15:50

21

A.

Yes, the -- yes.

15:50

22

Q.

And you did those tests on May 28th, 2010, and on

15:50

23

May 29th, 2010?

15:50

24

A.

Yes.

15:50

25

Q.

You do remember that?

Does that look the same as the one on April 17th,

Yeah.

I don't remember the exact number, but if you say

You used this before you performed your test on

Let's look at your tests, then, to see what you

OFFICIAL TRANSCRIPT

4777
TIMOTHY QUIRK - DIRECT

15:50

A.

Yes.

15:50

Q.

All right.

15:50

May 28th test and this is the engineer, you, Tim Quirk;

15:50

correct?

15:50

A.

15:51

want to make sure I didn't miss something.

15:51

Q.

Go back, then, to page --

15:51

A.

To the weigh-up sheet that you had just before.

15:51

Q.

I'm going to show you right now.

15:51

10

A.

Okay.

15:51

11

there --

15:51

12

Q.

I'm not sure where you're reading, sir.

15:51

13

A.

At the very top.

15:51

14

Q.

Yeah.

15:51

15

A.

Okay.

15:51

16

asking you about a while ago for the thickening time and UCA

15:51

17

strengths that were tested by Jesse before the incident.

15:51

18

Q.

15:51

19

before the incident.

15:51

20

A.

I --

15:51

21

Q.

-- so that you could look at -- I'm sorry.

15:51

22

me finish my question.

15:51

23

15:51

24

from Houston to perform these tests without looking to see what

15:52

25

Gagliano had used prior to the explosion; is that right?

Right.

Right.

Let's look at TREX-5593.3.

This is the

Would you mind going back to the screen before?

Okay.

5593.

That sheet, that 73909, Part 2 right

At the very top.

That sheet right there is the part that I was

I know that.

These are the ones that he used

You printed them out on May 20th, 2010 --

Mr. Quirk, let

You didn't know what to do when you got a phone call

OFFICIAL TRANSCRIPT

4778
TIMOTHY QUIRK - DIRECT

15:52

A.

I would have to see what was used, that's correct.

15:52

Q.

And you -- do you deny printing out on May 20th, the

15:52

weigh-up sheet, which is exactly the same weigh-up sheet from

15:52

April 17th, 2010?

15:52

A.

I don't recall printing that.

15:52

Q.

Okay.

15:52

THE COURT:

Wait a minute.

15:52

MR. BREIT:

I'm sorry, Judge.

15:52

THE COURT:

Under your system, these weigh-up sheets,

15:52

10

that date at the top would always be the date it was printed?

15:52

11

That May 20th date --

15:52

12

15:52

13

will show when it was printed.

15:52

14

the answer is yes.

15:52

15

THE COURT:

15:52

16

THE WITNESS:

15:52

17

THE COURT:

15:52

18

THE WITNESS:

15:52

19

MR. BREIT:

15:52

20

THE WITNESS:

15:52

21

MR. BREIT:

Printed on Thursday, May 20th, 2010, at

15:52

22

15:52

23

THE COURT:

Okay.

15:52

24

BY MR. BREIT:

15:52

25

Q.

Let's move to your tests of May 28, 2010.

THE WITNESS:

Well, if you go to the very bottom, it


If they match up, then I'll say

Let's see what the bottom says.


Yes, May 20th, there you go.

Where do you see that?


At the very bottom where it says --

Right there, Judge.


-- see page 1 of 2.

1:30 p.m.

So do you now agree that this particular weigh-up sheet


OFFICIAL TRANSCRIPT

4779
TIMOTHY QUIRK - DIRECT

15:53

was printed on that day in order for someone, maybe it was

15:53

someone else and not you, to perform some slurry tests?

15:53

A.

15:53

who printed it or why it was printed.

15:53

Q.

15:53

else on May 20th doing yet another test on this cement slurry

15:53

that we don't know about?

15:53

A.

15:53

sheet right here.

15:53

10

Q.

15:53

11

doing on May 28th.

15:53

12

A.

Okay.

15:53

13

Q.

Now, this is the cement lab weigh-up sheet printed on

15:53

14

May 28th, 2010.

15:53

15

you?

15:53

16

A.

Or having a technician performing the test, right.

15:53

17

Q.

And this is Timothy Quirk, that's you?

15:53

18

A.

Right.

15:53

19

Q.

And on the zone sealant, SCR-100L, it's Lot No. 6264;

15:53

20

correct?

15:53

21

A.

Yes.

15:54

22

Q.

But the sample ID is missing from this sheet?

15:54

23

A.

Right.

15:54

24

Q.

Let's turn to TREX-5593.5, which would be the other part

15:54

25

of this test, and you see the SCR-100L.

I don't know why it was printed.

I don't -- I don't know

Are you suggesting to the Court that there was someone

I'm just saying I don't know anything about this printed


That's all I'm saying.

Let's look at your test then, the one that you do remember
Okay?

And that would be TREX-5593.3.

You remember doing the test on May 28th, don't

Let's go to the top

OFFICIAL TRANSCRIPT

4780
TIMOTHY QUIRK - DIRECT

15:54

first.

This is the same weigh-up sheet for May 28th, 2010.

15:54

And if you see here the SCR-100L, October 22nd, 2009, and the

15:54

same exact sample ID, 54573.

15:54

15:54

exact same number that was on Jesse Gagliano's April 17th, 2010

15:54

sheet.

15:54

A.

Okay.

15:54

Q.

And so if I understand this correctly, this particular

15:54

SCR-100L, with this lot number from the Deepwater Horizon that

15:54

10

was dated into the lab on October 22nd, 2009, with the

15:54

11

Sample ID 54573, you used on May 28th, 2010, in order to

15:55

12

perform your testing for the two gentlemen in Houston.

15:55

13

that right?

15:55

14

A.

15:55

15

that back to being the same sample?

15:55

16

Q.

15:55

17

again, I'll show it to you.

15:55

18

A.

15:55

19

number from different places, and you can use the same lot

15:55

20

number for something that's already on the rig.

15:55

21

Q.

15:55

22

Jesse Gagliano's April 17th sheet, to show you the

15:55

23

Lot No. 6264, the lab date, October 22nd, 2009, and then your

15:55

24

representation that the sample ID of 54573 further narrows this

15:55

25

particular chemical to being the one used on the Deepwater

And I will represent to you that the 54573 is the

Does that make sense to you?


Yes.

Isn't

The sample for Jesse's test is the same -- you can date

Yes.

I just showed it to you.

If you'd like to see it

What I'm getting at is a lot number can be the same lot

That's exactly why I spent the time with you looking at

OFFICIAL TRANSCRIPT

4781
TIMOTHY QUIRK - DIRECT

15:55

Horizon just before the explosion.

15:55

15:55

A.

15:56

trying to wrap my brain around everything you're saying.

15:56

know where you're going, that I would have taken something out

15:56

of the locker.

15:56

point of ever putting it in the locker finally -- I can assure

15:56

you, I didn't take anything out of the locker.

15:56

Q.

15:56

10

specifically IDs this chemical as the chemical used by Jesse

15:56

11

Gagliano for his April 17th, 2010 test.

15:56

12

you right now.

15:56

13

A.

Okay.

15:56

14

Q.

Is that right?

15:56

15

A.

It's the same lot number.

15:56

16

Q.

It's the same lot number, it's the same lab date number,

15:56

17

and it's the exact same sample ID.

15:56

18

there?

15:56

19

A.

Yes.

15:56

20

Q.

And you would agree with me that on May 28th, 2010,

15:56

21

however you got your hands on it, or whoever got their hands on

15:56

22

it, this ID sample product was the product that was being used

15:56

23

by Jesse Gagliano on April 17th, 2010 for that test?

15:57

24

A.

It's a -- it's a portion of a sample of it.

15:57

25

Q.

It's a portion of the sample that had been told to you to

You said that, didn't you, sir?


Yes.

I -- I'm a little bit confused right now.

I'm
I

But I didn't -- either we hadn't got to the

What I'm asking you, sir, is that this ID here, 54573,

That's all I'm asking

Okay.

Would you agree with me

OFFICIAL TRANSCRIPT

Now, the --

4782
TIMOTHY QUIRK - DIRECT

15:57

be secured in your office so that no one else would touch it.

15:57

Isn't that true?

15:57

A.

15:57

assure you that I did not take a sample.

15:57

we used a sample of that as last stock and it had the same lab

15:57

ID number as a part of that or something.

15:57

Q.

15:57

54573 ID'ed this particular chemical as being used, not just

15:57

from the lot, not just from the lab date, but the actual

15:57

10

chemical that was used by Jesse Gagliano for his

15:57

11

April 17th test.

15:57

12

same --

15:57

13

A.

I want to --

15:57

14

Q.

Let me finish, please.

15:57

15

15:57

16

whoever did this test on May 28th, 2010?

15:57

17

A.

Well, I'd like to clarify something.

15:57

18

Q.

Go ahead.

15:57

19

A.

You can have six or ten samples that have that same ID

15:58

20

number.

15:58

21

Q.

15:58

22

This specific sample ID is the one that was being used by

15:58

23

Gagliano on April 17th, 2010, wasn't it?

15:58

24

further designation?

15:58

25

There's a missing piece to this puzzle.

Because I can

Either we -- either

I asked you, first of all, whether or not this particular

All I'm asking you:

Isn't this the exact

Isn't that the exact same sample ID that was used by

You could have six samples that have the same lot number.

You don't have a

There is no -- let me finish.

There's no other column, is there?


OFFICIAL TRANSCRIPT

There's a lot

4783
TIMOTHY QUIRK - DIRECT

15:58

number that says Deepwater Horizon, there's a lab date that

15:58

says the lab date, the date the lab got it, and there's a

15:58

sample ID that shows the date that this particular rig used

15:58

this particular chemical, or the lab did, for purposes of

15:58

testing.

15:58

ID number and put down the wrong number, do they?

15:58

A.

15:58

time period of October 2009 --

15:58

Q.

15:58

10

labs, or are we talking about --

15:58

11

A.

15:59

12

THE COURT:

15:59

13

THE WITNESS:

15:59

14

when the lab received this sample of SCR-100L, there's a

15:59

15

possibility that this sample was split up into different

15:59

16

samples.

15:59

17

15:59

18

same lot number and sample ID, can be on more than one

15:59

19

container.

15:59

20

BY MR. BREIT:

15:59

21

Q.

15:59

22

even on more than one container, it is a part of the product

15:59

23

that you were told, "take everything from the Macondo well,

15:59

24

anything used on the Macondo well, and put it in your office,

15:59

25

including 54573"?

Isn't that right?

They don't use a different sample

I would like to explain.

What I'm saying is that in this

October of 2009, meaning when the lab is securing these

When the lab received -Let him answer, Mr. Breit.


I'm saying that in October of 2009,

What I'm saying is that that sample ID, that

And you would agree with me, would you not, that if it's

OFFICIAL TRANSCRIPT

4784
TIMOTHY QUIRK - DIRECT

15:59

You don't leave out stuff that was used on Macondo

15:59

because you make a decision, "Well, no one needs it because

15:59

I've got a couple of extra bottles."

15:59

15:59

weren't you?

15:59

A.

16:00

there?

16:00

Q.

16:00

that was submitted into the record, Lot No. 6264 is the

16:00

10

16:00

11

16:00

12

16:00

13

16:00

14

this is, in fact, the sample ID that's the same one used on

16:00

15

April 17th, 2010, for whatever reason and however it happened,

16:00

16

you used the same sample ID chemical that had supposedly been

16:00

17

secured in your office before this date?

16:00

18

A.

16:00

19

SCR-100L that was used when Jesse submitted the test was a

16:00

20

sample from the Deepwater Horizon and not just Lab Stock 6264?

16:00

21

Q.

16:01

22

Again, if I could go to the SCR-100 line.

16:01

23

If you see here, SCR-100L, you see Lot No. 6264.

16:01

24

see source, Transocean, Tank No. 8.

16:01

25

lab, 10-22-09 date, and you see the exact same sample ID,

You were told to put all of it in your closet,

If it's part of the lab stock, then -- does it show a rig


Because if you scan it, it should show the rig.

I'm telling you, based on testimony that the judge has

Deepwater Horizon.
And if Mr. Godwin or anybody from Halliburton wants
to tell me that that's not, then I'm sure we'll hear about it.
So if this is, in fact, the Deepwater Horizon, and

Now, as I'm sitting here now, do we know for sure that the

Let's go back to 4566, and we'll see what he said.

You see the exact same

OFFICIAL TRANSCRIPT

You

4785
TIMOTHY QUIRK - DIRECT

16:01

54573.

16:01

A.

16:01

the SCR-100L.

16:01

Q.

16:01

depositions for the judge that have been taken, Mr. Broussard

16:01

and Mr. Morgan.

16:01

it's not, I'm sure we'll hear about it.

16:01

So if Mr. Gagliano used the sample ID 54573 on his

16:01

test on April 17th, which is the rig sample that was used to

16:01

10

decide whether or not to use this cement down the well on

16:01

11

April 20th and April 21st, it is, in fact, the same sample ID

16:02

12

that you used on May 28th?

16:02

13

A.

It --

16:02

14

Q.

Appears to be, doesn't it?

16:02

15

A.

All I'm trying to say is that I don't -- I can't tell by

16:02

16

looking at this that that's necessarily a Horizon sample, is

16:02

17

what I'm saying.

16:02

18

Q.

16:02

19

16:02

20

please -- May 29th, 2010, the second test that you were doing

16:02

21

for the two gentlemen in Houston.

16:02

22

16:02

23

going to represent to you is the Deepwater Horizon, lab date of

16:02

24

October 22nd, 2009, sample ID 54573.

16:02

25

But you don't see Transocean in the blank there next to

Again, I'll represent to you that there are at least two

Okay.

6264 is, in fact, the Deepwater Horizon.

If

Let's go to 5593.4.

This would be your lab sheet, Tim Quirk -- top third,

And once again, SCR-100L, Lot No. 6264, which I'm

Again, that is the same exact lab sample ID number


OFFICIAL TRANSCRIPT

4786
TIMOTHY QUIRK - DIRECT

16:02

for the April 17th test by Mr. Gagliano, is it not?

16:03

A.

Yes.

16:03

Q.

Now, let's switch subjects for a second.

16:03

Jesse Gagliano had recommended the BP Kodiak cement that

16:03

contained the D-Air 3000.

16:03

A.

This weekend.

16:03

Q.

So any time between April of 2010 to August of 2012 you

16:03

never knew, as the head of the lab in Broussard, that Jesse

16:03

Gagliano had recommended a lab -- recommend that BP use the

16:03

10

Kodiak cement that had D-Air 3000.

16:03

11

A.

The Kodiak blend?

16:03

12

Q.

The Kodiak blend was used -- half a dozen witnesses or

16:03

13

more -- that was recommended by Jesse Gagliano to BP that

16:03

14

included the D-Air 3000.

16:03

15

the first time?

16:04

16

A.

16:04

17

understand what you're asking me.

16:04

18

Q.

16:04

19

cement blend that Jesse Gagliano represented to BP to be the

16:04

20

right blend for this well had D-Air 3000.

16:04

21

A.

16:04

22

Yes, I've been knowing that the blend had D-Air 3000.

16:04

23

Q.

16:04

24

for the first time that Jesse Gagliano represented to BP that

16:04

25

it would be a good choice to take the Kodiak cement blend that

You knew that

Did you find that out?

You never heard that?

You just heard that this weekend for

Please rephrase the question.

I want to make certain I

I want to know when is the first time you knew that the

Okay.

You were saying Kodiak.

And that's -- D-Air 3000.

Well, let me ask you this question.

OFFICIAL TRANSCRIPT

When did you find out

4787
TIMOTHY QUIRK - DIRECT

16:04

had been left over on the Kodiak well on the Deepwater Horizon

16:04

when it moved over to Macondo?

16:04

A.

16:04

they were Kodiak samples, but I didn't -- specific to the

16:04

cement, I didn't know that the samples of cement that were from

16:04

Kodiak were used for Macondo.

16:05

Q.

16:05

in August of 2012 did you ever find out that Jesse Gagliano had

16:05

recommended to BP that this specific Kodiak cement slurry that

16:05

10

contained D-Air 3000 should be used on the Macondo well?

16:05

11

A.

16:05

12

samples.

16:05

13

Q.

16:05

14

recommended a design that had come from Kodiak that included

16:05

15

D-Air 3000?

16:05

16

A.

16:05

17

were samples of -- were the same recipe, same blend; right.

16:05

18

Q.

16:05

19

asked to design a foam for BP, that it not be blended with

16:05

20

D-Air 3000; correct?

16:05

21

A.

16:05

22

D-Air 3000.

16:05

23

Q.

16:06

24

foam cement, like the foam cement that was used on the

16:06

25

Deepwater Horizon?

Did you ever hear that?

I didn't know anything about specific cement.

I knew that

I didn't know that.

So from no time between April of 2010 until when you left

I knew of the design.

I didn't know about specific cement

When you say you knew of the design, you knew that he had

Just in the list that I put together, you know, that there

Okay.

And you would prefer, if you had been the person

Ideally, you wouldn't want to design it with the

You would agree that certain additives can destabilize

OFFICIAL TRANSCRIPT

4788
TIMOTHY QUIRK - DIRECT

16:06

A.

Certain additives, yes.

16:06

Q.

Now, are you familiar with the Halliburton Global

16:06

Laboratory Best Practices, TREX-4347-1848-1?

16:06

16:06

familiar with Halliburton's Global Laboratory Best Practices?

16:06

A.

Yes.

16:06

Q.

And you would agree that the best practices of

16:06

Halliburton, this particular document, July of 2009, the

16:06

defoamer is for base slurry testing purposes only and should

16:06

10

not be included in the foam slurry tests outlined in this

16:06

11

section or in actual job designs.

16:06

12

16:06

13

said, to everyone in the lab, don't use defoamers for an actual

16:06

14

job design?

16:06

15

A.

That's what I read there.

16:06

16

Q.

And that's correct; right?

16:06

17

A.

Right.

16:06

18

Q.

And you expected all of your lab people to know that?

16:07

19

A.

I mean, it's -- it's global best practices.

16:07

20

Q.

Now, are you familiar with Halliburton's technology

16:07

21

bulletin on Zone Sealant 2000, TREX-5570?

16:07

22

This is a technology bulletin on Zone Sealant 2000.

16:07

23

MR. BREIT:

16:07

24

section.

16:07

25

you very much.

First of all, are you familiar -- or were you

You would agree that Halliburton's best practices

You knew that?

And then 5570.3, please, compatibility

Just that section right there, please, Carl.

OFFICIAL TRANSCRIPT

Thank

4789
TIMOTHY QUIRK - DIRECT

15:59

BY MR. BREIT:

15:59

Q.

16:07

dispersants."

16:07

the foam."

16:07

Now, you were aware of that Halliburton

16:07

technology bulletin, weren't you, prior to April 20th?

16:07

A.

16:07

last time I read it or memorized it, but I'm sure I read it in

16:07

the past.

16:07

10

Q.

16:07

11

who is in the lab but designing cement slurry, to know that

16:08

12

D-Air, defoamers, and dispersants will destabilize a foam.

16:08

13

Wouldn't you expect that?

16:08

14

A.

16:08

15

know -- I don't know -- I'm not aware of his knowledge.

16:08

16

Q.

16:08

17

goes around to everyone, and people should read it and should

16:08

18

be aware of the fact that these materials would destabilize the

16:08

19

foam?

16:08

20

A.

16:08

21

something that you want to --

16:08

22

Q.

16:08

23

aware of that; right?

16:08

24

A.

That it can destabilize the foam; right.

16:08

25

Q.

And that SCR-100 is a dispersant?

"Compatibility.

Yes.

Defoamers.

Do not use defoamers or

They will -- "These materials will destabilize

I mean, I can't say that I -- I can't tell you the

You would expect your lab people, such as Jesse Gagliano,

I would rather not speak for Jesse, because I don't

You would agree that the Halliburton technology bulletin

Well, it's a global best practice.

No dispersants; correct?

So, yes.

I mean, it's

Destabilizes the foam.

OFFICIAL TRANSCRIPT

You were

4790
TIMOTHY QUIRK - DIRECT

16:08

A.

It's a --

16:08

Q.

It's a dispersant?

16:08

A.

It's a retarder with secondary dispersing properties.

16:08

Q.

Now, you're familiar with the Halliburton Foam Cementing

16:08

Operations Manual, 745.16.1?

16:09

A.

16:09

working with SCR-100, it's a disperse -- it's a retarder with

16:09

secondary dispersant properties.

16:09

temperature, that -- that changes.

16:09

10

Q.

16:09

11

suggests and recommends that dispersants, in any purpose, might

16:09

12

destabilize foam and shouldn't be used.

16:09

13

that; right?

16:09

14

A.

Based on what you just read.

16:09

15

Q.

Now, let me show you the Halliburton Foam Cementing

16:09

16

Operations Manual.

16:09

17

before you left?

16:09

18

A.

The foam cementing manual?

16:09

19

Q.

Halliburton's Foam Cementing Operations Manual.

16:09

20

Table 2.1 from that manual.

16:09

21

A.

I can't say that I'm that familiar with that.

16:09

22

Q.

Would you agree that this particular document, which I

16:09

23

represent to you is Table 2.1 from page 16 of that particular

16:09

24

manual, says that defoamers, such as D-Air, and dispersants,

16:10

25

are incompatible with foam cement?

I'd like to add something.

SCR -- to my knowledge, and

But as it's exposed to

But again, Halliburton, in its own technological bulletin,

You would agree with

Are you familiar with that, or were you

OFFICIAL TRANSCRIPT

This is

4791
TIMOTHY QUIRK - DIRECT

16:10

Again, reaffirming something that was already in

16:10

another manual.

16:10

A.

Okay.

16:10

Q.

You would agree with that, right, those two things?

16:10

A.

Yes.

16:10

foam.

16:10

Q.

16:10

15:59

15:59

10

Q.

16:10

11

would want to see tests run on the final slurry before it's

16:10

12

sent down the well; isn't that right?

16:10

13

A.

Yes, I would agree with that.

16:10

14

Q.

And you are aware of the fact that Mr. Gagliano did not

16:10

15

test the final slurry that went down that well?

16:10

16

A.

16:10

17

16:10

18

some clarity as to what he's talking about, "testing"?

16:10

19

there were multiple tests that were run.

16:10

20

16:10

21

BY MR. BREIT:

16:10

22

Q.

16:10

23

.09.

16:11

24

A.

Okay.

16:11

25

Q.

Are you aware of the fact that Jesse Gagliano never asked

I agree that a true dispersant is not ideal for

Now -MR. BREIT:

Thank you, Carl.

BY MR. BREIT:
Now, you would agree with me, as a lab manager, that you

Did not test -MR. UNDERHILL:

MR. BREIT:

Objection, Your Honor.

Can we get
I mean,

I'll focus it, Your Honor.

The SCR-100 slurry -- that was put in the slurry -- was a


That was the one that finally went down into the well.

OFFICIAL TRANSCRIPT

4792
TIMOTHY QUIRK - DIRECT

16:11

for or ever had a lab final test with that particular .09?

16:11

16:11

BY MR. BREIT:

16:11

Q.

16:11

aware of that?

16:11

MR. HILL:

16:11

tests are you talking about?

16:11

16:11

16:11

10

16:11

11

MR. HILL:

16:11

12

THE COURT:

16:11

13

question, asking him if he's aware -- if he knows this to be

16:11

14

true or not.

16:11

15

BY MR. BREIT:

16:11

16

Q.

16:11

17

weigh-up sheet, which included .09 SCR-100 retardant, was never

16:11

18

given a full, final testing before it was used in the well?

16:11

19

A.

16:12

20

That's why I'm wanting to know what specific testing, because I

16:12

21

remember seeing thickening time tests.

16:12

22

tests, a couple -- I think maybe two thickening time tests.

16:12

23

Now, the timingwise, I would have to -- you would

16:12

24

have to show me that.

16:12

25

Q.

MR. HILL:

Objection, misstates the record.

Did he ask for it and then cancel the tests?

Are you

Your Honor, maybe I can be helpful.

What

The final slurry that had .09, that was

MR. BREIT:

eventually used down the well, never got the final testing with
the .09 in it.
Same objection.
Hold on.

Why don't you restate the

Do you know to be true that the April 17th, 2010 lab

The -- what I've looked at shows testing on -- on that.

I remember seeing UCA

Did you ever become aware of the fact that the .09
OFFICIAL TRANSCRIPT

4793
TIMOTHY QUIRK - DIRECT

16:12

retardant SCR-100 that was used in this well, that Jesse

16:12

Gagliano had ordered up the tests and then canceled that test

16:12

before it was completed?

16:12

16:12

16:12

THE COURT:

16:12

THE WITNESS:

16:12

BY MR. BREIT:

16:12

Q.

16:12

10

16:12

11

16:12

12

16:12

13

MR. BREIT:

16:12

14

THE WITNESS:

16:12

15

testing that was performed on that 73909 Part 2, where I think

16:12

16

they ran two thickening times and the UCA tests.

16:13

17

16:13

18

after the job, I don't know right now.

16:13

19

recall.

16:13

20

BY MR. BREIT:

16:13

21

Q.

16:13

22

of 2012, did you ever become aware of the fact that Jesse

16:13

23

Gagliano had ordered up testing that he canceled before it was

16:13

24

completed?

16:13

25

A.

MR. HILL:

Did you ever become aware of that?

Objection, again.

Misstates the record.

We haven't even identified the test he's talking about.


Overruled.
I've looked at --

If you're not aware of it, then just tell us you're not

aware of it.
THE COURT:
answer.

Well, wait a minute, Mr. Breit.

Let him

You asked the question, let him answer.


I apologize, Your Honor.
What I'm trying to say is I looked at

Whether or not that was performed before or


Right now I can't

I don't remember.

At any time during the time period of April through August

Well, parts of the test.


OFFICIAL TRANSCRIPT

4794
TIMOTHY QUIRK - DIRECT

16:13

Q.

Were never completed?

16:13

A.

Part -- right.

16:13

Q.

And parts of those tests would have been tests that would

16:13

have been in the full battery of tests that would normally be

16:13

done on a slurry before it goes down the well; isn't that

16:13

right?

16:13

A.

In some cases, yes.

16:13

Q.

But it wasn't in this case, was it?

16:13

A.

No.

16:13

10

16:13

11

16:13

12

that jobs are pumped before every test is completed on a

16:14

13

specific test.

16:14

14

communication I've had over the years.

16:14

15

16:14

16

they'll just get results later.

16:14

17

fluid loss and a free water test.

16:14

18

Q.

16:14

19

and cancel them, and part of those tests no one ever found out

16:14

20

the answers to before the well was pumped?

16:14

21

A.

I remember seeing that he canceled some tests.

16:14

22

Q.

That's all I wanted to know.

16:14

23

Now, let me switch subjects on you.

16:14

24

Do you know what a multiple analysis cement slurry

16:14

25

That's correct.

What I'm getting at is it's -- I'm not -- very seldom

in my position would I know when a job is actually pumped.


I know that, based on communication over the years,

That part I know just based on some of the

An example would be like a UCA test.

My simple question is:

Rheology test.

You know,
Possibly a

Did Gagliano order up some tests

analyzer is?
OFFICIAL TRANSCRIPT

4795
TIMOTHY QUIRK - DIRECT

16:14

A.

Yes.

Yes, I do.

16:14

Q.

And you know that a MAC analyzer's purpose is to measure

16:14

static gel strength of cement?

16:14

A.

That's correct.

16:14

Q.

No MAC analyzer was used prior to April 20th, 2010, was

16:14

it?

Not that you're aware of?

16:14

A.

Not that I'm aware of.

16:14

Q.

And a MAC analyzer tells you how long it takes a slurry to

16:14

go from a liquid state to a gel state up to 500 pounds per

16:15

10

100 square feet; isn't that correct?

16:15

11

A.

That's correct.

16:15

12

Q.

That information is not available unless you run that

16:15

13

test?

16:15

14

A.

16:15

15

be -- but, no, that's correct.

16:15

16

the results.

16:15

17

Q.

16:15

18

wanted it so they could get the answer to that question prior

16:15

19

to April 20th, 2010, would have been Jesse Gagliano.

16:15

20

never asked for it?

16:15

21

A.

16:15

22

handling the account, possibly somebody else could do it, could

16:15

23

order it.

16:15

24

Q.

16:15

25

this case, Jesse Gagliano -- is the one who's supposed to order

Unless a specific test had been run similar to that would


You have to run the test to get

And the person who would have ordered that test, if they

But he

I mean, I don't -- if there's more than one person

So the answer to the question is the account manager -- in

OFFICIAL TRANSCRIPT

4796
TIMOTHY QUIRK - DIRECT

16:15

that test if he wants it?

16:15

A.

16:15

order --

16:15

Q.

16:15

you've looked.

16:15

prior to April 20th, did they?

16:16

else?

16:16

A.

Not that I'm aware of.

16:16

Q.

Okay.

16:16

10

16:16

11

products that you had been asked to secure in your office;

16:16

12

correct?

16:16

13

A.

Yes.

16:16

14

Q.

And I believe you described those products that you were

16:16

15

asked to put in your office as coming from the Macondo well.

16:16

16

Correct?

16:16

17

A.

From the Horizon rig.

16:16

18

Q.

From the Deepwater Horizon rig that had been at Macondo;

16:16

19

correct?

16:16

20

A.

Initially, I thought it was all just Horizon rig samples.

16:16

21

Q.

So the Deepwater Horizon samples, that's what you were

16:16

22

asked to put in your closet; correct?

16:16

23

A.

That's what I recall initially, right.

16:16

24

Q.

Now, let's look to see what was put in and was cataloged

16:16

25

on April 30th, 2010, after Tony Angelle had asked you to do it.

Well, it makes sense.

But someone else could also

Well, since April 2010 until August of 2012, I'm sure


Nobody had ordered or asked for a MAC analyzer
Not Mr. Gagliano and no one

Now, let me back up briefly to another subject.

You knew that there had been products from the lab,

OFFICIAL TRANSCRIPT

4797
TIMOTHY QUIRK - DIRECT

16:16

And let's look at TREX-48002.

48002 first.

16:17

I'm doing to represent to you that this came from

16:17

Tony Angelle's computer custodial file on April 30th, 2010,

16:17

showing which products were inside the closet, not yet secured

16:17

in an air-conditioned locker, on April 30th, 2010.

16:17

16:17

A.

Yes.

16:17

Q.

All right.

16:17

16:17

10

in that closet here in the second paragraph.

16:17

11

BY MR. BREIT:

16:17

12

Q.

16:17

13

No. 2, Kodiak, bar code sample date February 23rd, 2010 -- I'm

16:17

14

sorry -- there you go.

16:17

15

5-gallon bucket.

16:18

16

And this represents, does it not, that there was a --

16:18

17

half of a 5-gallon bucket in your closet that had come from the

16:18

18

Deepwater Horizon and marked coming from Well No. 2 at the

16:18

19

Kodiak; is that right?

16:18

20

A.

16:18

21

16:18

22

first page of 48002, if I can, please.

16:18

23

BY MR. BREIT:

16:18

24

Q.

16:18

25

Horizon rig.

Have you ever seen a sheet like this?

MR. BREIT:

Let's go to 48002.2 and look at what was

And you see here in your closet, on April 30th, is Well

Thank you -- with lab sample ID 63981,

I don't know that that was in the closet.


MR. BREIT:

All right.

Well, let's go back to the

Materials -- materials currently in lab for BP/Transocean

OFFICIAL TRANSCRIPT

4798
TIMOTHY QUIRK - DIRECT

16:18

Now, these are the things that were in the rig from

16:18

the Transocean Horizon rig that were placed somehow, or

16:18

cataloged, on April 30th, 2010.

16:18

would you not?

16:18

A.

16:18

that was in the locker.

16:18

in inventory.

16:18

Q.

16:19

you gathered up, from the Transocean Horizon rig, these

16:19

10

16:19

11

16:19

12

BY MR. BREIT:

16:19

13

Q.

16:19

14

there was this particular 5-gallon bucket with half of it still

16:19

15

remaining with particular cement blend from the Kodiak well

16:19

16

with this lab sample 63981.

16:19

17

16:19

18

A.

Yes.

16:19

19

Q.

And this particular lab sample ID of 63981 specifically

16:19

20

identifies a particular cement slurry so that you'll know, if

16:19

21

ever there's a request later, exactly what the blend looked

16:19

22

like that was used; correct?

16:19

23

A.

Yes.

16:19

24

Q.

Now, let's look at TREX-559 for a second -- 5595, I

16:19

25

apologize.

Right.

Okay.

You would agree with me there,

That's the first page of that document.

I'm just trying to clarify that I don't know that


That was just from what we gathered up

So on April 30th, 2010, you'll agree with me that

materials.
MR. BREIT:

And now let's go to 48002.2.

And in those particular materials that you gathered up,

You'd agree with me there, you had gathered it up?

5595.

This is a lab sheet dated March 7th, 2010,


OFFICIAL TRANSCRIPT

4799
TIMOTHY QUIRK - DIRECT

16:20

Jesse Gagliano, from the Mississippi Canyon 252, which would be

16:20

Macondo well; correct?

16:20

A.

Yes.

16:20

Q.

And this particular cement weigh-up sheet for March 7th,

16:20

2010 lists --

16:20

16:20

Carl.

16:20

BY MR. BREIT:

16:20

Q.

16:20

10

particular March 7th test by Jesse Gagliano came from the

16:20

11

Transocean, that they have the exact same date of

16:20

12

February 23rd, 2010, and they have the exact same sample ID

16:20

13

number, 63981, which is the exact same sample ID of those

16:20

14

materials that were put in your office on April 30th, 2010.

16:20

15

16:20

16

16:20

17

16:20

18

16:21

19

16:21

20

it's not -- well, go ahead.

16:21

21

BY MR. BREIT:

16:21

22

Q.

I'm sorry.

16:21

23

A.

I'm sorry?

16:21

24

Q.

It was the same sample ID, was it not, 63981?

16:21

25

February 23rd, 2010, wasn't it?

MR. BREIT:

And now go to the materials section,

And this shows that the materials that were used for this

Would you agree with me that's the same sample ID?


A.

Yes, based on what I see here.


MR. BREIT:

Now, let's go back, if we could, to

48002.2.
THE WITNESS:

But that sample right there is not --

Let me -- finish your answer.

OFFICIAL TRANSCRIPT

Same date,

4800
TIMOTHY QUIRK - DIRECT

16:21

A.

Yeah.

16:21

Q.

Yes?

16:21

A.

Yeah, I think so.

16:21

Q.

Now, let's look at what was in the Kodiak cement here that

16:21

was in your office on April 30th, 2010, and compare it to the

16:21

April 17th, 2010 test, TREX-3110.

16:21

16:21

BY MR. BREIT:

16:21

Q.

16:22

10

closet has the exact same ingredients as the Kodiak II cement.

16:22

11

Do you not see that?

16:22

12

A.

Yes, I see that.

16:22

13

Q.

And do you see here that your Kodiak cement has the exact

16:22

14

same -- every ingredient in the exact same amount; is that

16:22

15

right?

16:22

16

A.

Yes, I see that.

16:22

17

Q.

Now, if you look at the Kodiak cement with lab sample

16:22

18

63981 --

16:22

19

16:22

20

April 17th -- I'm sorry -- back to the March 7th, I'm sorry,

16:22

21

which would be 5595.

16:23

22

63981.

16:23

23

BY MR. BREIT:

16:23

24

Q.

16:23

25

closet from the Kodiak cement blend as you did from the Macondo

MR. BREIT:

So TREX-3110-48002.2, please, Carl.

And if you see here, the Macondo blend that's in your

MR. BREIT:

Let's go look at TREX-3110 by itself, the

Again, the materials section, sample ID,

And so on April 30th, you had the exact chemicals in your

OFFICIAL TRANSCRIPT

4801
TIMOTHY QUIRK - DIRECT

16:23

blend.

They were exactly identical; correct?

16:23

A.

They were in the -- they weren't in the closet.

16:23

Q.

They were in your office?

16:23

office, as coming from the Transocean rig; correct?

16:23

A.

At what point were they in my office?

16:23

Q.

April 30th.

16:23

A.

Yes.

16:23

Q.

On April 30th, you had gathered up those things and you

16:23

were told to secure those things so that no one would take

16:23

10

them, no one would touch them, and nothing would happen to

16:23

11

them; correct?

16:23

12

A.

Well, there was a misunderstanding about that.

16:23

13

Q.

Well, before we get to the misunderstanding, you were told

16:23

14

by higher-ups to put in your closet everything from the

16:24

15

Transocean rig; and it included a bucket that said

16:24

16

"Transocean," and it had the Kodiak cement which was the exact

16:24

17

identical chemical blend makeup as the cement that was used on

16:24

18

the Deepwater Horizon on April 17th, wasn't it?

16:24

19

A.

The ingredients were the same.

16:24

20

Q.

Now, you would agree with me that despite being told that

16:24

21

those materials should remain in your office and secured and

16:24

22

not touched, that somehow, between April 30th, 2010 and

16:24

23

July 20, 2010, the cement bucket that had the word "Kodiak" and

16:24

24

"Transocean rig" somehow got moved and disappeared?

16:24

25

A.

They were secured in your

At the time that I gathered up everything, right.

All of the samples that were Kodiak got moved.


OFFICIAL TRANSCRIPT

4802
TIMOTHY QUIRK - DIRECT

16:24

Q.

The question is:

16:24

closet, the April 30th sample that had 63981, that was used by

16:24

Jesse Gagliano on March 7th, that you were supposed to secure

16:25

in your office so that no one would touch it, that had the

16:25

exact chemical makeup of the Macondo well cement, that was used

16:25

on April 17th, somehow, between April 30th and July 20th, it

16:25

went missing, didn't it?

16:25

A.

16:25

Tony Angelle's instructions.

16:25

10

secure the Macondo well cement samples.

16:25

11

was not Macondo and put it in our warehouse.

16:25

12

Q.

16:25

13

Transocean rig and you had, in fact, secured the Transocean rig

16:25

14

cement that had been used by Jesse Gagliano on March 7th on the

16:25

15

Macondo well -- let me finish my question, please, sir -- it's

16:25

16

the exact same chemical ID -- are you telling me that

16:25

17

everything -- somehow, between April 30th, you decided to move

16:26

18

it out, not put it in the locked locker, and somehow up until

16:26

19

last week, Wednesday, is the first time in three years someone

16:26

20

from Halliburton realized that the Kodiak cement that had been

16:26

21

used on the Macondo well was sitting on a shelf in a closet?

16:26

22

A.

16:26

23

labeled "Kodiak," whatever that other location was, was used

16:26

24

for Macondo.

16:26

25

sample.

No, sir.

Was the sample that you had put in your

What I'm trying to say is that I misunderstood


And those instructions were to
I took everything that

So after you were told to secure everything from the

Yes.

I did not know that the sample of cement that was

I have no way of knowing that by looking at that

All I see is Kodiak from some other location.


OFFICIAL TRANSCRIPT

4803
TIMOTHY QUIRK - DIRECT

16:26

Q.

So you moved it?

16:26

A.

I was asked to secure the Macondo well Mississippi Canyon

16:26

sample.

16:26

corrected me, so I took those samples, put them back in -- I

16:26

didn't discard them.

16:26

secured the Macondo well cement samples.

16:26

16:26

Q.

16:26

they didn't make it into the air-conditioned locker, after the

16:27

10

United States Government issued you a subpoena, after three

16:27

11

different commissions looking for the cement to test on the

16:27

12

Macondo well, you didn't think for a second, Hey, maybe I

16:27

13

should look at the cement that I had secured from the

16:27

14

Transocean rig that had the exact same chemical ID because

16:27

15

someone may be looking for it?

16:27

16

A.

16:27

17

Macondo well cement, put it -- why wouldn't I grab the other

16:27

18

cement sample and put it in?

16:27

19

16:27

20

any -- all of my history, if I look at a cement sample labeled

16:27

21

a different well and a different location, how am I to assume

16:27

22

that that's -- it's a different location, a different rig?

16:27

23

see it as a complete -- not being the same cement.

16:27

24

that's my -- that's the truth.

16:27

25

Q.

That's what I did.

I misunderstood him initially.

He

I put them back in the warehouse and

I had no way of knowing.


So is it your testimony that after July 20th, when somehow

Sir, with all due respect, if I was going to take the

I had no reason not to do that.

I did not know that -- I did not -- I had no --

That's --

Well, you understood April 30th, when you were securing


OFFICIAL TRANSCRIPT

4804
TIMOTHY QUIRK - DIRECT

16:27

materials from the Transocean rig, that they included the

16:27

Kodiak cement in that 5-gallon bucket and it included at least

16:27

two or three other Kodiak cement plugs.

16:28

16:28

A.

16:28

That's --

16:28

Q.

16:28

one of those buckets of Kodiak, one bucket sitting on an upper

16:28

shelf, was found three years after the fact, but no other

16:28

10

Kodiak cement was found, just the one that had been removed

16:28

11

from your office on April 30th, until last week?

16:28

12

explain that, why only one of three managed to be there?

16:28

13

you were going to move all of the Kodiak cement out, why just

16:28

14

one?

16:28

15

A.

16:28

16

was not -- I wasn't -- I was not paying attention to whether it

16:28

17

was Kodiak.

16:28

18

I was just looking at what was Macondo.

16:28

19

that wasn't Macondo was removed from -- was not put in the

16:28

20

locker.

16:28

21

Q.

16:28

22

Houston call you and say, "Hey, we're trying to gather up these

16:28

23

chemicals"?

16:28

24

We already know that on May 28th and May 29th, you

16:28

25

used the SCR-100L that had been used on this particular well

Do you remember that?


They had other samples that weren't Macondo well.

And can you explain to this Court why, a week ago, only

Can you
If

I didn't say -- I'm saying every other -- anything that

That meant nothing to me.


Anything

I didn't --

But you knew there was a subpoena.

Didn't anyone from

OFFICIAL TRANSCRIPT

4805
TIMOTHY QUIRK - DIRECT

16:28

from whatever bottle you got it from.

Did anyone ask you,

16:29

"Where is the rest of the cement?"

16:29

A.

16:29

samples.

16:29

MR. BREIT:

I have no other questions, Your Honor.

16:29

THE COURT:

Mr. Quirk, I want to clarify something.

16:29

The materials, the samples, whatever they were called, that you

16:29

originally secured in your office --

16:29

16:29

10

THE COURT:

16:29

11

THE WITNESS:

16:29

12

16:29

13

16:29

14

had originally moved into your office all these samples, and

16:29

15

then at some point you -- you've explained why you moved some

16:29

16

out.

16:29

17

16:29

18

Angelle asked me to gather the samples, I gathered the -- all

16:29

19

the Transocean rig samples.

16:29

20

everything that I had inventoried, he said that we just need to

16:30

21

secure the Macondo well samples.

16:30

22

16:30

23

samples and put those samples into the locker and secured it.

16:30

24

Everything else I put back into the storage area in our storage

16:30

25

warehouse.

I don't recall anybody talking to me about the Kodiak

THE WITNESS:

Yes, sir.

-- where did those come from?


Just from my material storage area

where we retain all of our samples that come in from rigs.


THE COURT:

So I'm just trying to understand.

So you

Is that what -THE WITNESS:

Yeah.

I gathered up -- when Tony

And then when I gave him a list of

So I made a new list with just the Macondo well

OFFICIAL TRANSCRIPT

4806
TIMOTHY QUIRK - DIRECT

16:30

16:30

16:30

THE WITNESS:

16:30

THE COURT:

Okay.

16:30

MR. BREIT:

Two follow-ups, Your Honor, if I could.

16:30

BY MR. BREIT:

16:30

Q.

16:30

the chemical additives, over time?

16:30

A.

There's a shelf life on cement and additives.

16:30

10

Q.

And after that shelf life, you can't test the same things,

16:30

11

can you?

16:30

12

A.

16:30

13

of quality control test, I assume, to determine whether or not

16:30

14

it would act like, you know -- or it would behave --

16:30

15

Q.

16:30

16

degrades over time?

16:31

17

A.

16:31

18

that could happen.

16:31

19

Q.

16:31

20

an air-controlled unit like your locker, is it?

16:31

21

A.

16:31

22

MR. BREIT:

Okay.

16:31

23

THE COURT:

United States have any questions?

16:31

24

MS. McCLELLAN:

16:31

25

THE COURT:

What exactly is it that the -- the cement

that was located last week, where do that come from?


In our storage warehouse.
Are you finished?

You would agree with me that those cements degrade, as do

You don't get the same results with the same tests?

I don't know that for a fact, but you could run some type

And you would agree they have a shelf life, though, that

It depended on what it's exposed to.

I could see where

You would agree that the closet, the storage closet, isn't

It's climate-controlled.
Thank you, Your Honor.

Yes.

Good afternoon, Your Honor.

Mr. Quirk, Jessica McClellan for the United


OFFICIAL TRANSCRIPT

4807
TIMOTHY QUIRK - DIRECT

16:31

States.

16:31

And I have the witness on cross-examination.

16:31

If we could please have Demonstrative 3602.

16:31

The Court has heard testimony about the printed

16:31

lab weigh-up sheets that Halliburton used pertaining to the

16:31

Macondo well's production casing and cement job.

16:31

you've heard about a few of these lab weigh-up sheets.

16:31

also heard over the past few weeks about a few of the lab

16:31

reports that were generated by Halliburton's account

16:31

10

16:32

11

In order to avoid duplication today, I'd like to

16:32

12

focus on the internal link that was the method of communication

16:32

13

between the account representative and the cement laboratory,

16:32

14

which was the Viking system.

16:32

15

16:32

16

screen shot hasn't been laid with any witness, because those

16:32

17

exhibits were produced after --

16:32

18

16:32

19

16:32

20

16:32

21

through -- for Your Honor's convenience -- you had expressed

16:32

22

frustration last week with the way that the plaintiffs had

16:32

23

presented the lab testing information because there were a lot

16:32

24

of tests.

16:32

25

Your Honor,
You've

representative, Mr. Gagliano, and provided to BP.

Your Honor, the foundation laid for the Viking

THE COURT:

I'm trying to understand -- first of all,

the United States hasn't sued Halliburton, have you?


MS. McCLELLAN:

And so we
THE COURT:

Your Honor, we'd like to walk

-Are you talking about the chain of


OFFICIAL TRANSCRIPT

4808
TIMOTHY QUIRK - DIRECT

16:32

custody here?

16:32

16:32

be addressing any of the territories that Mr. Breit has just

16:32

covered with the witness.

16:32

the flow of information within Halliburton's lab.

16:33

THE COURT:

16:33

MS. McCLELLAN:

16:33

shots, we do believe that Mr. Quirk would be a proper

16:33

custodian.

16:33

10

16:33

11

16:33

12

16:33

13

16:33

14

BY MS. McCLELLAN:

16:33

15

Q.

16:33

16

are you?

16:33

17

A.

No, ma'am.

16:33

18

Q.

But in February and April of 2010, you were employed by

16:33

19

Halliburton?

16:33

20

A.

Yes.

16:33

21

Q.

And you were the area lab manager for Halliburton's Gulf

16:33

22

of Mexico region?

16:33

23

A.

That's correct, the fluids lab.

16:33

24

Q.

In February and April of 2010, how did the Broussard

16:33

25

cement lab receive test requests?

MS. McCLELLAN:

No, Your Honor.

We are not going to

Instead, we would just like to show

Go ahead.
So with respect to the Viking screen

He was Halliburton's 30(b)(6) witness for some of

the February and April lab testing.


THE COURT:

If you have any questions for him, go

ahead and ask.


CROSS-EXAMINATION

Mr. Quirk, you're not currently employed by Halliburton,

OFFICIAL TRANSCRIPT

4809
TIMOTHY QUIRK - CROSS

16:33

A.

Through the Viking lab database management system.

16:33

Q.

And you're familiar with that system as the former area

16:33

lab manager for Halliburton?

16:33

A.

Yes, ma'am.

16:33

Q.

Did the lab use the same system for reporting test

16:33

results?

16:34

A.

16:34

service coordinators, and everybody used -- everyone involved

16:34

used that system to generate a lab report.

16:34

10

Q.

16:34

11

a request had been submitted?

16:34

12

A.

16:34

13

results as it was given from the lab technicians.

16:34

14

Q.

16:34

15

16:34

16

16:34

17

16:34

18

information pertaining to the Halliburton lab cement testing,

16:34

19

what I would like to do is with one test, use a side-by-side

16:34

20

comparison of the Viking screen shots with the lab weigh-up

16:34

21

sheets for the first test that was performed on the Macondo

16:34

22

slurry, which was the February thickening-time test, in order

16:34

23

to give the Court a clear and concise example as to how the

16:34

24

flow of information was at the Halliburton lab.

The system was designed for the labs and the engineers and

And Viking would allow a user to see the test stats after

The individual that submitted the request could see

Thank you.
MS. McCLELLAN:

If we could have TREX-37042.4.1 with

TREX-802-W.1.1.
Your Honor, to illustrate the flow of

25
OFFICIAL TRANSCRIPT

4810
TIMOTHY QUIRK - CROSS

16:35

BY MS. McCLELLAN:

16:35

Q.

16:35

screen shot for Viking from the February testing; and on the

16:35

right is the first weigh-up sheet, dated February the 10th.

16:35

16:35

the 802-W.1.2.

16:35

BY MS. McCLELLAN:

16:35

Q.

16:35

shot, as well as the weigh-up sheet on the bottom, both pertain

16:35

10

to Request ID 65112?

16:35

11

A.

16:35

12

top, but I will . . .

16:35

13

Q.

16:35

14

representative, Mr. Gagliano, who initiated this request in

16:35

15

Viking?

16:35

16

A.

16:35

17

16:36

18

802-W.1.4.

16:36

19

BY MS. McCLELLAN:

16:36

20

Q.

16:36

21

additives that were used are shown in Viking on the screen shot

16:36

22

on the top?

16:36

23

A.

Yes, I see that.

16:36

24

Q.

And it would have been Mr. Gagliano who specified the

16:36

25

additives to be used in the testing; correct?

So, Mr. Quirk, on the left, for orientation purposes, is a

MS. McCLELLAN:

If we could have TREX-37042.4.2 with

This is just a fly-out.

Mr. Quirk, do you recognize on top that the Viking screen

Yes, I guess it looks like it.

It's kind of blurry at the

As shown on the top, it was Halliburton's account

Yes.

I see that.
MS. McCLELLAN:

If we could have TREX-48193.3.2 with

Do you see on top that -- do you see on top that -- the

OFFICIAL TRANSCRIPT

4811
TIMOTHY QUIRK - CROSS

16:36

A.

That's correct.

16:36

Q.

And the additives are then reproduced dependent on the

16:36

bottom in the materials section of the weigh-up sheet?

16:36

A.

16:36

16:36

TREX-802-W.2.5.

16:36

BY MS. McCLELLAN:

16:36

Q.

16:36

Viking system as shown on the top; correct?

16:36

10

A.

That's correct.

16:36

11

Q.

And the tests were also printed on the weigh-up sheet on

16:36

12

the bottom that the lab used?

16:36

13

A.

Yes.

16:36

14

Q.

Both the screen shot and the weigh-up sheet show that each

16:36

15

test has a unique test ID?

16:37

16

A.

Yes.

16:37

17

Q.

And on the top in Viking, there's also a section for

16:37

18

conditions; correct?

16:37

19

A.

Yes, ma'am.

16:37

20

Q.

For example, Mr. Gagliano specified for the thickening

16:37

21

time test, he needed a five- to six-hour pump time window; is

16:37

22

that correct?

16:37

23

A.

That's correct.

16:37

24

Q.

And that condition, as well as the others, are all

16:37

25

reproduced on the bottom on the weigh-up sheet?

That's correct.
MS. McCLELLAN:

If we could have TREX-48193.4.3 with

Mr. Gagliano also specified the required test in the

OFFICIAL TRANSCRIPT

4812
TIMOTHY QUIRK - CROSS

16:37

A.

Yes, ma'am.

16:37

Q.

How was the lab notified that Mr. Gagliano had submitted

16:37

these requests in Viking for testing?

16:37

A.

16:37

as Jesse, or anyone, for that matter, would submit a request,

16:37

it would go into that queue, and the lab would recognize that

16:37

there's a test in the queue.

16:37

Q.

16:37

requirement of five to six hours, what would have been the

16:37

10

first thing that the lab did?

16:37

11

A.

16:38

12

know, search the database and he'd try to determine a volume of

16:38

13

additives -- of retarder in this case, if you're looking for

16:38

14

five to six hours.

16:38

15

to try to look at slurries that we tested or they would have

16:38

16

tested at that temperature, unless specific instructions -- for

16:38

17

example, you know, if he had tested maybe, you know, something

16:38

18

very similar, he may give specific instructions to the lab to

16:38

19

say "Just run this volume," in which case the lab would --

16:38

20

Q.

16:38

21

concentration to start testing with.

16:38

22

16:38

23

with TREX-802-W.1.6.

16:38

24

BY MS. McCLELLAN:

16:38

25

Q.

The system is designed with a request queue.

And as soon

So after receiving the test in the lab with a pump time

Unless specific instructions were given, they would, you

So SCR-100L, they would search the database

So in this instance, the lab first selected the retarder

MS. McCLELLAN:

If we could pull up TREX-48193.3.4

We see that the lab selected .10 gallons per sack of


OFFICIAL TRANSCRIPT

4813
TIMOTHY QUIRK - CROSS

16:38

SCR-100L retarder?

16:38

A.

16:38

that when Jesse submitted the request, that he started it with

16:39

.17 and the lab person agreed with that and just put it off the

16:39

weigh sheet.

16:39

originally request, I don't know.

16:39

Q.

16:39

concentration, they would then print the weigh-up sheet; would

16:39

that be the next step?

16:39

10

A.

That's correct.

16:39

11

Q.

If we could have TREX-802W.1.7, we see here that the lab

16:39

12

started the thickening time test on February the 11th, at 11:06

16:39

13

in the evening; is that correct?

16:39

14

A.

It looks like 11:06 p.m. on February 11th.

16:39

15

Q.

And if we could have Demonstrative 3601A, is what you just

16:39

16

saw on the weigh-up sheet showing that the first thickening

16:39

17

time test on the .10 gallons per sack retarder was started on

16:39

18

February 11th at 11:06 p.m.?

16:40

19

the weigh-up sheet?

16:40

20

A.

Is that what we just read?

16:40

21

Q.

That's correct.

16:40

22

A.

Okay.

16:40

23

right here.

16:40

24

Q.

16:40

25

Well, I don't know that for sure.

I mean, it's possible

Whether or not it was changed from Jesse's

Well, after the lab picker starting the retarder

Okay.

Is that accurately reflected on

I'm not familiar with what I'm looking at

This was generated by you, I guess, or somebody --

Yes, it is.
What we've tried to do for the Court is simplify all
OFFICIAL TRANSCRIPT

4814
TIMOTHY QUIRK - CROSS

16:40

of the weigh-up sheets and put in the dates and times of each

16:40

test starting, as well as some of the comments that are made.

16:40

A.

I'm sorry --

16:40

Q.

So my question is simply whether the entry that we just

16:40

looked at -- and we can look at it again -- TREX-802-W --

16:40

A.

16:40

slurry showed just now that we looked at.

16:40

know, in the recipe for the SCR-100L.

16:40

Q.

16:40

10

.10.

16:40

11

A.

Is that what we just looked at?

16:40

12

Q.

Yes.

16:40

13

A.

Is that what you showed me?

16:40

14

Q.

Yes.

16:40

15

A.

Okay.

16:40

16

thought that was a 7.

16:40

17

Q.

Thank you.

16:40

18

A.

Okay.

16:41

19

16:41

20

TREX-802W.1.7.

16:41

21

BY MS. McCLELLAN:

16:41

22

Q.

16:41

23

lab technician can fill in the results of the tests?

16:41

24

A.

Yes, ma'am.

16:41

25

Q.

And as we see for the first thickening time test, the time

I'm sorry, but I thought it was .17 that we had that the
I may be -- you

The first retarded -- starting retarder concentration was

This is just not clear.

I looked at that and I

Okay.

MS. McCLELLAN:

All right.

If we could go back to

Mr. Quirk, the weigh-up sheet also has spaces where the

OFFICIAL TRANSCRIPT

4815
TIMOTHY QUIRK - CROSS

16:41

that it took to reach 70 BC -- which is when it would be

16:41

unpumpable; correct?

16:41

A.

Yes, ma'am.

16:41

Q.

That was three hours and four minutes?

16:41

A.

Yes, ma'am.

16:41

Q.

And so that thickening time result of three hours and four

16:41

minutes didn't meet the requirement that Mr. Gagliano had

16:41

specified of five to six hours, did it?

16:41

A.

16:41

10

16:41

11

BY MS. McCLELLAN:

16:41

12

Q.

16:41

13

six-hour requirement, the result was still entered into the

16:41

14

Viking as shown on the screen; correct?

16:41

15

A.

Yes, ma'am.

16:41

16

Q.

In February and April of 2010, did Halliburton's lab

16:41

17

routinely enter test results into Viking even if the result did

16:41

18

not meet the requirement?

16:41

19

A.

Yes, ma'am.

16:41

20

Q.

And why was that so?

16:42

21

A.

Just to have, you know, a record of progression to

16:42

22

establish the criteria -- test criteria.

16:42

23

16:42

24

That's correct.
MS. McCLELLAN:

If we could have TREX-48195.1.2.

Even though the test result did not meet the five- or

MS. McCLELLAN:

If we could have TREX-48193.7.6 with

802X.1.2.

25
OFFICIAL TRANSCRIPT

4816
TIMOTHY QUIRK - CROSS

16:42

BY MS. McCLELLAN:

16:42

Q.

16:42

wasn't met, the lab increased the retarder concentration to .14

16:42

gallons per sack and ran the thickening time test again;

16:42

correct?

16:42

A.

16:42

Correct.

16:42

16:42

16:42

10

BY MS. McCLELLAN:

16:42

11

Q.

16:42

12

thickening time test on February the 12th at 3:08 a.m.

16:42

13

A.

16:42

14

16:43

15

Demonstrative 3601A.

16:43

16

BY MS. McCLELLAN:

16:43

17

Q.

16:43

18

demonstrative calendar; correct?

16:43

19

A.

16:43

20

THE COURT:

16:43

21

MS. McCLELLAN:

16:43

22

THE COURT:

16:43

23

weigh-in sheet information and the Viking information are the

16:43

24

same?

16:43

25

Since the pump time requirement of five to six hours

That's what -- that's what appears to have happened there.

MS. McCLELLAN:

And if we could have TREX-802X.1.4

with 48195.5.4.

Here, we see that the lab started the second February

Okay.
MS. McCLELLAN:

And if we could have the

That date and time are accurately reflected here on the

Yes, ma'am.
So what's the point of this exercise?
Your Honor --

Are you just trying to show that the

It's the same or consistent?


MS. McCLELLAN:

Yes, Your Honor, and we are also --

OFFICIAL TRANSCRIPT

4817
TIMOTHY QUIRK - CROSS

16:43

we've chosen one test that we don't believe there's any dispute

16:43

with the parties on in order to walk through the process as to

16:43

how the lab communicated with the account representative.

16:43

16:43

cut through all of this.

16:43

this?

16:43

to get to.

16:43

16:43

16:43

10

16:43

11

16:43

12

16:44

13

16:44

14

yet, and I was using Mr. Quirk in order to lay the foundation

16:44

15

for one of the tests that could then have been extrapolated to

16:44

16

all of the Viking screen shots as well as the weigh-up sheets,

16:44

17

in order to make sure that the record is complete.

16:44

18

16:44

19

16:44

20

point is here, what's the relevance, what we're trying to prove

16:44

21

here.

16:44

22

MS. McCLELLAN:

16:44

23

THE COURT:

16:44

24

admitting those documents or not, but I don't know where we're

16:44

25

going with this.

THE COURT:

Well, I'm just trying to see if we can


I mean, is there any dispute about

What's the ultimate point here?

MS. McCLELLAN:

That's what I'm trying

Absolutely, Your Honor.

We have a

list of all of the weigh-up sheets as well as the Viking screen


shots that we would move for admission into the record.
THE COURT:

These are not otherwise in the record or

not going to be in the record otherwise?


MS. McCLELLAN:

They have not been admitted as of

But I can move along, Your Honor.


THE COURT:

I'm just trying to find out what the

I've got to tell you, I'm not following you.


Thank you, Your Honor.

I don't know if there's any problem with

OFFICIAL TRANSCRIPT

4818
TIMOTHY QUIRK - CROSS

16:44

16:44

we'd be happy to look at what they want in.

16:44

legitimate set of documents pertaining to --

16:44

16:44

16:45

MS. McCLELLAN:

16:45

THE COURT:

16:45

on the cement slurry before and after the incident, pertaining

16:45

to Macondo well?

16:45

10

16:45

11

incident, Your Honor, which would have been the February and

16:45

12

April testing

16:45

13

16:45

14

already offered those.

16:45

15

already?

16:45

16

MS. McCLELLAN:

16:45

17

MR. HILL:

16:45

18

MS. McCLELLAN:

16:45

19

16:45

20

16:45

21

16:45

22

16:45

23

16:45

24

THE COURT:

Okay.

16:45

25

MR. REGAN:

We can take a look.

MR. HILL:

THE COURT:

Your Honor, from Halliburton's position,


If there's a

Are these -- are you trying to introduce

the Viking documents and the weigh-in sheets pertaining to -All pertaining to --

-- all the various tests that were done

MS. McCLELLAN:

Only those pertaining to before the

of the Macondo.

THE COURT:

I would have assumed somebody would have


I'm surprised.

They're not in evidence

Not yet, Your Honor, not totally.

Sir, I think pieces are in.


I have a complete production, Your

Honor.
THE COURT:

Does anybody have any objection to this?

All right.
MR. HILL:

Those are admitted.

Your Honor, do you mind if we review them

to make sure they are actually Macondo-related?


All right.

OFFICIAL TRANSCRIPT

4819
TIMOTHY QUIRK - CROSS

16:45

MS. McCLELLAN:

I'll be happy to circulate them.

16:45

THE COURT:

16:45

said they were, purport to be, which I assume they are, those

16:45

are admitted.

16:45

16:45

speak for Halliburton, but I think Mr. Gagliano will be a

16:45

witness later in the trial, and he actually would be a

16:45

percipient witness to those documents.

16:45

16:45

10

16:46

11

MR. REGAN:

16:46

12

MS. McCLELLAN:

16:46

13

TREX-802X.16.9 with TREX-48195.9.6.

16:46

14

BY MS. McCLELLAN:

16:46

15

Q.

16:46

16

shown on the weigh-up sheet that the Court has already heard

16:46

17

some testimony about.

16:46

18

16:46

19

testing on the Macondo slurry.

16:46

20

sheet for the foam crush compressive strength test on the

16:46

21

.20 slurry in February, there's a notation that the slurry is

16:46

22

settling on top.

16:46

23

A.

Yes, ma'am.

16:46

24

Q.

And do you also see that comment, "Reproduced on the

16:46

25

bottom", in the Viking screen shot?

Well, assuming they are what she just

Okay.

MR. REGAN:

THE COURT:

I think Mr. -- I mean, I don't want to

Okay.

Okay.

You like that word, don't you, "percipient"?


He saw it.
If we could please have

I'd like to talk about a few of the comments that are

The Court has heard testimony concerning stability


And as shown on the weigh-up

Do you see that?

OFFICIAL TRANSCRIPT

4820
TIMOTHY QUIRK - CROSS

16:46

A.

Is that "Severe settling"?

16:46

Q.

Correct.

16:46

A.

Okay.

16:46

Q.

Based on your knowledge and experience in the Broussard

16:46

lab practices, how would the lab have known that there was

16:47

settling during a crush compressive strength test?

16:47

A.

16:47

strength.

16:47

the compressive strength is 0.

16:47

10

16:47

11

16:47

12

condition the slurry prior to pouring it, and so he was going

16:47

13

to repeat it by conditioning the slurry.

16:47

14

Q.

16:47

15

this test would have been stopped; correct?

16:47

16

A.

That's correct.

16:47

17

Q.

And we see on the bottom of the Viking screen shot that

16:47

18

the test data was "test/tests failed"?

16:47

19

A.

Yes.

16:47

20

Q.

The Court has heard testimony about various tests in this

16:47

21

litigation that were performed at Halliburton's lab that

16:47

22

failed.

16:47

23

A.

16:48

24

or not -- that some of the techs, I don't think, were all in

16:48

25

sync.

Well, as I read this, it was not a crush compressive


The slurry was not set.

It just has that -- you see

He has "the slurry is settling,

will repeat the test."


From what I read there, he didn't -- he didn't

And because the lab noted that the slurry was settling,

Could you explain what that means?

That there was a little bit of confusion regarding whether

But "tests/test failed" would typically indicate -OFFICIAL TRANSCRIPT

4821
TIMOTHY QUIRK - CROSS

16:48

well, it should indicate that there was a problem with the

16:48

test, meaning that we had equipment malfunction or maybe, you

16:48

know, something else related to -- not specific to the slurry

16:48

design, but equipment or some -- some type of error.

16:48

Q.

16:48

mean that the slurry design has failed?

16:48

A.

16:48

as it was intended to be used at the Gulf of Mexico Fluids Lab.

16:48

Q.

16:48

10

whether a particular result is acceptable?

16:48

11

A.

16:48

12

specific parameter -- for example, a five- to six-hour

16:48

13

thickening time, that's quite clear -- it would be -- in a case

16:49

14

where a technician has noticed something out of the ordinary in

16:49

15

a case, like settling, then the technician would be -- it would

16:49

16

be expected that the technician would make note of that and

16:49

17

then, at that point, make a decision whether to communicate

16:49

18

with someone, whether it be the shift leader or engineer or lab

16:49

19

manager or something like that.

16:49

20

Q.

16:49

21

design is appropriate for use on a job?

16:49

22

A.

16:49

23

laboratory is to test the slurry and then report the results.

16:49

24

The individual that submits the request has to make that

16:49

25

decision.

So is it fair to say, then, that a "test fail" does not

That's not what it -- that's not what it was intended --

And is it the role of a lab technician to determine

Well, in a case where it's -- where it's clear or a

But does the lab make a decision as to whether a slurry

The lab just -- the job of the field test of the

OFFICIAL TRANSCRIPT

4822
TIMOTHY QUIRK - CROSS

16:49

16:49

BY MS. McCLELLAN:

16:49

Q.

16:49

tests that were not performed on the .09 slurry, which was the

16:49

slurry that was actually pumped on the Macondo well's

16:50

production casing.

16:50

16:50

A.

Yes.

16:50

Q.

This Viking screen shot, TREX-48194, shows the tests that

16:50

10

were actually performed on the .09 slurry; is that correct?

16:50

11

A.

16:50

12

compressive strength.

16:50

13

Q.

Does that refresh your recollection earlier --

16:50

14

A.

The miscibility and a mud -- and a pressurized mud

16:50

15

analysis.

16:50

16

there on the right.

16:50

17

Q.

16:50

18

recalled that there were two thickening time tests that were

16:50

19

run as well as the UCA test?

16:50

20

A.

16:50

21

16:50

22

have TREX-3773.1.2.

16:50

23

BY MS. McCLELLAN:

16:50

24

Q.

16:51

25

July 14th e-mail from Richard Vargo of Halliburton to you and

MS. McCLELLAN:

If we could have TREX-48194.8.2.

Mr. Quirk, the Court has also heard testimony about the

You're familiar with that?

It's showing a thickening time, a repeat, and a UCA

I'm just looking at where it says "finished," right

Does this refresh your recollection earlier that you

Yes, ma'am.
MS. McCLELLAN:

One final area.

If we could please

Mr. Quirk, do you recognize this e-mail?

OFFICIAL TRANSCRIPT

This is a

4823
TIMOTHY QUIRK - CROSS

16:51

Mr. Richard Dubois?

16:51

A.

16:51

could see the attachment.

16:51

16:51

BY MS. McCLELLAN:

16:51

Q.

16:51

Segment Recommended Practice Drilling and Completions Cementing

16:51

Manual, Cement Lab Section on Testing, which we have called in

16:51

this litigation SRP 4.1-0003; is that correct?

16:51

10

A.

Yes, that's what I see there.

16:51

11

Q.

Had you seen BP's cement laboratory testing section before

16:52

12

April 20th, 2010?

16:52

13

A.

16:52

14

can't recall the dates.

16:52

15

Q.

16:52

16

attached, does that refresh your recollection of July the 14th,

16:52

17

2010?

16:52

18

A.

16:52

19

something about it, now that I'm looking at it, but I don't

16:52

20

recall -- I just don't have much recollection about this right

16:52

21

now.

16:52

22

Q.

16:52

23

16:52

24

16:52

25

I don't recall what that's about without -- maybe if I

MS. McCLELLAN:

Yes.

If we could have 3773.4.3.

Attached to this July 14th e-mail is a copy of BP's E & P

I remember looking at -- at a BP document like that.

Well, does the e-mail that -- this document that's

I mean, it's -- some.

Very, very cloudy.

I do remember

Okay.
MS. McCLELLAN:

No other questions, Your Honor.

Thank you.
THE COURT:

All right.

Does Alabama have any

OFFICIAL TRANSCRIPT

4824
TIMOTHY QUIRK - CROSS

16:52

questions?

16:52

16:52

16:52

16:53

asking questions at the end of Mr. Breit's, an explanation of

16:53

where this bucket was found.

MR. MAZE:

Very brief.

Corey Maze for the State of Alabama on cross-examination.


I'd actually like to pick up where Your Honor was

7
8

Yes, Your Honor.

Carl, if you could bring up Demonstrative 325 -excuse me, 3264 -- that's TREX-23063.

9
10

CROSS-EXAMINATION

16:52

11

BY MR. MAZE:

16:53

12

Q.

16:53

13

told to separate the buckets from the Macondo well and those

16:53

14

that were separated as Kodiak; correct?

16:53

15

A.

16:53

16

secure the Macondo well samples.

16:53

17

Q.

16:53

18

Kodiak samples; correct?

16:53

19

A.

16:53

20

of the isolated samples.

16:53

21

Q.

Do you recognize this shelf that is in TREX-23063?

16:53

22

A.

Yes.

16:53

23

Q.

Is this where you would have put the four buckets that

16:54

24

were labeled "Kodiak"?

16:54

25

A.

Now, Mr. Quirk, you testified that at some point you were

I -- not really worded that way.

Okay.

I just -- I was asked to

So you had to do something different with the

Remove them from the -- well, just not have them as part

That's the storage in the Gulf of Mexico Fluids Lab.

As well as everything else.


OFFICIAL TRANSCRIPT

4825
TIMOTHY QUIRK - CROSS

16:54

Q.

As well as everything else that wasn't labeled "Macondo"?

16:54

A.

I don't recall whether or not it was there the whole time.

16:54

My memory is that it -- on the top shelf, I think, at the time

16:54

that I left Halliburton, but I can't say that I walked out

16:54

there every day and looked at the samples.

16:54

memory.

16:54

Q.

16:54

would have been sitting on the top of that shelf, to the best

16:54

of your knowledge?

16:54

10

16:54

11

16:54

12

MR. MAZE:

16:54

13

THE COURT:

16:54

14

MR. MAZE:

16:54

15

BY MR. MAZE:

16:54

16

Q.

16:54

17

earlier; correct?

16:54

18

A.

16:54

19

Horizon rig."

16:54

20

Q.

Do you remember this document from earlier?

16:55

21

A.

Yes, yes.

16:55

22

16:55

23

48002.2.

16:55

24

BY MR. MAZE:

16:55

25

Q.

I just -- that's my

And so in August 2012, those four buckets of Kodiak blend

MR. HILL:

Objection, misstates the record.

There's

been no evidence of four buckets of Kodiak blend.


I can prove that, Your Honor.
Okay.
Carl, can you please bring up TREX-48002.

This is the document that Mr. Breit was showing you

"This material is currently in lab for BP/Transocean

MR. MAZE:

Carl, if you can go to the second page,

Can you see that very well, Mr. Quirk?


OFFICIAL TRANSCRIPT

See it well enough

4826
TIMOTHY QUIRK - CROSS

16:55

to read it at that size?

16:55

A.

16:55

16:55

you just highlighted, make it just a little bit bigger.

16:55

BY MR. MAZE:

16:55

Q.

16:55

No. 2 - Kodiak"; correct?

16:55

A.

Yes.

16:55

Q.

MC727 is the Kodiak well; correct?

16:55

10

A.

That's what I read here.

16:55

11

Q.

As opposed to MC252, which is Macondo; correct?

16:55

12

A.

Mississippi Canyon 252 is what I remember as being

16:55

13

Macondo.

16:55

14

Q.

16:55

15

with approximately half remaining; correct?

16:55

16

A.

16:55

17

16:55

18

the next one, that says "Location 727."

16:55

19

the bottom.

16:55

20

BY MR. MAZE:

16:56

21

Q.

Does it also say "Location:

16:56

22

A.

Yes.

16:56

23

Q.

So now we have a second bucket.

16:56

24

correct?

16:56

25

A.

Yes.
MR. MAZE:

Okay.

Carl, if you could pull out the thing that

You see that it says, "Location:

All right.

MC727, Well

So there's one example of a 5-gallon bucket

That's correct.
MR. MAZE:

All right.

Carl, if you can go down to


It's the second from

MC727, Well No. 2 - Kodiak"?

This one is 1 gallon;

Yes.
OFFICIAL TRANSCRIPT

4827
TIMOTHY QUIRK - CROSS

16:56

16:56

next one, please.

16:56

BY MR. MAZE:

16:56

Q.

16:56

16:56

A.

That's correct.

16:56

Q.

And that is Kodiak; correct?

16:56

16:56

16:56

10

A.

16:56

11

typed on there but . . .

16:56

12

Q.

16:56

13

16:56

14

48002-3.

16:56

15

BY MR. MAZE:

16:56

16

Q.

16:56

17

No. 2."

16:56

18

16:57

19

buckets; correct?

16:57

20

A.

That's correct.

16:57

21

Q.

And it says that it is also a 1-gallon bucket; correct?

16:57

22

A.

That's correct.

16:57

23

Q.

So according to this document, there were four buckets

16:57

24

from MC727, the Kodiak Well No. 2; correct?

16:57

25

A.

MR. MAZE:

"Location:

Okay.

Carl, if you can go down to the

MC727, Well No. 2."

Again, this is from MC727; correct?

From what we've seen earlier, the other two that were
labeled "727" said "Kodiak"?
I guess it didn't say "Kodiak" on the bucket, so it's not

Understood.
MR. MAZE:

Carl, if you could go to the next page,

The very top one, please.

This says:

"Location:

MC727" -- skipping over -- "Well

That's the same as we've seen on the other three

Yes.
OFFICIAL TRANSCRIPT

4828
TIMOTHY QUIRK - CROSS

16:57

Q.

One was 5 gallons and one was 3 gallons; correct?

16:57

A.

One was 5 gallons and three were 3 gallons.

16:57

Q.

Yes, three -- my understanding is that the last three we

16:57

looked at said "1-gallon bucket."

16:57

16:57

Is that possible?

16:57

BY MR. MAZE:

16:57

Q.

16:57

the Court understand where everything is.

16:57

10

16:57

11

submitted by Halliburton to Your Honor and the parties on March

16:57

12

the 18th.

16:57

13

BY MR. MAZE:

16:57

14

Q.

16:57

15

is what -- the description of what Halliburton says they now

16:57

16

have locked in a secure lab.

16:58

17

bucket with 63981.

16:58

18

about.

16:58

19

16:58

20

containing SCR-100L."

16:58

21

want to do it again, for time's sake, but those are the three

16:58

22

1-gallon buckets that we just looked at that also said they

16:58

23

were from the MC727 well.

16:58

24

16:58

25

MR. MAZE:

Carl, can we switch to the ELMO, please?

I'm not trying to trick you here.

MR. MAZE:

Correct.

I'm just trying to help

Your Honor, this is the letter that was

Specifically -- I'm just going to show you by pen -- this

The first is a -- one 5-gallon

This is the bucket Mr. Breit was talking

And then below that, it says "three 1-gallon buckets

MR. MAZE:

And if we were to go back -- and I don't

So unless Halliburton wants to object, I

think that shows that these were the four buckets that
OFFICIAL TRANSCRIPT

4829
TIMOTHY QUIRK - CROSS

16:58

Mr. Quirk took and moved somewhere in the facility.

16:58

BY MR. MAZE:

16:58

Q.

Does that sound right, Mr. Quirk?

16:58

A.

Yeah.

16:58

they were full buckets of cement.

16:58

Whatever was on that list is everything that we separated.

16:58

Q.

And you personally did that; correct?

16:58

A.

I had -- I was -- I'm sure I was involved with helping --

16:58

working with somebody to separate them.

16:58

10

MR. MAZE:

16:59

11

Demonstrative 3264.

16:59

12

BY MR. MAZE:

16:59

13

Q.

16:59

14

the top of this shelf in the warehouse; correct?

16:59

15

A.

16:59

16

it was there for the last few years, I don't know.

16:59

17

have been somewhere else in the warehouse, and then maybe got

16:59

18

moved to that just to conserve space.

16:59

19

sure.

16:59

20

Q.

16:59

21

when you worked there?

16:59

22

A.

16:59

23

often, but I was -- when it got really -- you know, where we

16:59

24

didn't have any more samples, I would sometimes go back there

16:59

25

with the guys to kind of help out and get it cleaned up.

I think the confusion a while ago is maybe that


But I don't recall four.

Carl, if you can put back up


That's the shelf we were looking at.

So you put those four buckets of Kodiak No. 2 cement on

I recall it being there towards the end.

Understood.

Whether or not
It could

I don't know that for

How often did you go through that warehouse

Actually, I went through it a few times.

OFFICIAL TRANSCRIPT

I don't know how

4830
TIMOTHY QUIRK - CROSS

16:59

Q.

All right.

Mr. Quirk, you admit, do you not, that you

16:59

knew that the Kodiak 2 cement blend was taken by the Horizon

16:59

onto the Macondo well?

17:00

A.

Was taken by the --

17:00

Q.

Let me rephrase it.

17:00

17:00

on Transocean's Deepwater Horizon; correct?

17:00

A.

17:00

that it was Transocean, Horizon.

17:00

10

Q.

Right.

17:00

11

A.

Right.

17:00

12

Q.

And you also know that that Kodiak No. 2 went with the

17:00

13

Horizon to the Macondo 252 well in February of 2010; correct?

17:00

14

A.

17:00

15

17:00

16

deposition, page 549, line 23.

17:00

17

BY MR. MAZE:

17:01

18

Q.

17:01

19

mentioned that you knew that the Kodiak blend was on the

17:01

20

Horizon because it was labeled on the bucket; correct?

17:01

21

A.

Right.

17:01

22

Q.

It was very clearly labeled on the bucket that this had

17:01

23

been on the Horizon, no question?

17:01

24

A.

17:01

25

answer your question.

You do know that; right?

You know that Kodiak 2 blend cement was on the -- was

I -- only from looking at the bucket that says, you know,

I did not know that.


MR. MAZE:

Carl, if you could bring up Mr. Quirk's

While they're doing that, let me ask you this:

You just

Right.

Well, let me define what "clarity" is for me before I

OFFICIAL TRANSCRIPT

4831
TIMOTHY QUIRK - CROSS

17:01

Q.

Go ahead.

17:01

A.

When I -- the Deepwater Horizon rig that had Kodiak

17:01

samples, as I sit here -- as of this weekend, finally hearing

17:01

this information, I would have just assumed that that sample

17:01

was sent to the lab while Horizon rig was on another location.

17:01

I have no reason to believe anything other than that because I

17:01

haven't been told anything other than that.

17:01

17:02

17:02

10

part of the operation, so I can't sit here and tell you that I

17:02

11

knew that that -- it doesn't really mean anything to me.

17:02

12

Q.

17:02

13

would tell you that it went to the Macondo MC252 well?

17:02

14

A.

17:02

15

17:02

16

is TREX-23057.

17:02

17

BY MR. MAZE:

17:02

18

Q.

17:02

19

Halliburton.

17:02

20

A.

17:02

21

But --

17:02

22

Q.

It's a 5-gallon bucket; right?

17:02

23

A.

Yes.

17:02

24

Q.

Those are pretty big buckets?

17:02

25

A.

Yes.

So all I see is that that sample was from that well.


I'm not keeping track -- I don't -- I'm not involved in that

So there's no markings on that bucket or anything that

It says Mississippi Canyon 7-something on it.


MR. MAZE:

Carl, if you could bring up D-3258, which

This is a picture we were sent earlier this week by


Do you recognize this bucket, Mr. Quirk?

I -- you know, I haven't seen the bucket in a few years.

OFFICIAL TRANSCRIPT

4832
TIMOTHY QUIRK - CROSS

17:02

Q.

In fact, Mr. Breit, I borrowed his fancy bucket that he

17:02

brought for me.

17:02

right?

17:03

A.

Yes.

17:03

Q.

Okay.

17:03

from the Deepwater Horizon?

17:03

A.

That's one thing it says on it.

17:03

Q.

Right.

17:03

that it says MC727; right?

17:03

10

A.

That's correct.

17:03

11

Q.

And it also says "No. 2 Kodiak" at the bottom?

17:03

12

A.

That's correct.

17:03

13

Q.

Which is, under your testimony, why it got moved away from

17:03

14

the Macondo cement?

17:03

15

A.

17:03

16

17:03

17

Demonstrative 3257, which is TREX-23056, which is the top of

17:03

18

the bucket.

17:03

19

BY MR. MAZE:

17:03

20

Q.

17:03

21

17:03

22

BY MR. MAZE:

17:03

23

Q.

17:03

24

from the Deepwater Horizon; correct?

17:03

25

A.

That's about the size of a 5-gallon bucket;

This bucket says very clearly, does it not, this is


Correct?

And I'm assuming that you're trying to say also

That's correct.
MR. MAZE:

Carl, if you can switch to

I'm going to say that this is also the same bucket.


MR. MAZE:

Carl, can you blow up --

First of all, again, this bucket clearly states this is

Correct.
OFFICIAL TRANSCRIPT

4833
TIMOTHY QUIRK - CROSS

17:03

17:03

17:03

up this sticker on the bucket.

17:03

BY MR. MAZE:

17:03

Q.

17:03

It will be easier.

17:04

where I'm pointing?

17:04

A.

It looks like February 2010.

17:04

Q.

Yes.

17:04

10

A.

It's like a 2.

17:04

11

9.

17:04

12

Q.

Regardless -- it's actually a 3, but...

17:04

13

A.

Oh.

17:04

14

Q.

I base that based on the letter that was given to us by

17:04

15

Halliburton, who took the picture, 23/02/2010.

17:04

16

17:04

17

to the Macondo well before that, actually three days before it?

17:04

18

A.

17:04

19

don't know the time period that it moved.

17:04

20

Q.

17:04

21

this bucket was on the Macondo well, because it was placed on

17:04

22

here February 23rd, 2010, which is after it moved; right?

17:04

23

A.

17:05

24

into the lab.

17:05

25

Q.

No question?
MR. MAZE:

All right.

Carl, if you can actually blow

Mr. Quirk, can you read -- you're looking on your screen.


Can you read the date on this?

Do you see

Can you read that date?

Do you see what the date is in front of it?


I can't tell if the second one is a 1 or a

It's not -- probably it's -- it's probably a 1 then.

You have knowledge that the Deepwater Horizon moved

I would have to assume that, based on the -- I mean, I


I mean...

But, regardless, that means that that sticker shows that

Well, I can speak for when -- that's when it was logged

MR. MAZE:

Carl, do we have Mr. Quirk's deposition?


OFFICIAL TRANSCRIPT

4834
TIMOTHY QUIRK - CROSS

17:05

Do we have the ability to get on page 549?

17:05

MR. BREIT:

17:05

MR. MAZE:

17:05

BY MR. MAZE:

17:05

Q.

Mr. Quirk, you testified, right, in deposition?

17:05

A.

Yes, I did.

17:05

Q.

I'm going to turn to page 549 and read to you a portion.

17:05

17:05

17:05

10

17:05

11

17:05

12

17:05

13

17:05

14

BY MR. MAZE:

17:05

15

Q.

17:05

16

17:05

17

17:06

18

17:06

19

17:06

20

17:06

21

page 549.

17:06

22

BY MR. MAZE:

17:06

23

Q.

17:06

24

17:06

25

"QUESTION:

I do.

Excuse me, Your Honor.

All right.

We can switch to ELMO, please.

Are you aware that when the Deepwater

Horizon arrived at the Macondo to replace the Marianas rig


that it had on board cement dry blend" -THE COURT:

Wait, wait.

We can't see it.

The

witness can't read along with it.


MR. MAZE:

I will do it more slowly.

(Reading):
"QUESTION:

Are you aware that when the Deepwater

Horizon arrived at the Macondo" -THE COURT:


screen.

Wait.

That's not the part that's on the

What line does this start -MR. MAZE:

We're going to start on line 23.

This is

(Reading):
"QUESTION:

Are you aware that when the Deepwater

Horizon arrived at the Macondo to replace the Marianas rig


OFFICIAL TRANSCRIPT

4835
TIMOTHY QUIRK - CROSS

17:06

that it had on board" --

17:06

17:06

17:06

17:06

17:06

17:06

BY MR. MAZE:

17:06

Q.

17:06

17:06

10

Halliburton had originally brought over from the Kodiak

17:06

11

No. 2 well?

17:06

12

"ANSWER:

17:06

13

"QUESTION:

17:06

14

"ANSWER:

17:06

15

17:06

16

17:06

17

A.

Yes.

17:06

18

Q.

So your testimony at deposition was that you did know that

17:06

19

there was on board cement dry blend brought over from Kodiak on

17:06

20

the Macondo; right?

17:06

21

A.

17:07

22

17:07

23

then, you know that the dry cement that was on board the

17:07

24

Deepwater Horizon and used for Macondo was originally developed

17:07

25

for the Kodiak Well No. 2?"

THE COURT:

Wait.

You need to move up to the top

again.
This is why I like letting Carl do it.

MR. MAZE:

He's better than I am.


THE COURT:

You're not quite there.

(Reading):
"QUESTION:

-- on board cement dry blend that

Yes.
So --

Only because they were -- I saw the lab

samples."
Did I read that correctly?

Yes.

I'd like to read it all to see what my -(Reading):

"So from looking at the lab samples,

OFFICIAL TRANSCRIPT

4836
TIMOTHY QUIRK - CROSS

17:07

And I say that I'm not certain about all of that.

17:07

17:07

17:07

picture of the bucket, D-3257.

17:07

BY MR. MAZE:

17:07

Q.

17:07

on February 23rd of 2010?

17:07

A.

Yes.

17:07

Q.

And you -- you do realize that -- well, strike that.

17:07

10

17:07

11

17:07

12

the Macondo buckets; right?

17:07

13

A.

I separated every -- all buckets from the Macondo.

17:07

14

Q.

At the direction of someone else?

17:07

15

A.

Right.

17:07

16

Q.

Were you present at the Halliburton lab when -- let me go

17:07

17

back.

17:07

18

17:07

19

all relevant cement in this case?

17:08

20

A.

17:08

21

didn't -- can you rephrase the question?

17:08

22

Q.

17:08

23

federal government?

17:08

24

A.

Yes.

17:08

25

Q.

Were you there the day that that happened?

Q.

Right.

But is it clear from --

MR. MAZE:

Carl, if you could switch back to the

It is clear from the bucket, correct, that this was logged

Let's move to the next question.


So you personally separated the Kodiak buckets from

Do you remember the lab being subpoenaed to turn over

I don't recall -- I don't recall the subpoena.

Do you remember when the lab turned over cement to the

OFFICIAL TRANSCRIPT

4837
TIMOTHY QUIRK - CROSS

17:08

A.

Yes.

17:08

Q.

Who else was there that day?

17:08

A.

Members from the government.

17:08

there at the facility.

17:08

there.

17:08

Q.

17:08

Halliburton employees who were there?

17:08

A.

17:08

because I don't remember exactly who was there at that time.

17:08

10

Q.

Were any Halliburton attorneys there?

17:08

11

A.

Yes.

17:08

12

Q.

Did any -- and I can't ask you what they told you.

17:09

13

understand that?

17:09

14

17:09

15

actual document, the actual subpoena, requesting something for

17:09

16

the federal government?

17:09

17

A.

I don't recall.

17:09

18

Q.

Do you recall if anyone told you what it was you were

17:09

19

looking for?

17:09

20

A.

That I was looking for?

17:09

21

Q.

Well, that Halliburton was looking for.

17:09

22

A.

Halliburton was looking for in what regard?

17:09

23

Q.

Well, you had to be looking for --

17:09

24

A.

I'm not understanding your question.

17:09

25

Q.

Okay.

I mean, individuals who were

I don't recall everybody that was

Were there -- can you remember the names of any

Right offhand, I'm -- I'm -- I would only be guessing

Do you

Did any of the Halliburton attorneys show you the

You had to be given some direction as to what it


OFFICIAL TRANSCRIPT

4838
TIMOTHY QUIRK - CROSS

17:09

was the federal employees were there to take; correct?

17:09

A.

17:09

well cement samples.

17:09

Q.

17:09

just from the Deepwater Horizon rig?

17:09

A.

17:09

locker, he told me that I had to put the Macondo well samples

17:09

into the locker.

17:09

Q.

17:10

10

about the day that the federal government showed up at the lab.

17:10

11

Who told you what you had to turn over to the federal

17:10

12

government?

17:10

13

A.

17:10

14

of the locker.

17:10

15

specific instructions about anything other than that.

17:10

16

MR. MAZE:

17:10

17

Demonstrative 3258.

17:10

18

BY MR. MAZE:

17:10

19

Q.

17:10

20

what it was you were looking for, that you were just giving

17:10

21

them what was in a closet?

17:10

22

A.

17:10

23

government was going to be there to pick up the samples that we

17:10

24

had secured in the locker.

17:10

25

something more than that, I don't remember.

As I understood it, they were there to get the Macondo

Who told you that it had to be from Macondo as opposed to

When Tony Angelle asked me to secure the samples in the

That's a different day, though, isn't it?

I'm asking you

The federal government came there and took the samples out
That's what I remember.

I don't remember

Carl, can you go back to

So your testimony is is that no one specifically told you

What I recall is that -- you know, that the federal

That's what I recall.

OFFICIAL TRANSCRIPT

If there was

4839
TIMOTHY QUIRK - CROSS

17:10

Q.

And knowing full well that in the other part of the lab

17:10

there were buckets that came from the Deepwater Horizon, you

17:11

never told anybody that they were there, did you?

17:11

A.

17:11

out the significance of those samples.

17:11

thing by keeping them.

17:11

17:11

the Macondo well samples, and that's what I was instructed to

17:11

do.

That's what I did.

17:11

10

Q.

And I understand your frustration.

17:11

11

17:11

12

these didn't count, the ones that were from the

17:11

13

Deepwater Horizon?

17:11

14

17:11

15

turned over too.

17:11

16

A.

17:11

17

that didn't count.

17:11

18

Angelle asked me to secure the Macondo well samples, and that's

17:11

19

what I did.

17:11

20

Q.

17:11

21

day that there were other samples from the Deepwater Horizon at

17:11

22

the facility?

17:11

23

A.

Yes.

17:11

24

Q.

Gave them a list of everything that you had --

17:12

25

A.

Inventoried.

Sir, I'm sorry.

But as I sit here today, I'm just finding


I think I did a good

Knowing -- I could have discarded them.

Knowing -- I don't recall anything about -- I secured

My question is:

Who is it that instructed you that

I'm trying to understand why it is these didn't get

No one said that didn't count.

No one specifically said

They just told me to secure the -- Tony

And you never offered to Tony Angelle or anyone else that

I gave them a list of everything.

OFFICIAL TRANSCRIPT

4840
TIMOTHY QUIRK - CROSS

17:12

17:12

17:12

A.

Tony Angelle.

17:12

Q.

So you gave Tony Angelle, on the day the federal

17:12

government showed up --

17:12

A.

No, not the day the federal government showed up.

17:12

Q.

Okay.

17:12

A.

The day that I inventoried everything in the lab.

17:12

Q.

So Tony Angelle --

17:12

10

A.

The list that you had up a while ago, I gave -- I sent

17:12

11

that to Tony Angelle.

17:12

12

Q.

17:12

13

another part of the lab there were these buckets from the

17:12

14

Deepwater Horizon?

17:12

15

A.

17:12

16

the samples.

17:12

17

that's what I did.

17:12

18

just put them on a shelf.

17:12

19

Q.

So he might have even thought you threw them away?

17:12

20

A.

It's possible.

17:12

21

about that after.

17:12

22

Q.

17:12

23

or not.

17:12

24

A.

17:13

25

don't remember the communication after that.

Q.

-- inventoried.
Who did you give it to?

Okay.

So Tony Angelle and you both understood that in

I don't -- I don't know that Tony knew that we even kept


Tony asked me to secure Macondo well samples, and
I just -- I just kept those samples.

I don't recall conversations with him

Maybe we did.

I just don't recall.

So Tony Angelle didn't care whether they were thrown away


He just didn't tell you?

No, I didn't say that.

I just say that I don't know -- I

OFFICIAL TRANSCRIPT

That's what I'm

4841
TIMOTHY QUIRK - CROSS

17:13

saying.

I don't remember the specific communication regarding

17:13

what to do with that, other than the fact that I just put them

17:13

out there on the shelf.

17:13

Q.

17:13

to get right to the end.

17:13

17:13

government was there, or did you simply give them what you had

17:13

in the closet and that was it?

17:13

A.

That's it.

17:13

10

Q.

And you personally never told anyone from the federal

17:13

11

government or Halliburton attorneys or anyone else that there

17:13

12

were other buckets from the Deepwater Horizon?

17:13

13

A.

I don't recall.

17:13

14

Q.

And you never heard Tony Angelle offer to anyone that he

17:13

15

also knew there were other buckets that he had asked to be

17:13

16

separated?

17:13

17

A.

17:13

18

communication.

17:14

19

17:14

20

during that process were that I looked at the Mississippi

17:14

21

Canyon 727, a different well, being something completely

17:14

22

different.

17:14

23

Q.

17:14

24

were instructed that by Tony?

17:14

25

A.

Okay.

And I don't want to belabor the point, so I'm going

Did you go into the warehouse the day the federal

I'm not -- I don't know.

I'm not aware of Tony's

Sir, I just want to make it clear.

My thoughts

That's --

And you looked at it as something different because you

Well, I -- there was never a reason that I felt like -OFFICIAL TRANSCRIPT

4842
TIMOTHY QUIRK - CROSS

17:14

obviously, now I'm hearing this conversation.

But I looked at

17:14

it as a different location, a different well.

That's what I

17:14

see when I look at the bucket.

17:14

17:14

cement in that bucket was part of the cement that was used on

17:14

Macondo.

17:14

Q.

17:14

17:14

17:14

10

it up because the ELMO is not up -- says it's approximately

17:15

11

three-quarters full.

17:15

12

17:15

13

17:15

14

17:15

15

bucket while you were there?

17:15

16

A.

17:15

17

highly unlikely.

17:15

18

Q.

17:15

19

last question.

17:15

20

17:15

21

whether or not Mr. Faul had asked you to do tests on the side

17:15

22

before, if that had ever happened, you said it was, quote, a

17:15

23

little unusual; right?

17:15

24

17:15

25

I don't -- I didn't realize that that cement -- that

I just didn't know that.

Just two other questions and I'll be done.


You logged in that this bucket was half full and

the -- what we've been shown by Halliburton -- and I can't put

Would you have any explanation as to why it would


be -- strike that.
Is it possible that anybody added anything to the

Highly unlikely.

I mean, anything is possible, but it's

Actually, that answer, "highly unlikely," leads me to my

You told Mr. Breit earlier that -- when he asked you

So the fact that it was a little unusual means that


it happened before; right?

This was not completely the first

OFFICIAL TRANSCRIPT

4843
TIMOTHY QUIRK - CROSS

17:15

time ever; it's just unusual, but it does happen?

17:15

A.

What happens?

17:15

Q.

That you've been asked to do a test on the side.

17:15

A.

No, I don't recall being asked to do -- I mean, it may

17:15

have, but I just don't recall.

17:16

MR. MAZE:

17:16

THE COURT:

17:16

MR. KANNER:

Your Honor?

17:16

THE COURT:

Oh, I'm sorry.

17:16

10

MR. KANNER:

17:16

11

17:16

12

17:16

13

17:16

14

17:16

15

17:16

16

17:16

17

THE COURT:

17:17

18

MR. HILL:

17:17

19

for Halliburton.

17:17

20

examination.

17:17

21

17:17

22

17:17

23

17:17

24

BY MR. HILL:

17:17

25

Q.

That's all, Your Honor.


Okay.

Transocean?

As a present observer of the examination

by my fellow plaintiffs, Louisiana passes the witness.


Thank you, Mr. Kanner.

THE COURT:

I inadvertently

overlooked you there.


Transocean?
MR. HILL:

Your Honor, I believe Halliburton will go

next.
Halliburton next?

Okay.

Good afternoon, Your Honor.

Gavin Hill

I'll be taking Mr. Quirk on direct

May I proceed?
THE COURT:

Sure.
DIRECT EXAMINATION

Tim, we've got a few things that -- I'd like to properly


OFFICIAL TRANSCRIPT

4844
TIMOTHY QUIRK - DIRECT

17:17

introduce you to the Court and give him a little bit about your

17:17

background and your interaction post-incident.

17:17

17:17

a couple of things that counsel that came before me talked

17:17

about.

17:17

17:17

lab, at the time that you were the fluid labs manager and,

17:17

prior to that, the actual cement lab manager, how was SCR

17:17

bought by lot?

17:17

10

terms of volume?

17:17

11

A.

17:17

12

from -- you know, depending on the additives -- from 500 to

17:17

13

several thousand gallons.

17:18

14

Q.

17:18

15

purposes?

17:18

16

A.

Yes.

17:18

17

Q.

For example, if you were to take it and send it to a rig,

17:18

18

you could also take that same lot number and make a lab sample;

17:18

19

correct?

17:18

20

A.

That's correct.

17:18

21

Q.

Is the lot number rig-specific for SCR?

17:18

22

A.

No, it's not.

17:18

23

Q.

If you were to go into the Viking database, would you find

17:18

24

6264, which I believe is the lot number that was used in the

17:18

25

operational testing, associated with other -- testing done on

But before we do that, I want to turn immediately to

You were asked -- well, let me ask you this:

In the

Can you explain to the Court, what is a lot in

The manufacturers that make it, it could be anywhere

Okay.

And would that volume of SCR be used for different

OFFICIAL TRANSCRIPT

4845
TIMOTHY QUIRK - DIRECT

17:18

other rigs?

17:18

A.

That's correct.

17:18

Q.

And done for other customers; correct?

17:18

A.

That's correct.

17:18

Q.

Now, I think you were confused by some of the questions --

17:18

you seemed confused to me -- as to whether or not the specific

17:18

ID number that Mr. Breit showed you, 54573, associated with the

17:18

Lot Number 6264 of SCR-100L was actually a sample ID specific

17:18

to a rig or something else?

17:18

10

17:19

11

17:19

12

BY MR. HILL:

17:19

13

Q.

17:19

14

document, not necessarily something that's tracked with Bates

17:19

15

numbers.

17:19

16

17:19

17

17:19

18

17:19

19

BY MR. HILL:

17:19

20

Q.

Mr. Quirk, do you recognize this document?

17:19

21

A.

Yes, I do.

17:19

22

Q.

Did you author it?

17:19

23

A.

Yes.

17:19

24

do that, but either I typed it or she typed it.

17:19

25

recall.

A.

Okay?

I want to talk about that.

Okay.
MR. HILL:

Can you bring up TREX-48001, please.

This is a fancy IT way of saying that this is a native

MR. HILL:

But go ahead and go to the next page,

please.
Can you please switch to the ELMO?

I was -- I may have been working with a secretary to

OFFICIAL TRANSCRIPT

I don't

4846
TIMOTHY QUIRK - DIRECT

17:19

Q.

What was the purpose of preparing this document?

17:20

A.

This was a material transfer ticket for the United States

17:20

Government.

17:20

Q.

17:20

about where the Department of Justice or federal agents came

17:20

and took possession of things that had been set aside that was

17:20

Macondo related, this was the ticket that went with that

17:20

transfer when you handed that material over; correct?

17:20

A.

Yes, that's correct.

17:20

10

Q.

When you prepared this document, did you use the

17:20

11

information available to you to identify, with respect to what

17:20

12

you were turning over, what actually came from location and

17:20

13

what actually came from the lab?

17:20

14

A.

That's from the -- that's the location samples.

17:20

15

Q.

What does that mean, "location"?

17:20

16

A.

That means it comes from the rig.

17:20

17

Q.

And so if one were to peruse TREX-48001, they would see

17:20

18

specifically location blends and things that were turned over

17:21

19

to the U.S. Government; correct?

17:21

20

A.

Yes.

17:21

21

Q.

And, in fact, this one right here, the second one that's

17:21

22

added, says it came from Macondo.

17:21

23

blend; correct?

17:21

24

17:21

25

Okay.

So that -- that event that Mr. Maze just asked you

MR. BREIT:

That was an actual cement

Your Honor, this is their witness.

going to object to the leading.


OFFICIAL TRANSCRIPT

I'm

4847
TIMOTHY QUIRK - DIRECT

17:21

17:21

BY MR. HILL:

17:21

Q.

17:21

17:21

BY MR. HILL:

17:21

Q.

17:21

sample ID 67314?

17:21

A.

"Sample came from Tank 8."

17:21

Q.

What does that "Tank 8" represent to you?

17:21

10

A.

I'm assuming it's just a tank that's out there on the rig.

17:21

11

Q.

Further confirmation that it's rig blend?

17:21

12

A.

Yes.

17:21

13

MR. BREIT:

17:21

14

Let him answer the questions.

17:21

15

I don't want him to know too much on direct by leading.

17:21

16

MR. HILL:

17:21

17

THE COURT:

17:21

18

BY MR. HILL:

17:21

19

Q.

17:21

20

bottom, there are -- I'm sorry, the margins here aren't helping

17:22

21

me.

17:22

22

17:22

23

location samples, there are some that are marked differently;

17:22

24

correct?

17:22

25

A.

THE COURT:

Try not to lead.

Can you tell us what that note says -MR. HILL:

Did you find it?

Can you tell us what that note says that's associated with

Again, Your Honor, it's their witness.


He didn't know a lot on cross.

Of course, Your Honor.


All right.

Now, I'm going to turn to the second page.

Down at the

In addition to other items that are marked as

Can you tell the Court what that says on line 9?

"Lab sample."
OFFICIAL TRANSCRIPT

4848
TIMOTHY QUIRK - DIRECT

17:22

Q.

And this particular sample is what material?

17:22

A.

Zone Sealant 2000.

17:22

Q.

If I turn over to the third page of this exhibit, 54573 is

17:22

the SCR-100L with Lot 6264 that Mr. Breit identified to you;

17:22

correct?

17:22

A.

Yes.

17:22

Q.

Can you please tell the Court how it was identified.

17:22

A.

It's a lab sample.

17:22

Q.

Did it come from the rig?

17:22

10

A.

No.

17:22

11

Q.

I just wanted to make sure that we're clear on this point.

17:22

12

Does your lab provide unique sample ID numbers to additives in

17:23

13

the lab that never go offshore?

17:23

14

A.

Yes.

17:23

15

Q.

Why do you do that?

17:23

16

A.

When samples come in, they're just -- they have to be

17:23

17

logged in and bar-coded.

17:23

18

they'll print stickers, and the Viking system automatically

17:23

19

generates a sample ID.

17:23

20

Q.

17:23

21

explained what you explained to the Court, I'm going to ask you

17:23

22

the question that Mr. Breit asked you.

17:23

23

17:23

24

17:23

25

All right.

And so when a sample comes in,

Now, having seen what you've seen and having

And that is:

Okay?

Did you use this particular SCR-100L in

any post-incident testing that had come from the rig?


MR. BREIT:

I'm going to object to the question,


OFFICIAL TRANSCRIPT

4849
TIMOTHY QUIRK - DIRECT

17:23

Your Honor.

He's confusing two points into one question.

17:23

Coming from the rig or lab sample, two different --

17:23

17:23

17:23

THE COURT:

I'll overrule the objection.

You'll have

MR. BREIT:

Thank you, Your Honor.

17:23

THE COURT:

Okay.

17:23

BY MR. HILL:

17:23

Q.

17:24

you tell the judge whether or not you have ever used any

17:24

10

specific SCR identified by Lot No. 6264 that was specific to

17:24

11

the Macondo rig?

17:24

12

A.

17:24

13

of lot numbers and store those and -- which meant that we would

17:24

14

still have other lab stock in the lab.

17:24

15

Q.

17:24

16

tracking it in the lab, does that mean that it automatically

17:24

17

was checked in from a rig into your lab?

17:24

18

A.

No.

17:24

19

Q.

I also want to get back to this issue of you sitting in

17:24

20

the lab and receiving samples from rigs.

17:24

21

A.

Okay.

17:24

22

Q.

I'm leading up to this, but I want you to explain to the

17:24

23

Court, do you know how many cement blends were even on the

17:24

24

Deepwater Horizon?

17:24

25

A.

redirect.

To your knowledge, based on what you've seen today, can

No.

What -- my memory now is that we had to take samples

And just because something has a sample ID for purposes of

I do not.
OFFICIAL TRANSCRIPT

Okay?

4850
TIMOTHY QUIRK - DIRECT

17:24

Q.

If you want to educate yourself as to what blends are on

17:24

the Deepwater, how do you know what is being sent in is from

17:25

the Macondo versus the Kodiak versus the Kaskida well?

17:25

A.

Just from the documentation that's on the bucket.

17:25

Q.

By "documentation," are you talking about the label that's

17:25

affixed to the top that you saw in the picture?

17:25

A.

17:25

you know.

17:25

Q.

Or the writings on the bucket?

17:25

10

A.

Right.

17:25

11

17:25

12

Blow this up right here, please.

17:25

13

BY MR. HILL:

17:25

14

Q.

17:25

15

showed you, correct, from April 17th?

17:26

16

A.

Yes, I see April 17th at the top.

17:26

17

Q.

Where he was identifying this sample ID associated with

17:26

18

Lot 6264 of SCR-100L; correct?

17:26

19

A.

Correct.

17:26

20

Q.

Again, is there anything on this document that would tell

17:26

21

you whether or not this particular sample that was used in the

17:26

22

lab was rig-specific?

17:26

23

A.

No.

17:26

24

Q.

This column right here says "Source"; correct?

17:26

25

A.

That's correct.

Well, from the label or something written on the bucket,

MR. HILL:

Could you please bring up TREX-60415.

Now, I believe this is the weigh-up sheet that Mr. Breit

I don't see anything that tells me it's rig-specific.

OFFICIAL TRANSCRIPT

4851
TIMOTHY QUIRK - DIRECT

17:26

Q.

The fact that all of those lines right there for additives

17:26

say "Transocean" and have the same sample date and are part of

17:26

the same sample ID, what does that tell you?

17:26

A.

That that sample is from the rig.

17:26

Q.

With respect to "Zone Sealant," did that come from the

17:26

rig?

17:26

A.

That looks like lab stock.

17:26

Q.

Why do you -- what leads you to believe that, or how do

17:26

you know that?

17:26

10

A.

17:27

11

plant, which is--

17:27

12

Q.

17:27

13

source for the sample ID 54573 of SCR-100L on this lab sheet?

17:27

14

A.

17:27

15

17:27

16

BY MR. HILL:

17:27

17

Q.

17:27

18

summary fashion -- we'll talk more specifically about the

17:27

19

tests -- about certain testing you did post-incident in the

17:27

20

lab; correct?

17:27

21

A.

Correct.

17:27

22

Q.

I just want to ask you a couple of questions right off the

17:28

23

bat, and then we're going to move somewhere else.

17:28

24

this up another time.

17:28

25

questions now.

Because it looks like the source was a Morgan City bulk

Is the Transocean source, the rig, identified as the

No, I don't see it as that.


MR. HILL:

Take that down, please.

Mr. Quirk, you have explained to the Court, kind of in a

We'll tie

But I want to make sure I ask you these

OFFICIAL TRANSCRIPT

4852
TIMOTHY QUIRK - DIRECT

17:28

Did you do any post-incident testing using actual

17:28

cement -- cement blend from the rig?

17:28

A.

I did not.

17:28

Q.

Once you reported post-incident tests results to Mr. Faul,

17:28

did you discard your handwritten notes because you were trying

17:28

to conceal the results?

17:28

A.

I was not.

17:28

Q.

In fact, since lab stock materials were used, could you

17:28

perform those same tests again right here, assuming you had the

17:28

10

additives?

17:28

11

A.

Yes.

17:28

12

Q.

Now, I think you had -- I want to introduce you a little

17:28

13

bit better to the Court.

17:28

14

live.

17:28

15

A.

I live in Fulshear, Texas.

17:28

16

Q.

Where is that?

17:28

17

A.

It's about 20 miles west of Houston.

17:28

18

Q.

And by whom are you currently employed?

17:28

19

A.

I'm employed by Chevron.

17:28

20

Q.

What do you do for them?

17:29

21

A.

I'm a technical team leader over the cement and drilling

17:29

22

fluids labs.

17:29

23

Q.

Now, when did you take that job?

17:29

24

A.

August 27th, 2012.

17:29

25

Q.

So prior to that, who would have been your employer?

No, I did not.

Could you tell the Court where you

What big city --

OFFICIAL TRANSCRIPT

4853
TIMOTHY QUIRK - DIRECT

17:29

A.

Halliburton.

17:29

Q.

Okay.

17:29

identified before, the 24th of 2012?

17:29

A.

17:29

last day with Halliburton was August 24th of 2012.

17:29

Q.

17:29

job?

17:29

A.

17:29

position and accepted it.

17:29

10

Q.

Do you have a college degree, Mr. Quirk?

17:29

11

A.

Yes.

17:29

12

Q.

What's that in?

17:29

13

A.

I have an Associate of Science in petroleum services

17:29

14

technology.

17:29

15

Q.

When did you obtain that degree, sir?

17:29

16

A.

In 1987.

17:29

17

Q.

Now, when were you actually hired by Halliburton?

17:29

18

A.

March 18th, 2000 -- 1990.

17:29

19

Q.

And I'm just going to ask this.

17:30

20

briefly identify some of the major positions you've had at

17:30

21

Halliburton since -- or some of the positions that you've held

17:30

22

since 1990 up until the time you left in August of 2012.

17:30

23

A.

17:30

24

through different levels of lab techs, meaning lab tech, senior

17:30

25

lab tech, principal lab technician, which it was a promotion to

Yes.

And that was up until August, I think you

I actually started with Chevron August 27th, and my

Do you mind telling the Court why you took a different

Just a better opportunity is what I felt.

I was offered a

If you could, just

In 1990, I was hired as a lab technician and progressed

OFFICIAL TRANSCRIPT

4854
TIMOTHY QUIRK - DIRECT

17:30

one of the shift leader positions in the lab.

17:30

17:30

position.

17:30

went through 1995 or so.

17:30

then the chemist position, you know, somewhere around that time

17:30

frame, and then senior chemist and then principal chemist,

17:30

which put me as the cement lab manager.

17:30

Q.

17:31

in what lab?

17:31

10

A.

In the Gulf of Mexico lab.

17:31

11

Q.

And what -- where is that lab located?

17:31

12

A.

It's in Broussard, Louisiana.

17:31

13

Q.

And you were in a position of cement lab manager from what

17:31

14

date to what date?

17:31

15

A.

From roughly 2004 to 2008.

17:31

16

Q.

Okay.

17:31

17

any other positions at Halliburton?

17:31

18

A.

I was the fluids lab manager in Broussard, Louisiana.

17:31

19

Q.

And that would have been from 2008 until the time that you

17:31

20

left?

17:31

21

A.

That's correct.

17:31

22

Q.

So in April of 2010, you would have been fluid lab

17:31

23

manager; correct?

17:31

24

A.

That's correct.

17:31

25

Q.

And that's not -- I understand that to be different than

And then from there was put on -- put in the chemist

Okay.

And the first three positions I discussed probably


Don't hold me to those dates.

But

So you were the cement lab manager for Halliburton

And after the cement lab manager, did you obtain

OFFICIAL TRANSCRIPT

4855
TIMOTHY QUIRK - DIRECT

17:31

actually the cement lab?

17:31

A.

That's correct.

17:31

Q.

Can you explain to the Court a little bit about the

17:31

structure of the labs and who reported to you.

17:31

A.

17:32

technicians, something like that, and each shift had a shift

17:32

leader.

17:32

Q.

17:32

along towards the end of the day.

17:32

10

17:32

11

part of the fluids lab?

17:32

12

A.

17:32

13

lab, the completion fluids lab, and the production enhancement

17:32

14

lab.

17:32

15

Q.

Did each of those four labs have its own manager?

17:32

16

A.

That's correct.

17:32

17

Q.

And who did they report to?

17:32

18

A.

They reported to me.

17:32

19

Q.

Okay.

17:32

20

of -- in April of 2010 that reported to you?

17:32

21

A.

That was Richard Dubois.

17:32

22

Q.

Now, prior to April 20th, 2010, did you have any direct

17:32

23

involvement with any testing done in the cement lab for the

17:32

24

Macondo well?

17:32

25

A.

The cement lab had rotating shifts with about 16 to 20 lab

Let me go ahead and stop you just because I want to move

Can you tell us what the four labs were that were

I'm sorry.

We had the cement lab, the drilling fluids

Who was the manager of the cement lab in April

No, I didn't -- I don't recall being a part of anything.


OFFICIAL TRANSCRIPT

4856
TIMOTHY QUIRK - DIRECT

17:32

Q.

Now, after April 20th, 2010 -- I'm going to call that

17:32

"point-incident."

17:32

A.

Okay.

17:32

Q.

Did you have any involvement with the aftermath of the

17:33

Macondo incident?

17:33

A.

Lab testing?

17:33

Q.

Any involvement.

17:33

A.

Yes.

17:33

Q.

Can you maybe briefly tell the Court what you understand

17:33

10

your involvement to have been in this case.

17:33

11

A.

Post-incident testing --

17:33

12

Q.

Okay.

17:33

13

A.

-- and communication with the legal team, just to --

17:33

14

communication with the legal team later on, you know, in the

17:33

15

year.

17:33

16

Q.

Okay.

17:33

17

A.

Communication, I'm sure.

17:33

18

specifics right now.

17:33

19

Q.

17:33

20

well; right?

17:33

21

A.

Yes.

17:33

22

Q.

Before we talk about what you know, I'd like to talk a

17:33

23

little bit about your personal level of familiarity with a

17:33

24

couple of things.

17:33

25

Okay?

Anything else?
I just can't pinpoint the

And I think we've seen -- you've taken a deposition as

What is your personal level of familiarity with


OFFICIAL TRANSCRIPT

4857
TIMOTHY QUIRK - DIRECT

17:33

drilling deepwater wells?

17:34

A.

17:34

of deepwater drilling.

17:34

Q.

17:34

slurry?

17:34

A.

17:34

experience.

17:34

Q.

17:34

purposes of doing testing?

17:34

10

A.

Yes.

17:34

11

Q.

And what are those?

17:34

12

A.

Bottom hole well pressures and temperatures.

17:34

13

Q.

Where do you obtain that information?

17:34

14

A.

From the engineer submitting a request.

17:34

15

Q.

What is your level of familiarity with cementing

17:34

16

operations generally?

17:34

17

A.

17:34

18

a couple of times in the early '90s to do some simple lab

17:34

19

testing, but I don't have much knowledge about downhole

17:34

20

operations or cementing operations.

17:34

21

Q.

17:34

22

like OptiCem?

17:35

23

A.

No, I don't have any experience in that.

17:35

24

Q.

Have you ever run one?

17:35

25

A.

No, I have not.

I'm not -- I don't have experience at all in the operation

How about evaluating the downhole performance of a cement

In regards to well conditions, I don't have any

Are there downhole conditions that you actually need for

My experience has been in the lab.

Fair enough.

I've been on location

How about running cement modeling programs

OFFICIAL TRANSCRIPT

4858
TIMOTHY QUIRK - DIRECT

17:35

Q.

I'd like to talk to you a little bit, some questions about

17:35

the cement lab and how it was organized during the time that

17:35

you were the fluids lab manager in April of 2010.

17:35

17:35

workforce is structured?

17:35

A.

Are you talking about just the personnel?

17:35

Q.

Sure.

17:35

A.

Four rotating shifts.

17:35

with shift leaders on each team, each shift team, and they were

17:35

10

aligned with, you know, chemists and then the cement lab

17:35

11

manager.

17:35

12

Q.

17:35

13

your lab?

17:35

14

A.

17:35

15

requested by the engineers and service coordinators.

17:35

16

Q.

17:35

17

technicians actually worked in the cement lab?

17:36

18

A.

Probably somewhere between 16 and 20, I would say.

17:36

19

Q.

Could you explain to the Court how these lab technicians

17:36

20

are actually trained to run tests in the lab?

17:36

21

A.

17:36

22

to just kind of watch their progression and teach them how to

17:36

23

perform tests.

17:36

24

Q.

17:36

25

technician that has a mentor is ready to fly on his own and run

Can you give us a brief overview of how the lab

Okay.

Two shifts working, two shifts off,

What are the responsibilities of the technicians in

Responsible for performing all the testing that is

Do you recall at the time in April 2010 about how many lab

When the technicians are hired, they're assigned mentors

And at some point, how do you know whether or not a lab

OFFICIAL TRANSCRIPT

4859
TIMOTHY QUIRK - DIRECT

17:36

tests?

17:36

A.

17:36

that was established within Halliburton, and the technicians

17:36

are -- were assessed by qualified assessors to determine

17:36

whether or not they could be deemed competent in that

17:36

particular procedure.

17:36

Q.

17:36

memory a little bit.

17:36

can you recall the average number of years of work experience

17:37

10

for the lab technicians in your workforce?

17:37

11

A.

17:37

12

nine years, somewhere in that -- somewhere around that time

17:37

13

frame.

17:37

14

Q.

17:37

15

Broussard, were you confident that those techs knew how to

17:37

16

perform the tests that they were requested to perform?

17:37

17

A.

Yes.

17:37

18

Q.

Now, during your tenure in the cement lab and even as the

17:37

19

fluid lab manager, was the cement lab ever audited?

17:37

20

A.

Yes, it was audited.

17:37

21

Q.

About how many times a year did that cement lab get

17:37

22

audited?

17:37

23

A.

17:37

24

there were some years we may get audited four or five times in

17:37

25

one year.

There's a competency system, a global competency system

All right.

And I know this is asking you to reach back in


But in April of 2010, or that time frame,

It was -- it was probably eight -- seven, eight,

Now, when you were the head manager over all the labs in

There were some years we didn't get audited at all, and

OFFICIAL TRANSCRIPT

4860
TIMOTHY QUIRK - DIRECT

17:37

Q.

And who -- sorry.

17:37

A.

And we were audited internally and by our customers.

17:37

Q.

And who -- I want to make sure -- let's break that down a

17:38

little bit.

17:38

17:38

audits?

17:38

A.

That's correct.

17:38

Q.

Okay.

17:38

audits?

17:38

10

A.

17:38

11

was dedicated to, you know, going around the world and

17:38

12

evaluating -- auditing labs.

17:38

13

Q.

17:38

14

that conducts those audits?

17:38

15

A.

17:38

16

any customer or company that we work for.

17:38

17

Chevron, BP, ExxonMobil.

17:38

18

Q.

So major operators actually --

17:38

19

A.

Major operators.

17:38

20

Q.

-- may request to audit the lab?

17:38

21

A.

Right.

17:38

22

Q.

All right.

17:38

23

audits, did the auditors pay attention to technician

17:38

24

competency?

17:38

25

A.

You had internal audits and then you had customer

When you say "internal audits," who performs those

It was a team that -- you know, within Halliburton that

When you say "customer audits," who are you referring to

All the companies that we work for, any company that we -It could be Shell,

Any customer.

I would like to -- by the way, in these

Yes.
OFFICIAL TRANSCRIPT

4861
TIMOTHY QUIRK - DIRECT

17:38

Q.

Did they pay attention to specific testing procedures?

17:38

specific testing procedures.

17:38

A.

Yes, they do.

17:38

Q.

Do they pay attention to the documentation associated with

17:39

testing?

17:39

A.

17:39

17:39

audited-out as everybody, so I'm going to go quickly through

17:39

this, but I just want to identify for the Court one of these

17:39

10

17:39

11

17:39

12

first page sideways, please.

17:39

13

BY MR. HILL:

17:39

14

Q.

17:39

15

TREX-3769?

17:39

16

A.

Yes, I do.

17:39

17

Q.

Okay.

17:39

18

17:39

19

please.

17:39

20

BY MR. HILL:

17:39

21

Q.

17:39

22

that you were talking about?

17:39

23

A.

Yes, it does.

17:39

24

Q.

Can you tell us who these auditors were?

17:39

25

A.

That's Perry Boudreaux and Richard McDonald.

Yes, they do.


MR. HILL:

Can you bring up TREX-3769.

And I'm as

audits.
Next page, please.

Turn it sideways.

Turn that

Do you recognize this document that's been identified as

Who --

MR. HILL:

All right.

You might just blow it up right here,

Does this reflect one of those internal audits

OFFICIAL TRANSCRIPT

4862
TIMOTHY QUIRK - DIRECT

17:40

Q.

Are they Halliburton employees?

17:40

A.

Yes, they're Halliburton employees.

17:40

Q.

And did you and Richard Dubois actually participate in

17:40

this audit?

17:40

A.

17:40

17:40

out.

17:40

BY MR. HILL:

17:40

Q.

17:40

10

With respect to Audit Issue 1.02, "Based on

17:40

11

appearance, would you trust test results from this lab," would

17:40

12

you please tell the Court what you scored in terms of maximum

17:40

13

value?

17:40

14

A.

We scored a 36.

17:40

15

Q.

Could you score any higher?

17:40

16

A.

I think that's max.

17:40

17

Q.

What was -- what was the comment associated with it?

17:40

18

A.

"Without question."

17:40

19

17:40

20

there.

17:41

21

BY MR. HILL:

17:41

22

Q.

17:41

23

comfortable bringing a customer here," what was the audit

17:41

24

score?

17:41

25

A.

Yes.
MR. HILL:

Can you go to Section 1.02.

Pull that

With respect to the audit --

MR. HILL:

Could you go to 1.03, please.

Right

With respect to the audit question "Would you feel

36.
OFFICIAL TRANSCRIPT

4863
TIMOTHY QUIRK - DIRECT

17:41

Q.

Is there a higher score?

17:41

A.

I think 36 is the highest.

17:41

Q.

What's the comment associated with that by the auditors?

17:41

A.

"Without question, world-class facility."

17:41

17:41

Section 7 on "Employee Competency," Your Honor, as well as

17:41

several others.

17:41

summary page.

17:41

17:41

10

17:41

11

BY MR. HILL:

17:41

12

Q.

17:41

13

score?

17:41

14

A.

It was 93 percent.

17:41

15

Q.

With respect to slurry preparation, what did your lab

17:41

16

score?

17:41

17

A.

100 percent.

17:41

18

Q.

With respect to free fluid loss -- I'm sorry.

17:42

19

17:42

20

what did your lab score?

17:42

21

A.

100 percent.

17:42

22

Q.

Crush compressive strengths?

17:42

23

A.

100 percent.

17:42

24

Q.

Thickening time testing?

17:42

25

A.

95 percent.

MR. HILL:

Now, we could go through here and identify

I think the easiest thing is to just go to the

Keep going.

There we go.

Pull this up right here, including the totals.

With respect to employee competency, what did your lab

With respect to fluid loss and free fluid testing,

OFFICIAL TRANSCRIPT

4864
TIMOTHY QUIRK - DIRECT

17:42

Q.

Rheology testing?

17:42

A.

100 percent.

17:42

Q.

Do you recall the total overall score of your lab in this

17:42

internal audit?

17:42

A.

92 percent.

17:42

Q.

Thank you.

17:42

17:42

about weigh-up sheets, customer reports, and a variety of

17:42

different lab documents.

17:42

10

Judge Barbier a little bit about the process for initiating lab

17:42

11

testing.

17:42

12

17:42

13

for a cement job?

17:42

14

A.

17:42

15

coordinator.

17:42

16

Q.

In this -- I'm sorry.

17:42

17

A.

Go ahead.

17:42

18

Q.

In the case of Macondo, who would that have been, to your

17:42

19

understanding?

17:42

20

A.

That would have been Jesse, Jesse Gagliano.

17:42

21

Q.

All right.

17:42

22

works.

17:43

23

tests be done?

17:43

24

A.

17:43

25

system.

Now, it's important, I think, for -- we have talked

I would like you to explain to

Who requests the specific lab tests to be performed

It's requested by the engineer, usually, or service

And can you please explain how that process

Does Jesse come to the lab and ask -- and request the

No.

He uses the web-based Viking lab database management

OFFICIAL TRANSCRIPT

4865
TIMOTHY QUIRK - DIRECT

17:43

Q.

Once the requesting engineer fills out Viking and makes a

17:43

request, what, if anything, does the lab do?

17:43

A.

17:43

know, initiate testing.

17:43

Q.

17:43

print in order to go do their job?

17:43

A.

They would print the lab weigh sheet.

17:43

Q.

All right.

17:43

17:43

10

A.

17:43

11

technician.

17:43

12

Q.

17:43

13

used in the lab?

17:43

14

A.

17:43

15

the day and night, they are -- they write down the results

17:43

16

obtained during testing -- the testing process.

17:44

17

17:44

18

BY MR. HILL:

17:44

19

Q.

17:44

20

seeing on the screen here.

17:44

21

A.

That's a lab -- that's a lab weigh-up sheet.

17:44

22

Q.

When you said that the lab actually goes and prints it out

17:44

23

of Viking, are these handwritten notes on it when it's printed?

17:44

24

A.

Yes.

17:44

25

Q.

Are these handwritten notes on it when it's printed from

The lab would -- would receive the request and then, you

Is there any documents or anything that the lab has to

The judge has heard about the weigh-up sheets.

Who in the lab prints it?


It could be the lab manager, chemist, or even the

And once that lab weigh-up sheet is printed, how are they

They're used to -- as the testing is performed throughout

MR. HILL:

Bring up TREX-60405, please.

60405.

Can you explain to the Court, Judge Barbier, what he's

OFFICIAL TRANSCRIPT

4866
TIMOTHY QUIRK - DIRECT

17:44

the Viking system --

17:44

A.

17:44

print the sheet and begin testing.

17:44

Q.

Who adds the handwriting?

17:44

A.

Like I said, it could be a lab chemist, a lab -- cement

17:44

lab manager, or even one of the lab techs.

17:44

Q.

17:45

actually conduct these tests?

17:45

A.

17:45

10

just with experience, you know.

17:45

11

have to be tested first would determine where the paperwork --

17:45

12

the lab worksheet's going to be put.

17:45

13

be weighed up.

17:45

14

17:45

15

first or fluid loss free water first or rheologies or

17:45

16

compressive strength -- depending on what they were wanting to

17:45

17

do would be where that paperwork would be directed.

17:45

18

Q.

17:45

19

same lab technician who finishes it?

17:45

20

A.

In some cases, but in most cases not.

17:45

21

Q.

And why is that?

17:45

22

A.

Just because the lab runs 24 hours a day, and sometimes

17:45

23

the testing -- for example, a 12- or 24-hour test, the

17:45

24

technician may not even be there when it's over.

17:46

25

Q.

No, no, no.

Okay.

I'm sorry, it's not.

It's added after they

Now, let's -- how are lab technicians assigned to

Well, there's a -- there's kind of a flow that goes about,


Depending on what's going to

So it would first have to

And then, if they're going to run a thickening time

The same lab technician who starts a test, is that the

Now, once lab test results are obtained through testing,


OFFICIAL TRANSCRIPT

4867
TIMOTHY QUIRK - DIRECT

17:46

what does the technician do with them at that point?

17:46

A.

They put it into the Viking system.

17:46

Q.

To whom do the lab technicians communicate those test

17:46

results?

17:46

A.

17:46

there's any questions or if an engineer wants to call and speak

17:46

to someone, then they would just make a phone call.

17:46

also a message system within Viking also.

17:46

Q.

17:46

10

17:46

11

17:46

12

results are done and input into Viking?

17:46

13

A.

17:46

14

message system.

17:46

15

could be set up for various reasons.

17:46

16

test result for that particular test is obtained, they could

17:46

17

get an e-mail and a text message.

17:46

18

subscribe to a daily report where, once a day, they get a

17:46

19

report of everything that they have going on.

17:46

20

17:47

21

you can adjust your user profile.

17:47

22

Q.

17:47

23

an outside customer like BP or any other owner -- well owner or

17:47

24

operator?

17:47

25

A.

Well, the lab technicians are inputted into Viking.

If

Or there's

I'm glad you said that because that's where I wanted to go

next.
How would a requesting engineer know that testing

There's several ways.

One's a phone call.

One is a

And there's a user profile in Viking that


One could be as soon as a

The way could be they could

There's just several -- there's different ways that

Does your lab and its technicians report test results to

That's not generally part of the process, no.


OFFICIAL TRANSCRIPT

4868
TIMOTHY QUIRK - DIRECT

17:47

Q.

Who actually reports tests to the operator?

17:47

A.

The engineer submitting the request.

17:47

Q.

What is that document called that is used to report test

17:47

results?

17:47

A.

17:47

17:47

BY MR. HILL:

17:47

Q.

17:47

generally the format of the -- of those customer reports you're

17:47

10

identifying?

17:47

11

A.

Yes.

17:47

12

Q.

And how is this report generated?

17:47

13

A.

The engineer would go into Viking and enter in -- go into

17:47

14

the Customer Report part of the system and then select that

17:47

15

request number or enter that request number and then select the

17:48

16

tests that they're interested in reporting.

17:48

17

17:48

18

BY MR. HILL:

17:48

19

Q.

17:48

20

specifically about the weigh-up sheets and specifically what

17:48

21

the lab techs do.

17:48

22

17:48

23

A.

The lab technicians.

17:48

24

Q.

And what's done with notations for a particular test?

17:48

25

What becomes of the handwritten covered weigh-up sheets?

It's a customer report.


MR. HILL:

Can you bring up TREX-7722, please.

Is this -- this actually relates to Macondo.

MR. HILL:

All right.

This is

You can take that down.

So let's talk about -- a little bit more

Who at Halliburton uses the weigh-up sheets?

OFFICIAL TRANSCRIPT

4869
TIMOTHY QUIRK - DIRECT

17:48

A.

They get filed on the Viking.

Lab weigh-up sheets just

17:48

get filed.

17:48

Q.

Where are they filed?

17:48

A.

In the lab, in the cement lab.

17:48

Q.

Are the handwritten weigh-up sheets accessible through

17:48

Viking to people outside of the lab?

17:48

A.

17:48

something like that.

17:48

Q.

And my question is:

17:48

10

A.

No, they're not.

17:48

11

Q.

Are they typically provided to the requesting engineer?

17:48

12

A.

No.

17:48

13

Q.

Are they provided to external customers like BP or well

17:48

14

operator -- or well owners or operators?

17:49

15

A.

No.

17:49

16

Q.

Now, if someone wanted to see weigh-up sheets from a job,

17:49

17

to whom would they direct that request?

17:49

18

A.

They'd probably talk to the cement lab manager or chemist.

17:49

19

Q.

And in that case, it would have been Richard Dubois?

17:49

20

A.

Yes, or Kenny Miller.

17:49

21

Q.

Could they have called you?

17:49

22

A.

Could have called me, too.

17:49

23

Q.

Now, do you recall if any weigh-up sheets associated with

17:49

24

Macondo were requested of you?

17:49

25

A.

Not unless they, you know, would call in and request


I mean, but typically, no, it's not.
Are they accessible through Viking?

No.

Not until, you know, much later when I was working with
OFFICIAL TRANSCRIPT

4870
TIMOTHY QUIRK - DIRECT

17:49

the legal team.

17:49

Q.

17:49

request for weigh-up sheets associated with Macondo?

17:49

A.

Yes.

17:49

Q.

Do you recall when that was?

17:49

A.

Late September/October, that time frame.

17:49

Q.

Let's talk -- there's been discussion in this case about

17:49

foam testing --

17:49

17:50

10

A.

2010.

17:50

11

Q.

So that's late September/October of 2010?

17:50

12

A.

Right.

17:50

13

Q.

Okay.

17:50

14

testing.

17:50

15

standard slurry testing and foam testing?

17:50

16

what's the difference between those slurries?

17:50

17

A.

17:50

18

additive added to it, applying shear and entraining air into

17:50

19

the slurry.

17:50

20

Q.

17:50

21

slurry in the lab, what is that?

17:50

22

A.

It's just atmospheric air.

17:50

23

Q.

Out on the rig, what is it?

17:50

24

A.

It's nitrogen.

17:50

25

Q.

Why don't you do nitrogen testing in the lab?

All right.

Let's answer this:

Do you remember getting a

I'm sorry, October of what year?

There's been a lot of discussion about foam

Can you explain to the judge the difference between


Just generally,

The foam slurry is basically a base slurry with foaming

So the gas that's entrained to make bubbles in the cement

OFFICIAL TRANSCRIPT

4871
TIMOTHY QUIRK - DIRECT

17:50

A.

It's just not very safe.

17:50

Q.

Are there certain tests that can be conducted on a base

17:50

slurry or a non-foam slurry that can't be conducted on a foam

17:50

slurry, just based on the equipment available?

17:50

A.

Yes, that's correct.

17:51

Q.

Can you identify a couple?

17:51

A.

Thickening time.

17:51

Q.

UCA compressive strength testing, can that be done on a

17:51

foam slurry with field lab equipment?

17:51

10

A.

17:51

11

had at Halliburton when I was there.

17:51

12

17:51

13

BY MR. HILL:

17:51

14

Q.

Do you recognize this document, Mr. Quirk?

17:51

15

A.

Yes.

17:51

16

Q.

10B-4, API 10B-4?

17:51

17

A.

Yeah, 10-B 4.

17:51

18

Q.

Can you go to page -- the Court has actually seen this

17:51

19

document before.

17:51

20

17:51

21

going to get the section that crosses the bottom of page 10 up

17:51

22

to page 11.

17:51

23

17:51

24

please.

17:52

25

page.

Not with our field lab equipment or the equipment that we

MR. HILL:

Can you bring up TREX-6235, please?

That's the API document.

MR. HILL:

I thought you said "Timothy."

Could you please go to page 10.

Right here.

We're

Can you blow that up at the bottom,

And then the top of the first page -- or the next

OFFICIAL TRANSCRIPT

4872
TIMOTHY QUIRK - DIRECT

17:52

BY MR. HILL:

17:52

Q.

17:52

instability when we talked with Mr. Benge when he was here

17:52

testifying for the U.S. Government.

17:52

17:52

signs of foam instability.

17:52

API-specified signs of foam instability?

17:52

A.

Yes.

17:52

Q.

In fact, if we were to go to Halliburton's global lab best

17:52

10

practices -- are you familiar with that document?

17:52

11

A.

Yes.

17:52

12

Q.

Basically, there's a recitation of these same signs in the

17:52

13

Halliburton --

17:52

14

A.

Yes.

17:52

15

Q.

-- global lab best practices; correct?

17:52

16

A.

Yes.

17:52

17

Q.

All right.

17:52

18

these lab technicians trained to identify, with respect to foam

17:52

19

testing, these indications of instability during foam testing?

17:52

20

A.

Yes.

17:52

21

Q.

What, if anything, are lab technicians trained to do if

17:52

22

they observe any such indications of instability?

17:52

23

A.

They're trained to document that.

17:52

24

Q.

What would you -- by "document," write it on that weigh-up

17:53

25

sheet we just talked about?

Now, the Court has heard us discuss the signs of

We identified this section of API that speaks of


Are you familiar with the

So my question to you is this:

OFFICIAL TRANSCRIPT

Are any of

4873
TIMOTHY QUIRK - DIRECT

17:53

A.

Right, right.

That's correct.

17:53

Q.

What would you expect to see on a weigh-up sheet if a

17:53

technician performing a foam stability test did not observe any

17:53

of these signs of instability?

17:53

A.

17:53

instability issues to address.

17:53

Q.

17:53

17:53

17:53

10

retested.

17:53

11

the QC process in the lab.

17:53

12

17:53

13

recognize perhaps an odd or an out-of-the-ordinary test result?

17:53

14

A.

Repeat the test.

17:53

15

Q.

How do you know that, by the way?

17:53

16

A.

It's just what we communicate with.

17:53

17

meetings with our team, and part of those meetings involved,

17:53

18

you know, making sure that if results don't look in line, that

17:54

19

we repeat the test.

17:54

20

Q.

17:54

21

the requesting engineer when a test is repeated?

17:54

22

A.

I can't say that it happens every time.

17:54

23

Q.

Let's talk about focus -- focus just on foam stability

17:54

24

testing for a minute.

17:54

25

I would assume there were no problems with the slurry, no

Okay.

Switching direction just a little bit.

There are instances in the weigh-up sheets on some of


these demonstratives that the Court has seen where tests were
Okay?

So I want to talk to you a little bit about

What are lab technicians expected to do when they

We had regular

In your experience, Mr. Quirk, does the lab always tell

When a set foam stability test is conducted in the


OFFICIAL TRANSCRIPT

4874
TIMOTHY QUIRK - DIRECT

17:54

lab and the test shows a higher density on the top than on the

17:54

bottom, is that what you would expect to see if air was

17:54

breaking out of that test sample?

17:54

A.

I wouldn't expect for it to be heavier on the top, no.

17:54

Q.

Would that be an out-of-ordinary test result?

17:54

A.

Yes.

17:54

Q.

What would a lab tech expect to see in that -- well, let's

17:54

assume that air is breaking out of the sample.

17:54

lab tech expect do see in terms of the density of that sample?

17:54

10

A.

Heavier density on the bottom and then lighter on the top.

17:54

11

Q.

Why is that, by the way?

17:54

12

A.

Just because air is breaking out.

17:54

13

the top and it would be lighter on top.

17:54

14

Q.

17:55

15

of these out-of-the-ordinary test results where density of a

17:55

16

foam stability test was higher on top than on bottom?

17:55

17

A.

I would expect him to repeat it.

17:55

18

Q.

All right.

17:55

19

about D-Air, and I think you recognize that Halliburton's

17:55

20

internal guidance actually -- cautioned against the use of

17:55

21

D-Air in a foam slurry.

17:55

22

A.

That's correct.

17:55

23

Q.

So if you were designing a foam slurry from scratch, would

17:55

24

you recommend putting D-Air in the foam blend?

17:55

25

A.

What would a

It's moving its way to

What would you expect a lab tech to do if he observed one

Shifting to D-Air.

You had some questions

Correct?

No.
OFFICIAL TRANSCRIPT

4875
TIMOTHY QUIRK - DIRECT

17:55

Q.

But if you were presented with a situation where D-Air was

17:55

already blended in the dry cement blend, is there anything that

17:55

you can do to make sure that it performs successfully?

17:55

A.

17:55

had a sample and had to test it, then I would increase the zone

17:55

sealant to overcome the effects of the D-Air.

17:55

Q.

17:55

said.

17:55

A.

It's a foaming additive.

17:56

10

Q.

And how does it compensate to overcome the effects of

17:56

11

D-Air?

17:56

12

A.

17:56

13

to adding -- you know, if you took a little bit of Dawn

17:56

14

dishwashing liquid and put it in the water versus adding more,

17:56

15

you'll getting more foaming if you sheared it.

17:56

16

to that.

17:56

17

Q.

17:56

18

that's intended to be foamed, does it automatically disqualify

17:56

19

it from being able to be foamed, in your experience?

17:56

20

A.

Not in my experience, it doesn't disqualify it.

17:56

21

Q.

And if you wanted to know whether the relevant

17:56

22

concentrations of D-Air and surfactant that you put in that

17:56

23

blend -- if you wanted to know if the concentration of

17:56

24

surfactant is sufficient to overcome the effects of D-Air, how

17:56

25

do you know that?

I would -- if I was presented with a situation where we

Okay.

So I just want to follow-up with what you just

The zone sealant is a different additive; correct?


Correct.

Just adding more foaming additive.

It would be equivalent

It's equivalent

It's a foaming additive.

Now, Mr. Quirk, the mere presence of D-Air in a dry blend

OFFICIAL TRANSCRIPT

4876
TIMOTHY QUIRK - DIRECT

17:56

A.

You order a test.

17:56

Q.

What test do you run?

17:56

A.

A foam stability test.

17:56

Q.

Now, BP's counsel brought out something with Dr. Benge, I

17:57

believe -- don't hold me to that.

17:57

Gagliano's weigh-up sheets -- or the weigh-up sheets associated

17:57

with the foam stability test that Jesse Gagliano requested

17:57

actually changed the surfactant concentration from the

17:57

beginning to the end.

17:57

10

A.

Okay.

17:57

11

Q.

Have you reviewed the weigh-up sheets associated with the

17:57

12

foam stability testing at Macondo?

17:57

13

A.

Yes.

17:57

14

Q.

Do you recall what the surfactant concentration is?

17:57

15

A.

I think it was .11, I believe.

17:57

16

17:57

17

BY MR. HILL:

17:57

18

Q.

Can you identify what the surfactant concentration is?

17:57

19

A.

It's .11 gallons per sack.

17:57

20

Q.

Okay.

17:58

21

concentration of surfactant that you typically see in a foam

17:58

22

cement job?

17:58

23

A.

Yes.

17:58

24

Q.

What is it?

17:58

25

A.

Typically, it's .07.

MR. HILL:

But they asked if Jesse

Okay?

Bring up 7722, please.

In your experience, is there a standard

OFFICIAL TRANSCRIPT

4877
TIMOTHY QUIRK - DIRECT

17:58

Q.

So .07 is less than .11 gallons per sack; correct?

17:58

A.

That's correct.

17:58

Q.

There's also been discussion about the propriety of the

17:58

labs actually conditioning the base slurry prior to conducting

17:58

foam stability tests.

17:58

that.

17:58

17:58

base slurry is prior to actually conducting a foam stability

17:58

test?

17:58

10

A.

17:58

11

the hole and exposing it to temperature.

17:58

12

Q.

17:58

13

talking about 3 miles from rig to bottom hole, right,

17:58

14

approximately?

17:58

15

A.

Correct.

17:58

16

Q.

Approximately?

17:58

17

A.

Based on the depth, yeah.

17:59

18

Q.

That takes time to pump down that deep, doesn't it?

17:59

19

A.

Yes.

17:59

20

Q.

Can you explain to the Court what happens to the slurry as

17:59

21

it's pumped downhole for 3 miles over time.

17:59

22

17:59

23

But I think we established a few minutes ago that he's never

17:59

24

done any downhole work.

17:59

25

So I want to turn your attention to

What do you understand the purpose of conditioning a

Simulating the job placement time, meaning pumping it down

All right.

So in a well the size of Macondo, we're

MR. REGAN:

THE COURT:

Your Honor -- and maybe he can do it.

I sustain the objection.


OFFICIAL TRANSCRIPT

4878
TIMOTHY QUIRK - DIRECT

17:59

BY MR. HILL:

17:59

Q.

17:59

is -- what are you actually simulating when you do

17:59

conditioning?

17:59

A.

17:59

submitted on the request.

17:59

Q.

Specifically, what are those conditions?

17:59

A.

Temperature and pressure.

17:59

Q.

How is it determined the time for conditioning when you

17:59

10

actually do condition a base slurry prior to foaming?

17:59

11

A.

17:59

12

it as a job placement time, you know, or -- a given time.

17:59

13

Q.

17:59

14

placement time connected with the condition time?

17:59

15

A.

18:00

16

we'd represent how we would -- roughly how long it would take

18:00

17

to pump the cement in place.

18:00

18

lab.

18:00

19

Q.

18:00

20

April 2010 was conditioned, prior to foaming?

18:00

21

A.

Three hours.

18:00

22

Q.

Are you aware, Mr. Quirk, of any test that would tell the

18:00

23

Court whether conditioning that slurry in the lab before

18:00

24

foaming it artificially thickened the slurry in the lab?

18:00

25

A.

All right.

Can you explain what the purpose in the lab

I'm simulating the downhole well conditions that were

The engineer submitting the request would generally submit

So just -- can you explain to the Court, how is the job

It's -- typically, that would be the same, meaning that

So you try to mimic that in the

Do you know how long the final foam stability test on

I'm not aware of a -- of a test that indicates that?


OFFICIAL TRANSCRIPT

4879
TIMOTHY QUIRK - DIRECT

18:00

Q.

Yeah.

18:00

A.

That it thickened it?

18:00

Q.

Or one that would show whether or not that's true.

18:00

A.

A thicken time, sure.

18:00

18:00

18:00

18:01

here, please.

18:01

BY MR. HILL:

18:01

10

Q.

18:01

11

test was conducted?

18:01

12

A.

135 degrees Fahrenheit.

18:01

13

Q.

Do you know the retarder concentration of this particular

18:01

14

test?

18:01

15

A.

I think it's -- .08, I believe.

18:01

16

Q.

That's a Part 2 test, so it was --

18:01

17

A.

Oh.

18:01

18

Q.

Okay.

18:01

19

A.

Gallons.

18:01

20

Q.

-- gallons of retarder?

18:01

21

A.

Yes.

18:01

22

18:01

23

in Bates No. 8711.

18:01

24

BY MR. HILL:

18:01

25

Q.

MR. HILL:

Can you bring up 7722.

Go to the first

page for a second.


Again, bring up this thickening time test right

What was the temperature at which that thickening time

That's .09, right?

Yes, I think it would be .09.

.09 --

MR. HILL:

Can you go to the chart on the page ending


Pull that up.

Mr. Quirk, can you explain what this chart is?


OFFICIAL TRANSCRIPT

4880
TIMOTHY QUIRK - DIRECT

18:01

A.

That's a thickening time chart.

18:01

Q.

What is this line right here?

18:01

A.

That's the cement viscosity.

18:01

Q.

So what does that point right there indicate?

18:01

A.

That's the initial viscosity upon starting the test.

18:01

Q.

As this slurry for conducting the thickening time test is

18:01

heated to 135 degrees, what happens to that viscosity trend

18:02

line?

18:02

A.

It goes down, meaning it thins somewhat.

18:02

10

Q.

Do you know why that happens?

18:02

11

A.

It's because of the heat being applied to the slurry.

18:02

12

It's thermal thinning, basically.

18:02

13

Q.

18:02

14

your -- based on what you can see here, does the viscosity at

18:02

15

three hours ever get up to the initial viscosity point?

18:02

16

A.

It's just below it, right -- yeah, just below it.

18:02

17

Q.

Now, just to make sure we're clear, this particular test

18:02

18

is run with SA-541 additive in the slurry; correct?

18:02

19

A.

That's correct.

18:02

20

Q.

What is SA-541?

18:02

21

A.

It's a suspension aid, suspending aid in cement.

18:02

22

Q.

How is it activated?

18:02

23

A.

By temperature.

18:02

24

Q.

So if you were wondering whether or not that SA-541 was

18:02

25

actually artificially activated by conditioning time heat,

After three hours, does that viscosity ever get up, in

It's heat-activated.

OFFICIAL TRANSCRIPT

4881
TIMOTHY QUIRK - DIRECT

18:02

would this test tell you whether or not that's true?

18:02

A.

18:03

it didn't activate.

18:03

viscosity at the time that you would expect it to, as it's

18:03

gaining temperature.

18:03

Q.

At least with respect to those three hours; correct?

18:03

A.

Correct.

18:03

18:03

18:03

10

18:03

11

18:03

12

going to be short, and we took him instead of Mr. Barnhill.

18:03

13

That's the last time I'll believe any of you guys.

18:03

14

MR. HILL:

18:03

15

THE COURT:

18:03

16

18:04

17

THE DEPUTY CLERK:

18:04

18

(WHEREUPON, the proceedings were concluded.)

19

*****

20

CERTIFICATE

21
22
23
24
25

It appeared, by looking at this chart, that it didn't --

MR. HILL:
to 40 minutes.

It actually thinned rather than rising in

Your Honor, I've still got about 40 -- 35

I don't know if you want me to keep going or --

I'm at a stopping point.


THE COURT:

this long.

I only took this witness because he was

I can press on.


I can't believe this witness is taking

We're going to recess until 8:00 tomorrow morning.


All rise.

I, Jodi Simcox, RMR, FCRR, Official Court Reporter


for the United States District Court, Eastern District of
Louisiana, do hereby certify that the foregoing is a true and
correct transcript, to the best of my ability and
understanding, from the record of the proceedings in the
above-entitled and numbered matter.

s/Jodi Simcox, RMR, FCRR


Jodi Simcox, RMR, FCRR
Official Court Reporter

OFFICIAL TRANSCRIPT

12 [1] 4866/23
1201 [2] 4672/3 4673/9
'04 [1] 4684/1
1221 [1] 4673/5
'05 [1] 4684/1
123 [1] 4709/15
'90s [1] 4857/18
12th [1] 4748/18
'it [1] 4699/3
12th at [1] 4816/12
13 [2] 4698/8 4698/9
.
1308 [1] 4669/19
.07 [2] 4876/25 4877/1
1331 [1] 4673/12
.08 [2] 4775/16 4879/15
135 [1] 4880/7
.09 [13] 4775/12 4775/18 4791/23
135 degrees [1] 4879/12
4792/1 4792/8 4792/10 4792/17
1356A [1] 4690/25
4792/25 4822/4 4822/10 4879/17
1356A.20.4 [2] 4690/23 4691/16
4879/17 4879/18
1356A.22.2 [1] 4692/10
.1.1 [1] 4682/15
14 [4] 4668/14 4698/3 4729/18 4742/3
.1.2 [1] 4682/14
140 [1] 4678/25
.1.3 [1] 4682/20
140 rigs [1] 4679/23
.10 [3] 4812/25 4813/17 4814/10
142 [1] 4729/9
.11 [3] 4876/15 4876/19 4877/1
14271 [1] 4670/22
.13.2 [1] 4740/5
1429.20.1 [1] 4750/9
.13.3 [1] 4740/13
1449 [4] 4703/21 4705/5 4709/15
.14 [1] 4816/3
4712/23
.17 [2] 4813/4 4814/6
1449.123.1 [1] 4709/9
.2.1 [1] 4714/17
1449.132.1 [1] 4712/24
.20 [1] 4819/21
1449.15.1 [1] 4707/24
.20 slurry [1] 4819/21
1449.20.1 [1] 4707/13
.9 [1] 4775/16
1449.5.3 [1] 4705/5
1449.5.4 [1] 4706/12
0
1472.1.3 [1] 4738/21
0003 [1] 4823/9
14th [2] 4822/25 4823/16
02771 [1] 4668/7
15 [5] 4690/24 4691/17 4698/3 4742/3
05593 [1] 4775/7
4742/11
09 [1] 4775/25
15-minute [1] 4753/6
15.1 [1] 4691/1
1
16 [3] 4790/23 4855/5 4858/18
1-gallon [4] 4827/21 4828/4 4828/19
1601 [1] 4669/3
4828/22
1665 [1] 4673/12
1.02 [2] 4862/6 4862/10
17 [2] 4692/12 4732/2
1.03 [1] 4862/19
17.1 [1] 4692/14
1.1 [1] 4700/9
1700 [1] 4673/9
10 [3] 4732/2 4871/20 4871/21
174 [1] 4698/8
10 minutes [1] 4724/15
175 [1] 4697/24
10-22-09 date [1] 4784/25
17th [22] 4766/21 4771/23 4772/3
10-B [1] 4871/17
4772/6 4772/9 4772/13 4772/23 4773/5
10-CV-02771 [1] 4668/7
4776/2 4778/4 4780/5 4781/11 4781/23
10-CV-4536 [1] 4668/9
4782/23 4784/15 4785/9 4792/16
10-MD-2179 [1] 4668/4
4800/6 4800/20 4801/18 4802/6
10/22/09 [1] 4775/25
4850/15
100 [7] 4728/1 4784/22 4789/25 4790/7 18 [4] 4758/12 4758/13 4759/2 4765/16
4791/22 4792/17 4793/1
1885 [1] 4671/12
100 percent [6] 4727/23 4728/11
18th [3] 4682/13 4828/12 4853/18
4863/17 4863/21 4863/23 4864/2
19 [5] 4668/7 4675/3 4698/17 4769/20
100 square [1] 4795/10
4769/21
1000 [2] 4672/17 4673/16
19,000 [1] 4708/24
1001 [1] 4672/10
1987 [1] 4853/16
100L [28] 4773/7 4773/10 4773/20
1990 [3] 4853/18 4853/22 4853/23
4774/1 4774/6 4774/19 4775/12
1995 [1] 4854/4
4775/16 4775/24 4779/19 4779/25
1:00 [1] 4739/11
4780/2 4780/9 4783/14 4784/19
1:00 in [3] 4738/22 4739/9 4739/12
4784/23 4785/3 4785/22 4804/25
1:30 p.m [1] 4778/22
4812/14 4813/1 4814/8 4828/20 4845/8 1A [2] 4702/25 4703/19
4848/4 4848/23 4850/18 4851/13
1B [3] 4702/23 4702/25 4724/15
101 [1] 4669/16
2
10B-4 [2] 4871/16 4871/16
10th [1] 4810/4
2.1 [2] 4790/20 4790/23
11 [8] 4750/25 4758/12 4758/13
20 [5] 4668/5 4752/12 4801/23 4855/5
4767/16 4767/25 4769/3 4769/12
4858/18
4871/22
20 barrels [4] 4729/20 4729/22 4730/17
1100 [1] 4672/6
4732/18
1110 [1] 4672/20
20 miles [1] 4852/17
11:06 [1] 4813/12
200 [1] 4683/25
11:06 p.m [2] 4813/14 4813/18
2000 [4] 4788/21 4788/22 4848/2
11th [3] 4700/10 4813/12 4813/14
4853/18

'

20004 [2] 4670/22 4672/4


2004 [4] 4714/20 4727/13 4728/6
4854/15
20044 [2] 4670/17 4671/6
2005 [5] 4726/5 4728/20 4729/3
4730/14 4732/16
2007 [4] 4721/12 4721/13 4721/19
4721/20
2008 [4] 4745/18 4754/3 4854/15
4854/19
2009 [30] 4679/19 4679/25 4680/6
4726/5 4728/20 4729/3 4730/1 4730/14
4732/16 4735/4 4743/14 4745/5 4746/1
4746/17 4747/4 4747/14 4748/3 4748/9
4748/11 4748/21 4749/3 4774/2 4780/2
4780/10 4780/23 4783/8 4783/9
4783/13 4785/24 4788/8
2010 [95] 4668/5 4677/25 4678/8
4679/18 4679/20 4680/1 4682/13
4683/17 4684/23 4685/4 4685/23
4700/11 4704/9 4728/9 4738/23 4746/2
4747/22 4748/15 4748/18 4754/13
4755/4 4763/14 4763/24 4764/16
4764/22 4765/2 4771/3 4771/3 4772/3
4772/6 4772/14 4772/16 4772/23
4773/5 4775/6 4775/9 4776/12 4776/22
4776/23 4777/19 4778/4 4778/6
4778/21 4779/14 4780/1 4780/5
4780/11 4781/11 4781/20 4781/23
4782/16 4782/23 4784/15 4785/20
4786/7 4787/7 4792/16 4795/5 4795/19
4796/4 4796/25 4797/3 4797/5 4797/13
4798/3 4798/8 4798/25 4799/5 4799/12
4799/14 4799/25 4800/5 4800/6
4801/22 4801/23 4808/18 4808/24
4815/16 4823/12 4823/17 4830/13
4833/8 4833/15 4833/22 4836/7
4854/22 4855/20 4855/22 4856/1
4858/3 4858/16 4859/8 4870/10
4870/11 4878/20
2012 [12] 4763/16 4763/24 4775/15
4786/7 4787/8 4793/22 4796/4 4825/7
4852/24 4853/3 4853/5 4853/22
2013 [2] 4668/7 4675/3
2016.7D-1.1 [1] 4700/9
20th [38] 4678/10 4685/23 4721/12
4721/13 4733/11 4733/19 4733/20
4738/1 4745/5 4746/2 4747/21 4748/15
4755/3 4759/20 4761/13 4761/17
4763/4 4763/14 4767/8 4767/14
4767/24 4775/6 4775/9 4777/19 4778/2
4778/16 4778/21 4779/6 4785/11
4789/6 4795/5 4795/19 4796/6 4802/6
4803/8 4823/12 4855/22 4856/1
21 [1] 4760/6
216.71.1 [1] 4700/8
2179 [1] 4668/4
2187 [1] 4714/17
2187.1.2 [1] 4714/15
2187.212.1 [1] 4720/2
2187.5 [1] 4715/9
21st [3] 4738/19 4738/22 4785/11
2211 [1] 4672/20
2216 [1] 4670/6
22nd [7] 4669/10 4742/23 4774/2
4780/2 4780/10 4780/23 4785/24
23 [2] 4830/16 4834/20
23/02/2010 [1] 4833/15
23056 [1] 4832/17
23057 [1] 4831/16
23063 [2] 4824/8 4824/21
23451 [1] 4669/10
23rd [4] 4797/13 4799/12 4799/25

41215.1.2 [1] 4682/10


41222.31.1 [1] 4704/5
23rd... [1] 4833/22
4255 [1] 4728/14
24 [1] 4866/22
4255.20.3 [1] 4729/15
24-hour [1] 4866/23
4255.21.3 [1] 4732/25
24th [2] 4677/25 4680/1
4255.44.3 [1] 4730/11
24th of [1] 4853/3
4255.62.4 [1] 4731/18
252 [3] 4799/1 4826/12 4830/13
4275 [1] 4689/18
2615 [1] 4669/6
4310 [1] 4670/3
27th [2] 4852/24 4853/4
4341 [1] 4684/3
28 [1] 4778/6
4341.1 [2] 4683/11 4683/12
2817.178.1 [1] 4716/1
435 [1] 4669/16
28th [13] 4776/9 4776/12 4776/22
4418.1 [1] 4728/25
4777/3 4779/11 4779/14 4779/14
45 [1] 4752/10
4780/1 4780/11 4781/20 4782/16
450 [1] 4670/10
4785/12 4804/24
4500 [1] 4673/5
29th [3] 4776/23 4785/20 4804/24
4536 [1] 4668/9
2A [1] 4703/2
4566 [2] 4772/13 4784/21
2B [1] 4703/2
4594 [2] 4685/12 4686/1
2nd [1] 4749/3
4595 [1] 4702/15
4595.1 [2] 4724/12 4724/12
3
48001 [2] 4845/11 4846/17
30 [2] 4752/13 4808/9
48002 [4] 4797/1 4797/1 4797/22
300 [1] 4671/23
4825/14
3000 [10] 4786/5 4786/10 4786/14
48002-3 [1] 4827/14
4786/20 4786/21 4786/22 4787/10
48002.2 [5] 4797/9 4798/11 4799/18
4787/15 4787/20 4787/22
4800/7 4825/23
306 [1] 4729/12
48093.1.1 [1] 4734/1
3089 [1] 4672/17
48193.3.2 [1] 4810/17
30th [15] 4796/25 4797/3 4797/5
48193.3.4 [1] 4812/22
4797/12 4798/3 4798/8 4799/14 4800/5 48193.4.3 [1] 4811/5
4800/24 4801/6 4801/8 4801/22
48193.7.6 [1] 4815/23
4802/17 4803/25 4804/11
48194 [1] 4822/9
3110 [2] 4800/6 4800/19
48194.8.2 [1] 4822/1
316 [3] 4769/19 4769/21 4769/21
48195.1.2 [1] 4815/10
317 [2] 4769/20 4769/21
48195.5.4 [1] 4816/9
318 [1] 4765/15
48195.9.6 [1] 4819/13
31st [5] 4745/18 4746/1 4746/16 4747/4 4942.20 [1] 4750/14
4747/14
4:00 [1] 4753/5
325 [1] 4824/7
4th [2] 4748/3 4748/11
3257 [2] 4832/17 4836/4
5
3258 [2] 4831/15 4838/17
3264 [2] 4824/8 4829/11
5,000 wells [1] 4729/4
329 [1] 4729/7
5-gallon [8] 4797/15 4797/17 4798/14
35 [1] 4881/8
4804/2 4826/14 4828/16 4831/22
35,050 feet [1] 4680/10
4832/2
355 [1] 4672/14
500 [4] 4668/20 4671/9 4673/19
35th [1] 4672/14
4844/12
36 [3] 4862/14 4862/25 4863/2
500 pounds [1] 4795/9
3601A [2] 4813/15 4816/15
5000 [1] 4671/19
3602 [1] 4807/3
504 [1] 4673/20
36028 [1] 4670/10
52545 [1] 4745/10
36130 [1] 4671/10
52546 [1] 4745/20
36604 [1] 4669/4
52658.1 [1] 4747/18
3668 [1] 4668/20
52658.12 [1] 4748/13
3700 [2] 4672/6 4672/10
52658.16 [1] 4748/23
37042.4.1 [1] 4809/15
52658.4 [1] 4747/24
37042.4.2 [1] 4810/5
5395 [1] 4670/10
3769 [2] 4861/7 4861/15
541 [3] 4880/18 4880/20 4880/24
3773.1.2 [1] 4822/22
54573 [16] 4774/5 4774/19 4776/1
3773.4.3 [1] 4823/4
4780/3 4780/4 4780/11 4780/24 4781/9
39 [1] 4760/6
4782/8 4783/25 4785/1 4785/8 4785/24
3:00 [1] 4752/1
4845/7 4848/3 4851/13
3:08 a.m [1] 4816/12
546 [1] 4672/23
5474 [1] 4701/24
4
5474.102.1 [1] 4701/24
4,130 feet [1] 4680/10
5482.1.1.TO [1] 4749/18
4.1-0003 [1] 4823/9
5482.10.1.TO [1] 4749/10
40 [2] 4881/8 4881/9
549 [4] 4830/16 4834/1 4834/7 4834/21
4000 [1] 4673/16
55 [1] 4752/10
402 [1] 4669/10
556 [2] 4668/20 4729/4
406 [1] 4673/19
5570 [1] 4788/21
41215 [1] 4682/9
5570.3 [1] 4788/23

559 [1] 4798/24


5593 [1] 4777/9
5593.3 [2] 4777/2 4779/11
5593.4 [1] 4785/18
5593.5 [1] 4779/24
5595 [3] 4798/24 4798/25 4800/21
5642 [1] 4677/23
5642.2.1 [1] 4678/15
5642.4.4 [1] 4680/1
5642.5.1 [1] 4678/3
5643 [2] 4721/12 4721/13
5643.4.1 [1] 4722/7
5650 [2] 4744/25 4744/25
589-7780 [1] 4673/20

6
6,795 [1] 4726/5
600 [3] 4669/10 4669/13 4672/17
601 [1] 4669/6
60405 [2] 4865/17 4865/17
60415 [1] 4850/11
60654 [1] 4671/24
618 [1] 4669/22
6235 [1] 4871/12
6264 [16] 4773/9 4773/14 4773/16
4775/25 4779/19 4780/23 4784/9
4784/20 4784/23 4785/6 4785/22
4844/24 4845/8 4848/4 4849/10
4850/18
63141 [4] 4758/11 4760/6 4765/15
4769/19
63213 [1] 4739/16
63213.13.1 [1] 4739/22
63213.14.1 [1] 4742/3
63981 [9] 4797/14 4798/16 4798/19
4799/13 4799/24 4800/18 4800/22
4802/2 4828/17
65112 [1] 4810/10
6726.1 [1] 4746/4
6726.2 [1] 4746/10
6726.3 [1] 4746/24
6726.4 [1] 4747/9
6730 [2] 4726/3 4726/4
67314 [1] 4847/7
6:00 [1] 4753/4
6:00 altogether [1] 4753/1

7
7-5395 [1] 4670/10
7-something [1] 4831/14
70 [1] 4815/1
701 [2] 4671/16 4671/19
70113 [1] 4668/24
70130 [6] 4669/7 4669/13 4670/7
4671/17 4672/24 4673/19
70139 [1] 4671/20
70163 [1] 4672/7
702 [2] 4730/5 4730/8
70360 [1] 4669/16
70458 [1] 4669/19
70501 [1] 4672/18
70502 [1] 4668/21
70801 [1] 4669/23
70804 [1] 4671/13
711 [5] 4730/4 4730/7 4734/25 4735/3
4735/9
727 [3] 4826/18 4827/9 4841/21
73909 [2] 4777/10 4793/15
745.16.1 [1] 4790/5
75 percent [1] 4690/5
75270 [1] 4673/10
7611 [1] 4670/16
7651 [1] 4727/14

7
7651.1.3 [1] 4727/9
7685.1.4 [1] 4704/7
7685.4.1 [2] 4704/14 4704/15
77002 [2] 4672/10 4673/17
77006 [1] 4670/4
77010 [2] 4673/5 4673/13
77098 [1] 4672/21
7722 [3] 4868/6 4876/16 4879/5
7780 [1] 4673/20
7th [6] 4772/15 4798/25 4799/4 4799/10
4800/20 4802/3

8
802-W.1.2 [1] 4810/6
802-W.1.4 [1] 4810/18
802W.1.7 [2] 4813/11 4814/20
802X.1.2 [1] 4815/24
802X.1.4 [1] 4816/8
802X.16.9 [1] 4819/13
820 [1] 4668/23
84 percent [1] 4729/18
8711 [1] 4879/23
89 [1] 4758/12
8:00 [1] 4881/16

9
9.3 [1] 4747/3
90071 [1] 4672/14
92 percent [1] 4864/5
93 percent [1] 4863/14
94 [1] 4759/4
94005 [1] 4671/13
94102 [1] 4670/11
95 percent [1] 4863/25
9th [1] 4669/13

A
a.m [1] 4816/12
ability [4] 4719/6 4719/7 4834/1 4881/22
able [5] 4702/2 4720/22 4751/21 4752/6
4875/19
abnormal [5] 4740/22 4741/2 4741/7
4741/17 4741/25
aboard [2] 4747/21 4749/24
about [145] 4678/1 4678/10 4678/17
4683/15 4683/24 4686/11 4686/17
4688/25 4689/16 4689/20 4690/16
4690/17 4693/10 4693/11 4694/17
4694/22 4695/16 4696/21 4696/22
4700/7 4703/17 4705/1 4705/6 4705/7
4705/13 4706/8 4706/21 4706/21
4706/25 4708/1 4709/10 4709/12
4709/23 4711/5 4711/7 4711/9 4712/13
4713/4 4713/5 4720/17 4720/20
4724/14 4725/3 4726/15 4728/15
4729/17 4729/19 4732/24 4733/2
4733/3 4734/1 4734/2 4734/19 4735/13
4737/21 4739/9 4739/15 4742/22
4743/14 4743/17 4744/18 4744/21
4746/16 4746/22 4747/4 4750/22
4750/22 4750/25 4753/6 4757/12
4757/18 4759/7 4759/16 4761/10
4762/1 4762/9 4762/12 4762/15
4777/16 4779/7 4779/8 4783/10
4784/12 4785/7 4787/3 4787/11
4791/18 4792/7 4793/5 4801/12 4805/3
4807/4 4807/7 4807/8 4807/25 4817/5
4819/15 4819/17 4820/20 4822/3
4823/2 4823/19 4823/20 4828/18
4832/2 4836/1 4838/10 4838/15 4839/7
4840/21 4844/1 4844/5 4845/9 4846/5

4850/5 4851/18 4851/19 4852/17


4855/3 4855/5 4856/22 4856/23 4857/4
4857/19 4857/21 4858/1 4858/6
4858/16 4859/21 4861/22 4864/8
4864/10 4865/8 4866/9 4868/19
4868/20 4870/7 4870/13 4872/25
4873/10 4873/23 4874/19 4877/3
4877/13 4881/8
above [10] 4710/7 4710/9 4729/20
4729/22 4743/23 4743/25 4744/2
4754/16 4754/23 4881/23
above-entitled [1] 4881/23
Abramson [1] 4669/5
Absolutely [3] 4706/4 4728/13 4817/8
acceptable [1] 4821/10
accepted [1] 4853/9
access [1] 4718/5
accessible [2] 4869/5 4869/9
accident [6] 4710/20 4712/22 4714/16
4714/22 4714/25 4715/12
accomplish [1] 4704/21
accomplishing [1] 4737/10
accordance [3] 4691/25 4740/2 4742/6
according [6] 4731/13 4732/8 4746/18
4749/2 4749/23 4827/23
account [6] 4795/22 4795/24 4807/9
4807/13 4810/13 4817/3
accountable [1] 4727/23
accurate [2] 4687/22 4732/13
accurately [2] 4813/18 4816/17
achieved [1] 4679/9
achievement [1] 4680/13
achievements [1] 4681/6
across [3] 4699/22 4700/17 4706/11
act [1] 4806/14
Actinia [1] 4730/9
action [9] 4712/12 4723/4 4723/14
4723/25 4725/11 4725/17 4733/18
4733/24 4740/1
actions [1] 4722/17
activate [1] 4881/3
activated [4] 4735/5 4880/22 4880/23
4880/25
activities [4] 4713/13 4722/15 4737/4
4738/8
activity [1] 4738/3
actual [9] 4690/3 4782/9 4788/11
4788/13 4837/15 4837/15 4844/8
4846/22 4852/1
actually [39] 4707/10 4707/15 4741/10
4750/10 4794/10 4818/23 4819/7
4822/5 4822/10 4824/4 4829/22 4833/2
4833/12 4833/17 4842/18 4845/8
4846/12 4846/13 4853/4 4853/17
4855/1 4857/8 4858/17 4858/20
4860/18 4862/3 4865/22 4866/8 4868/1
4868/8 4871/18 4874/20 4876/8 4877/4
4877/8 4878/3 4878/10 4880/25 4881/3
Adamson [5] 4686/20 4687/19 4687/25
4738/20 4739/1
add [2] 4749/6 4790/6
added [7] 4746/16 4747/4 4747/13
4842/14 4846/22 4866/2 4870/18
adding [3] 4875/12 4875/13 4875/14
addition [4] 4692/17 4717/18 4770/16
4847/22
additional [3] 4699/7 4700/14 4751/14
additive [6] 4870/18 4875/8 4875/9
4875/12 4875/16 4880/18
additives [27] 4755/20 4758/20 4759/21
4759/24 4759/25 4760/2 4760/3 4760/4
4760/15 4760/16 4760/18 4760/21
4760/23 4768/15 4771/19 4787/23

4788/1 4806/8 4806/9 4810/21 4810/25


4811/2 4812/13 4844/12 4848/12
4851/1 4852/10
address [1] 4873/6
addressing [1] 4808/3
adds [1] 4866/4
adequate [1] 4715/3
adjust [1] 4867/21
admission [1] 4817/10
admit [1] 4830/1
admitted [6] 4675/25 4676/6 4676/13
4817/13 4818/21 4819/4
admitting [1] 4817/24
Adrian [1] 4686/3
ADs [2] 4727/24 4728/11
advantage [1] 4680/3
advised [1] 4739/1
advises [1] 4739/2
advisor [9] 4736/9 4736/11 4736/14
4736/16 4736/19 4736/21 4736/25
4737/6 4737/7
affixed [1] 4850/6
after [41] 4739/10 4742/17 4742/20
4746/22 4751/17 4755/3 4759/20
4761/3 4761/13 4761/17 4763/14
4763/19 4763/20 4763/23 4766/3
4767/2 4767/8 4767/14 4769/8 4769/12
4771/4 4793/18 4796/25 4802/12
4803/8 4803/9 4803/10 4804/9 4806/10
4807/17 4809/10 4812/8 4813/7 4818/8
4833/22 4840/21 4840/25 4854/16
4856/1 4866/2 4880/13
aftermath [1] 4856/4
afternoon [11] 4668/14 4675/2 4677/4
4738/23 4739/9 4739/12 4739/12
4743/9 4743/10 4806/24 4843/18
again [50] 4677/4 4680/1 4686/1 4689/5
4691/24 4692/12 4694/6 4697/16
4707/25 4719/22 4720/14 4721/24
4729/3 4731/24 4733/3 4734/20 4736/6
4736/13 4737/25 4739/16 4740/7
4741/11 4748/20 4749/5 4756/8 4763/2
4769/6 4769/7 4774/11 4775/23 4776/1
4780/17 4784/22 4785/4 4785/22
4785/25 4790/10 4791/1 4793/4
4800/21 4814/5 4816/4 4827/5 4828/21
4832/23 4835/3 4847/13 4850/20
4852/9 4879/7
against [2] 4707/3 4874/20
agency [1] 4692/19
agents [1] 4846/5
ago [10] 4705/5 4724/15 4759/16
4759/17 4768/25 4777/16 4804/7
4829/4 4840/10 4877/23
agree [30] 4681/18 4695/17 4706/10
4733/19 4735/4 4735/8 4735/12
4742/10 4778/25 4781/17 4781/20
4783/21 4787/23 4788/7 4788/12
4789/16 4790/12 4790/22 4791/4
4791/5 4791/10 4791/13 4798/3 4798/8
4798/17 4799/15 4801/20 4806/7
4806/15 4806/19
agreed [14] 4692/14 4718/18 4739/24
4740/8 4740/17 4740/25 4741/5
4741/12 4741/21 4742/1 4742/4 4742/9
4742/11 4813/4
agreement [2] 4691/13 4693/4
ahead [10] 4757/25 4758/1 4782/18
4799/20 4808/6 4808/12 4831/1
4845/16 4855/8 4864/17
aid [2] 4880/21 4880/21
aided [1] 4673/24
air [31] 4756/18 4786/5 4786/10

A
air... [28] 4786/14 4786/20 4786/21
4786/22 4787/10 4787/15 4787/20
4787/22 4789/12 4790/24 4797/5
4803/9 4806/20 4870/18 4870/22
4874/2 4874/8 4874/12 4874/18
4874/19 4874/21 4874/24 4875/1
4875/6 4875/11 4875/17 4875/22
4875/24
air-conditioned [3] 4756/18 4797/5
4803/9
air-controlled [1] 4806/20
al [2] 4668/8 4668/11
Alabama [8] 4669/4 4671/7 4671/8
4671/10 4698/5 4699/14 4823/25
4824/3
alarm [1] 4732/12
ALARP [3] 4714/9 4714/10 4715/5
alert [2] 4737/2 4737/7
ALEX [1] 4673/4
aligned [1] 4858/10
all [134] 4675/5 4675/7 4675/22
4676/19 4676/23 4678/13 4679/22
4681/15 4682/21 4683/6 4683/19
4684/6 4684/18 4687/12 4689/12
4692/1 4692/1 4692/3 4692/15 4692/16
4692/18 4692/21 4693/18 4694/7
4694/16 4697/16 4698/14 4700/22
4703/8 4703/21 4704/6 4704/17
4706/12 4706/24 4708/4 4708/12
4708/23 4710/3 4713/5 4713/12 4714/4
4719/12 4720/17 4722/15 4722/15
4725/19 4731/21 4734/7 4739/13
4743/22 4744/1 4750/18 4751/8 4751/9
4753/7 4753/9 4753/24 4757/3 4757/21
4759/19 4763/22 4767/19 4768/15
4769/6 4769/11 4774/2 4775/22
4775/24 4777/2 4779/9 4781/11 4782/7
4782/11 4784/4 4785/15 4788/4
4788/18 4794/22 4796/20 4797/8
4797/21 4801/25 4802/25 4803/16
4803/20 4804/13 4805/12 4805/14
4805/18 4807/18 4811/24 4813/25
4814/19 4817/5 4817/9 4817/16 4818/6
4818/7 4818/21 4818/24 4820/24
4823/25 4826/14 4826/17 4830/1
4831/8 4832/23 4833/2 4834/3 4835/21
4836/1 4836/13 4836/19 4843/6
4847/17 4848/20 4851/1 4857/2
4858/14 4859/7 4859/14 4859/23
4860/15 4860/22 4861/21 4864/21
4865/8 4868/19 4870/2 4872/17
4874/18 4877/12 4878/2 4881/17
ALLAN [1] 4671/15
allocution [3] 4739/15 4739/24 4741/22
allow [1] 4809/10
allowed [1] 4743/25
almost [2] 4729/3 4771/14
along [4] 4736/24 4817/18 4834/12
4855/9
already [21] 4683/24 4685/18 4689/21
4694/17 4694/22 4695/16 4715/22
4718/18 4734/21 4752/1 4755/7
4757/13 4762/12 4774/22 4780/20
4791/1 4804/24 4818/14 4818/15
4819/16 4875/2
also [44] 4676/8 4676/15 4679/8
4681/13 4684/17 4691/16 4692/25
4694/10 4694/12 4711/3 4711/14
4714/13 4716/6 4716/25 4720/4
4720/10 4731/14 4742/11 4747/4
4766/11 4770/23 4773/20 4796/2

4807/8 4811/8 4811/11 4811/17


4814/22 4816/25 4819/24 4822/3
4826/21 4827/21 4828/22 4830/12
4832/8 4832/11 4832/20 4841/15
4844/18 4849/19 4867/8 4867/8 4877/3
altogether [1] 4753/1
always [5] 4720/25 4721/1 4723/19
4778/10 4873/20
am [3] 4774/8 4803/21 4835/5
amazing [1] 4681/12
Ambrose [1] 4686/15
amended [1] 4749/5
amendment [1] 4692/8
AMERICA [9] 4668/10 4670/9 4670/13
4670/19 4671/3 4671/19 4671/22
4672/3 4749/21
Americas [1] 4730/7
amongst [3] 4679/22 4682/3 4684/18
amount [4] 4725/2 4744/6 4771/19
4800/14
Anadarko [1] 4731/4
analysis [6] 4710/18 4711/1 4727/4
4735/24 4794/24 4822/15
analyzer [4] 4794/25 4795/5 4795/8
4796/5
analyzer's [1] 4795/2
and/or [2] 4716/7 4722/19
Anderson [2] 4689/3 4749/25
Andrea [1] 4689/9
ANDREW [1] 4671/22
Angeles [1] 4672/14
Angelle [15] 4756/7 4756/8 4756/17
4796/25 4805/18 4838/6 4839/18
4839/20 4840/3 4840/4 4840/9 4840/11
4840/12 4840/22 4841/14
Angelle's [2] 4797/3 4802/9
annual [3] 4678/2 4678/7 4679/19
anomalies [1] 4740/11
another [13] 4709/9 4749/9 4756/8
4762/13 4762/15 4762/20 4774/2
4779/6 4791/2 4796/9 4831/5 4840/13
4851/24
answer [16] 4698/16 4699/11 4700/20
4760/14 4765/14 4778/14 4783/12
4793/12 4793/12 4795/18 4795/24
4799/22 4830/25 4842/18 4847/14
4870/2
answers [2] 4698/7 4794/20
ANTHONY [3] 4670/6 4676/14 4770/24
any [91] 4675/22 4676/5 4676/6
4676/12 4692/8 4692/18 4694/18
4698/22 4699/18 4700/13 4712/17
4715/18 4718/24 4725/9 4726/17
4726/21 4727/1 4727/3 4727/6 4728/2
4728/12 4732/9 4733/16 4734/11
4735/13 4735/21 4735/24 4736/6
4736/16 4752/17 4759/25 4760/4
4763/9 4763/17 4763/17 4763/18
4763/25 4764/4 4764/5 4764/15
4764/16 4765/7 4766/12 4766/25
4767/1 4767/12 4768/4 4770/20 4786/7
4790/11 4793/21 4803/20 4806/23
4807/16 4808/3 4808/11 4817/1 4817/5
4817/23 4818/20 4823/25 4829/24
4837/6 4837/10 4837/12 4837/14
4842/12 4848/24 4849/9 4852/1
4854/17 4855/22 4855/23 4856/4
4856/7 4857/6 4857/23 4860/15
4860/16 4860/17 4862/15 4865/5
4867/6 4867/23 4869/23 4872/17
4872/22 4873/3 4877/24 4878/22
4881/13
anybody [5] 4784/11 4805/3 4818/20

4839/3 4842/14
anyone [13] 4675/22 4763/25 4764/1
4764/15 4764/15 4804/21 4805/1
4812/5 4837/18 4839/20 4841/10
4841/11 4841/14
anything [28] 4676/22 4677/7 4699/7
4756/17 4763/18 4766/11 4779/8
4781/8 4783/24 4787/3 4804/15
4804/18 4831/6 4831/7 4831/11
4831/12 4838/15 4839/7 4842/14
4842/16 4850/20 4850/23 4855/25
4856/16 4865/2 4865/5 4872/21 4875/2
anywhere [3] 4766/12 4766/15 4844/11
API [4] 4871/15 4871/16 4872/5 4872/7
API-specified [1] 4872/7
APLC [1] 4671/18
apologize [3] 4728/18 4793/13 4798/25
appearance [1] 4862/11
Appearances [6] 4668/17 4669/1 4670/1
4671/1 4672/1 4673/1
appeared [1] 4881/2
appears [3] 4745/22 4785/14 4816/6
applicable [3] 4713/13 4740/2 4742/6
application [3] 4733/5 4733/13 4733/21
applied [2] 4699/7 4880/11
applies [4] 4668/6 4713/12 4715/18
4724/18
apply [5] 4694/10 4698/14 4698/20
4704/1 4711/12
applying [1] 4870/18
approach [8] 4693/17 4694/9 4701/17
4706/11 4708/21 4724/10 4735/20
4736/23
appropriate [8] 4723/4 4723/14 4723/25
4725/11 4725/16 4733/24 4740/1
4821/21
approval [1] 4714/19
approve [1] 4715/7
approved [3] 4722/22 4739/17 4739/17
approver [1] 4722/5
approvers [1] 4721/24
approximately [5] 4747/14 4826/15
4842/10 4877/14 4877/16
APRIL [101] 4668/5 4678/10 4685/3
4685/23 4728/8 4733/11 4733/12
4733/19 4733/20 4738/1 4738/19
4738/22 4742/23 4746/2 4747/21
4748/15 4754/13 4755/3 4759/20
4761/13 4761/17 4763/4 4763/4
4763/14 4763/23 4764/16 4766/21
4767/8 4767/14 4767/24 4771/3
4771/23 4772/3 4772/6 4772/9 4772/13
4772/15 4772/23 4773/5 4774/1 4775/7
4776/2 4778/4 4780/5 4780/22 4781/11
4781/23 4782/11 4782/23 4784/15
4785/9 4785/11 4785/11 4786/1 4786/7
4787/7 4789/6 4792/16 4793/21 4795/5
4795/19 4796/4 4796/6 4796/25 4797/3
4797/5 4797/12 4798/3 4798/8 4799/14
4800/5 4800/6 4800/20 4800/24 4801/6
4801/8 4801/18 4801/22 4802/2 4802/6
4802/6 4802/17 4803/25 4804/11
4808/10 4808/18 4808/24 4815/16
4818/12 4823/12 4850/15 4850/16
4854/22 4855/19 4855/20 4855/22
4856/1 4858/3 4858/16 4859/8 4878/20
April 17th [22] 4766/21 4771/23 4772/3
4772/6 4772/9 4772/13 4772/23 4773/5
4776/2 4778/4 4780/5 4781/11 4781/23
4782/23 4784/15 4785/9 4792/16
4800/6 4800/20 4801/18 4802/6
4850/15
April 17th at [1] 4850/16

A
April 17th is [1] 4774/1
April 17th lab [1] 4775/7
April 17th sheet [1] 4780/22
April 17th test [2] 4782/11 4786/1
April 19th and [1] 4763/4
April 2010 [2] 4796/4 4858/16
April 20th [26] 4678/10 4685/23 4733/11
4733/19 4733/20 4738/1 4746/2
4747/21 4748/15 4755/3 4759/20
4761/13 4761/17 4763/4 4763/14
4767/8 4767/14 4767/24 4785/11
4789/6 4795/5 4795/19 4796/6 4823/12
4855/22 4856/1
April 20th could [1] 4733/12
April 20th of [1] 4763/23
April 21st [3] 4738/19 4738/22 4785/11
April 22nd [1] 4742/23
April 30th [15] 4796/25 4797/3 4797/5
4797/12 4798/3 4798/8 4799/14 4800/5
4800/24 4801/6 4801/8 4801/22
4802/17 4803/25 4804/11
April 30th and [1] 4802/6
April 30th sample [1] 4802/2
April 7th [1] 4772/15
are [167] 4675/25 4676/6 4676/13
4677/17 4681/22 4682/1 4683/23
4685/17 4689/5 4690/6 4690/7 4690/9
4690/13 4690/14 4690/22 4691/19
4692/8 4692/12 4693/3 4693/5 4694/7
4694/10 4695/21 4695/22 4699/18
4700/4 4700/5 4700/23 4701/2 4701/3
4701/12 4702/24 4702/25 4703/2
4703/13 4707/4 4708/11 4709/22
4710/23 4713/18 4715/3 4717/12
4717/21 4718/18 4718/23 4719/2
4719/12 4719/12 4719/15 4719/19
4719/22 4720/22 4723/7 4723/8 4724/6
4727/23 4728/1 4728/8 4728/12 4731/5
4731/6 4734/21 4734/21 4734/22
4736/3 4736/9 4737/4 4737/10 4737/13
4738/6 4742/25 4744/10 4751/10
4751/11 4757/5 4761/10 4761/13
4762/1 4768/18 4768/23 4770/24
4770/25 4775/19 4776/10 4777/18
4779/5 4783/10 4785/4 4788/2 4788/4
4788/20 4790/16 4790/25 4791/14
4791/25 4792/4 4792/7 4794/12 4798/1
4802/16 4806/4 4807/25 4808/2
4808/16 4810/21 4811/2 4811/24
4814/2 4816/17 4816/22 4816/23
4816/25 4817/11 4818/4 4818/4
4818/17 4818/21 4818/23 4819/2
4819/3 4819/4 4819/15 4828/21
4831/24 4834/8 4834/16 4834/24
4847/20 4847/22 4847/23 4847/23
4850/1 4850/5 4851/2 4852/18 4857/8
4857/11 4858/6 4858/12 4858/20
4858/21 4859/4 4860/13 4862/1
4865/12 4865/15 4865/23 4865/25
4866/7 4866/25 4867/5 4867/12 4869/3
4869/5 4869/9 4869/11 4869/13 4871/2
4872/6 4872/10 4872/17 4872/21
4873/8 4873/12 4878/3 4878/7 4878/22
area [7] 4701/19 4728/2 4805/11
4805/24 4808/21 4809/2 4822/21
areas [1] 4719/10
aren't [1] 4847/20
argumentative [3] 4738/9 4767/18
4767/19
around [17] 4676/16 4689/25 4693/18
4694/7 4697/17 4705/14 4710/17

4726/5 4735/20 4738/22 4756/23


4757/17 4781/4 4789/17 4854/5
4859/12 4860/11
arrangement [1] 4693/12
Arrell [1] 4672/19
arrived [3] 4834/9 4834/17 4834/25
article [3] 4690/24 4691/14 4692/12
artificially [2] 4878/24 4880/25
as [168] 4677/1 4678/1 4678/7 4678/25
4679/19 4681/25 4682/23 4683/21
4684/12 4684/12 4684/13 4684/13
4685/3 4685/4 4685/20 4685/23
4686/16 4687/19 4688/20 4689/13
4691/8 4692/22 4695/24 4696/4 4696/8
4699/4 4700/14 4700/23 4701/1 4702/6
4708/14 4708/18 4709/16 4710/19
4712/7 4714/11 4714/11 4715/5 4715/5
4717/18 4719/5 4721/2 4721/9 4722/5
4722/13 4725/13 4725/14 4729/22
4731/10 4732/16 4733/14 4733/14
4735/21 4736/15 4736/16 4737/6
4737/11 4738/13 4739/24 4742/4
4744/3 4744/4 4744/8 4744/22 4746/19
4747/13 4748/6 4748/6 4748/20 4749/5
4749/6 4750/1 4751/12 4751/22
4753/14 4755/19 4764/11 4765/24
4769/4 4769/11 4772/24 4773/18
4776/2 4781/10 4782/5 4782/6 4782/8
4784/18 4786/8 4789/10 4790/8
4790/24 4791/10 4791/18 4796/15
4800/10 4800/25 4801/4 4801/17
4803/23 4806/7 4809/2 4809/13
4809/23 4810/9 4810/9 4810/13 4811/9
4811/24 4811/24 4812/4 4812/5 4814/2
4814/2 4814/25 4815/14 4817/2 4817/9
4817/9 4817/13 4817/16 4817/16
4819/19 4820/7 4821/8 4821/20
4822/19 4822/19 4824/14 4824/19
4824/25 4824/25 4825/1 4825/1
4826/11 4826/12 4827/18 4831/3
4831/3 4837/25 4838/2 4838/4 4839/4
4841/23 4842/2 4842/12 4843/10
4845/6 4847/22 4850/1 4851/12
4851/14 4853/23 4854/7 4856/19
4859/18 4861/7 4861/8 4861/14 4863/6
4863/6 4865/14 4867/15 4867/15
4877/20 4878/12 4880/6 4881/4
Asbill [1] 4672/8
aside [2] 4756/2 4846/6
ask [32] 4689/19 4690/17 4720/17
4733/2 4734/2 4739/20 4741/11
4750/23 4751/4 4751/4 4760/16
4760/22 4763/16 4764/15 4765/11
4765/17 4768/2 4768/16 4769/25
4770/12 4786/23 4792/4 4805/1
4808/12 4830/18 4837/12 4844/6
4848/21 4851/22 4851/24 4853/19
4864/22
asked [73] 4689/21 4696/22 4700/13
4705/6 4706/1 4706/24 4709/10
4709/11 4713/4 4723/6 4728/14
4728/24 4733/2 4734/1 4737/21
4739/14 4743/13 4744/17 4744/21
4756/19 4759/20 4759/23 4760/11
4760/15 4760/21 4762/1 4762/3
4762/17 4762/23 4763/25 4764/1
4764/12 4765/7 4765/20 4766/4 4766/6
4766/7 4766/9 4766/13 4768/7 4769/15
4770/2 4770/4 4770/8 4770/16 4771/23
4772/8 4776/20 4782/7 4787/19
4791/25 4793/12 4795/20 4796/5
4796/11 4796/15 4796/22 4796/25
4803/2 4805/18 4824/15 4838/6

4839/18 4840/16 4841/15 4842/20


4842/21 4843/3 4843/4 4844/6 4846/4
4848/22 4876/5
asking [13] 4681/22 4756/1 4758/9
4774/23 4777/16 4781/9 4781/11
4782/11 4786/17 4792/13 4824/5
4838/9 4859/7
aspects [1] 4727/22
assessed [2] 4714/7 4859/4
assessment [13] 4699/6 4699/10
4709/11 4710/21 4712/22 4713/5
4713/9 4713/12 4713/15 4713/19
4714/5 4714/16 4714/23
assessments [3] 4702/7 4727/4 4735/13
assessors [1] 4859/4
asset [2] 4668/8 4687/16
assigned [2] 4858/21 4866/7
assistant [1] 4748/24
Associate [1] 4853/13
associated [12] 4714/7 4844/25 4845/7
4847/6 4850/17 4861/4 4862/17 4863/3
4869/23 4870/3 4876/6 4876/11
assume [7] 4723/20 4803/21 4806/13
4819/3 4833/18 4873/5 4874/8
assumed [2] 4818/13 4831/4
assuming [4] 4819/2 4832/8 4847/10
4852/9
assurance [1] 4713/18
assure [2] 4781/7 4782/4
atmospheric [1] 4870/22
ATN [1] 4730/5
attached [2] 4823/6 4823/16
attachment [1] 4823/3
attention [5] 4804/16 4860/23 4861/1
4861/4 4877/5
Attorney [2] 4671/7 4671/11
attorneys [3] 4837/10 4837/14 4841/11
audit [7] 4860/20 4862/4 4862/9
4862/10 4862/22 4862/23 4864/4
audited [7] 4859/19 4859/20 4859/22
4859/23 4859/24 4860/2 4861/8
audited-out [1] 4861/8
auditing [1] 4860/12
auditors [3] 4860/23 4861/24 4863/3
audits [9] 4860/5 4860/6 4860/8 4860/9
4860/13 4860/14 4860/23 4861/10
4861/21
August [14] 4763/15 4763/16 4763/24
4775/15 4786/7 4787/8 4793/21 4796/4
4825/7 4852/24 4853/2 4853/4 4853/5
4853/22
August 2012 [1] 4825/7
August 24th of [2] 4763/15 4853/5
August 27th [2] 4852/24 4853/4
author [1] 4845/22
authority [9] 4705/7 4705/8 4705/10
4705/17 4706/22 4720/21 4720/23
4721/1 4721/11
authorized [2] 4721/16 4722/16
automatically [3] 4848/18 4849/16
4875/18
availability [2] 4719/8 4719/16
available [6] 4751/13 4751/17 4752/15
4795/12 4846/11 4871/4
Avenue [5] 4668/23 4670/10 4671/9
4672/3 4672/14
average [1] 4859/9
avoid [4] 4716/14 4733/9 4734/22
4807/11
avoided [3] 4733/4 4733/13 4733/21
aware [32] 4683/19 4692/8 4692/9
4692/12 4736/3 4739/2 4756/4 4759/25
4760/4 4763/12 4789/5 4789/15

A
aware... [20] 4789/18 4789/23 4791/14
4791/25 4792/5 4792/13 4792/25
4793/3 4793/9 4793/10 4793/22 4795/6
4795/7 4796/8 4834/8 4834/16 4834/24
4841/17 4878/22 4878/25
awareness [5] 4723/1 4723/13 4723/14
4723/24 4749/15
away [4] 4769/9 4832/13 4840/19
4840/22

B
back [33] 4683/25 4688/13 4689/12
4698/21 4704/13 4705/4 4743/6
4749/18 4751/10 4751/22 4764/22
4768/11 4768/12 4777/5 4777/7
4780/15 4784/21 4796/9 4797/21
4799/17 4800/20 4803/4 4803/5
4805/24 4814/19 4828/20 4829/10
4829/24 4836/3 4836/17 4838/16
4849/19 4859/7
background [1] 4844/2
Badalamenti [2] 4770/24 4775/3
ballooning [2] 4729/9 4729/10
bar [2] 4797/13 4848/17
bar-coded [1] 4848/17
BARBIER [3] 4668/15 4864/10 4865/19
Barnhill [7] 4751/10 4751/12 4751/17
4751/20 4752/12 4752/14 4881/12
Barnhill's [1] 4676/16
barrels [4] 4729/20 4729/22 4730/17
4732/18
barrier [1] 4735/5
base [7] 4788/9 4833/14 4870/17
4871/2 4877/4 4877/8 4878/10
based [21] 4710/6 4740/25 4741/15
4741/23 4754/19 4767/11 4774/9
4784/8 4790/14 4794/11 4794/13
4799/16 4820/4 4833/14 4833/18
4849/8 4862/10 4864/24 4871/4
4877/17 4880/14
basically [4] 4756/16 4870/17 4872/12
4880/12
basis [4] 4677/12 4679/24 4748/10
4764/25
bat [2] 4697/19 4851/23
Bates [2] 4845/14 4879/23
Baton [2] 4669/23 4671/13
batteries [3] 4695/16 4695/17 4695/21
battery [1] 4794/4
Baxter [2] 4697/20 4699/16
Baxter's [2] 4697/23 4698/16
BC [1] 4815/1
be [167] 4675/6 4680/2 4680/25
4681/18 4681/20 4683/9 4684/15
4684/24 4685/17 4689/14 4689/24
4690/3 4690/11 4691/3 4691/8 4691/23
4693/22 4694/13 4699/7 4699/9
4699/19 4700/2 4700/4 4701/23 4702/2
4703/4 4705/8 4708/10 4711/14
4711/16 4711/17 4711/17 4711/18
4711/18 4711/20 4711/21 4711/23
4712/2 4715/4 4717/8 4719/17 4720/15
4721/6 4722/10 4724/2 4725/9 4730/18
4731/21 4733/4 4733/11 4735/25
4736/7 4737/4 4738/6 4739/11 4739/17
4741/11 4743/11 4744/2 4745/9
4745/22 4746/15 4747/12 4751/9
4751/21 4751/21 4751/25 4752/6
4752/8 4752/13 4752/18 4752/20
4753/2 4753/10 4753/22 4756/2
4756/17 4758/11 4760/20 4772/8

4773/12 4774/16 4774/24 4775/7


4778/10 4779/11 4779/24 4780/18
4782/1 4783/18 4785/14 4785/19
4786/19 4786/25 4787/10 4787/19
4788/10 4789/18 4790/12 4792/6
4792/13 4792/16 4794/4 4794/15
4795/15 4799/1 4800/21 4803/15
4804/12 4808/3 4808/8 4810/25 4813/9
4814/7 4815/1 4817/12 4818/2 4819/1
4819/3 4819/6 4819/7 4821/8 4821/13
4821/15 4821/16 4821/18 4833/6
4837/8 4837/23 4837/25 4838/4
4838/23 4841/15 4842/7 4842/13
4843/19 4844/11 4844/14 4848/16
4854/25 4859/5 4860/16 4864/12
4864/23 4865/10 4866/5 4866/11
4866/12 4866/13 4866/17 4866/17
4866/24 4867/15 4867/15 4867/17
4871/2 4871/3 4871/8 4874/4 4874/5
4874/13 4875/12 4875/18 4875/19
4878/15 4879/17 4881/12
Bea [1] 4713/1
Beach [1] 4669/10
because [37] 4690/9 4695/20 4701/9
4715/21 4723/11 4724/1 4751/4 4752/6
4768/16 4770/1 4773/1 4782/3 4784/2
4784/2 4784/7 4789/14 4792/20
4803/14 4807/16 4807/23 4820/14
4830/20 4831/6 4833/21 4835/14
4837/9 4841/23 4842/10 4849/15
4851/10 4852/5 4855/8 4866/22 4867/9
4874/12 4880/11 4881/11
Beck [2] 4673/2 4673/3
become [3] 4792/25 4793/3 4793/22
becomes [1] 4868/25
becoming [1] 4754/10
been [93] 4676/25 4678/1 4681/6
4681/9 4683/25 4685/18 4689/21
4696/17 4705/1 4706/18 4714/6 4714/7
4714/9 4714/23 4715/3 4715/22 4721/7
4723/6 4733/13 4733/21 4740/15
4748/10 4748/20 4750/6 4750/7
4750/21 4751/24 4753/13 4754/10
4755/12 4755/21 4755/25 4756/1
4756/24 4757/8 4758/2 4761/5 4761/17
4761/18 4762/3 4762/12 4762/24
4763/3 4765/1 4765/3 4772/22 4781/25
4784/16 4785/5 4786/22 4787/1
4787/18 4794/3 4794/4 4795/14
4795/19 4796/10 4796/11 4796/18
4802/14 4802/20 4804/10 4804/25
4807/16 4809/11 4810/24 4812/9
4817/13 4817/15 4818/11 4820/15
4825/8 4825/11 4829/17 4830/23
4831/7 4842/9 4843/3 4845/23 4846/6
4852/25 4854/19 4854/22 4856/10
4857/17 4857/17 4861/14 4864/18
4864/20 4869/19 4870/7 4870/13
4877/3
before [48] 4668/15 4676/22 4678/10
4703/22 4712/12 4712/17 4728/24
4734/6 4739/3 4754/5 4755/22 4758/2
4761/24 4765/6 4765/10 4765/20
4772/17 4776/11 4777/5 4777/8
4777/17 4777/19 4781/1 4784/17
4790/17 4791/11 4792/18 4793/3
4793/17 4793/23 4794/5 4794/12
4794/20 4801/13 4818/8 4818/10
4823/11 4830/24 4833/17 4833/17
4842/22 4842/25 4844/3 4844/4 4853/3
4856/22 4871/19 4878/23
begin [2] 4740/17 4866/3
beginning [1] 4876/9

behave [1] 4806/14


being [28] 4682/3 4684/5 4698/4
4726/18 4726/22 4726/25 4732/12
4736/15 4760/12 4760/20 4761/19
4768/1 4780/15 4780/25 4781/22
4782/8 4782/22 4801/20 4803/23
4826/12 4829/15 4836/18 4841/21
4843/4 4850/2 4855/25 4875/19
4880/11
belabor [1] 4841/4
believe [27] 4677/13 4677/19 4680/25
4682/1 4682/2 4682/19 4683/9 4685/6
4685/10 4707/12 4712/7 4714/3 4725/5
4776/8 4796/14 4808/8 4817/1 4831/6
4843/15 4844/24 4850/14 4851/8
4876/5 4876/15 4879/15 4881/13
4881/15
believed [1] 4683/7
believes [1] 4679/3
below [7] 4701/2 4708/24 4729/20
4759/2 4828/19 4880/16 4880/16
Ben [1] 4671/5
Benge [2] 4872/3 4876/4
Bertone [1] 4688/23
best [14] 4677/7 4677/13 4682/8 4685/1
4788/3 4788/5 4788/7 4788/12 4788/19
4789/20 4825/8 4872/9 4872/15
4881/22
best-performing [2] 4682/8 4685/1
better [5] 4684/24 4702/17 4835/5
4852/13 4853/8
between [22] 4690/18 4691/13 4693/4
4693/7 4693/24 4693/24 4696/24
4702/25 4720/21 4727/6 4735/14
4737/18 4743/24 4786/7 4787/7
4801/22 4802/6 4802/17 4807/13
4858/18 4870/14 4870/16
BHP [1] 4730/8
big [2] 4831/24 4852/16
bigger [1] 4826/4
Bill [1] 4686/15
bit [17] 4694/17 4737/9 4781/3 4820/23
4826/4 4844/1 4852/13 4855/3 4856/23
4858/1 4859/8 4860/4 4864/10 4868/19
4873/7 4873/10 4875/13
blank [1] 4785/2
Bldg [1] 4670/10
blend [28] 4786/11 4786/12 4786/19
4786/20 4786/22 4786/25 4787/17
4798/15 4798/21 4800/9 4800/25
4801/1 4801/17 4825/7 4825/11 4830/2
4830/6 4830/19 4834/10 4835/9
4835/19 4846/23 4847/11 4852/2
4874/24 4875/2 4875/17 4875/23
blended [2] 4787/19 4875/2
blends [3] 4846/18 4849/23 4850/1
blew [1] 4739/10
blow [5] 4832/21 4833/2 4850/12
4861/18 4871/23
blowout [15] 4715/23 4716/3 4716/15
4716/22 4717/4 4718/7 4718/15
4718/22 4719/11 4735/10 4742/13
4742/17 4742/17 4744/8 4744/11
blowouts [3] 4691/22 4692/2 4719/3
blurry [1] 4810/11
board [7] 4686/23 4722/16 4834/10
4835/1 4835/9 4835/19 4835/23
Bob [2] 4728/1 4728/6
Bockius [1] 4673/14
BOP [25] 4694/24 4695/15 4695/16
4695/16 4695/17 4695/20 4695/24
4696/1 4696/3 4696/8 4696/11 4718/16
4718/18 4719/9 4720/4 4727/7 4727/7

4876/16 4879/5 4879/7


bringing [1] 4862/23
BOP... [8] 4735/4 4735/8 4743/24
broad [1] 4690/2
4743/24 4744/1 4744/1 4744/2 4746/14 broadly [2] 4695/24 4705/3
BOPs [3] 4716/23 4717/1 4747/11
BROCK [2] 4672/3 4752/12
borrowed [1] 4832/1
brought [4] 4832/2 4835/10 4835/19
both [16] 4681/18 4694/2 4705/16
4876/4
4709/22 4714/12 4715/4 4737/22
Broussard [18] 4754/3 4754/11 4754/14
4740/21 4744/17 4755/17 4760/10
4755/16 4757/21 4758/6 4763/13
4764/9 4770/24 4810/9 4811/14
4763/24 4764/22 4765/7 4773/19
4840/12
4785/5 4786/8 4808/24 4820/4 4854/12
bottle [1] 4805/1
4854/18 4859/15
bottles [1] 4784/3
BRUCE [1] 4673/8
bottom [26] 4679/15 4687/13 4703/4
bubbles [1] 4870/20
4722/2 4767/15 4767/25 4769/13
bucket [39] 4797/15 4797/17 4798/14
4778/12 4778/15 4778/18 4810/9
4801/15 4801/23 4804/2 4804/8 4824/6
4811/3 4811/12 4811/25 4819/25
4826/14 4826/23 4827/10 4827/21
4820/17 4826/19 4832/11 4847/20
4828/4 4828/17 4828/17 4830/8
4857/12 4871/21 4871/23 4874/2
4830/20 4830/22 4831/12 4831/19
4874/10 4874/16 4877/13
4831/20 4831/22 4832/1 4832/2 4832/5
Boudreaux [1] 4861/25
4832/18 4832/20 4832/23 4833/3
bought [1] 4844/9
4833/21 4836/4 4836/6 4842/3 4842/5
Boulevard [1] 4670/3
4842/8 4842/15 4850/4 4850/7 4850/9
Bounds [1] 4669/2
buckets [20] 4804/8 4824/13 4824/23
BOWMAN [1] 4673/8
4825/7 4825/11 4827/19 4827/23
box [7] 4668/20 4670/10 4670/16
4828/19 4828/22 4828/25 4829/5
4670/22 4671/13 4672/17 4703/19
4829/13 4831/24 4836/11 4836/12
BP [65] 4668/10 4671/18 4671/19
4836/13 4839/2 4840/13 4841/12
4671/20 4671/21 4671/22 4671/23
4841/15
4672/2 4672/3 4672/4 4675/12 4676/1 Buddy [1] 4687/9
4677/5 4679/25 4680/8 4680/15
building [1] 4752/21
4680/17 4680/23 4681/19 4683/20
buildup [1] 4740/9
4683/21 4690/19 4691/13 4692/4
bulk [2] 4718/3 4851/10
4693/4 4696/10 4696/24 4697/6
bullet [1] 4704/22
4697/12 4697/14 4697/14 4698/10
bulletin [5] 4788/21 4788/22 4789/6
4698/21 4698/23 4699/5 4730/6 4730/9 4789/16 4790/10
4731/1 4731/7 4731/24 4732/9 4732/17 Burling [1] 4672/2
4732/17 4735/1 4735/15 4737/18
burned [1] 4742/20
4739/25 4740/8 4740/21 4741/5
business [13] 4677/9 4677/10 4677/12
4770/12 4786/4 4786/9 4786/13
4679/6 4688/1 4694/7 4694/9 4698/23
4786/19 4786/24 4787/9 4787/19
4699/5 4699/21 4706/6 4723/16
4797/24 4807/10 4823/13 4825/18
4727/22
4860/17 4867/23 4869/13
C
BP's [8] 4690/16 4693/7 4696/23
4697/14 4740/16 4823/6 4823/11
cabin [2] 4717/23 4718/3
4876/4
CALDWELL [1] 4671/12
BP/Transocean [2] 4797/24 4825/18
calendar [1] 4816/18
BRAD [1] 4672/13
California [2] 4670/11 4672/14
brain [1] 4781/4
call [15] 4717/25 4753/11 4755/4
Branch [3] 4670/9 4670/19 4671/3
4757/12 4765/6 4767/24 4770/23
Braniff [1] 4687/7
4774/22 4777/23 4804/22 4856/1
Brazil [2] 4688/10 4725/21
4867/6 4867/7 4867/13 4869/7
break [2] 4752/23 4860/3
called [19] 4731/14 4743/17 4752/3
breaking [3] 4874/3 4874/8 4874/12
4755/7 4757/7 4757/18 4759/19
Breit [16] 4669/8 4669/9 4752/4 4753/11 4759/23 4761/5 4761/24 4765/11
4753/22 4783/12 4793/11 4808/3
4766/3 4771/3 4771/4 4805/7 4823/8
4825/16 4828/17 4832/1 4842/20
4868/3 4869/21 4869/22
4845/7 4848/4 4848/22 4850/14
calling [1] 4765/25
Breit's [1] 4824/5
came [13] 4734/2 4749/6 4773/10
Brennan [1] 4672/8
4797/2 4799/10 4838/13 4839/2 4844/4
BRIAN [5] 4672/13 4706/25 4711/7
4846/5 4846/12 4846/13 4846/22
4741/21 4741/22
4847/8
bridge [6] 4693/15 4693/24 4694/3
Cameron [5] 4672/22 4673/2 4696/2
4699/19 4721/5 4747/21
4743/2 4743/3
bridged [1] 4700/4
Camp [1] 4671/16
bridging [4] 4693/10 4693/11 4693/22
can [108] 4675/15 4681/22 4682/20
4694/1
4692/25 4702/17 4712/19 4713/12
brief [4] 4701/23 4743/11 4824/2 4858/4 4715/4 4722/7 4733/4 4737/3 4740/7
briefly [8] 4702/9 4703/16 4729/17
4744/2 4744/4 4745/7 4745/15 4747/23
4731/15 4734/8 4796/9 4853/20 4856/9 4747/23 4751/17 4751/17 4752/25
4753/2 4756/12 4759/1 4759/5 4759/8
bring [14] 4704/7 4824/7 4825/14
4762/14 4762/14 4768/12 4769/21
4830/15 4831/15 4845/11 4850/11
4780/14 4780/18 4780/19 4781/7
4861/7 4865/17 4868/6 4871/12

4782/3 4782/19 4783/18 4787/23


4789/24 4791/17 4792/6 4797/22
4804/7 4804/11 4806/11 4814/5
4814/23 4817/4 4817/18 4818/25
4825/12 4825/14 4825/22 4825/25
4826/17 4827/1 4828/5 4829/10
4832/16 4832/21 4833/2 4833/5 4833/6
4833/7 4833/23 4834/3 4836/21 4837/6
4838/16 4844/9 4845/11 4845/18
4847/3 4847/6 4847/24 4848/7 4849/8
4855/3 4855/10 4856/9 4858/4 4859/9
4861/7 4861/24 4862/6 4864/21
4865/19 4867/21 4868/6 4868/17
4870/14 4871/2 4871/6 4871/8 4871/12
4871/18 4871/23 4875/3 4876/18
4877/20 4877/22 4878/2 4878/13
4879/5 4879/22 4879/25 4880/14
4881/14
can't [23] 4698/22 4709/2 4730/9
4765/13 4770/4 4785/15 4789/7 4789/7
4790/21 4793/18 4806/10 4823/14
4825/4 4831/10 4833/10 4834/11
4834/12 4837/12 4842/9 4856/17
4871/3 4873/22 4881/15
cancel [2] 4792/4 4794/19
canceled [4] 4775/20 4793/2 4793/23
4794/21
Canducci [1] 4687/9
Canyon [5] 4799/1 4803/2 4826/12
4831/14 4841/21
Canyon 727 [1] 4841/21
capabilities [2] 4677/16 4719/7
capable [1] 4677/17
captain [2] 4689/9 4721/10
Captain Kuchta [1] 4689/9
care [3] 4740/2 4742/6 4840/22
CARL [24] 4668/15 4760/7 4788/24
4791/8 4799/7 4800/7 4824/7 4825/14
4825/22 4826/3 4826/17 4827/1
4827/13 4828/5 4829/10 4830/15
4831/15 4832/16 4832/21 4833/2
4833/25 4835/4 4836/3 4838/16
Carondelet [2] 4669/13 4672/23
CARRIE [1] 4671/22
carry [3] 4699/5 4708/19 4712/19
case [34] 4689/25 4691/3 4692/4
4702/1 4702/4 4703/8 4708/10 4709/12
4710/10 4710/12 4710/15 4710/19
4713/20 4713/21 4713/23 4714/12
4723/19 4751/13 4753/21 4770/1
4773/20 4773/25 4794/8 4795/25
4812/13 4812/19 4821/11 4821/13
4821/15 4836/19 4856/10 4864/18
4869/19 4870/7
cases [3] 4794/7 4866/20 4866/20
casing [5] 4683/2 4726/21 4726/25
4807/6 4822/6
cataloged [2] 4796/24 4798/3
catch [2] 4744/1 4744/14
category [1] 4733/17
cause [1] 4742/13
cautioned [1] 4874/20
cautious [1] 4732/12
cement [124] 4683/3 4726/18 4754/12
4755/8 4755/21 4755/22 4757/9
4757/14 4768/3 4769/5 4769/9 4772/1
4772/3 4772/15 4772/17 4772/18
4772/23 4772/24 4772/25 4773/25
4775/10 4779/6 4779/13 4785/10
4786/4 4786/10 4786/19 4786/25
4787/3 4787/5 4787/5 4787/9 4787/11
4787/24 4787/24 4789/11 4790/25
4794/24 4795/3 4798/15 4798/20

C
cement... [83] 4799/4 4800/4 4800/10
4800/13 4800/17 4800/25 4801/16
4801/17 4801/23 4802/5 4802/10
4802/14 4802/20 4802/22 4803/6
4803/11 4803/13 4803/17 4803/18
4803/20 4803/23 4804/2 4804/3
4804/10 4804/13 4805/2 4806/1 4806/9
4807/6 4807/13 4808/25 4809/18
4818/8 4823/8 4823/11 4829/5 4829/13
4830/2 4830/6 4832/14 4834/10 4835/9
4835/19 4835/23 4836/19 4836/22
4838/3 4842/4 4842/5 4842/5 4844/8
4846/22 4849/23 4852/2 4852/2
4852/21 4854/7 4854/8 4854/13
4854/16 4855/1 4855/5 4855/12
4855/19 4855/23 4857/4 4857/21
4858/2 4858/10 4858/17 4859/18
4859/19 4859/21 4864/13 4866/5
4869/4 4869/18 4870/20 4875/2
4876/22 4878/17 4880/3 4880/21
cementing [7] 4790/4 4790/15 4790/18
4790/19 4823/7 4857/15 4857/20
cements [1] 4806/7
center [1] 4721/10
centralizers [1] 4727/1
CEO [8] 4678/1 4681/25 4685/20
4707/16 4707/21 4708/14 4728/6
4728/8
CERNICH [1] 4670/14
certain [7] 4742/14 4786/16 4787/23
4788/1 4836/1 4851/19 4871/2
certainly [2] 4696/2 4745/7
CERTIFICATE [1] 4881/20
certify [1] 4881/22
chain [6] 4720/18 4720/22 4722/9
4722/10 4754/16 4807/25
CHAKERES [1] 4670/16
challenging [2] 4680/4 4737/1
chance [1] 4752/25
CHANG [1] 4670/15
change [5] 4690/15 4701/13 4701/13
4706/18 4720/18
changed [2] 4813/5 4876/8
changes [3] 4722/10 4744/21 4790/9
changing [1] 4701/12
characterize [2] 4733/23 4750/1
charge [1] 4754/22
charged [2] 4695/18 4695/18
chart [22] 4685/12 4685/14 4685/20
4687/19 4687/23 4689/13 4701/25
4709/9 4709/13 4716/1 4726/3 4726/6
4730/19 4731/13 4731/24 4732/15
4747/20 4750/15 4879/22 4879/25
4880/1 4881/2
check [2] 4734/11 4739/5
checked [1] 4849/17
checking [1] 4770/17
checklist [1] 4736/6
chemical [13] 4773/20 4780/25 4781/10
4781/10 4782/8 4782/10 4783/4
4784/16 4801/17 4802/5 4802/16
4803/14 4806/8
chemicals [3] 4755/20 4800/24 4804/23
chemist [8] 4754/11 4854/2 4854/5
4854/6 4854/6 4865/10 4866/5 4869/18
chemists [1] 4858/10
Chevron [3] 4852/19 4853/4 4860/17
Chicago [1] 4671/24
chief [6] 4689/9 4707/10 4708/1 4708/3
4750/19 4753/21
Chinese [1] 4731/4

choice [1] 4786/25


choke [1] 4733/16
choose [1] 4684/24
chosen [1] 4817/1
circulate [1] 4819/1
circulated [1] 4675/19
circulation [1] 4724/8
circumstances [1] 4680/25
city [2] 4851/10 4852/16
Civil [2] 4670/9 4670/19
clarify [5] 4708/18 4741/20 4782/17
4798/5 4805/6
clarity [2] 4791/18 4830/24
class [1] 4863/4
cleaned [1] 4829/25
clear [12] 4693/22 4712/14 4739/11
4809/23 4814/15 4821/11 4821/13
4836/2 4836/6 4841/19 4848/11
4880/17
clearly [3] 4830/22 4832/5 4832/23
CLERK [1] 4753/15
client [3] 4730/21 4731/20 4732/5
clients [3] 4731/8 4731/10 4732/17
climate [1] 4806/21
climate-controlled [1] 4806/21
CLINGMAN [1] 4672/9
clips [1] 4751/15
closed [3] 4744/12 4744/13 4746/14
closer [1] 4754/7
closet [17] 4784/4 4796/22 4797/4
4797/10 4797/12 4797/17 4797/20
4800/10 4800/25 4801/2 4801/14
4802/2 4802/21 4806/19 4806/19
4838/21 4841/8
cloudy [1] 4823/18
CMS [2] 4701/1 4701/6
CNOOC [1] 4731/4
code [1] 4797/13
coded [1] 4848/17
collaboration [2] 4684/18 4735/14
collaborative [1] 4682/25
collect [1] 4757/5
college [1] 4853/10
column [3] 4719/6 4782/25 4850/24
combined [1] 4721/21
combustible [1] 4718/8
come [12] 4704/13 4775/17 4787/14
4797/17 4805/10 4805/12 4806/2
4848/9 4848/16 4848/24 4851/5
4864/22
comes [7] 4677/14 4701/25 4714/12
4727/7 4773/20 4846/16 4848/17
comfortable [1] 4862/23
coming [4] 4796/15 4797/18 4801/4
4849/2
command [4] 4720/18 4720/23 4722/10
4722/11
commenced [1] 4740/10
comment [3] 4819/24 4862/17 4863/3
comments [2] 4814/2 4819/15
Commercial [1] 4671/3
commissions [1] 4803/11
Committee [1] 4753/22
communicate [3] 4821/17 4867/3
4873/16
communicated [2] 4703/14 4817/3
communication [10] 4735/14 4794/11
4794/14 4807/12 4840/25 4841/1
4841/18 4856/13 4856/14 4856/17
companies [2] 4717/18 4860/15
company [14] 4671/20 4671/23 4672/4
4679/17 4688/13 4692/3 4700/24
4702/20 4702/22 4708/5 4728/3 4731/4

4860/15 4860/16
company's [2] 4692/22 4693/1
companywide [1] 4702/24
compare [5] 4757/19 4757/21 4758/5
4759/12 4800/5
compared [1] 4758/24
compares [1] 4746/7
comparison [2] 4700/3 4809/20
compatibility [2] 4788/23 4789/2
compensate [1] 4875/10
Competence [1] 4727/21
competency [5] 4859/2 4859/2 4860/24
4863/6 4863/12
competent [4] 4708/19 4709/5 4749/15
4859/5
competitive [1] 4680/3
competitors [1] 4731/11
competitors' [1] 4706/8
COMPLAINT [1] 4668/7
complete [6] 4685/14 4689/5 4740/10
4803/23 4817/17 4818/18
completed [6] 4684/10 4761/3 4793/3
4793/24 4794/1 4794/12
completely [2] 4841/21 4842/25
completion [1] 4855/13
Completions [1] 4823/7
complex [4] 4677/14 4680/4 4737/1
4737/9
complexity [2] 4709/19 4736/24
complying [2] 4695/25 4696/7
component [2] 4705/10 4720/4
comprehensive [1] 4702/22
compressive [8] 4819/20 4820/6 4820/7
4820/9 4822/12 4863/22 4866/16
4871/8
comprise [1] 4701/22
computer [3] 4673/24 4717/11 4797/3
computer-aided [1] 4673/24
conceal [1] 4852/6
concentrated [1] 4715/12
concentration [10] 4812/21 4813/8
4814/9 4816/3 4875/23 4876/8 4876/14
4876/18 4876/21 4879/13
concentrations [1] 4875/22
concept [5] 4688/16 4693/22 4693/23
4714/13 4737/22
concerning [1] 4819/18
concise [1] 4809/23
concluded [1] 4881/18
condition [4] 4811/24 4820/12 4878/10
4878/14
conditioned [4] 4756/18 4797/5 4803/9
4878/20
conditioning [9] 4762/4 4762/17 4820/13
4877/4 4877/7 4878/4 4878/9 4878/23
4880/25
conditions [5] 4811/18 4857/6 4857/8
4878/5 4878/7
conduct [5] 4712/18 4742/5 4742/12
4742/13 4866/8
conducted [8] 4692/19 4722/15 4732/9
4739/4 4871/2 4871/3 4873/25 4879/11
conducting [6] 4702/7 4711/15 4711/19
4877/4 4877/8 4880/6
conducts [1] 4860/14
confidence [1] 4677/20
confident [1] 4859/15
confirm [3] 4690/22 4737/25 4739/16
confirmation [1] 4847/11
confirming [2] 4714/22 4715/2
conflict [3] 4693/2 4693/7 4699/16
confused [3] 4781/3 4845/5 4845/6
confusing [2] 4701/15 4849/1

C
confusion [2] 4820/23 4829/4
Congress [1] 4682/13
conjunction [1] 4675/23
connected [1] 4878/14
connection [3] 4676/15 4721/18 4737/23
CONRAD [1] 4669/15
consequences [2] 4716/6 4720/7
consequently [1] 4701/11
conserve [1] 4829/18
consider [1] 4712/15
considered [2] 4684/14 4715/4
considers [1] 4722/17
consistent [14] 4690/22 4691/19
4691/23 4692/5 4692/7 4693/3 4694/2
4694/3 4697/16 4700/16 4701/14
4705/1 4732/21 4816/24
constantly [2] 4724/3 4725/4
constitutes [1] 4721/3
construction [2] 4682/24 4734/4
contact [2] 4688/17 4754/25
contacted [1] 4755/24
contained [3] 4692/24 4786/5 4787/10
container [2] 4783/19 4783/22
containing [1] 4828/20
contamination [2] 4770/17 4770/21
content [1] 4735/21
context [1] 4734/7
contingent [5] 4726/17 4726/21 4726/25
4727/3 4727/6
continued [3] 4740/22 4741/17 4741/25
continues [4] 4680/2 4691/7 4692/24
4744/3
continuing [1] 4741/2
continuously [1] 4698/11
continuum [1] 4736/24
contract [10] 4690/18 4690/25 4691/1
4691/15 4691/21 4692/6 4693/5 4693/6
4693/9 4701/13
contracting [2] 4698/22 4698/24
contractor [15] 4678/21 4683/2 4683/2
4683/2 4683/3 4690/6 4691/2 4691/24
4692/14 4692/20 4692/21 4692/24
4694/12 4698/25 4700/1
contractor's [4] 4690/4 4693/1 4693/2
4699/17
contractors [1] 4682/4
contracts [1] 4701/12
contractual [1] 4690/16
contractually [1] 4692/13
control [44] 4691/25 4692/2 4693/2
4694/13 4695/5 4697/3 4716/15
4716/16 4716/19 4716/20 4716/24
4717/2 4720/21 4722/25 4722/25
4723/1 4723/3 4724/11 4724/15
4724/20 4724/22 4726/11 4727/22
4728/20 4729/4 4731/20 4733/5
4733/14 4733/22 4733/23 4733/25
4734/16 4734/21 4742/6 4743/14
4744/21 4745/12 4745/22 4746/8
4746/16 4747/13 4747/20 4749/5
4806/13
controlled [2] 4806/20 4806/21
controls [9] 4693/8 4697/13 4697/14
4713/9 4714/8 4715/3 4718/16 4718/18
4719/9
convenience [1] 4807/21
convenient [1] 4752/15
conversation [4] 4709/14 4758/8
4759/15 4842/1
conversations [1] 4840/20
coordinator [1] 4864/15

coordinators [2] 4809/8 4858/15


copy [2] 4750/13 4823/6
core [2] 4727/21 4750/24
COREY [2] 4671/8 4824/3
corner [2] 4703/17 4745/15
Corporate [1] 4669/16
Corporation [2] 4672/23 4673/3
correct [285]
corrected [1] 4803/4
correctly [4] 4722/20 4741/7 4780/8
4835/16
could [93] 4678/14 4682/9 4683/11
4684/21 4687/17 4690/23 4697/23
4698/8 4700/8 4702/15 4704/13 4713/4
4713/8 4717/8 4724/12 4728/25
4729/15 4733/12 4733/20 4751/5
4756/24 4759/22 4763/17 4763/19
4765/3 4768/13 4768/14 4772/7
4773/12 4775/8 4777/21 4782/21
4784/22 4795/18 4795/22 4795/22
4796/2 4799/17 4806/5 4806/12
4806/17 4806/18 4807/3 4809/12
4809/15 4810/5 4810/17 4811/5
4812/22 4813/11 4813/15 4814/19
4815/10 4815/23 4816/8 4816/14
4817/15 4819/12 4820/22 4822/1
4822/21 4823/3 4823/4 4824/7 4826/3
4827/13 4829/16 4830/15 4831/15
4836/3 4839/6 4844/11 4844/18
4850/11 4852/8 4852/13 4853/19
4858/19 4859/5 4860/16 4862/15
4862/19 4863/5 4865/10 4866/5
4867/15 4867/15 4867/16 4867/17
4867/17 4869/21 4869/22 4871/20
couldn't [1] 4713/8
counsel [4] 4698/4 4699/13 4844/4
4876/4
count [3] 4839/12 4839/16 4839/17
couple [17] 4711/5 4715/21 4715/21
4759/20 4761/13 4761/17 4763/11
4763/18 4766/3 4767/8 4784/3 4792/22
4844/4 4851/22 4856/24 4857/18
4871/6
course [5] 4696/11 4699/8 4774/21
4775/14 4847/16
court [46] 4668/1 4673/18 4685/16
4693/23 4705/7 4709/14 4729/9
4731/15 4753/8 4756/1 4767/14 4779/5
4804/7 4807/4 4809/23 4813/25
4819/16 4819/18 4820/20 4822/3
4828/9 4844/1 4844/9 4847/24 4848/7
4848/21 4849/23 4851/17 4852/13
4852/13 4853/6 4855/3 4856/9 4858/19
4861/9 4862/12 4865/19 4871/18
4872/2 4873/9 4877/20 4878/13
4878/23 4881/21 4881/21 4881/25
courtroom [1] 4752/4
cover [4] 4677/6 4678/2 4678/7 4749/18
covered [3] 4715/22 4808/4 4868/25
Covington [1] 4672/2
create [3] 4760/19 4762/23 4763/2
creation [1] 4698/11
crew [17] 4677/10 4680/21 4685/7
4694/21 4695/2 4695/6 4695/10
4695/13 4712/17 4712/18 4716/16
4716/20 4737/3 4740/9 4747/21
4749/24 4750/2
crews [2] 4749/14 4749/15
criminal [1] 4737/23
criteria [2] 4815/22 4815/22
cross [9] 4676/9 4677/2 4677/5 4753/23
4807/2 4808/13 4824/3 4824/10
4847/14

cross-examination [8] 4676/9 4677/2


4677/5 4753/23 4807/2 4808/13 4824/3
4824/10
crosses [1] 4871/21
crush [4] 4819/20 4820/6 4820/7
4863/22
Cumulative [1] 4738/9
Cunningham [9] 4669/2 4669/3 4716/2
4719/25 4729/25 4733/2 4743/14
4744/18 4749/13
Cunningham's [1] 4707/14
curing [1] 4724/10
current [2] 4713/23 4722/10
currently [4] 4797/24 4808/15 4825/18
4852/18
Curt [1] 4689/8
Curtis [2] 4748/23 4750/1
custodial [1] 4797/3
custodian [1] 4808/9
custody [1] 4808/1
customer [17] 4693/12 4693/14 4701/18
4719/18 4726/13 4732/9 4737/8 4860/5
4860/13 4860/16 4860/17 4862/23
4864/8 4867/23 4868/5 4868/9 4868/14
customers [4] 4680/4 4845/3 4860/2
4869/13
cut [1] 4817/5
CV [2] 4668/7 4668/9

D
D-3257 [1] 4836/4
D-3258 [1] 4831/15
D-4275 [1] 4689/18
D-4341 [1] 4684/3
D-4341.1 [1] 4683/11
D-4418.1 [1] 4728/25
D-4594 [2] 4685/12 4686/1
D-4595 [1] 4702/15
D-4595.1 [2] 4724/12 4724/12
D-6726.1 [1] 4746/4
D-6726.2 [1] 4746/10
D-6726.3 [1] 4746/24
D-6726.4 [1] 4747/9
D-6730 [2] 4726/3 4726/4
D-Air [20] 4786/5 4786/10 4786/14
4786/20 4786/21 4786/22 4787/10
4787/15 4789/12 4790/24 4874/18
4874/19 4874/21 4874/24 4875/1
4875/6 4875/11 4875/17 4875/22
4875/24
D-Air 3000 [2] 4787/20 4787/22
D.C [4] 4670/17 4670/22 4671/6 4672/4
daily [3] 4735/18 4737/12 4867/18
Dallas [1] 4673/10
damage [2] 4716/8 4722/18
Dan [1] 4727/18
DANIEL [1] 4671/4
DAS [1] 4730/4
data [5] 4717/11 4732/20 4732/21
4755/14 4820/18
database [5] 4809/1 4812/12 4812/14
4844/23 4864/24
date [32] 4745/6 4745/15 4745/25
4748/6 4765/25 4774/3 4775/24
4775/25 4778/10 4778/10 4778/11
4780/14 4780/23 4781/16 4782/9
4783/1 4783/2 4783/2 4783/3 4784/17
4784/25 4785/23 4797/13 4799/11
4799/24 4816/17 4833/6 4833/7 4833/9
4851/2 4854/14 4854/14
dated [5] 4677/25 4774/2 4780/10
4798/25 4810/4
dates [3] 4814/1 4823/14 4854/4

D
Daun [1] 4687/9
Dauphin [1] 4669/3
DAVID [3] 4673/3 4673/3 4689/9
Dawn [1] 4875/13
day [27] 4668/14 4694/6 4699/20
4721/22 4722/12 4737/12 4737/17
4739/9 4751/2 4765/11 4768/15 4779/1
4825/5 4836/25 4837/2 4838/9 4838/10
4839/21 4840/4 4840/6 4840/8 4841/6
4853/5 4855/9 4865/15 4866/22
4867/18
days [4] 4717/9 4742/21 4742/22
4833/17
DD1 [2] 4730/5 4730/8
DD3 [1] 4724/21
DEANNA [1] 4670/15
December [3] 4735/4 4748/3 4748/11
December 4th [2] 4748/3 4748/11
decide [1] 4785/10
decided [2] 4767/9 4802/17
decision [4] 4784/2 4821/17 4821/20
4821/25
dedicated [1] 4860/11
deemed [5] 4741/1 4741/12 4741/16
4741/24 4859/5
deep [1] 4877/18
deepest [2] 4680/8 4683/25
deepwater [97] 4668/4 4672/6 4672/7
4672/9 4672/10 4672/13 4672/13
4672/17 4672/17 4672/20 4672/21
4679/22 4680/5 4680/7 4680/20 4681/9
4681/11 4682/6 4682/8 4683/16
4683/20 4684/14 4684/24 4685/1
4685/3 4685/5 4685/8 4688/7 4689/19
4694/25 4695/3 4696/11 4698/13
4702/1 4703/7 4703/9 4710/13 4711/2
4712/5 4714/1 4720/18 4723/16
4723/23 4724/6 4735/15 4736/14
4740/3 4742/7 4747/21 4748/24
4749/21 4749/24 4750/5 4751/1 4755/9
4756/2 4767/15 4767/25 4770/11
4773/10 4773/14 4773/16 4774/23
4775/25 4780/9 4780/25 4783/1
4784/10 4784/13 4784/20 4785/6
4785/23 4787/1 4787/25 4796/18
4796/21 4797/18 4801/18 4830/7
4831/2 4832/6 4832/24 4833/16 4834/8
4834/16 4834/24 4835/24 4838/5
4839/2 4839/13 4839/21 4840/14
4841/12 4849/24 4850/2 4857/1 4857/3
Deepwater Horizon [7] 4702/1 4703/7
4703/9 4710/13 4712/5 4714/1 4839/13
defendant [4] 4740/17 4740/17 4740/21
4741/5
defer [3] 4738/12 4738/14 4752/14
define [1] 4830/24
defined [1] 4714/5
definitions [1] 4714/4
defoamer [1] 4788/9
defoamers [5] 4788/13 4789/2 4789/2
4789/12 4790/24
degrade [1] 4806/7
degrades [1] 4806/16
deGravelles [2] 4669/21 4669/22
degree [2] 4853/10 4853/15
degrees [2] 4879/12 4880/7
DELEMARRE [1] 4670/20
deliver [3] 4684/21 4699/2 4699/4
demanding [1] 4679/5
demonstrated [1] 4715/3
demonstrative [13] 4683/14 4702/13

4729/1 4729/19 4746/6 4807/3 4813/15


4816/15 4816/18 4824/7 4829/11
4832/17 4838/17
Demonstrative 3257 [1] 4832/17
Demonstrative 3258 [1] 4838/17
Demonstrative 3264 [1] 4829/11
Demonstrative 3602 [1] 4807/3
demonstratives [1] 4873/9
DENISE [1] 4673/15
densities [3] 4768/18 4768/21 4768/23
density [5] 4769/4 4874/1 4874/9
4874/10 4874/15
deny [3] 4759/16 4759/18 4778/2
Department [5] 4670/8 4670/12 4670/18
4671/2 4846/5
depended [1] 4806/17
dependent [1] 4811/2
depending [3] 4844/12 4866/10 4866/16
depicted [2] 4687/19 4707/18
depiction [2] 4702/21 4707/20
deposition [12] 4676/3 4697/20 4697/24
4698/2 4751/15 4758/12 4769/1
4830/16 4833/25 4834/5 4835/18
4856/19
depositions [1] 4785/5
depth [3] 4680/9 4683/25 4877/17
depths [1] 4681/15
DEPUTY [1] 4753/15
describe [2] 4702/9 4711/11
described [3] 4699/16 4707/1 4796/14
description [5] 4678/17 4707/15 4708/21
4732/13 4828/15
design [12] 4757/9 4757/15 4760/11
4787/11 4787/13 4787/14 4787/19
4787/21 4788/14 4821/4 4821/6
4821/21
designation [1] 4782/24
designed [6] 4680/17 4712/12 4734/22
4737/7 4809/7 4812/4
designing [2] 4789/11 4874/23
designs [1] 4788/11
desirable [1] 4691/8
despite [1] 4801/20
destabilize [6] 4787/23 4789/3 4789/12
4789/18 4789/24 4790/12
Destabilizes [1] 4789/22
detail [1] 4689/20
details [1] 4708/7
detected [1] 4725/14
detection [2] 4718/8 4718/11
determine [8] 4693/15 4699/18 4699/18
4806/13 4812/12 4821/9 4859/4
4866/11
determined [1] 4878/9
developed [1] 4835/24
development [1] 4715/14
Dewey [2] 4748/14 4749/25
Dexter [1] 4671/9
Diane [3] 4702/15 4704/13 4722/3
did [116] 4680/16 4684/4 4688/13
4698/14 4703/24 4704/1 4707/14
4722/9 4722/21 4734/10 4734/11
4738/7 4738/19 4740/10 4741/5
4742/10 4749/3 4750/4 4757/9 4758/15
4758/19 4760/16 4760/22 4761/21
4761/24 4762/18 4762/20 4763/8
4763/13 4763/16 4763/18 4764/2
4764/3 4764/4 4764/7 4766/14 4766/25
4768/18 4768/21 4769/8 4769/25
4770/21 4772/18 4776/22 4782/4
4782/16 4783/4 4786/5 4786/23 4787/2
4787/8 4791/14 4791/16 4792/4
4792/25 4793/3 4793/22 4794/18

4796/6 4800/25 4802/22 4803/3


4803/19 4803/19 4805/1 4805/10
4808/24 4809/5 4812/10 4815/8
4815/12 4815/16 4815/17 4829/7
4829/20 4830/14 4834/6 4835/16
4835/18 4837/12 4837/14 4839/3
4839/5 4839/9 4839/19 4840/2 4840/17
4840/21 4841/6 4841/7 4845/22
4846/10 4847/4 4848/9 4848/23 4851/5
4851/19 4852/1 4852/3 4852/5 4852/7
4852/23 4853/15 4854/16 4855/15
4855/17 4855/22 4856/4 4859/21
4860/23 4861/1 4862/3 4863/12
4863/15 4863/20 4873/3
didn't [76] 4686/1 4706/1 4707/13
4724/20 4734/13 4741/14 4744/14
4759/21 4759/24 4760/1 4761/1
4765/10 4766/5 4766/12 4766/16
4766/23 4766/24 4766/25 4767/2
4767/3 4767/5 4767/12 4767/16 4768/6
4768/8 4768/13 4768/16 4768/21
4768/25 4769/10 4769/16 4770/8
4770/10 4770/14 4770/18 4770/20
4771/8 4771/20 4775/19 4777/6
4777/23 4781/2 4781/6 4781/8 4787/3
4787/4 4787/5 4787/6 4787/11 4802/7
4803/5 4803/9 4803/12 4804/15
4804/20 4804/21 4815/7 4820/11
4820/11 4827/10 4829/24 4836/21
4839/12 4839/14 4839/16 4839/17
4840/22 4840/23 4840/24 4842/4
4842/6 4847/14 4855/25 4859/23
4881/2 4881/3
died [1] 4751/1
difference [6] 4693/24 4729/19 4752/17
4775/11 4870/14 4870/16
differences [1] 4700/4
different [26] 4687/23 4744/10 4750/10
4780/19 4783/5 4783/15 4803/11
4803/21 4803/21 4803/22 4803/22
4824/17 4838/9 4841/21 4841/22
4841/23 4842/2 4842/2 4844/14 4849/2
4853/6 4853/24 4854/25 4864/9
4867/20 4875/8
differently [1] 4847/23
difficult [1] 4677/17
direct [10] 4689/16 4705/24 4713/2
4726/15 4753/19 4843/19 4843/23
4847/15 4855/22 4869/17
directed [1] 4866/17
direction [3] 4836/14 4837/25 4873/7
directions [1] 4767/7
directive [1] 4756/16
directly [1] 4688/1
director [1] 4686/15
directors [1] 4686/23
disappeared [1] 4801/24
discard [2] 4803/5 4852/5
discarded [2] 4767/4 4839/6
discharge [3] 4708/17 4709/4 4742/14
discuss [2] 4761/5 4872/2
discussed [5] 4735/22 4737/22 4751/12
4751/22 4854/3
discussing [1] 4711/10
discussion [3] 4870/7 4870/13 4877/3
discussions [1] 4714/13
dishwashing [1] 4875/14
dispersant [4] 4789/25 4790/2 4790/8
4791/5
dispersants [5] 4789/3 4789/12 4789/22
4790/11 4790/24
disperse [1] 4790/7
dispersing [1] 4790/3

D
displacement [1] 4712/9
displacing [2] 4711/21 4712/1
dispute [2] 4817/1 4817/5
disqualify [2] 4875/18 4875/20
distributed [1] 4676/10
DISTRICT [5] 4668/1 4668/2 4668/15
4881/21 4881/21
divert [2] 4746/15 4747/12
diverter [1] 4744/7
division [4] 4670/9 4670/19 4686/20
4749/22
do [279]
Docket [3] 4668/4 4668/7 4668/9
document [97] 4678/24 4679/2 4679/7
4679/10 4679/11 4680/12 4683/5
4683/6 4693/10 4693/11 4693/22
4694/1 4701/2 4705/4 4706/17 4707/14
4707/25 4708/9 4709/10 4709/14
4710/19 4712/23 4714/19 4715/1
4715/6 4715/8 4716/18 4716/25 4717/7
4718/10 4718/17 4720/9 4720/13
4721/25 4722/23 4727/11 4727/12
4727/13 4727/15 4728/15 4729/8
4729/14 4730/13 4730/16 4730/20
4731/2 4732/8 4732/23 4733/7 4734/2
4734/6 4738/24 4739/16 4740/4
4740/12 4740/20 4740/24 4741/4
4741/9 4742/1 4742/8 4742/10 4742/16
4743/15 4745/7 4745/9 4745/19 4747/6
4747/15 4748/4 4749/2 4749/4 4749/19
4749/23 4750/13 4788/8 4790/22
4798/4 4823/13 4823/15 4825/16
4825/20 4827/23 4837/15 4845/14
4845/20 4846/1 4846/10 4850/20
4861/14 4868/3 4871/14 4871/15
4871/19 4872/10 4872/23 4872/24
documentation [4] 4755/15 4850/4
4850/5 4861/4
documented [1] 4680/5
documents [11] 4685/18 4702/6
4702/10 4703/1 4724/14 4817/24
4818/3 4818/5 4819/8 4864/9 4865/5
does [50] 4675/22 4676/1 4686/16
4697/4 4707/12 4713/10 4724/19
4726/9 4736/3 4741/18 4746/8 4758/25
4765/17 4765/24 4773/10 4775/17
4776/2 4780/6 4784/6 4797/16 4818/20
4821/5 4821/20 4822/13 4822/17
4823/15 4823/16 4823/25 4826/21
4829/3 4832/5 4834/19 4843/1 4846/15
4847/9 4848/12 4849/16 4851/3
4861/21 4861/23 4864/22 4865/2
4867/1 4867/22 4873/20 4875/10
4875/18 4880/4 4880/13 4880/14
doesn't [9] 4706/1 4706/20 4744/1
4752/17 4752/18 4785/14 4831/11
4875/20 4877/18
doghouse [2] 4717/24 4718/2
doing [12] 4688/17 4708/23 4717/18
4725/13 4763/20 4779/6 4779/11
4779/14 4785/20 4797/2 4830/18
4857/9
Domengeaux [1] 4668/18
DON [1] 4671/19
don't [126] 4676/19 4682/1 4684/6
4684/8 4705/18 4712/10 4723/10
4723/23 4733/10 4735/2 4736/22
4739/11 4745/7 4751/24 4751/25
4752/11 4755/13 4758/1 4758/8
4759/14 4759/16 4759/18 4761/8
4761/19 4762/10 4762/10 4762/11

4762/14 4762/15 4762/20 4763/22


4764/10 4765/3 4765/4 4765/9 4765/13
4765/22 4765/22 4767/19 4768/3
4768/23 4768/24 4769/3 4769/17
4772/20 4772/20 4776/4 4776/15
4778/5 4779/3 4779/3 4779/3 4779/7
4779/8 4779/14 4782/23 4783/5 4784/1
4785/2 4785/15 4788/13 4789/14
4789/15 4792/12 4793/18 4793/19
4795/21 4797/20 4798/5 4805/3
4806/11 4806/12 4813/2 4813/6 4817/1
4817/23 4817/24 4819/5 4819/10
4820/24 4823/2 4823/19 4823/20
4825/2 4828/20 4829/5 4829/16
4829/18 4829/22 4831/9 4833/19
4836/20 4836/20 4837/4 4837/9
4837/17 4838/14 4838/25 4839/7
4840/15 4840/15 4840/20 4840/21
4840/24 4840/25 4841/1 4841/4
4841/13 4841/17 4842/4 4843/4 4843/5
4845/24 4847/15 4850/23 4851/14
4854/4 4855/25 4857/2 4857/6 4857/19
4857/23 4870/25 4873/18 4876/5
4881/9
DONALD [1] 4673/7
done [35] 4681/6 4681/10 4681/12
4693/10 4710/12 4710/24 4711/3
4734/24 4735/13 4735/24 4751/5
4757/14 4757/16 4761/1 4761/5 4762/4
4762/7 4762/14 4762/25 4763/5 4764/8
4768/1 4769/12 4771/14 4794/5 4818/7
4842/7 4844/25 4845/3 4855/23
4864/23 4867/12 4868/24 4871/8
4877/24
doubt [1] 4733/16
doubts [2] 4728/2 4728/12
DOUGLAS [1] 4671/16
down [28] 4686/19 4703/4 4712/1
4722/2 4745/15 4755/22 4759/1 4763/9
4768/21 4770/13 4773/2 4783/6
4785/10 4791/12 4791/15 4791/23
4792/9 4794/5 4826/17 4827/1 4847/19
4851/15 4860/3 4865/15 4868/17
4877/10 4877/18 4880/9
downhole [6] 4857/4 4857/8 4857/19
4877/21 4877/24 4878/5
DOYEN [1] 4672/12
dozen [1] 4786/12
DP [2] 4689/10 4689/10
Dr. [2] 4713/1 4876/4
Dr. Bea [1] 4713/1
Dr. Benge [1] 4876/4
drawing [2] 4707/14 4707/15
drawings [1] 4696/16
drawn [1] 4688/11
Drescher [1] 4669/8
drew [1] 4688/3
drill [20] 4680/4 4684/23 4715/23
4716/3 4716/15 4716/16 4716/19
4717/4 4718/7 4718/16 4718/22
4734/10 4737/8 4740/9 4740/19
4740/22 4741/3 4741/7 4741/18
4741/25
drilled [10] 4679/25 4680/7 4680/9
4680/20 4680/24 4683/20 4683/25
4684/5 4684/19 4736/15
driller [14] 4717/23 4718/5 4725/6
4725/7 4725/8 4725/12 4725/22 4726/9
4726/12 4726/16 4726/24 4744/1
4748/14 4748/24
driller's [6] 4717/23 4717/23 4718/2
4718/2 4725/13 4749/24
drillers [4] 4717/21 4724/3 4727/24

4728/11
drillers/ADs [1] 4727/24
drilling [55] 4672/6 4672/9 4672/13
4672/17 4672/20 4677/14 4677/17
4678/21 4678/21 4679/1 4679/5 4680/7
4681/14 4681/21 4682/4 4683/2
4683/16 4685/5 4685/8 4689/2 4690/4
4690/6 4690/7 4691/1 4691/2 4691/4
4691/8 4691/9 4691/15 4691/17 4695/2
4703/25 4704/1 4704/6 4704/8 4704/17
4711/24 4715/15 4721/7 4723/16
4724/1 4724/6 4725/22 4727/21 4730/1
4730/5 4730/25 4736/23 4737/19
4743/23 4823/7 4852/21 4855/12
4857/1 4857/3
drilling/engineering [1] 4736/23
drillship [1] 4679/12
Drive [1] 4669/16
dry [6] 4834/10 4835/9 4835/19 4835/23
4875/2 4875/17
Dubois [4] 4823/1 4855/21 4862/3
4869/19
due [2] 4679/4 4803/16
DUKE [1] 4669/15
duly [2] 4677/1 4753/13
dumped [1] 4755/22
Duncan [12] 4757/8 4757/19 4757/20
4757/22 4758/6 4758/22 4760/25
4761/3 4761/18 4761/18 4762/24
4764/9
duplication [1] 4807/11
during [14] 4676/3 4676/3 4731/7
4737/18 4738/4 4740/1 4750/15
4793/21 4820/6 4841/20 4858/2
4859/18 4865/16 4872/19
duties [1] 4739/25
duty [1] 4742/5
dynamic [1] 4724/1
dynamically [1] 4679/12

E
e-mail [7] 4738/19 4738/21 4738/25
4822/24 4822/25 4823/15 4867/17
each [9] 4699/20 4706/14 4761/5
4811/14 4814/1 4855/6 4855/15 4858/9
4858/9
earlier [16] 4677/7 4684/14 4686/11
4688/25 4695/20 4709/23 4721/19
4729/18 4731/16 4822/13 4822/17
4825/17 4825/20 4827/8 4831/18
4842/20
early [1] 4857/18
easier [3] 4702/13 4702/16 4833/6
easiest [1] 4863/7
EASTERN [2] 4668/2 4881/21
educate [1] 4850/1
Edwards [1] 4668/19
effect [1] 4748/6
effective [2] 4681/14 4681/21
effectively [3] 4703/14 4713/18 4735/5
effects [3] 4875/6 4875/10 4875/24
efficient [2] 4681/14 4681/21
efficiently [1] 4712/20
effort [1] 4682/25
eight [3] 4750/6 4859/11 4859/11
either [7] 4685/17 4755/15 4761/4
4781/6 4782/4 4782/4 4845/24
element [3] 4699/8 4719/17 4732/22
ELIZABETH [1] 4671/5
Ellis [1] 4671/21
Elm [1] 4673/9
ELMO [4] 4828/5 4834/3 4842/10
4845/18

E
else [21] 4676/22 4764/15 4766/15
4779/2 4779/6 4782/1 4795/22 4796/2
4796/7 4805/24 4821/3 4824/25 4825/1
4829/17 4836/14 4837/2 4839/20
4841/11 4845/9 4851/23 4856/16
emergency [5] 4719/6 4721/2 4721/3
4721/5 4721/9
emphasis [1] 4679/4
employed [4] 4808/15 4808/18 4852/18
4852/19
employee [6] 4685/15 4706/14 4706/20
4756/9 4863/6 4863/12
employees [8] 4689/24 4695/8 4701/15
4705/13 4837/7 4838/1 4862/1 4862/2
employer [1] 4852/25
end [7] 4683/25 4721/20 4824/5
4829/15 4841/5 4855/9 4876/9
endeavor [1] 4677/6
ending [1] 4879/22
Energy [2] 4673/7 4673/11
Enforcement [1] 4670/13
engaged [1] 4715/14
engineer [13] 4772/16 4777/3 4821/18
4857/14 4864/14 4865/1 4867/6
4867/11 4868/2 4868/13 4869/11
4873/21 4878/11
engineering [3] 4686/14 4723/18
4736/23
engineers [3] 4680/17 4809/7 4858/15
enhancement [1] 4855/13
enough [4] 4706/21 4744/14 4825/25
4857/21
ensure [1] 4703/13
enter [3] 4815/17 4868/13 4868/15
entered [1] 4815/13
entities [2] 4682/25 4684/19
entitled [3] 4692/13 4706/2 4881/23
entity [2] 4698/23 4721/22
entrained [1] 4870/20
entraining [1] 4870/18
entry [1] 4814/4
environment [2] 4670/13 4704/20
environmental [2] 4670/13 4716/7
environments [2] 4677/18 4680/5
epicenter [1] 4718/1
equipment [16] 4685/3 4691/25 4694/16
4694/18 4695/23 4704/21 4716/24
4717/2 4719/10 4722/18 4821/2 4821/4
4871/4 4871/9 4871/10 4871/10
equipment/structure [1] 4722/18
equivalent [2] 4875/12 4875/15
error [1] 4821/4
escalation [1] 4735/10
ESQ [57] 4668/19 4668/23 4669/3
4669/6 4669/9 4669/12 4669/15
4669/18 4669/22 4670/3 4670/6 4670/9
4670/14 4670/14 4670/15 4670/15
4670/16 4670/19 4670/20 4670/20
4670/21 4670/21 4671/4 4671/4 4671/5
4671/8 4671/8 4671/9 4671/12 4671/15
4671/16 4671/19 4671/22 4671/22
4671/23 4672/3 4672/6 4672/9 4672/9
4672/12 4672/13 4672/13 4672/16
4672/20 4672/23 4673/3 4673/3 4673/4
4673/4 4673/7 4673/8 4673/8 4673/9
4673/12 4673/15 4673/15 4673/16
essence [1] 4723/20
establish [1] 4815/22
established [2] 4859/3 4877/23
et [2] 4668/8 4668/11
etc [1] 4735/19

evacuate [1] 4719/8


evaluating [2] 4857/4 4860/12
even [12] 4763/25 4783/22 4793/5
4815/12 4815/17 4840/15 4840/19
4849/23 4859/18 4865/10 4866/6
4866/24
evening [2] 4748/24 4813/13
event [16] 4716/6 4721/1 4723/8 4733/3
4733/9 4733/12 4733/20 4743/14
4743/18 4743/20 4743/21 4743/25
4744/5 4744/8 4744/13 4846/4
events [9] 4724/5 4728/20 4729/4
4730/14 4731/20 4731/21 4732/3
4732/24 4733/19
eventually [2] 4740/16 4792/9
ever [21] 4680/8 4735/1 4763/16
4765/20 4781/7 4787/2 4787/8 4792/1
4792/25 4793/3 4793/22 4794/19
4797/6 4798/21 4842/22 4843/1 4849/9
4857/24 4859/19 4880/13 4880/15
every [18] 4685/15 4693/12 4694/6
4699/20 4701/13 4705/14 4711/23
4712/2 4713/22 4726/7 4733/14 4751/2
4794/12 4800/14 4804/15 4825/5
4836/13 4873/22
everybody [3] 4809/8 4837/4 4861/8
everyone [5] 4675/6 4753/10 4788/13
4789/17 4809/8
everything [20] 4709/2 4756/12 4757/2
4781/4 4783/23 4801/7 4801/14
4802/10 4802/12 4802/17 4805/20
4805/24 4824/25 4825/1 4828/9 4829/6
4839/23 4839/24 4840/8 4867/19
everything's [1] 4723/20
evidence [7] 4675/21 4676/2 4721/6
4745/9 4747/17 4818/14 4825/11
EX [1] 4719/10
EX-rated [1] 4719/10
exact [24] 4769/17 4771/15 4771/16
4776/4 4776/6 4780/3 4780/5 4781/17
4782/11 4782/15 4784/24 4784/25
4785/25 4799/11 4799/12 4799/13
4800/10 4800/13 4800/14 4800/24
4801/16 4802/5 4802/16 4803/14
exactly [9] 4758/8 4759/14 4769/17
4778/3 4780/21 4798/21 4801/1 4806/1
4837/9
exam [1] 4752/9
examination [17] 4676/4 4676/9 4677/2
4677/5 4685/16 4713/2 4743/7 4752/7
4753/19 4753/23 4807/2 4808/13
4824/3 4824/10 4843/10 4843/20
4843/23
examinations [1] 4685/19
example [10] 4680/6 4711/7 4794/15
4809/23 4811/20 4812/17 4821/12
4826/14 4844/17 4866/23
exceeded [2] 4685/4 4685/7
except [1] 4775/11
exception [2] 4683/18 4683/21
excerpt [2] 4682/12 4700/10
exchanged [1] 4737/18
Excluding [1] 4719/19
excuse [2] 4824/8 4834/2
execute [1] 4707/3
executive [4] 4707/10 4708/1 4708/3
4750/19
exemplary [2] 4681/11 4684/15
exercise [3] 4705/17 4742/5 4816/20
exhibit [8] 4692/24 4701/24 4704/14
4714/17 4727/14 4729/1 4739/15
4848/3
Exhibit 5474.102.1 [1] 4701/24

exhibits [7] 4675/14 4675/18 4675/23


4676/2 4676/9 4676/15 4807/17
exists [1] 4707/1
exiting [1] 4744/6
expands [1] 4744/4
expect [19] 4701/10 4711/20 4711/21
4711/23 4711/25 4712/2 4718/23
4728/11 4752/7 4789/10 4789/13
4873/2 4874/2 4874/4 4874/7 4874/9
4874/14 4874/17 4881/4
expectation [1] 4712/16
expectations [4] 4703/13 4707/3
4708/18 4709/5
expected [4] 4734/10 4788/18 4821/16
4873/12
expects [1] 4728/1
expects/100 [1] 4728/1
experience [14] 4724/5 4736/23 4750/4
4820/4 4857/2 4857/7 4857/17 4857/23
4859/9 4866/10 4873/20 4875/19
4875/20 4876/20
experiments [1] 4768/8
expertise [2] 4679/22 4680/4
explain [16] 4783/7 4804/7 4804/12
4820/22 4844/9 4849/22 4855/3
4858/19 4864/9 4864/21 4865/19
4870/14 4877/20 4878/2 4878/13
4879/25
explained [6] 4729/9 4741/8 4805/15
4848/21 4848/21 4851/17
explanation [2] 4824/5 4842/12
exploration [9] 4668/10 4671/18
4671/21 4672/2 4715/14 4723/7
4729/12 4740/3 4742/7
explosion [6] 4742/18 4742/20 4755/3
4755/5 4777/25 4781/1
exposed [2] 4790/8 4806/17
exposing [1] 4877/11
expressed [1] 4807/21
expressly [2] 4703/25 4706/13
external [1] 4869/13
extra [2] 4732/12 4784/3
extrapolated [1] 4817/15
ExxonMobil [1] 4860/17
Ezell [4] 4689/3 4739/3 4747/24
4748/11

F
facilities [3] 4692/17 4708/5 4708/13
facility [4] 4829/1 4837/4 4839/22
4863/4
fact [32] 4679/8 4702/13 4757/5
4757/18 4761/3 4764/21 4765/1 4765/6
4765/10 4767/2 4769/8 4773/14 4774/1
4784/13 4784/14 4785/6 4785/11
4789/18 4791/14 4791/25 4792/25
4793/22 4802/13 4804/9 4806/12
4832/1 4841/2 4842/24 4846/21 4851/1
4852/8 4872/9
Fahrenheit [1] 4879/12
fail [1] 4821/5
failed [4] 4820/18 4820/22 4820/25
4821/6
failure [2] 4720/5 4720/10
fair [15] 4677/11 4678/17 4681/18
4693/16 4693/25 4696/21 4697/4
4697/14 4705/2 4707/20 4708/20
4715/19 4725/2 4821/5 4857/21
fairness [1] 4727/11
falls [1] 4733/17
false [1] 4732/12
familiar [17] 4694/14 4735/17 4736/9
4737/12 4739/13 4788/2 4788/4 4788/5

F
familiar... [9] 4788/20 4790/4 4790/16
4790/21 4809/2 4813/22 4822/7 4872/6
4872/10
familiarity [3] 4856/23 4856/25 4857/15
fan [1] 4727/24
fancy [2] 4832/1 4845/13
Fannin [1] 4672/10
far [3] 4684/12 4684/13 4686/14
fashion [1] 4851/18
fatalities [1] 4716/8
Faul [23] 4754/17 4754/18 4754/19
4755/1 4755/4 4755/24 4756/6 4757/7
4757/18 4759/19 4759/23 4760/10
4760/14 4760/25 4762/23 4764/12
4765/6 4766/3 4767/7 4769/15 4770/16
4842/21 4852/4
Faul's [1] 4771/4
FCRR [4] 4673/18 4881/21 4881/24
4881/25
February [25] 4704/8 4745/5 4745/8
4748/18 4797/13 4799/12 4799/25
4808/10 4808/18 4808/24 4809/22
4810/3 4810/4 4813/12 4813/14
4813/18 4815/16 4816/11 4816/12
4818/11 4819/21 4830/13 4833/8
4833/22 4836/7
February 11th [1] 4813/14
February 11th at [1] 4813/18
February 12th [1] 4748/18
February 2010 [1] 4833/8
February 20th [1] 4745/5
February 23rd [4] 4797/13 4799/12
4799/25 4833/22
February 23rd of [1] 4836/7
federal [13] 4670/10 4836/23 4837/16
4838/1 4838/10 4838/11 4838/13
4838/22 4840/4 4840/6 4841/6 4841/10
4846/5
feel [1] 4862/22
feels [1] 4706/20
feet [3] 4680/10 4680/10 4795/10
fellow [1] 4843/11
felt [3] 4749/14 4841/25 4853/8
few [18] 4683/23 4685/16 4690/17
4690/21 4705/6 4712/25 4735/3
4737/23 4739/20 4807/7 4807/8 4807/8
4819/15 4829/16 4829/22 4831/20
4843/25 4877/23
field [3] 4821/22 4871/9 4871/10
fifth [2] 4718/15 4731/25
figure [1] 4775/4
file [1] 4797/3
filed [3] 4869/1 4869/2 4869/3
fill [1] 4814/23
filling [2] 4688/12 4688/14
fills [1] 4865/1
final [8] 4791/11 4791/15 4792/1 4792/8
4792/9 4792/18 4822/21 4878/19
finally [3] 4781/7 4791/23 4831/3
find [11] 4701/15 4755/19 4756/13
4772/11 4775/19 4786/5 4786/23
4787/8 4817/19 4844/23 4847/4
finding [1] 4839/4
finish [8] 4675/14 4751/12 4751/20
4777/22 4782/14 4782/24 4799/22
4802/15
finished [5] 4676/18 4751/22 4753/2
4806/4 4822/15
finishes [1] 4866/19
fire [5] 4691/21 4692/2 4719/9 4742/18
4742/20

firefighting [1] 4719/7


Firm [2] 4669/18 4670/5
first [46] 4679/12 4688/17 4698/14
4704/11 4704/17 4704/18 4704/22
4707/13 4716/14 4743/22 4745/2
4746/7 4747/24 4757/12 4761/3
4772/14 4775/24 4780/1 4782/7
4786/15 4786/18 4786/24 4788/4
4797/1 4797/22 4798/4 4802/19
4807/18 4809/21 4810/4 4812/10
4812/20 4813/16 4814/9 4814/25
4828/16 4832/23 4842/25 4854/3
4861/12 4866/11 4866/12 4866/15
4866/15 4871/24 4879/5
firsthand [1] 4736/16
firsts [2] 4679/9 4679/13
five [13] 4718/21 4725/18 4737/12
4737/17 4770/17 4811/21 4812/9
4812/14 4815/8 4815/12 4816/2
4821/12 4859/24
five-day [2] 4737/12 4737/17
fleet [4] 4678/25 4679/3 4700/17
4713/22
Fleytas [1] 4689/9
floating [1] 4743/23
floor [10] 4669/13 4672/14 4715/23
4716/3 4716/15 4717/5 4718/8 4718/16
4718/22 4744/6
flow [16] 4734/11 4735/6 4739/5 4739/5
4740/23 4740/25 4741/15 4741/23
4744/11 4746/15 4747/7 4747/11
4808/5 4809/17 4809/24 4866/9
flow-check [1] 4734/11
flowing [3] 4725/5 4747/2 4747/6
FLOYD [1] 4673/8
fluid [8] 4794/17 4844/7 4854/22
4859/19 4863/18 4863/19 4863/19
4866/15
fluids [9] 4808/23 4821/8 4824/22
4852/22 4854/18 4855/11 4855/12
4855/13 4858/3
fly [2] 4810/6 4858/25
fly-out [1] 4810/6
foam [47] 4758/20 4764/18 4764/18
4764/20 4770/17 4787/19 4787/24
4787/24 4788/10 4789/4 4789/12
4789/19 4789/22 4789/24 4790/4
4790/12 4790/15 4790/18 4790/19
4790/25 4791/6 4819/20 4870/8
4870/13 4870/15 4870/17 4871/3
4871/3 4871/9 4872/6 4872/7 4872/18
4872/19 4873/3 4873/23 4873/25
4874/16 4874/21 4874/23 4874/24
4876/3 4876/7 4876/12 4876/21 4877/5
4877/8 4878/19
foamed [2] 4875/18 4875/19
foaming [8] 4870/17 4875/9 4875/12
4875/15 4875/16 4878/10 4878/20
4878/24
focus [7] 4703/16 4715/21 4715/22
4791/20 4807/12 4873/23 4873/23
folder [2] 4755/14 4755/16
folks [1] 4726/13
follow [3] 4686/19 4806/5 4875/7
follow-up [1] 4875/7
follow-ups [1] 4806/5
following [3] 4715/13 4734/14 4817/21
follows [2] 4677/1 4753/14
foregoing [1] 4881/22
foreseeable [1] 4714/24
forgive [1] 4703/22
formally [3] 4675/17 4675/20 4676/8
format [1] 4868/9

former [1] 4809/2


forth [2] 4689/12 4692/22
forward [4] 4699/19 4721/22 4737/15
4737/17
found [6] 4755/11 4768/18 4794/19
4804/9 4804/10 4824/6
foundation [2] 4807/15 4817/14
four [22] 4730/18 4730/24 4731/24
4732/2 4732/6 4732/16 4752/20
4754/13 4770/17 4815/4 4815/6
4824/23 4825/7 4825/11 4827/23
4828/25 4829/5 4829/13 4855/10
4855/15 4858/8 4859/24
four-year [6] 4730/18 4730/24 4731/24
4732/2 4732/6 4732/16
fourth [1] 4718/7
frac [1] 4727/3
frame [5] 4761/10 4854/6 4859/8
4859/13 4870/6
framework [2] 4720/25 4723/13
Francisco [1] 4670/11
Franklin [1] 4671/5
frankly [1] 4718/24
Fraud [1] 4671/3
free [4] 4794/17 4863/18 4863/19
4866/15
frequently [2] 4701/12 4765/17
Frilot [1] 4672/5
front [1] 4833/9
Frug [1] 4669/21
frustration [2] 4807/22 4839/10
full [8] 4753/15 4759/5 4792/18 4794/4
4829/5 4839/1 4842/8 4842/11
fully [2] 4689/5 4704/22
Fulshear [1] 4852/15
function [2] 4725/13 4726/17
functional [1] 4701/3
fundamental [8] 4705/21 4712/16
4733/5 4733/13 4733/21 4733/23
4733/25 4749/3
fundamentally [1] 4712/11
FUNDERBURK [1] 4673/16
further [6] 4741/6 4751/6 4759/1
4780/24 4782/24 4847/11

G
Gagliano [45] 4755/8 4755/21 4771/23
4772/2 4772/8 4772/16 4774/17
4775/11 4775/15 4777/25 4781/11
4781/23 4782/10 4782/23 4785/8
4786/1 4786/4 4786/9 4786/13 4786/19
4786/24 4787/8 4789/10 4791/14
4791/25 4793/2 4793/23 4794/18
4795/19 4795/25 4796/6 4799/1
4799/10 4802/3 4802/14 4807/10
4810/14 4810/24 4811/8 4811/20
4812/2 4815/7 4819/6 4864/20 4876/7
Gagliano's [4] 4766/20 4780/5 4780/22
4876/6
gain [1] 4732/2
gaining [1] 4881/5
gallon [13] 4797/15 4797/17 4798/14
4804/2 4826/14 4826/23 4827/21
4828/4 4828/16 4828/19 4828/22
4831/22 4832/2
gallons [12] 4812/25 4813/17 4816/4
4828/1 4828/1 4828/2 4828/2 4844/13
4876/19 4877/1 4879/19 4879/20
GANNAWAY [1] 4673/4
gap [1] 4699/6
gaps [3] 4699/18 4700/4 4700/5
gas [9] 4680/8 4706/6 4718/8 4719/25
4723/17 4734/10 4742/14 4742/18

4797/21 4798/11 4799/6 4799/17


4799/20 4800/19 4808/6 4808/11
4812/6 4814/19 4825/22 4826/17
4827/1 4827/13 4828/20 4829/20
4829/24 4831/1 4836/16 4838/16
4841/6 4843/15 4844/23 4845/16
4845/16 4848/13 4855/8 4861/8 4862/6
4862/19 4863/5 4863/7 4863/9 4864/17
4865/6 4867/9 4868/13 4868/13
4871/18 4871/20 4872/9 4879/5
4879/22
Godwin [4] 4673/7 4673/7 4673/11
4784/11
goes [8] 4715/7 4727/7 4750/23
4789/17 4794/5 4865/22 4866/9 4880/9
going [65] 4677/6 4685/17 4689/19
4690/4 4700/19 4704/1 4712/13
4712/14 4712/14 4717/12 4720/18
4721/22 4723/11 4723/20 4723/21
4723/21 4728/23 4737/4 4741/10
4743/10 4751/9 4751/10 4751/25
4751/25 4752/9 4752/18 4757/20
4758/6 4773/13 4775/2 4776/6 4777/5
4777/9 4781/5 4785/23 4803/16
4804/13 4808/2 4817/12 4817/25
4820/12 4828/14 4832/20 4834/7
4834/20 4838/23 4841/4 4846/25
4847/19 4848/21 4848/25 4851/23
4853/19 4856/1 4860/11 4861/8 4863/9
4866/10 4866/12 4866/14 4867/19
4871/21 4881/9 4881/12 4881/16
Golden [1] 4670/10
gone [1] 4687/25
good [11] 4677/4 4691/25 4707/9
4708/21 4743/9 4743/10 4749/14
4786/25 4806/24 4839/5 4843/18
got [21] 4731/3 4752/6 4757/12 4767/3
4775/12 4777/23 4781/6 4781/21
4781/21 4783/2 4784/3 4792/9 4801/24
4801/25 4805/1 4817/21 4829/17
4829/23 4832/13 4843/25 4881/8
govern [1] 4701/7
governing [1] 4701/1
government [17] 4683/1 4770/12
4803/10 4836/23 4837/3 4837/16
4838/10 4838/12 4838/13 4838/23
4840/5 4840/6 4841/7 4841/11 4846/3
4846/19 4872/4
governmental [1] 4692/18
grab [1] 4803/17
gradient [1] 4727/4
Grand [1] 4672/14
graphical [2] 4702/21 4730/13
graphically [1] 4709/16
greater [1] 4730/17
group [6] 4669/15 4688/23 4689/2
4689/8 4734/4 4775/2
guess [5] 4729/1 4770/9 4810/11
4813/23 4827/10
guessing [1] 4837/8
guidance [1] 4874/20
guide [1] 4776/17
guidelines [1] 4692/22
guilty [1] 4758/2
GULF [13] 4668/5 4680/9 4693/20
4693/21 4698/11 4742/15 4767/16
4767/25 4769/13 4808/21 4821/8
4824/22 4854/10
guys [3] 4750/6 4829/25 4881/13

gas... [1] 4870/20


Gate [1] 4670/10
gather [5] 4756/5 4756/12 4756/19
4804/22 4805/18
gathered [11] 4721/9 4756/18 4757/2
4798/6 4798/9 4798/13 4798/17 4801/7
4801/8 4805/17 4805/18
gathering [1] 4757/12
gauges [2] 4717/9 4717/11
gave [8] 4682/17 4711/7 4736/12
4805/19 4839/23 4839/24 4840/4
4840/10
GAVIN [2] 4673/9 4843/18
gel [3] 4771/7 4795/3 4795/9
general [11] 4671/7 4671/11 4693/17
4694/1 4694/9 4696/14 4696/15
4699/25 4701/6 4706/11 4724/10
generally [14] 4689/21 4690/3 4692/7
4696/25 4697/18 4719/24 4732/13
4736/21 4737/16 4857/16 4867/25
4868/9 4870/15 4878/11
generate [1] 4809/9
generated [4] 4771/21 4807/9 4813/23
4868/12
generates [1] 4848/19
generic [1] 4735/17
generically [2] 4736/10 4737/22
Geneva [1] 4739/12
gentleman [1] 4727/15
gentlemen [7] 4688/16 4738/6 4760/10
4770/24 4776/20 4780/12 4785/21
Geoff [1] 4676/9
GEOFFREY [1] 4673/4
geolograph [1] 4717/10
get [33] 4687/13 4703/22 4707/13
4707/20 4710/4 4752/25 4760/19
4767/24 4769/21 4775/22 4791/17
4794/16 4795/15 4795/18 4801/13
4806/11 4817/7 4829/25 4834/1 4838/2
4839/14 4841/5 4849/19 4859/21
4859/23 4859/24 4867/17 4867/18
4869/1 4869/2 4871/21 4880/13
4880/15
getting [4] 4780/18 4794/9 4870/2
4875/15
give [10] 4758/15 4758/19 4759/5
4770/5 4809/23 4812/18 4840/2 4841/7
4844/1 4858/4
given [6] 4792/18 4809/13 4812/11
4833/14 4837/25 4878/12
gives [1] 4680/3
giving [2] 4700/20 4838/20
glad [1] 4867/9
global [8] 4724/22 4788/2 4788/5
4788/19 4789/20 4859/2 4872/9
4872/15
GlobalSantaFe [1] 4722/11
globe [1] 4699/23
GmbH [1] 4668/8
GMS [1] 4750/22
go [88] 4678/3 4680/1 4682/14 4682/20
4688/20 4692/25 4699/1 4704/11
4704/14 4705/4 4707/24 4714/17
4715/9 4722/2 4722/7 4723/20 4728/17
4731/18 4732/25 4740/5 4740/13
4746/24 4749/18 4751/14 4751/17
4751/17 4751/22 4752/21 4754/8
4757/25 4758/1 4759/1 4763/16
H
4768/14 4777/7 4778/12 4778/16
habit [1] 4764/21
4779/25 4782/18 4784/21 4784/22
had [179] 4675/19 4678/25 4679/25
4785/18 4795/9 4797/9 4797/14

4681/9 4681/10 4681/11 4681/12


4683/24 4683/25 4684/4 4684/8
4684/18 4684/22 4684/23 4688/9
4688/9 4688/14 4689/13 4695/15
4696/21 4705/4 4707/15 4711/2 4711/3
4714/1 4714/1 4721/7 4721/18 4726/7
4728/15 4729/19 4734/14 4735/8
4739/3 4739/4 4739/5 4750/6 4750/7
4752/5 4752/12 4754/10 4754/25
4755/7 4755/7 4755/8 4755/9 4755/12
4755/21 4755/22 4755/25 4756/1
4756/24 4757/8 4757/14 4757/16
4757/20 4758/21 4761/1 4761/5
4761/17 4761/18 4762/3 4762/7
4762/12 4762/17 4762/24 4762/25
4763/3 4764/6 4765/1 4765/1 4765/6
4765/11 4767/2 4767/16 4769/6 4769/9
4771/4 4771/23 4772/2 4772/8 4772/11
4775/11 4775/15 4775/16 4775/20
4776/20 4777/8 4777/25 4781/25
4782/5 4784/16 4786/4 4786/9 4786/10
4786/20 4786/22 4787/1 4787/8
4787/13 4787/14 4787/18 4792/1
4792/8 4793/2 4793/23 4794/14
4795/14 4796/5 4796/10 4796/11
4796/18 4796/25 4797/17 4798/17
4800/24 4801/8 4801/16 4801/23
4802/1 4802/2 4802/4 4802/13 4802/14
4802/20 4803/7 4803/13 4803/14
4803/18 4803/19 4804/5 4804/10
4804/25 4805/14 4805/20 4807/21
4807/22 4809/11 4812/2 4812/17
4814/6 4815/7 4821/2 4823/11 4824/17
4829/8 4830/22 4831/2 4834/10 4835/1
4835/10 4837/23 4837/25 4838/4
4838/7 4838/11 4838/24 4839/24
4840/10 4841/7 4841/15 4842/21
4842/22 4846/6 4848/24 4849/12
4852/9 4852/12 4853/20 4855/5 4855/6
4855/12 4860/5 4860/5 4871/11
4873/16 4874/18 4875/5 4875/5
hadn't [1] 4781/6
half [6] 4702/23 4786/12 4797/17
4798/14 4826/15 4842/8
Halliburton [60] 4673/7 4673/11 4675/7
4675/8 4754/2 4754/11 4754/17
4754/20 4756/8 4768/2 4772/25
4784/11 4788/2 4788/8 4789/5 4789/16
4790/4 4790/10 4790/15 4802/20
4807/5 4807/19 4808/15 4808/19
4809/3 4809/18 4809/24 4819/6
4822/25 4825/4 4828/11 4828/15
4828/24 4831/19 4833/15 4835/10
4836/16 4837/7 4837/10 4837/14
4837/21 4837/22 4841/11 4842/9
4843/15 4843/17 4843/19 4853/1
4853/5 4853/17 4853/21 4854/8
4854/17 4859/3 4860/10 4862/1 4862/2
4868/22 4871/11 4872/13
Halliburton's [14] 4788/5 4788/12
4788/20 4790/19 4807/9 4808/5 4808/9
4808/21 4810/13 4815/16 4818/1
4820/21 4872/9 4874/19
hand [7] 4687/4 4705/25 4705/25
4706/1 4734/3 4734/3 4734/4
handbook [2] 4724/15 4724/22
handed [1] 4846/8
handling [1] 4795/22
handover [1] 4721/4
hands [2] 4781/21 4781/21
handwriting [1] 4866/4
handwritten [5] 4852/5 4865/23 4865/25
4868/25 4869/5

4766/5 4766/6 4766/7 4766/9 4766/11


4766/12 4766/13 4766/14 4766/16
hang [1] 4767/13
4767/11 4768/6 4769/16 4769/25
HANKEY [1] 4670/15
4770/2 4770/4 4770/8 4770/8 4770/12
happen [6] 4712/15 4723/11 4724/9
4770/18 4775/16 4775/18 4775/20
4801/10 4806/18 4843/1
4777/18 4784/21 4787/13 4792/4
happened [11] 4733/12 4757/20
4792/13 4793/23 4794/21 4795/19
4762/17 4763/10 4768/6 4770/11
4796/1 4803/3 4805/20 4808/9 4811/21
4784/15 4816/6 4836/25 4842/22
4812/17 4812/18 4813/3 4819/7
4842/25
4819/11 4820/9 4820/11 4820/11
happening [2] 4725/9 4734/22
4820/12 4832/1 4838/7 4840/19
happens [10] 4694/6 4735/18 4743/22
4840/23 4841/14 4841/15 4842/20
4743/22 4743/25 4843/2 4873/22
4847/14 4850/17 4864/24 4872/3
4877/20 4880/7 4880/10
4874/14 4877/22 4881/11
happy [3] 4751/13 4818/2 4819/1
he'd [1] 4812/12
hard [1] 4684/24
he's [15] 4686/15 4706/2 4706/21
HARIKLIA [1] 4671/22
4752/6 4752/21 4752/22 4756/10
harm [1] 4704/20
4756/11 4791/18 4792/13 4793/5
Harrell [3] 4688/21 4689/2 4739/1
4835/5 4849/1 4865/19 4877/23
harsh [2] 4677/18 4680/5
head [2] 4786/8 4859/14
HARTLEY [1] 4673/8
health [9] 4692/23 4703/18 4704/23
has [56] 4675/8 4679/8 4683/15
4706/12 4707/9 4708/4 4708/11
4693/13 4693/14 4694/2 4698/10
4708/16 4722/14
4705/7 4706/14 4707/10 4713/17
hear [4] 4705/9 4784/12 4785/7 4787/2
4714/7 4714/23 4715/3 4715/8 4718/5 heard [19] 4675/19 4705/7 4706/8
4721/1 4721/10 4724/21 4724/21
4720/20 4725/2 4738/16 4763/11
4725/2 4725/7 4725/8 4725/9 4725/13
4786/10 4786/14 4807/4 4807/7 4807/8
4726/13 4726/16 4743/3 4765/17
4819/16 4819/18 4820/20 4822/3
4765/20 4772/25 4773/21 4784/8
4841/14 4865/8 4872/2
4800/10 4800/13 4807/4 4808/3
hearing [4] 4675/25 4676/13 4831/3
4811/15 4814/22 4819/16 4819/18
4842/1
4820/8 4820/9 4820/20 4821/6 4821/14 hearts [1] 4727/24
4821/24 4822/3 4849/15 4857/17
heat [3] 4880/11 4880/23 4880/25
4858/25 4865/5 4865/8 4871/18 4872/2 heat-activated [1] 4880/23
4873/9
heated [1] 4880/7
hasn't [2] 4807/16 4807/19
heavier [2] 4874/4 4874/10
HAUSER [1] 4671/4
held [1] 4853/21
have [225]
help [3] 4765/24 4828/8 4829/25
haven't [4] 4684/6 4793/5 4831/7
helped [1] 4757/5
4831/20
helpful [3] 4700/21 4705/9 4792/6
having [11] 4676/25 4689/16 4692/19
helping [3] 4680/4 4829/8 4847/20
4701/12 4730/1 4732/5 4753/13
here [61] 4682/12 4683/23 4684/19
4775/14 4779/16 4848/20 4848/20
4688/15 4702/23 4703/4 4704/15
HAYCRAFT [1] 4671/19
4709/14 4709/19 4709/22 4710/6
hazard [10] 4710/20 4710/25 4710/25
4731/25 4732/3 4734/5 4751/16
4712/22 4713/19 4714/5 4714/16
4752/18 4752/20 4752/21 4753/1
4714/22 4716/14 4749/14
4761/11 4774/9 4779/9 4780/2 4781/9
hazards [9] 4713/18 4714/6 4714/7
4784/18 4784/23 4797/10 4797/12
4714/24 4715/12 4715/13 4715/18
4799/16 4800/4 4800/9 4800/13 4808/1
4716/3 4720/4
4813/11 4813/23 4816/11 4816/17
HAZID [1] 4710/23
4817/6 4817/20 4817/21 4826/10
HAZOP [1] 4710/23
4828/8 4831/3 4831/10 4833/22 4839/4
HB [1] 4673/19
4846/21 4847/20 4850/12 4850/24
HB-406 [1] 4673/19
4852/9 4861/18 4862/23 4863/5
he [134] 4686/23 4687/23 4688/6
4863/10 4865/20 4871/23 4872/3
4688/8 4688/21 4698/19 4706/20
4879/8 4880/2 4880/14
4714/22 4715/7 4715/8 4721/10
hereby [1] 4881/22
4722/17 4725/8 4734/8 4739/2 4739/2 hereunder [1] 4692/19
4739/2 4741/11 4741/12 4748/2
Herman [3] 4668/22 4668/22 4668/23
4748/14 4748/15 4748/17 4748/23
Hey [2] 4803/12 4804/22
4748/25 4749/2 4749/3 4751/17
hierarchy [4] 4702/10 4702/19 4724/14
4751/17 4752/4 4752/12 4752/20
4754/16
4755/7 4756/12 4756/14 4756/14
high [2] 4699/10 4723/24
4756/19 4757/7 4757/9 4757/19
high-level [1] 4699/10
4757/21 4757/23 4757/23 4758/3
higher [6] 4764/15 4801/14 4862/15
4758/5 4758/15 4758/19 4758/19
4863/1 4874/1 4874/16
4758/21 4758/22 4759/12 4759/20
higher-ups [1] 4801/14
4759/21 4759/23 4759/24 4760/1
highest [4] 4692/20 4732/6 4732/18
4760/1 4760/16 4760/19 4760/21
4863/2
4760/22 4761/24 4762/12 4762/15
highlight [1] 4685/16
4762/17 4762/18 4762/20 4762/23
highlighted [3] 4679/21 4722/13 4826/4
4763/20 4763/20 4765/6 4765/10
highlights [1] 4679/8
4765/17 4765/17 4765/20 4766/4
highly [5] 4710/17 4719/10 4842/16

4842/17 4842/18
HILL [2] 4673/9 4843/18
him [25] 4686/9 4687/6 4751/20
4752/21 4753/1 4758/9 4765/24 4766/6
4766/13 4767/12 4770/4 4770/5
4783/12 4792/13 4793/11 4793/12
4803/3 4805/19 4808/11 4840/20
4844/1 4847/14 4847/15 4874/17
4881/12
hindsight [1] 4768/11
hire [2] 4707/2 4708/19
hired [3] 4853/17 4853/23 4858/21
hiring [1] 4709/5
his [13] 4676/18 4686/20 4715/2
4750/16 4762/9 4762/25 4769/17
4781/11 4782/10 4785/8 4789/15
4832/1 4858/25
historic [1] 4680/13
history [4] 4679/9 4683/16 4696/12
4803/20
HITEC [1] 4717/8
hits [1] 4727/24
hold [4] 4768/3 4792/12 4854/4 4876/5
Holdings [5] 4672/5 4672/8 4672/12
4672/16 4672/19
hole [5] 4692/3 4726/22 4857/12
4877/11 4877/13
Holthaus [1] 4669/21
Honor [62] 4675/8 4675/9 4675/13
4675/18 4676/1 4676/7 4676/24
4741/10 4743/5 4743/10 4747/17
4751/7 4751/11 4751/16 4751/22
4752/3 4752/11 4752/14 4753/20
4767/20 4791/17 4791/20 4792/6
4793/13 4805/5 4806/5 4806/22
4806/24 4807/6 4807/15 4807/20
4808/2 4809/17 4816/21 4816/25
4817/8 4817/18 4817/22 4818/1
4818/11 4818/16 4818/19 4818/22
4823/23 4824/2 4824/4 4825/12
4828/10 4828/11 4834/2 4843/6 4843/8
4843/15 4843/18 4846/24 4847/13
4847/16 4849/1 4849/5 4863/6 4877/22
4881/8
Honor's [1] 4807/21
HONORABLE [1] 4668/15
hope [1] 4702/16
hoped [1] 4752/6
hopefully [1] 4677/8
hoping [1] 4709/13
HORIZON [101] 4668/4 4680/7 4680/20
4681/9 4681/11 4682/6 4682/8 4683/20
4684/24 4685/1 4685/3 4688/7 4689/19
4694/25 4695/3 4698/13 4702/1 4703/7
4703/9 4704/9 4704/24 4710/13 4711/2
4712/5 4714/1 4714/16 4715/4 4718/11
4718/13 4720/18 4724/20 4735/15
4736/15 4738/1 4739/10 4747/21
4748/24 4749/21 4749/24 4750/5
4751/1 4755/9 4756/2 4756/14 4756/15
4756/17 4756/20 4756/23 4756/24
4757/3 4767/15 4767/25 4770/11
4773/10 4773/14 4773/16 4774/24
4775/25 4780/9 4781/1 4783/1 4784/10
4784/13 4784/20 4785/6 4785/16
4785/23 4787/1 4787/25 4796/17
4796/18 4796/20 4796/21 4797/18
4797/25 4798/2 4798/9 4801/18
4825/19 4830/2 4830/7 4830/9 4830/13
4830/20 4830/23 4831/2 4831/5 4832/6
4832/24 4833/16 4834/9 4834/17
4834/25 4835/24 4838/5 4839/2
4839/13 4839/21 4840/14 4841/12

H
HORIZON... [1] 4849/24
Horizon's [4] 4679/22 4683/16 4684/15
4696/11
Houma [1] 4669/16
hour [4] 4811/21 4815/13 4821/12
4866/23
hours [11] 4812/9 4812/14 4815/4
4815/6 4815/8 4816/2 4866/22 4878/21
4880/13 4880/15 4881/6
house [1] 4686/6
Houston [16] 4670/4 4672/10 4672/21
4673/5 4673/13 4673/17 4739/12
4754/19 4770/24 4771/1 4776/20
4777/24 4780/12 4785/21 4804/22
4852/17
how [52] 4694/6 4707/16 4707/20
4711/7 4711/11 4721/21 4744/10
4750/4 4750/25 4752/7 4752/9 4755/19
4758/23 4763/13 4795/8 4803/21
4808/24 4809/23 4812/2 4817/3 4820/5
4829/20 4829/22 4844/8 4848/7
4849/23 4850/2 4851/8 4857/4 4857/21
4858/2 4858/4 4858/16 4858/19
4858/22 4858/24 4859/15 4859/21
4864/21 4865/12 4866/7 4867/11
4868/12 4873/15 4875/10 4875/24
4878/9 4878/13 4878/16 4878/16
4878/19 4880/22
however [4] 4690/2 4763/5 4781/21
4784/15
HSE [4] 4686/6 4707/16 4713/20 4715/4
HUGH [1] 4673/15
Hughes [1] 4672/19
huh [1] 4775/13
Hulme [6] 4730/4 4730/8 4734/5 4745/2
4746/19 4749/7
Hulme, [3] 4734/1 4734/25 4744/18
human [1] 4687/1
hydraulic [1] 4720/10
hydrocarbon [1] 4718/8
hydrocarbons [1] 4744/6
HYMEL [1] 4672/16
hypothetical [1] 4735/12

I
I'd [23] 4677/23 4685/11 4690/15
4690/21 4696/20 4698/7 4712/21
4714/16 4720/2 4727/12 4728/14
4730/11 4739/22 4749/10 4782/17
4790/6 4807/11 4819/15 4824/4
4835/21 4843/25 4856/22 4858/1
I'll [16] 4677/7 4678/5 4704/7 4720/17
4753/2 4772/22 4773/3 4778/13
4780/17 4785/4 4791/20 4819/1 4842/7
4843/19 4849/3 4881/13
I'm [130] 4677/6 4681/25 4689/19
4692/9 4693/10 4700/19 4708/14
4720/18 4728/23 4734/8 4737/6
4741/10 4743/10 4747/8 4752/18
4752/18 4756/21 4758/1 4759/4
4759/14 4759/22 4759/25 4760/4
4765/14 4771/1 4771/12 4773/13
4776/6 4777/9 4777/12 4777/21 4778/8
4779/8 4779/9 4780/18 4781/3 4781/3
4781/9 4781/11 4782/11 4783/7
4783/13 4783/17 4784/8 4784/12
4784/18 4785/7 4785/15 4785/17
4785/22 4789/8 4789/15 4790/21
4792/20 4793/14 4794/9 4794/9 4795/7
4796/4 4796/8 4797/2 4797/13 4798/5
4799/22 4799/23 4800/20 4800/20

4802/8 4804/15 4805/13 4807/18


4813/22 4813/22 4814/3 4814/6 4817/4
4817/6 4817/19 4817/21 4818/14
4822/15 4823/19 4828/8 4828/8
4828/14 4829/8 4831/9 4831/9 4832/8
4832/20 4833/7 4834/7 4836/1 4837/8
4837/8 4837/24 4838/9 4839/4 4839/4
4839/14 4840/25 4841/4 4841/17
4841/17 4842/1 4843/9 4846/24
4847/10 4847/19 4847/20 4848/21
4848/25 4849/22 4852/19 4852/21
4853/19 4855/12 4856/1 4856/17
4857/2 4861/7 4861/8 4863/18 4864/16
4866/2 4867/9 4870/9 4878/5 4878/25
4881/10
I've [12] 4690/24 4758/2 4763/11
4775/18 4784/3 4786/22 4792/19
4793/7 4794/14 4817/21 4857/17
4881/8
IADC [3] 4748/2 4748/17 4749/2
ID [48] 4773/18 4773/18 4773/21
4774/6 4774/19 4776/1 4779/22 4780/3
4780/11 4780/24 4781/9 4781/17
4781/22 4782/6 4782/15 4782/19
4782/22 4783/3 4783/6 4783/17
4783/18 4784/14 4784/16 4784/25
4785/8 4785/11 4785/24 4785/25
4797/14 4798/19 4799/12 4799/13
4799/15 4799/24 4800/21 4802/16
4803/14 4810/10 4811/15 4845/7
4845/8 4847/7 4848/12 4848/19
4849/15 4850/17 4851/3 4851/13
ID'ed [1] 4782/8
idea [4] 4696/22 4726/10 4734/20
4735/18
ideal [1] 4791/5
Ideally [1] 4787/21
identical [2] 4801/1 4801/17
identification [2] 4710/25 4723/2
identified [12] 4714/6 4714/9 4714/23
4720/4 4793/5 4848/4 4848/7 4849/10
4851/12 4853/3 4861/14 4872/5
identifies [2] 4716/6 4798/20
identify [8] 4693/23 4846/11 4853/20
4861/9 4863/5 4871/6 4872/18 4876/18
identifying [5] 4715/12 4716/3 4736/24
4850/17 4868/10
IDs [1] 4781/10
ignition [1] 4719/11
II [1] 4800/10
II cement [1] 4800/10
Illinois [1] 4671/24
illustrate [1] 4809/17
immediately [2] 4755/3 4844/3
impact [1] 4716/7
implemented [1] 4703/14
implementing [1] 4704/22
importance [1] 4768/12
important [8] 4727/22 4767/17 4768/3
4768/17 4768/17 4769/3 4773/1 4864/7
impression [1] 4762/3
Imprevento [1] 4669/8
inadvertently [1] 4843/12
INC [16] 4668/11 4671/19 4671/22
4672/3 4672/6 4672/7 4672/9 4672/10
4672/13 4672/13 4672/17 4672/17
4672/20 4672/21 4673/7 4673/12
incident [32] 4700/15 4706/15 4734/25
4735/4 4735/11 4739/4 4744/18 4745/2
4745/4 4745/8 4746/2 4746/19 4746/22
4749/7 4762/2 4762/6 4763/19 4763/21
4766/4 4767/3 4777/17 4777/19 4818/8
4818/11 4844/2 4848/24 4851/19

4852/1 4852/4 4856/2 4856/5 4856/11


incidents [1] 4704/20
include [1] 4710/9
included [7] 4786/14 4787/14 4788/10
4792/17 4801/15 4804/1 4804/2
including [10] 4679/12 4680/10 4691/7
4693/20 4693/21 4708/16 4719/8
4719/16 4783/25 4863/10
incompatible [1] 4790/25
increase [1] 4875/5
increased [1] 4816/3
increasing [1] 4709/19
independent [3] 4701/18 4701/19
4701/20
indicate [3] 4820/25 4821/1 4880/4
indicated [3] 4737/11 4772/25 4773/16
indicates [2] 4720/7 4878/25
indication [8] 4717/5 4717/15 4717/17
4718/1 4718/6 4723/2 4725/9 4773/9
indications [2] 4872/19 4872/22
indicator [1] 4733/14
indicators [1] 4734/11
individual [9] 4688/5 4688/14 4709/23
4710/1 4711/12 4712/18 4726/12
4809/12 4821/24
individuals [4] 4685/17 4688/12 4721/9
4837/3
industry [10] 4680/2 4685/4 4685/8
4699/24 4699/25 4706/11 4719/2
4719/22 4740/3 4742/7
inflow [1] 4739/4
influx [5] 4743/22 4743/25 4744/2
4744/3 4744/14
information [14] 4696/18 4704/19
4706/21 4718/3 4795/12 4807/23
4808/5 4809/18 4809/24 4816/23
4816/23 4831/4 4846/11 4857/13
ingredient [1] 4800/14
ingredients [5] 4758/4 4768/7 4768/9
4800/10 4801/19
inherent [1] 4713/5
initial [2] 4880/5 4880/15
initially [8] 4756/19 4757/2 4757/7
4760/14 4764/19 4796/20 4796/23
4803/3
initiate [1] 4865/4
initiated [1] 4810/14
initiating [1] 4864/10
injuries [1] 4716/7
injury [1] 4722/18
input [1] 4867/12
inputted [1] 4867/5
ins [5] 4731/15 4732/3 4732/6 4732/9
4732/19
inside [1] 4797/4
inspection [1] 4720/8
inspections [1] 4720/14
instability [7] 4872/3 4872/6 4872/7
4872/19 4872/22 4873/4 4873/6
installation [1] 4722/13
installations [2] 4708/5 4708/12
installed [1] 4718/13
instance [1] 4812/20
instances [1] 4873/8
instead [3] 4740/18 4808/4 4881/12
instructed [5] 4740/16 4756/4 4839/8
4839/11 4841/24
instructions [6] 4802/9 4802/9 4812/11
4812/16 4812/18 4838/15
instrumentation [5] 4717/5 4717/15
4717/17 4718/1 4718/5
integrity [8] 4702/1 4702/4 4703/8
4709/12 4710/10 4710/12 4713/21

I
integrity... [1] 4722/19
intended [3] 4821/7 4821/8 4875/18
intent [1] 4699/4
intention [1] 4764/19
interaction [1] 4844/2
interested [1] 4868/16
internal [6] 4807/12 4860/5 4860/8
4861/21 4864/4 4874/20
internally [1] 4860/2
International [2] 4672/22 4673/2
interrupt [3] 4706/15 4751/13 4758/1
intervene [2] 4707/5 4708/20
intervening [1] 4709/6
introduce [5] 4675/17 4676/8 4818/4
4844/1 4852/12
introduction [1] 4675/21
inventoried [4] 4805/20 4839/25 4840/1
4840/8
inventory [1] 4798/7
investigate [1] 4741/6
investigation [2] 4734/3 4740/10
investigations [1] 4734/24
investor [1] 4681/4
involved [5] 4684/19 4809/8 4829/8
4831/9 4873/17
involvement [4] 4855/23 4856/4 4856/7
4856/10
involving [1] 4682/25
Irpino [3] 4670/5 4670/6 4676/14
irrespective [2] 4724/24 4724/24
is [474]
isn't [17] 4699/24 4732/21 4751/4
4751/5 4762/25 4768/19 4772/9
4780/12 4782/2 4782/11 4782/15
4783/5 4791/12 4794/5 4795/10
4806/19 4838/9
isolated [1] 4824/20
isolation [1] 4699/9
issue [7] 4695/19 4710/15 4721/7
4721/8 4739/13 4849/19 4862/10
issued [1] 4803/10
issues [2] 4697/8 4873/6
it [466]
it's [120] 4688/16 4689/5 4697/10
4699/3 4700/21 4701/6 4701/19
4701/20 4702/16 4705/13 4705/16
4714/5 4723/12 4724/1 4725/5 4725/12
4728/17 4728/20 4732/22 4737/3
4750/10 4750/13 4752/1 4757/15
4762/2 4767/19 4768/3 4768/13
4768/15 4769/3 4770/15 4771/11
4771/13 4771/16 4775/10 4775/12
4776/6 4779/19 4781/15 4781/16
4781/16 4781/17 4781/24 4781/24
4781/25 4783/21 4784/6 4785/7
4788/19 4788/19 4789/20 4789/20
4790/1 4790/2 4790/3 4790/7 4790/7
4790/8 4791/11 4794/9 4799/20
4802/15 4803/22 4806/17 4806/21
4810/11 4813/2 4816/24 4821/11
4821/11 4822/11 4823/18 4826/18
4827/10 4831/22 4833/10 4833/11
4833/11 4833/11 4833/12 4840/20
4842/10 4842/16 4843/1 4844/22
4847/10 4847/11 4847/13 4848/8
4850/23 4852/17 4854/12 4864/7
4864/14 4865/23 4865/25 4866/2
4866/2 4866/24 4868/5 4869/8 4870/22
4870/24 4871/1 4873/16 4874/12
4875/9 4875/15 4875/16 4876/19
4876/25 4877/21 4878/15 4879/15

4734/8 4734/19 4735/3 4736/12 4737/2


4737/23 4737/25 4739/16 4739/20
4741/21 4741/22 4746/8 4754/16
4756/19 4758/8 4759/4 4759/4 4759/5
4759/14 4765/13 4766/13 4766/20
4767/1 4768/13 4769/6 4769/25 4770/4
4774/12 4777/8 4779/8 4780/16 4781/1
4782/8 4782/9 4784/20 4786/14
4787/16 4788/24 4790/14 4793/9
4794/13 4794/16 4796/20 4798/5
4798/6 4804/10 4804/13 4804/18
J
4805/11 4805/13 4805/20 4805/22
JAMES [2] 4668/19 4671/12
4808/3 4808/4 4810/6 4812/19 4813/4
January [1] 4685/4
4813/15 4813/20 4814/4 4814/7
January 2010 [1] 4685/4
4814/11 4814/15 4815/21 4816/22
Jason [2] 4749/25 4750/7
4817/4 4817/19 4819/2 4820/8 4821/22
Jefferson [2] 4668/20 4672/17
4822/15 4823/20 4824/15 4824/19
JEFFREY [2] 4669/9 4753/21
4825/5 4826/4 4826/4 4828/8 4828/14
JERRY [2] 4673/12 4687/9
4828/22 4829/18 4830/18 4831/4
Jesse [38] 4755/8 4771/22 4772/8
4838/5 4838/20 4839/4 4839/17
4772/16 4774/16 4775/11 4775/15
4840/17 4840/17 4840/18 4840/21
4777/17 4780/5 4780/22 4781/10
4840/23 4840/24 4841/2 4841/19
4781/23 4782/10 4784/19 4786/4
4842/6 4842/7 4843/1 4843/5 4846/4
4786/8 4786/13 4786/19 4786/24
4847/10 4848/11 4848/16 4849/15
4787/8 4789/10 4789/14 4791/25
4850/4 4851/22 4853/8 4853/19
4793/1 4793/22 4795/19 4795/25
4853/19 4855/8 4856/13 4856/17
4799/1 4799/10 4802/3 4802/14 4812/5 4858/6 4858/22 4861/9 4861/18 4863/7
4813/3 4864/20 4864/20 4864/22
4866/10 4866/22 4867/7 4867/20
4876/5 4876/7
4869/1 4870/15 4870/22 4871/1 4871/4
Jesse's [2] 4780/14 4813/5
4872/25 4873/7 4873/16 4873/23
JESSICA [3] 4670/19 4670/20 4806/25 4874/12 4875/7 4875/7 4875/12
jewelry [1] 4726/25
4878/13 4880/16 4880/16 4880/17
JIMMY [4] 4670/3 4686/3 4688/21
justice [6] 4670/8 4670/12 4670/18
4739/1
4671/2 4689/23 4846/5
job [28] 4688/9 4688/9 4688/17 4705/7
K
4705/8 4705/10 4705/16 4706/2
Kanner [3] 4671/15 4671/15 4843/12
4706/21 4706/22 4723/19 4735/18
KARIS [1] 4671/22
4788/11 4788/14 4793/18 4794/10
Kaskida [1] 4850/3
4807/6 4821/21 4821/22 4852/23
Katz [1] 4668/22
4853/7 4864/13 4865/6 4869/16
Keelan [7] 4686/20 4686/24 4687/1
4876/22 4877/10 4878/12 4878/13
4687/1 4687/19 4687/25 4738/20
jobs [3] 4689/14 4690/9 4794/12
keep [4] 4694/13 4696/18 4863/9
Jodi [5] 4673/18 4673/20 4881/21
4881/9
4881/24 4881/25
JOHN [7] 4669/22 4672/20 4673/16
keeping [2] 4831/9 4839/6
4676/7 4697/20 4714/20 4727/18
Keeton [3] 4714/20 4715/2 4727/18
Johnson [3] 4687/14 4687/15 4688/6
KELLEY [1] 4671/4
JONES [1] 4673/3
Kenny [1] 4869/20
JR [7] 4669/12 4673/8 4673/8 4730/4
Kent [2] 4687/14 4687/15
4734/1 4734/25 4744/18
Keplinger [1] 4689/10
judge [15] 4668/15 4676/14 4725/2
kept [2] 4840/15 4840/17
4752/2 4752/10 4753/2 4778/8 4778/19 KERRY [1] 4672/6
4784/8 4785/5 4849/9 4864/10 4865/8 key [2] 4689/5 4705/10
4865/19 4870/14
kick [13] 4706/22 4725/14 4729/23
Judge Barbier [1] 4864/10
4730/14 4730/17 4730/22 4730/25
July [7] 4788/8 4801/23 4802/6 4803/8 4731/12 4732/18 4733/15 4734/12
4822/25 4823/6 4823/16
4734/14 4734/20
July 14th [1] 4822/25
kicks [7] 4684/8 4723/6 4723/7 4729/7
July 14th e-mail [1] 4823/6
4729/12 4729/20 4732/2
July 20 [1] 4801/23
kill [5] 4740/18 4740/23 4741/1 4741/16
July 20th [2] 4802/6 4803/8
4741/23
Jurgen [1] 4727/25
Kinchen [3] 4672/19 4672/20 4676/7
jurisdiction [1] 4692/19
kind [10] 4699/6 4702/23 4763/19
just [178] 4675/13 4678/5 4678/17
4763/20 4765/7 4810/11 4829/25
4681/24 4685/15 4685/16 4687/17
4851/17 4858/22 4866/9
4688/3 4689/13 4689/17 4690/16
Kirkland [1] 4671/21
4690/21 4690/22 4693/22 4694/11
knew [19] 4755/24 4757/13 4767/15
4694/11 4697/19 4700/22 4700/22
4786/3 4786/8 4786/18 4787/3 4787/11
4701/23 4702/9 4703/16 4703/16
4787/13 4787/13 4788/16 4796/10
4704/13 4705/8 4706/5 4706/14
4804/21 4830/2 4830/19 4831/11
4709/11 4711/3 4711/5 4713/16
4840/15 4841/15 4859/15
4715/21 4717/9 4718/21 4722/2
know [138] 4681/25 4683/6 4684/6
4727/12 4728/4 4729/17 4733/2 4734/2 4684/8 4684/9 4684/10 4684/12

4880/11 4880/12 4880/16 4880/21


4880/23 4881/4
items [2] 4747/3 4847/22
its [22] 4679/3 4679/4 4692/15 4692/25
4696/11 4697/12 4697/12 4698/11
4701/6 4701/7 4724/20 4724/21
4724/21 4731/10 4731/11 4739/24
4741/21 4742/5 4790/10 4855/15
4867/22 4874/12
itself [3] 4724/11 4754/22 4800/19

K
know... [131] 4684/13 4686/17 4687/6
4687/14 4701/9 4701/16 4702/4
4710/15 4711/2 4723/10 4723/12
4727/15 4727/18 4727/24 4734/6
4734/24 4734/25 4736/10 4736/19
4739/11 4750/4 4751/24 4751/25
4758/23 4760/15 4762/10 4762/10
4762/11 4762/14 4762/20 4763/8
4763/8 4763/11 4768/1 4768/11
4771/19 4777/18 4777/23 4779/3
4779/3 4779/7 4779/8 4781/5 4784/18
4786/18 4787/3 4787/5 4787/6 4787/11
4787/16 4788/18 4789/11 4789/15
4789/15 4792/16 4792/20 4793/18
4794/10 4794/11 4794/13 4794/15
4794/22 4794/24 4795/2 4797/20
4798/5 4798/20 4802/22 4803/19
4804/24 4806/12 4806/14 4812/12
4812/17 4812/17 4813/2 4813/6 4814/8
4815/21 4817/23 4817/24 4821/3
4829/16 4829/18 4829/22 4829/23
4830/3 4830/6 4830/8 4830/12 4830/14
4831/20 4833/19 4835/18 4835/23
4838/22 4840/15 4840/24 4841/17
4842/6 4844/12 4847/14 4847/15
4849/23 4850/2 4850/8 4851/9 4854/5
4856/14 4856/22 4858/10 4858/24
4859/7 4860/10 4860/11 4865/4
4866/10 4867/11 4869/7 4869/25
4873/15 4873/18 4875/13 4875/21
4875/23 4875/25 4878/12 4878/19
4879/13 4880/10 4881/9
knowing [6] 4786/22 4802/24 4803/7
4839/1 4839/6 4839/7
knowledge [11] 4696/14 4696/15
4736/16 4775/17 4789/15 4790/6
4820/4 4825/9 4833/16 4849/8 4857/19
known [1] 4820/5
knows [1] 4792/13
Kodiak [56] 4786/4 4786/10 4786/11
4786/12 4786/21 4786/25 4787/1
4787/4 4787/6 4787/9 4787/14 4797/13
4797/19 4798/15 4800/4 4800/10
4800/13 4800/17 4800/25 4801/16
4801/23 4801/25 4802/20 4802/23
4802/25 4804/2 4804/3 4804/8 4804/10
4804/13 4804/17 4805/3 4824/14
4824/18 4824/24 4825/7 4825/11
4826/7 4826/9 4826/21 4827/7 4827/9
4827/10 4827/24 4829/13 4830/2
4830/6 4830/12 4830/19 4831/2
4832/11 4835/10 4835/19 4835/25
4836/11 4850/3
KRAUS [1] 4671/16
Kuchta [1] 4689/9
Kullman [1] 4669/5

L
L-E-O [1] 4753/18
lab [260]
label [2] 4850/5 4850/7
labeled [7] 4802/23 4803/20 4824/24
4825/1 4827/9 4830/20 4830/22
laboratory [5] 4788/3 4788/5 4807/13
4821/23 4823/11
labs [11] 4754/14 4783/10 4809/7
4844/7 4852/22 4855/4 4855/10
4855/15 4859/14 4860/12 4877/4
lack [3] 4740/25 4741/15 4741/23
laed.uscourts.gov [1] 4673/20
Lafayette [4] 4668/21 4672/18 4756/10

4756/11
Lafleur [1] 4672/16
laid [2] 4807/15 4807/16
Lamar [1] 4673/12
LANGAN [1] 4671/22
language [7] 4746/14 4747/2 4747/3
4747/11 4747/13 4749/6 4749/12
large [1] 4731/10
largest [4] 4678/20 4731/8 4731/10
4732/17
Larry [2] 4687/20 4688/4
Lasalle [1] 4671/23
last [23] 4705/2 4732/15 4740/7
4755/21 4763/3 4763/11 4763/15
4772/3 4772/17 4772/20 4772/23
4773/1 4782/5 4789/8 4802/19 4804/11
4806/2 4807/22 4828/3 4829/16
4842/19 4853/5 4881/13
Lastly [1] 4739/14
late [3] 4678/7 4870/6 4870/11
later [6] 4745/22 4794/16 4798/21
4819/7 4856/14 4869/25
latest [1] 4680/6
law [4] 4669/15 4669/18 4670/5 4694/11
LAWRENCE [1] 4670/21
lawyer [1] 4772/24
lawyers [1] 4764/15
lay [1] 4817/14
lead [3] 4679/16 4714/24 4847/1
leader [6] 4680/2 4705/24 4821/18
4852/21 4854/1 4855/7
leaders [3] 4680/23 4740/16 4858/9
leading [4] 4678/21 4846/25 4847/15
4849/22
leads [2] 4842/18 4851/8
leased [1] 4698/11
LEASING [1] 4668/8
least [6] 4756/1 4762/12 4764/8 4785/4
4804/2 4881/6
leave [1] 4784/1
led [2] 4720/15 4732/5
left [11] 4686/14 4687/13 4703/16
4763/24 4787/1 4787/7 4790/17 4810/2
4825/4 4853/22 4854/20
legal [3] 4856/13 4856/14 4870/1
Leger [2] 4669/12 4669/12
legitimate [1] 4818/3
length [1] 4686/11
Leo [1] 4753/17
less [2] 4701/15 4877/1
let [39] 4692/10 4699/3 4703/22 4704/5
4704/11 4707/13 4707/24 4709/9
4712/23 4713/16 4714/15 4721/12
4727/9 4738/21 4741/20 4749/9
4758/11 4767/23 4768/16 4772/14
4777/21 4782/14 4782/24 4783/12
4786/23 4790/15 4793/11 4793/12
4794/23 4796/9 4799/22 4802/15
4830/5 4830/18 4830/24 4836/16
4844/6 4847/14 4855/8
let's [53] 4675/7 4701/23 4705/4 4715/9
4716/1 4731/18 4732/25 4744/25
4745/10 4745/20 4746/4 4746/10
4746/24 4747/9 4748/13 4748/23
4749/18 4753/6 4765/15 4769/19
4772/13 4773/5 4773/5 4775/23
4775/24 4776/8 4776/16 4777/2 4778/6
4778/15 4779/10 4779/24 4779/25
4784/21 4785/18 4786/3 4796/24
4797/1 4797/9 4797/21 4798/11
4798/24 4799/17 4800/4 4800/19
4836/10 4860/3 4866/7 4868/19 4870/2
4870/7 4873/23 4874/7

letter [5] 4677/25 4678/6 4680/1


4828/10 4833/14
letting [1] 4835/4
level [18] 4699/10 4702/23 4702/25
4702/25 4702/25 4703/2 4703/4 4703/8
4703/10 4703/19 4707/25 4711/13
4723/24 4724/15 4735/14 4856/23
4856/25 4857/15
levels [4] 4702/9 4707/21 4709/17
4853/24
Lewis [5] 4669/5 4671/18 4673/7
4673/11 4673/14
LI [1] 4672/13
life [5] 4683/18 4722/18 4806/9 4806/10
4806/15
lighter [2] 4874/10 4874/13
like [68] 4675/20 4676/8 4677/23
4681/19 4684/22 4685/11 4689/21
4690/15 4690/21 4696/20 4698/7
4699/3 4706/20 4712/21 4714/17
4720/2 4727/13 4728/14 4730/11
4739/22 4749/10 4751/15 4751/21
4751/23 4765/1 4766/20 4769/17
4772/7 4780/16 4782/17 4783/7
4787/24 4790/6 4794/15 4797/6
4798/22 4806/14 4806/20 4807/11
4807/20 4808/4 4809/19 4810/11
4813/14 4819/10 4819/15 4821/15
4821/19 4823/13 4824/4 4833/8
4833/10 4835/4 4835/21 4841/25
4843/25 4851/7 4851/10 4855/6
4856/22 4857/22 4858/1 4860/22
4864/9 4866/5 4867/23 4869/8 4869/13
Limited [2] 4678/18 4678/20
line [30] 4686/19 4687/25 4688/3
4688/5 4698/8 4698/9 4698/17 4707/16
4710/6 4710/7 4710/9 4712/1 4731/25
4740/8 4740/16 4740/18 4740/23
4741/1 4741/16 4741/23 4759/2
4769/20 4784/22 4830/16 4834/19
4834/20 4847/24 4873/18 4880/2
4880/8
liner [1] 4727/1
lines [9] 4698/2 4698/3 4698/4 4744/7
4758/12 4760/6 4765/15 4769/20
4851/1
lines 19 [1] 4769/20
link [1] 4807/12
liquid [2] 4795/9 4875/14
Liskow [1] 4671/18
list [17] 4675/19 4675/23 4676/2
4676/10 4676/15 4689/18 4715/11
4715/13 4715/18 4787/16 4805/19
4805/22 4817/9 4829/6 4839/23
4839/24 4840/10
listed [4] 4716/14 4718/21 4719/5
4731/25
Listen [1] 4766/7
listening [1] 4752/19
lists [2] 4716/12 4799/5
Literally [1] 4717/11
litigation [6] 4671/3 4712/7 4734/7
4770/2 4820/21 4823/9
little [23] 4689/12 4694/17 4696/4
4737/8 4754/7 4770/15 4781/3 4820/23
4826/4 4842/23 4842/24 4844/1
4852/12 4855/3 4856/23 4858/1 4859/8
4860/4 4864/10 4868/19 4873/7
4873/10 4875/13
live [2] 4852/14 4852/15
LLC [13] 4668/19 4668/22 4669/2
4669/15 4671/15 4672/5 4672/6 4672/9
4672/12 4672/16 4672/20 4672/22

4671/20 4672/7 4672/18 4672/24


4673/16 4673/19 4843/11 4854/12
LLC... [1] 4673/14
4854/18 4881/22
Lloyd's [1] 4749/20
low [2] 4714/11 4715/5
LLP [7] 4669/21 4671/21 4672/2 4672/8 LUIS [1] 4672/13
4672/12 4672/19 4673/2
LUTHER [1] 4671/8
located [2] 4806/2 4854/11
M
location [21] 4703/5 4724/25 4756/25
4768/10 4802/23 4802/25 4803/21
M-I [2] 4673/14 4743/4
4803/22 4826/6 4826/18 4826/21
M. [1] 4730/4
4827/4 4827/16 4831/5 4842/2 4846/12 M. G [1] 4730/4
4846/14 4846/15 4846/18 4847/23
M.G. [5] 4734/1 4734/5 4734/25
4857/17
4744/18 4745/2
M.G. Hulme [2] 4734/5 4745/2
location-specific [1] 4703/5
locked [3] 4756/18 4802/18 4828/16
M.G. Hulme, Jr [3] 4734/1 4734/25
locker [15] 4756/18 4781/6 4781/7
4744/18
4781/8 4797/5 4798/6 4802/18 4803/9 ma'am [12] 4808/17 4809/4 4811/19
4812/1 4814/24 4815/3 4815/5 4815/15
4804/20 4805/23 4806/20 4838/7
4815/19 4816/19 4819/23 4822/20
4838/8 4838/14 4838/24
lockers [1] 4711/9
MAC [4] 4795/2 4795/5 4795/8 4796/5
Macondo [86] 4703/24 4704/18 4735/25
logged [4] 4833/23 4836/6 4842/8
4742/15 4756/13 4757/9 4757/14
4848/17
long [11] 4679/9 4727/1 4728/1 4728/6 4759/21 4759/23 4759/25 4760/2
4752/7 4752/9 4763/13 4795/8 4878/16 4760/3 4760/5 4760/18 4760/21
4878/19 4881/16
4772/18 4783/23 4783/24 4784/1
4787/2 4787/6 4787/10 4796/15
look [44] 4688/11 4693/14 4699/17
4736/12 4755/8 4755/19 4760/11
4796/18 4799/2 4800/9 4800/25 4802/5
4764/2 4764/4 4765/15 4769/19
4802/10 4802/11 4802/15 4802/21
4802/24 4803/2 4803/6 4803/12
4772/11 4772/13 4772/14 4773/5
4803/17 4804/5 4804/18 4804/19
4773/6 4773/6 4775/4 4775/8 4775/19
4775/21 4775/23 4775/24 4776/2
4805/21 4805/22 4807/6 4809/21
4776/8 4776/16 4777/2 4777/21
4818/9 4818/12 4818/23 4819/19
4779/10 4796/24 4797/1 4797/9
4822/5 4824/13 4824/16 4825/1
4798/24 4800/4 4800/17 4800/19
4826/11 4826/13 4830/3 4830/13
4803/13 4803/20 4812/15 4814/5
4831/13 4832/14 4833/17 4833/21
4818/2 4818/25 4842/3 4873/18
4834/9 4834/17 4834/25 4835/20
looked [19] 4737/17 4746/8 4761/1
4835/24 4836/12 4836/13 4838/2
4775/18 4792/19 4793/7 4793/14
4838/4 4838/7 4839/8 4839/18 4840/16
4796/5 4798/21 4814/5 4814/7 4814/11 4842/6 4846/7 4846/22 4849/11 4850/3
4814/15 4825/5 4828/4 4828/22
4855/24 4856/5 4864/18 4868/8
4841/20 4841/23 4842/1
4869/24 4870/3 4876/12 4877/12
looking [30] 4755/11 4755/13 4756/23 Macondo-related [1] 4818/23
4764/3 4768/11 4772/6 4774/22
made [4] 4696/10 4772/2 4805/22
4777/24 4780/21 4785/16 4802/24
4814/2
4803/11 4803/15 4804/18 4812/13
Magazine [1] 4670/6
4813/22 4822/15 4823/13 4823/19
MAHRA [3] 4710/20 4711/3 4711/6
4829/11 4830/8 4833/5 4835/22
MAHRAs [1] 4709/11
4837/19 4837/20 4837/21 4837/22
Mahtook [1] 4672/16
4837/23 4838/20 4881/2
mail [8] 4738/19 4738/21 4738/25
looks [7] 4751/23 4761/21 4810/11
4822/24 4822/25 4823/6 4823/15
4813/14 4833/8 4851/7 4851/10
4867/17
Los [1] 4672/14
Main [1] 4669/22
loss [13] 4716/8 4722/18 4722/19
maintain [2] 4691/25 4695/22
4723/2 4724/5 4724/5 4724/8 4724/10 maintained [1] 4703/12
4732/2 4794/17 4863/18 4863/19
maintaining [1] 4723/1
4866/15
maintenance [11] 4686/16 4688/23
loss/gain [1] 4732/2
4694/18 4694/21 4694/24 4695/19
4700/16 4716/23 4717/1 4720/8
losses [3] 4684/4 4684/4 4684/8
4720/14
lot [37] 4708/14 4736/22 4750/21
major [16] 4710/20 4712/21 4713/18
4750/22 4773/9 4773/10 4773/19
4713/19 4714/5 4714/6 4714/16
4773/22 4775/25 4779/19 4780/9
4714/22 4714/24 4715/12 4716/6
4780/18 4780/18 4780/19 4780/23
4716/8 4731/5 4853/20 4860/18
4781/15 4781/16 4782/9 4782/21
4860/19
4782/25 4783/18 4784/9 4784/23
majority [2] 4689/23 4690/4
4785/22 4807/23 4844/9 4844/9
make [33] 4681/25 4689/13 4701/15
4844/18 4844/21 4844/24 4845/8
4707/1 4707/2 4707/3 4712/14 4712/19
4847/14 4848/4 4849/10 4849/13
4714/4 4737/3 4752/17 4777/6 4780/6
4850/18 4870/13
4784/2 4786/16 4803/9 4817/17
Lot No. 6264 [1] 4780/23
LOUISIANA [25] 4668/2 4668/6 4668/21 4818/23 4821/16 4821/17 4821/20
4821/24 4826/4 4841/19 4844/11
4668/24 4669/7 4669/13 4669/16
4844/18 4848/11 4851/24 4860/3
4669/19 4669/23 4670/7 4671/11
4867/7 4870/20 4875/3 4880/17
4671/12 4671/13 4671/15 4671/17

makes [4] 4772/12 4772/12 4796/2


4865/1
makeup [2] 4801/17 4802/5
making [3] 4681/23 4775/4 4873/18
malfunction [1] 4821/2
MALINDA [1] 4670/21
man [1] 4728/3
managed [2] 4713/18 4804/12
management [31] 4678/21 4688/5
4696/20 4696/23 4698/25 4699/2
4699/17 4700/1 4700/2 4700/3 4700/7
4700/24 4701/8 4701/10 4701/11
4701/18 4701/22 4702/8 4702/10
4702/20 4702/22 4703/13 4704/23
4705/11 4705/21 4707/16 4707/21
4708/22 4709/17 4809/1 4864/24
manager [36] 4686/20 4687/15 4687/16
4688/6 4688/8 4688/12 4688/14
4722/14 4725/22 4754/2 4754/10
4754/12 4755/19 4763/13 4791/10
4795/24 4808/21 4809/3 4821/19
4844/7 4844/8 4854/7 4854/8 4854/13
4854/16 4854/18 4854/23 4855/15
4855/19 4858/3 4858/11 4859/14
4859/19 4865/10 4866/6 4869/18
manager/performance [1] 4688/8
manual [26] 4692/23 4692/25 4693/2
4693/7 4693/8 4724/11 4724/20
4744/22 4745/13 4745/23 4746/8
4746/16 4747/4 4747/13 4748/6 4748/9
4748/20 4749/5 4790/5 4790/16
4790/18 4790/19 4790/20 4790/24
4791/2 4823/8
manuals [2] 4693/2 4703/9
manufacturers [1] 4844/11
many [5] 4682/25 4770/10 4849/23
4858/16 4859/21
MAR [2] 4699/8 4699/10
March [22] 4668/7 4675/3 4677/25
4678/8 4679/18 4680/1 4745/18
4745/18 4746/1 4746/16 4747/4
4747/14 4748/9 4748/21 4798/25
4799/4 4799/10 4800/20 4802/3
4802/14 4828/11 4853/18
March 18th [1] 4853/18
March 2010 [1] 4678/8
March 24th [2] 4677/25 4680/1
March 31st [5] 4745/18 4746/1 4746/16
4747/4 4747/14
March 7th [5] 4798/25 4799/4 4799/10
4800/20 4802/3
March 7th on [1] 4802/14
margins [1] 4847/20
Marianas [2] 4834/9 4834/25
maritime [5] 4689/8 4695/9 4695/10
4695/12 4721/8
marked [4] 4756/24 4797/18 4847/22
4847/23
market [2] 4682/3 4682/6
marking [1] 4774/2
markings [1] 4831/12
master [5] 4720/21 4720/24 4720/25
4721/8 4721/8
match [1] 4778/13
mate [1] 4689/9
material [9] 4724/8 4756/5 4756/19
4773/6 4805/11 4825/18 4846/2 4846/8
4848/1
materials [16] 4774/23 4789/3 4789/18
4797/24 4797/24 4798/10 4798/13
4799/6 4799/9 4799/14 4800/21
4801/21 4804/1 4805/7 4811/3 4852/8
Matt [1] 4677/4

M
matter [4] 4706/1 4752/18 4812/5
4881/23
MATTHEW [1] 4671/23
max [1] 4862/16
maximum [1] 4862/12
may [46] 4682/13 4689/12 4691/8
4692/24 4697/13 4699/9 4700/10
4725/9 4764/16 4764/22 4765/2 4771/3
4775/6 4775/9 4776/9 4776/12 4776/22
4776/23 4777/3 4777/19 4778/2 4778/6
4778/11 4778/16 4778/21 4779/6
4779/11 4779/14 4779/14 4780/1
4780/11 4781/20 4782/16 4785/12
4785/20 4803/15 4804/24 4804/24
4812/18 4814/7 4843/4 4843/21
4845/23 4859/24 4860/20 4866/24
May 11th [1] 4700/10
May 18th [1] 4682/13
May 2010 [1] 4771/3
May 20th [7] 4775/6 4775/9 4777/19
4778/2 4778/16 4778/21 4779/6
May 20th date [1] 4778/11
May 28 [1] 4778/6
May 28th [11] 4776/12 4776/22 4777/3
4779/14 4779/14 4780/1 4780/11
4781/20 4782/16 4785/12 4804/24
May 29th [2] 4776/23 4785/20
maybe [16] 4706/9 4711/17 4711/18
4728/17 4779/1 4792/6 4792/22
4803/12 4812/17 4821/2 4823/2 4829/4
4829/17 4840/21 4856/9 4877/22
MAZE [3] 4671/8 4824/3 4846/4
MC252 [3] 4737/19 4826/11 4831/13
MC727 [9] 4826/6 4826/9 4826/21
4827/4 4827/5 4827/16 4827/24
4828/23 4832/9
McCLELLAN [2] 4670/19 4806/25
McDonald [1] 4861/25
McKinney [1] 4673/5
McMahan [6] 4686/8 4686/11 4686/19
4687/4 4687/20 4688/4
MD [1] 4668/4
me [95] 4681/22 4681/23 4692/10
4699/3 4703/22 4703/22 4704/5
4704/11 4704/14 4707/13 4707/24
4709/9 4712/23 4713/16 4714/15
4721/12 4727/9 4727/25 4733/19
4733/25 4736/12 4738/21 4741/20
4749/9 4752/17 4756/19 4758/9
4758/11 4758/22 4762/1 4764/1
4764/23 4766/6 4766/9 4766/13
4767/23 4768/7 4768/16 4770/5
4772/14 4777/22 4781/17 4781/20
4782/14 4782/24 4783/21 4784/12
4786/17 4786/23 4790/15 4791/10
4792/24 4794/23 4796/9 4798/3 4798/8
4798/17 4799/15 4799/22 4801/20
4802/15 4802/16 4803/4 4804/17
4805/3 4805/18 4806/7 4814/13 4824/8
4830/5 4830/18 4830/24 4830/24
4831/11 4832/2 4834/2 4836/16 4838/6
4838/7 4839/17 4839/18 4840/16
4842/18 4844/4 4844/6 4845/6 4847/21
4850/23 4854/4 4854/7 4855/8 4855/18
4869/22 4876/5 4881/9
mean [26] 4711/11 4741/14 4758/1
4759/2 4768/11 4768/13 4770/2
4788/19 4789/7 4789/20 4791/18
4795/21 4813/2 4817/5 4819/5 4821/6
4823/18 4831/11 4833/18 4833/19
4837/3 4842/16 4843/4 4846/15

4849/16 4869/8
meaning [7] 4723/10 4783/9 4821/2
4853/24 4877/10 4878/15 4880/9
means [8] 4692/2 4744/12 4744/13
4770/7 4820/22 4833/20 4842/24
4846/16
meant [3] 4766/17 4804/17 4849/13
measure [1] 4795/2
measures [2] 4692/16 4700/14
mechanical [1] 4673/23
mechanisms [1] 4737/10
medical [2] 4719/8 4719/16
medivac [4] 4719/9 4719/16 4719/17
4719/19
meet [3] 4815/7 4815/12 4815/18
meeting [3] 4707/4 4735/19 4735/21
meetings [4] 4735/18 4736/4 4873/17
4873/17
members [4] 4695/6 4695/8 4747/21
4837/3
memorandum [2] 4721/13 4722/9
memorized [1] 4789/8
memory [5] 4765/24 4825/3 4825/6
4849/12 4859/8
men [5] 4750/25 4767/16 4767/25
4769/3 4769/12
mentioned [3] 4686/20 4731/15 4830/19
mentor [1] 4858/25
mentors [1] 4858/21
mere [1] 4875/17
merger [2] 4721/18 4721/20
message [3] 4867/8 4867/14 4867/17
met [3] 4685/4 4685/7 4816/3
method [1] 4807/12
MEXICO [10] 4668/5 4680/9 4693/20
4693/21 4698/12 4742/15 4808/22
4821/8 4824/22 4854/10
MG [2] 4746/19 4749/7
MG Hulme [1] 4749/7
MGH [1] 4734/9
MHRA [4] 4713/19 4713/23 4714/1
4714/6
MICHAEL [2] 4670/9 4672/12
MICHELLE [1] 4670/20
microphone [1] 4754/7
might [14] 4689/14 4690/2 4690/17
4702/1 4709/13 4711/8 4711/12
4714/24 4722/3 4723/6 4740/15
4790/11 4840/19 4861/18
migrate [2] 4743/25 4744/3
migrates [1] 4744/4
MIKE [1] 4672/3
miles [4] 4747/24 4852/17 4877/13
4877/21
MILLER [2] 4672/6 4869/20
mimic [1] 4878/17
mind [7] 4743/15 4743/18 4744/19
4744/23 4777/5 4818/22 4853/6
minute [8] 4705/5 4753/6 4754/6 4754/6
4754/7 4778/7 4793/11 4873/24
minutes [10] 4705/2 4724/15 4739/3
4752/10 4752/13 4752/21 4815/4
4815/7 4877/23 4881/9
miscibility [3] 4763/1 4763/6 4822/14
misread [2] 4741/11 4741/14
miss [1] 4777/6
missing [4] 4734/8 4779/22 4782/3
4802/7
Mississippi [5] 4799/1 4803/2 4826/12
4831/14 4841/20
misstates [3] 4792/2 4793/4 4825/10
misunderstanding [2] 4801/12 4801/13
misunderstood [2] 4802/8 4803/3

mitigating [1] 4714/8


mitigations [4] 4719/5 4719/12 4719/19
4719/22
mix [3] 4758/23 4759/9 4759/9
MMS [2] 4695/25 4696/7
mobile [2] 4669/4 4678/25
modeling [1] 4857/21
models [1] 4679/17
modern [1] 4679/4
modification [1] 4700/14
modifications [2] 4696/10 4696/17
MODU [3] 4685/5 4698/10 4715/18
monitor [6] 4724/3 4725/5 4739/25
4746/14 4747/2 4747/11
monitoring [7] 4725/3 4726/10 4726/17
4726/18 4726/24 4740/18 4740/23
Montgomery [1] 4671/10
month [3] 4678/1 4678/10 4746/22
Moore [1] 4686/4
more [23] 4690/6 4692/10 4695/24
4696/4 4717/9 4727/22 4732/8 4737/1
4737/9 4751/5 4752/12 4783/18
4783/22 4786/13 4795/21 4829/24
4834/13 4838/25 4851/18 4868/19
4875/12 4875/14 4875/15
Morgan [11] 4673/14 4761/19 4761/21
4761/24 4762/3 4762/9 4762/25 4763/9
4763/18 4785/6 4851/10
Morgan's [1] 4763/4
morning [4] 4685/18 4743/13 4744/17
4881/16
most [5] 4677/17 4679/3 4681/14
4681/21 4866/20
move [13] 4675/20 4676/2 4676/8
4719/7 4778/6 4802/17 4804/13
4817/10 4817/18 4835/2 4836/10
4851/23 4855/8
moved [12] 4787/2 4801/24 4801/25
4803/1 4805/14 4805/15 4829/1
4829/18 4832/13 4833/16 4833/19
4833/22
moving [1] 4874/12
Mr [8] 4677/4 4689/3 4733/2 4805/6
4806/25 4819/5 4824/5 4872/3
Mr. [171] 4675/18 4675/24 4676/3
4676/16 4676/23 4677/6 4682/12
4682/23 4685/14 4685/21 4686/8
4686/11 4686/19 4687/4 4687/7
4687/14 4687/14 4687/15 4687/15
4688/6 4688/23 4689/2 4689/3 4689/3
4690/12 4690/24 4691/20 4692/12
4697/20 4697/23 4698/16 4699/16
4700/12 4706/25 4707/14 4711/7
4712/25 4715/2 4716/2 4719/25
4720/22 4722/3 4724/6 4727/11
4727/21 4729/25 4730/24 4734/3
4734/3 4734/4 4734/6 4735/13 4737/25
4738/12 4738/22 4739/1 4741/21
4741/22 4742/25 4743/3 4743/9
4743/14 4744/18 4747/23 4748/11
4749/13 4750/15 4751/8 4751/10
4751/12 4751/13 4751/14 4751/16
4751/17 4751/21 4752/4 4752/5
4752/12 4752/12 4752/14 4753/11
4753/23 4754/2 4755/21 4755/24
4756/17 4757/7 4757/18 4758/12
4759/19 4759/23 4760/10 4760/14
4760/25 4761/19 4761/21 4761/24
4762/3 4762/9 4762/23 4763/4 4764/12
4765/6 4766/3 4766/20 4767/7 4769/15
4770/16 4771/4 4775/3 4775/3 4777/21
4783/12 4784/11 4785/5 4785/6 4785/8
4786/1 4791/14 4793/11 4796/6

4751/21 4752/5 4753/23 4754/2


4758/12 4777/21 4808/8 4808/15
Mr.... [50] 4807/10 4808/3 4808/8
4810/2 4810/8 4814/22 4817/14 4822/3
4808/15 4810/2 4810/8 4810/14
4822/24 4824/12 4825/25 4829/1
4810/24 4811/8 4811/20 4812/2
4829/3 4830/1 4831/19 4833/5 4834/5
4814/22 4815/7 4817/14 4819/6 4822/3 4843/19 4845/20 4851/17 4853/10
4822/24 4823/1 4824/12 4825/16
4871/14 4873/20 4875/17 4878/22
4825/25 4828/17 4829/1 4829/3 4830/1 4879/25
4830/15 4831/19 4832/1 4833/5
Mr. Quirk's [2] 4830/15 4833/25
4833/25 4834/5 4842/20 4842/21
Mr. Regan [3] 4676/23 4690/12 4750/15
4843/12 4843/19 4845/7 4845/20
Mr. Richard [1] 4823/1
4846/4 4848/4 4848/22 4850/14
Mr. Turton [1] 4775/3
4851/17 4852/4 4853/10 4871/14
Mr. Webster's [3] 4675/18 4675/24
4873/20 4875/17 4878/22 4879/25
4676/3
4881/12
Mr. Woelfel [1] 4727/21
Mr. Adamson [1] 4739/1
much [9] 4750/4 4752/12 4758/16
Mr. Anderson [1] 4689/3
4769/12 4788/25 4823/20 4847/15
Mr. Angelle [1] 4756/17
4857/19 4869/25
Mr. Badalamenti [1] 4775/3
mud [3] 4683/2 4822/14 4822/14
Mr. Barnhill [6] 4751/10 4751/12
multiple [4] 4716/7 4740/9 4791/19
4751/17 4752/12 4752/14 4881/12
4794/24
Mr. Barnhill's [1] 4676/16
Munger [1] 4672/12
Mr. Baxter [1] 4699/16
Murkowski [1] 4700/13
Mr. Baxter's [2] 4697/23 4698/16
must [2] 4678/1 4713/22
Mr. Bertone [1] 4688/23
muster [1] 4721/6
Mr. Braniff [1] 4687/7
musters [1] 4721/5
Mr. Breit [13] 4752/4 4753/11 4783/12 mutual [2] 4697/8 4699/19
4793/11 4808/3 4825/16 4828/17
my [41] 4677/4 4677/7 4691/23 4696/4
4832/1 4842/20 4845/7 4848/4 4848/22 4727/13 4753/17 4757/1 4762/3
4850/14
4765/13 4766/7 4767/4 4767/13
Mr. Brian [4] 4706/25 4711/7 4741/21
4767/23 4768/6 4770/9 4777/22 4781/4
4741/22
4790/6 4794/10 4794/18 4801/5
Mr. Brock [1] 4752/12
4802/15 4803/20 4803/24 4805/11
Mr. Broussard [1] 4785/5
4814/4 4825/3 4825/5 4828/3 4835/21
Mr. Cunningham [6] 4716/2 4719/25
4839/11 4841/19 4842/18 4843/11
4729/25 4743/14 4744/18 4749/13
4849/12 4853/4 4857/17 4869/9
Mr. Cunningham's [1] 4707/14
4872/17 4875/20 4881/22
Mr. Ezell [2] 4689/3 4748/11
myself [4] 4743/13 4744/17 4751/4
Mr. Faul [17] 4755/24 4757/7 4757/18
4751/5
4759/19 4759/23 4760/10 4760/14
N
4760/25 4762/23 4764/12 4765/6
4766/3 4767/7 4769/15 4770/16
name [6] 4677/4 4686/21 4722/3 4722/5
4842/21 4852/4
4753/15 4753/17
Mr. Faul's [1] 4771/4
names [1] 4837/6
Mr. Gagliano [13] 4755/21 4785/8
narrow [2] 4689/17 4690/2
4786/1 4791/14 4796/6 4807/10
narrows [1] 4780/24
4810/14 4810/24 4811/8 4811/20
NATHANIEL [1] 4670/16
4812/2 4815/7 4819/6
native [1] 4845/13
Mr. Gagliano's [1] 4766/20
natural [2] 4670/13 4742/14
Mr. Godwin [1] 4784/11
Nautilus [1] 4724/21
Mr. Hand [3] 4734/3 4734/3 4734/4
necessarily [2] 4785/16 4845/14
Mr. Harrell [1] 4689/2
necessary [9] 4691/8 4692/16 4707/5
Mr. John [1] 4697/20
4708/20 4709/7 4714/8 4722/17
Mr. Johnson [3] 4687/14 4687/15
4746/15 4747/12
4688/6
need [11] 4693/15 4693/24 4694/3
Mr. Kanner [1] 4843/12
4700/4 4723/21 4723/24 4733/8
Mr. Keeton [1] 4715/2
4767/13 4805/20 4835/2 4857/8
Mr. Kent [2] 4687/14 4687/15
needed [3] 4694/13 4775/3 4811/21
Mr. Maze [1] 4846/4
needs [2] 4699/19 4784/2
Mr. McMahan [4] 4686/8 4686/11
negative [13] 4711/15 4711/19 4711/25
4686/19 4687/4
4712/5 4737/21 4738/4 4738/13
Mr. Morgan [6] 4761/19 4761/21
4739/22 4740/1 4740/18 4741/1
4761/24 4762/3 4762/9 4785/6
4741/16 4741/23
Mr. Morgan's [1] 4763/4
negligent [2] 4742/12 4742/12
Mr. Newman [23] 4677/6 4682/12
neither [1] 4741/7
4682/23 4685/14 4685/21 4690/24
never [20] 4763/25 4764/1 4765/7
4691/20 4692/12 4700/12 4712/25
4765/11 4765/24 4775/16 4786/8
4720/22 4724/6 4727/11 4730/24
4786/10 4791/25 4792/9 4792/17
4734/6 4735/13 4737/25 4738/12
4794/1 4795/20 4839/3 4839/20
4738/22 4742/25 4743/3 4743/9 4751/8 4841/10 4841/14 4841/25 4848/13
4877/23
Mr. Newman's [1] 4722/3
new [13] 4668/6 4668/24 4669/7
Mr. Nickels [1] 4747/23
Mr. Quirk [34] 4751/13 4751/14 4751/16 4669/13 4670/7 4671/17 4671/20

4672/7 4672/24 4673/19 4721/21


4733/8 4805/22
newbuild [1] 4679/1
NEWMAN [25] 4676/25 4677/4 4677/6
4682/12 4682/23 4685/14 4685/21
4690/24 4691/20 4692/12 4700/12
4712/25 4720/22 4724/6 4727/11
4730/24 4734/6 4735/13 4737/25
4738/12 4738/22 4742/25 4743/3
4743/9 4751/8
Newman's [1] 4722/3
next [19] 4692/25 4699/1 4740/21
4751/9 4753/11 4753/12 4768/15
4785/2 4813/9 4826/18 4827/2 4827/13
4836/10 4843/16 4843/17 4845/16
4861/11 4867/10 4871/24
Nickels [1] 4747/23
night [3] 4749/25 4751/1 4865/15
nine [2] 4750/7 4859/12
nine years [1] 4859/12
Ninth [1] 4669/19
nitrogen [2] 4870/24 4870/25
no [140] 4675/8 4675/19 4676/10
4676/17 4687/1 4690/13 4690/14
4690/14 4692/9 4694/3 4698/20
4699/15 4700/5 4704/2 4704/4 4704/20
4706/18 4706/19 4709/1 4719/14
4722/10 4724/7 4726/20 4726/23
4727/2 4727/5 4727/8 4733/10 4735/16
4735/23 4736/2 4736/18 4737/19
4737/20 4738/18 4739/5 4739/16
4743/3 4743/5 4744/9 4750/3 4751/6
4754/22 4756/2 4756/19 4759/18
4762/8 4763/9 4763/23 4764/17
4764/23 4764/25 4765/19 4767/1
4767/1 4768/22 4769/14 4770/22
4772/6 4772/6 4772/6 4773/14 4776/11
4779/19 4782/1 4782/24 4782/25
4784/2 4784/9 4784/23 4784/24
4785/22 4787/7 4789/22 4794/9
4794/19 4795/5 4795/15 4796/6
4797/13 4797/18 4801/9 4801/10
4802/4 4802/8 4802/24 4803/7 4803/18
4803/19 4804/9 4805/5 4808/2 4808/17
4823/23 4825/11 4826/21 4827/4
4827/17 4827/24 4829/13 4830/12
4830/23 4831/6 4831/12 4832/11
4833/1 4835/11 4835/25 4838/19
4839/16 4839/16 4840/6 4840/24
4843/4 4844/22 4848/10 4849/10
4849/12 4849/18 4850/23 4851/14
4852/7 4855/25 4857/23 4857/25
4864/24 4866/2 4866/2 4866/2 4867/25
4869/8 4869/10 4869/10 4869/12
4869/15 4873/5 4873/5 4874/4 4874/25
4879/23
No. [2] 4780/23 4826/7
No. 2 [1] 4826/7
Nobody [1] 4796/5
non [1] 4871/3
non-foam [1] 4871/3
none [2] 4675/25 4676/13
NONJURY [1] 4668/14
Nope [1] 4682/21
Norfolk [1] 4672/20
normal [1] 4680/25
normally [1] 4794/4
North [2] 4671/12 4749/21
not [232]
notation [1] 4819/21
notations [1] 4868/24
note [4] 4707/14 4821/16 4847/3 4847/6
noted [1] 4820/14

N
notes [12] 4763/18 4766/25 4767/1
4767/2 4767/4 4767/8 4767/13 4768/4
4770/20 4852/5 4865/23 4865/25
nothing [2] 4801/10 4804/17
notice [3] 4734/13 4775/23 4775/24
noticed [1] 4821/14
notified [1] 4812/2
notwithstanding [3] 4741/2 4741/17
4741/24
November [3] 4721/12 4721/13 4721/20
November 2007 [1] 4721/20
November 20th [2] 4721/12 4721/13
now [138] 4681/13 4682/17 4682/20
4683/11 4686/23 4687/13 4690/15
4690/18 4693/22 4696/10 4696/20
4696/22 4697/2 4697/19 4698/9
4698/10 4700/7 4703/12 4704/11
4705/4 4705/6 4707/24 4712/21
4712/23 4712/25 4715/9 4722/9 4723/6
4725/2 4728/14 4730/11 4731/14
4742/17 4745/12 4745/20 4747/9
4747/16 4748/13 4748/23 4749/18
4750/9 4750/21 4751/17 4751/20
4752/22 4754/16 4755/3 4755/24
4757/7 4758/10 4759/19 4760/16
4760/17 4760/25 4761/19 4762/23
4763/8 4764/9 4764/10 4764/12
4764/18 4766/3 4767/7 4768/12
4769/15 4770/16 4770/23 4771/1
4771/18 4772/13 4773/17 4774/11
4774/12 4775/2 4775/14 4775/23
4776/8 4777/9 4778/25 4779/13 4781/3
4781/12 4781/24 4784/18 4784/18
4786/3 4788/2 4788/20 4789/5 4790/4
4790/15 4791/7 4791/10 4792/23
4793/18 4793/18 4794/23 4796/9
4796/24 4798/1 4798/11 4798/24
4799/6 4799/17 4800/4 4800/17
4801/20 4814/7 4823/19 4823/21
4824/12 4826/23 4828/15 4842/1
4845/5 4847/19 4848/20 4849/12
4850/14 4851/25 4852/12 4852/23
4853/17 4855/22 4856/1 4856/18
4859/14 4859/18 4863/5 4864/7 4866/7
4866/25 4869/16 4869/23 4872/2
4875/17 4876/4 4880/17
number [36] 4696/21 4707/5 4726/13
4732/6 4732/18 4734/12 4750/11
4773/9 4773/19 4775/25 4776/4 4780/5
4780/9 4780/18 4780/19 4780/20
4781/15 4781/16 4781/16 4782/6
4782/20 4782/21 4783/1 4783/6 4783/6
4783/18 4785/25 4799/13 4844/18
4844/21 4844/24 4845/7 4845/8 4859/9
4868/15 4868/15
numbered [1] 4881/23
numbers [3] 4845/15 4848/12 4849/13
NW [1] 4672/3

O
O'Keefe [1] 4668/23
O'ROURKE [1] 4670/14
oath [1] 4759/16
object [4] 4741/10 4828/24 4846/25
4848/25
objection [11] 4738/9 4767/18 4767/21
4791/17 4792/2 4792/11 4793/4
4818/20 4825/10 4849/3 4877/25
objections [6] 4675/20 4675/23 4676/5
4676/6 4676/11 4676/12
objective [2] 4704/20 4737/11

objectives [1] 4704/19


obligated [2] 4706/2 4722/17
obligation [2] 4705/17 4706/14
obligations [1] 4707/10
observe [5] 4692/18 4692/21 4740/22
4872/22 4873/3
observed [2] 4740/8 4874/14
observer [1] 4843/10
obtain [3] 4853/15 4854/16 4857/13
obtained [3] 4865/16 4866/25 4867/16
obviously [2] 4737/25 4842/1
occurred [4] 4721/2 4735/14 4744/22
4745/5
occurrence [1] 4699/22
occurring [1] 4706/15
oceans [1] 4715/19
October [12] 4749/3 4774/2 4780/2
4780/10 4780/23 4783/8 4783/9
4783/13 4785/24 4870/6 4870/9
4870/11
October 2009 [1] 4783/8
October 22nd [5] 4774/2 4780/2
4780/10 4780/23 4785/24
October 2nd [1] 4749/3
odd [1] 4873/13
off [15] 4697/19 4719/7 4727/7 4734/12
4734/20 4758/3 4768/7 4768/15
4769/15 4770/5 4770/7 4770/8 4813/4
4851/22 4858/8
off-the-shelf [2] 4758/3 4768/7
offer [2] 4675/17 4841/14
offered [3] 4818/14 4839/20 4853/8
offhand [1] 4837/8
office [25] 4668/20 4670/16 4670/22
4671/13 4672/17 4754/19 4757/1
4757/3 4757/13 4774/24 4782/1
4783/24 4784/17 4796/11 4796/15
4799/14 4800/5 4801/3 4801/4 4801/5
4801/21 4802/4 4804/11 4805/8
4805/14
officer [4] 4707/11 4708/1 4708/3
4750/19
offices [2] 4708/6 4708/13
Official [3] 4673/18 4881/21 4881/25
officials [1] 4683/1
offshore [13] 4672/6 4672/9 4672/12
4672/16 4672/20 4677/14 4678/20
4679/1 4679/5 4722/13 4760/13
4760/20 4848/13
often [3] 4750/25 4829/20 4829/23
Oh [4] 4726/1 4833/13 4843/9 4879/17
OIC [4] 4711/3 4713/21 4713/23 4714/2
oil [10] 4668/4 4668/4 4680/8 4706/6
4723/16 4731/4 4735/6 4740/3 4742/7
4742/14
oilfield [1] 4692/1
OIM [10] 4688/21 4704/8 4707/16
4707/21 4720/21 4720/23 4721/8
4722/16 4727/25 4739/1
OIMs [2] 4750/18 4750/22
Okay [108] 4675/16 4676/13 4676/20
4678/10 4687/3 4688/3 4688/16
4689/10 4689/15 4694/16 4697/2
4700/22 4703/12 4703/16 4710/5
4710/20 4712/21 4713/15 4719/25
4720/19 4721/3 4721/21 4721/24
4726/15 4729/12 4733/8 4738/25
4754/8 4759/9 4761/15 4762/7 4762/20
4770/6 4774/7 4774/15 4776/7 4776/16
4776/18 4777/10 4777/10 4777/15
4778/6 4778/23 4779/11 4779/12
4780/7 4781/13 4781/13 4785/18
4786/21 4787/18 4791/3 4791/24

4796/9 4798/8 4806/4 4806/22 4813/22


4813/22 4814/15 4814/16 4814/18
4816/13 4818/24 4819/4 4819/9 4819/9
4820/3 4823/22 4824/17 4825/13
4826/6 4827/1 4832/5 4837/25 4840/7
4840/12 4841/4 4843/7 4843/17
4844/14 4845/9 4845/10 4846/4
4848/22 4849/6 4849/20 4849/21
4853/2 4854/8 4854/16 4855/19 4856/2
4856/3 4856/12 4856/16 4858/12
4860/8 4861/17 4866/7 4870/13 4873/7
4873/10 4875/7 4876/9 4876/10
4876/20 4879/18
Oklahoma [12] 4757/8 4757/13 4757/16
4757/19 4757/20 4758/22 4759/13
4761/5 4763/9 4763/10 4763/17 4764/5
olden [1] 4717/9
Olson [1] 4672/12
OMS [3] 4698/14 4698/21 4699/8
OMS.' [1] 4699/4
on board [5] 4722/16 4834/10 4835/9
4835/19 4835/23
onboard [3] 4680/23 4689/18 4691/8
once [7] 4746/14 4785/22 4852/4
4865/1 4865/12 4866/25 4867/18
one [103] 4679/3 4679/17 4680/15
4681/4 4682/8 4683/15 4683/18
4683/21 4685/1 4688/14 4691/12
4692/5 4692/10 4699/9 4702/6 4703/22
4710/5 4713/19 4721/22 4721/24
4723/19 4726/7 4727/22 4727/22
4731/7 4731/10 4732/15 4732/16
4734/2 4740/15 4754/23 4755/15
4756/1 4756/3 4757/5 4761/17 4762/12
4762/13 4762/14 4762/15 4763/9
4764/15 4765/20 4765/21 4768/17
4772/21 4773/1 4774/1 4775/10 4776/2
4779/10 4780/25 4782/1 4782/22
4783/18 4783/22 4784/2 4784/14
4791/23 4794/19 4795/21 4795/25
4796/6 4801/9 4801/10 4802/4 4804/8
4804/8 4804/10 4804/12 4804/14
4809/19 4817/1 4817/15 4822/21
4826/14 4826/18 4826/23 4827/2
4827/14 4828/1 4828/1 4828/2 4828/16
4832/7 4833/10 4838/19 4839/16
4839/16 4846/17 4846/21 4846/21
4849/1 4854/1 4857/24 4859/25 4861/9
4861/21 4866/6 4867/13 4867/15
4874/14 4879/3
One's [1] 4867/13
ones [4] 4702/23 4766/20 4777/18
4839/12
only [21] 4677/20 4684/21 4688/14
4690/11 4711/3 4712/15 4713/8 4739/3
4743/22 4743/22 4772/25 4773/19
4775/11 4788/9 4804/7 4804/12
4818/10 4830/8 4835/14 4837/8
4881/11
onshore [3] 4688/6 4688/8 4688/17
operability [1] 4710/25
operate [7] 4677/11 4695/22 4700/15
4701/11 4701/19 4701/20 4721/22
operated [1] 4715/18
operating [3] 4700/17 4701/7 4701/13
operation [8] 4706/15 4722/19 4727/6
4732/21 4734/16 4743/23 4831/10
4857/2
operational [1] 4844/25
operations [24] 4691/1 4691/2 4691/4
4691/7 4691/17 4692/16 4692/19
4702/1 4702/4 4702/7 4703/7 4709/12
4710/9 4710/12 4713/21 4732/9

4838/13 4839/5 4841/3 4847/10 4861/8


4862/7 4865/1 4865/22 4870/23
operations... [8] 4732/22 4739/2 4790/5 4873/13 4874/3 4874/5 4874/8 4874/12
4790/16 4790/19 4857/16 4857/20
4874/15 4876/4
4857/20
out-of-ordinary [1] 4874/5
operator [18] 4683/1 4683/19 4683/22 out-of-the-ordinary [2] 4873/13 4874/15
4689/10 4689/10 4690/7 4690/7
outlined [1] 4788/10
4693/14 4694/2 4694/12 4699/17
outside [2] 4867/23 4869/6
4699/25 4701/7 4701/19 4724/24
over [32] 4686/14 4692/19 4696/11
4867/24 4868/1 4869/14
4732/2 4732/3 4732/16 4732/18 4739/6
operators [7] 4681/19 4694/7 4694/11
4763/11 4767/12 4787/1 4787/2
4731/5 4860/18 4860/19 4869/14
4794/11 4794/14 4806/8 4806/16
opportunity [1] 4853/8
4807/8 4827/16 4835/10 4835/19
opposed [2] 4826/11 4838/4
4836/18 4836/22 4838/11 4839/15
OptiCem [1] 4857/22
4846/8 4846/12 4846/18 4848/3
orally [3] 4765/7 4765/11 4765/18
4852/21 4859/14 4866/24 4877/21
order [16] 4753/21 4755/25 4756/4
overall [3] 4701/4 4722/14 4864/3
4779/1 4780/11 4794/18 4795/23
overcome [3] 4875/6 4875/10 4875/24
4795/25 4796/3 4807/11 4809/22
overlooked [1] 4843/13
4817/2 4817/14 4817/17 4865/6 4876/1 overriding [2] 4721/1 4721/10
ordered [4] 4793/2 4793/23 4795/17
overrule [2] 4767/21 4849/3
4796/5
Overruled [1] 4793/6
ordinary [4] 4821/14 4873/13 4874/5
overview [1] 4858/4
4874/15
own [11] 4677/10 4692/25 4708/18
organization [2] 4685/14 4722/11
4713/13 4724/20 4724/21 4724/21
organizational [1] 4685/11
4767/10 4790/10 4855/15 4858/25
organize [1] 4709/13
owner [6] 4695/24 4696/2 4696/3
organized [2] 4688/13 4858/2
4696/5 4867/23 4867/23
orient [1] 4685/15
owners [1] 4869/14
orientation [1] 4810/2
owns [1] 4694/19
oriented [1] 4689/13
P
original [1] 4696/2
p.m [3] 4778/22 4813/14 4813/18
originally [6] 4756/14 4805/8 4805/14
page [55] 4674/2 4678/2 4678/14
4813/6 4835/10 4835/24
Orleans [10] 4668/6 4668/24 4669/7
4684/20 4688/20 4692/25 4697/24
4669/13 4670/7 4671/17 4671/20
4698/8 4699/2 4702/23 4704/11
4672/7 4672/24 4673/19
4704/17 4704/18 4709/15 4714/5
other [49] 4679/13 4688/10 4696/16
4719/25 4722/3 4728/17 4745/2 4745/6
4699/9 4699/20 4703/23 4710/23
4747/24 4749/18 4758/12 4759/4
4716/23 4717/1 4717/18 4726/13
4759/5 4759/5 4760/6 4765/15 4769/19
4732/9 4737/10 4752/16 4757/15
4769/20 4777/7 4778/20 4790/23
4761/5 4765/21 4769/11 4773/13
4797/22 4798/4 4825/22 4827/13
4773/15 4779/24 4782/25 4802/23
4830/16 4834/1 4834/7 4834/21
4802/25 4803/17 4804/3 4804/5 4804/9 4845/16 4847/19 4848/3 4861/11
4804/15 4805/5 4823/23 4827/8
4861/12 4863/8 4871/18 4871/20
4827/18 4831/6 4831/7 4838/15 4839/1 4871/21 4871/22 4871/24 4871/25
4839/21 4841/2 4841/12 4841/15
4879/6 4879/22
4842/7 4844/25 4845/1 4845/3 4847/22 pages [1] 4746/7
4849/14 4854/17 4867/23
Palmintier [1] 4669/21
others [5] 4683/3 4689/3 4742/13
paperwork [2] 4866/11 4866/17
4811/24 4863/7
paragraph [3] 4740/7 4742/11 4797/10
otherwise [3] 4731/21 4817/11 4817/12 paragraphs [2] 4739/21 4742/3
our [38] 4676/15 4677/12 4679/19
parameter [1] 4821/12
4679/20 4680/3 4680/6 4682/8 4685/1 Pardon [1] 4704/14
4685/15 4687/1 4689/25 4694/9
part [39] 4701/3 4702/7 4702/8 4705/21
4695/22 4701/9 4701/10 4701/10
4723/14 4725/11 4725/16 4739/24
4701/11 4701/17 4701/17 4701/22
4757/6 4757/15 4759/14 4762/16
4702/8 4702/21 4704/19 4709/13
4764/21 4765/13 4773/4 4776/3
4711/24 4725/7 4727/22 4736/22
4777/10 4777/15 4779/24 4782/6
4737/2 4737/7 4751/13 4802/11
4783/22 4784/6 4793/15 4794/2
4805/12 4805/24 4806/3 4860/2
4794/13 4794/19 4824/19 4831/10
4871/10 4873/17
4834/18 4839/1 4840/13 4842/5 4851/2
ours [3] 4695/21 4695/21 4695/22
4855/11 4855/25 4867/25 4868/14
out [57] 4687/17 4690/11 4693/5 4699/5 4873/17 4879/16
4701/25 4705/14 4708/19 4712/19
participate [1] 4862/3
4714/12 4717/18 4729/1 4732/11
particular [30] 4773/20 4775/9 4778/25
4780/8 4780/25 4782/7 4782/8 4783/3
4734/2 4753/1 4753/21 4755/20
4783/4 4788/8 4790/22 4790/23 4792/1
4771/19 4772/11 4774/12 4775/4
4798/13 4798/14 4798/15 4798/19
4775/10 4775/19 4776/14 4777/19
4798/20 4799/4 4799/10 4804/25
4778/2 4781/5 4781/8 4784/1 4786/5
4821/10 4848/1 4848/23 4850/21
4786/23 4787/8 4794/19 4802/18
4859/6 4867/16 4868/24 4879/13
4804/13 4805/16 4810/6 4817/19
4880/17
4821/14 4825/4 4826/3 4829/25

particularly [1] 4721/1


parties [3] 4752/16 4817/2 4828/11
parts [2] 4793/25 4794/3
passes [1] 4843/11
passive [1] 4719/9
past [6] 4681/8 4681/13 4681/17 4768/8
4789/9 4807/8
PAUL [1] 4669/6
pay [3] 4860/23 4861/1 4861/4
paying [1] 4804/16
PC [3] 4669/9 4673/7 4673/11
peace [1] 4700/5
pen [1] 4828/14
pencil [1] 4709/19
Pennsylvania [1] 4672/3
people [31] 4677/16 4681/5 4685/7
4689/22 4689/24 4690/3 4690/5 4690/9
4701/10 4701/17 4704/20 4707/2
4707/4 4708/19 4708/24 4708/24
4709/6 4712/12 4712/13 4717/12
4723/19 4736/22 4737/2 4737/7
4738/12 4738/16 4770/10 4788/18
4789/10 4789/17 4869/6
per [7] 4708/18 4795/9 4812/25 4813/17
4816/4 4876/19 4877/1
perceived [1] 4749/13
percent [13] 4690/5 4727/23 4728/1
4728/11 4729/18 4729/18 4863/14
4863/17 4863/21 4863/23 4863/25
4864/2 4864/5
Percentage [1] 4729/18
percipient [4] 4738/13 4738/16 4819/8
4819/10
perform [15] 4759/10 4764/18 4764/21
4765/12 4766/4 4770/17 4771/7
4776/10 4777/24 4779/2 4780/12
4852/9 4858/23 4859/16 4859/16
performance [11] 4684/15 4684/17
4686/9 4687/15 4688/1 4688/8 4690/25
4691/17 4708/20 4709/6 4857/4
performed [12] 4714/23 4758/21 4768/8
4776/11 4793/15 4793/17 4809/21
4820/21 4822/4 4822/10 4864/12
4865/14
performing [8] 4682/8 4684/22 4685/1
4692/21 4776/19 4779/16 4858/14
4873/3
performs [2] 4860/8 4875/3
perhaps [1] 4873/13
period [12] 4730/18 4730/24 4731/7
4731/25 4732/2 4732/7 4732/16
4757/17 4761/14 4783/8 4793/21
4833/19
perished [4] 4767/16 4768/1 4769/3
4769/12
permanently [1] 4718/13
Perry [1] 4861/25
person [10] 4687/23 4717/20 4725/4
4725/13 4725/23 4761/18 4787/18
4795/17 4795/21 4813/4
personal [2] 4856/23 4856/25
personally [5] 4764/23 4764/24 4829/7
4836/11 4841/10
personnel [10] 4683/1 4690/6 4690/7
4690/8 4692/17 4708/5 4708/12 4716/7
4768/2 4858/6
persons [2] 4689/18 4722/15
perspective [1] 4726/9
pertain [1] 4810/9
pertaining [8] 4749/20 4807/5 4809/18
4818/3 4818/5 4818/6 4818/8 4818/10
pertains [1] 4695/7
peruse [1] 4846/17

P
PETITION [1] 4668/8
Petrobras [2] 4725/21 4731/3
petroleum [1] 4853/13
PHILLIP [1] 4672/23
phone [11] 4755/4 4757/12 4765/6
4766/6 4766/13 4767/12 4767/24
4774/22 4777/23 4867/7 4867/13
phrase [3] 4689/17 4726/15 4732/23
pick [4] 4684/23 4734/11 4824/4
4838/23
picker [1] 4813/7
picture [4] 4831/18 4833/15 4836/4
4850/6
piece [1] 4782/3
pieces [2] 4769/8 4818/17
Pigman [1] 4672/22
pinpoint [1] 4856/17
pipe [7] 4740/9 4740/19 4740/22 4741/3
4741/7 4741/18 4741/25
place [16] 4684/18 4692/20 4715/4
4721/18 4721/20 4733/20 4734/22
4737/5 4738/3 4738/14 4742/17 4745/4
4745/8 4746/22 4755/25 4878/17
placed [2] 4798/2 4833/21
placement [3] 4877/10 4878/12 4878/14
places [2] 4688/10 4780/19
plaintiffs [14] 4668/18 4668/22 4669/2
4669/5 4669/8 4669/12 4669/15
4669/18 4669/21 4670/2 4670/5
4751/19 4807/22 4843/11
plaintiffs' [3] 4675/23 4753/21 4753/22
plan [9] 4711/16 4711/17 4711/18
4711/21 4711/23 4712/2 4712/19
4723/17 4751/23
planners [3] 4737/12 4737/12 4737/17
planning [3] 4710/1 4711/12 4712/17
plans [4] 4712/4 4712/8 4737/15
4737/18
plant [1] 4851/11
play [1] 4751/15
players [1] 4689/6
PLC [3] 4671/20 4671/23 4672/4
plea [1] 4737/23
please [47] 4675/6 4687/18 4753/10
4753/15 4758/12 4759/1 4765/16
4766/8 4769/20 4775/8 4775/8 4782/14
4785/20 4786/16 4788/23 4788/24
4797/22 4800/7 4802/15 4807/3
4819/12 4822/21 4825/14 4827/2
4827/14 4828/5 4834/3 4845/11
4845/17 4845/18 4848/7 4850/11
4850/12 4851/15 4861/11 4861/12
4861/19 4862/12 4862/19 4864/21
4865/17 4868/6 4871/12 4871/20
4871/24 4876/16 4879/8
pleasure [1] 4751/18
plenty [1] 4772/22
plug [1] 4739/6
plugs [1] 4804/3
plus [1] 4679/1
POB [1] 4689/18
pods [4] 4695/16 4695/16 4695/21
4695/21
point [20] 4687/17 4699/6 4763/6
4774/12 4781/7 4801/5 4805/15
4816/20 4817/6 4817/20 4821/17
4824/12 4841/4 4848/11 4856/2
4858/24 4867/1 4880/4 4880/15
4881/10
point-incident [1] 4856/2
pointing [1] 4833/7

points [1] 4849/1


policies [13] 4693/24 4697/12 4697/14
4700/16 4701/3 4701/14 4701/21
4702/24 4703/2 4703/5 4703/9 4703/18
4736/3
policy [14] 4694/2 4694/3 4703/25
4705/4 4706/5 4706/8 4706/13 4706/18
4707/9 4708/18 4713/16 4724/22
4725/12 4733/8
populated [1] 4719/10
pore [1] 4727/3
portion [4] 4745/12 4781/24 4781/25
4834/7
position [7] 4685/23 4794/10 4818/1
4853/9 4854/3 4854/5 4854/13
positioned [2] 4679/12 4679/15
positions [5] 4853/20 4853/21 4854/1
4854/3 4854/17
positive [2] 4711/25 4733/14
possession [1] 4846/6
possibility [3] 4723/12 4735/9 4783/15
possible [9] 4715/13 4716/8 4725/14
4751/25 4813/2 4828/6 4840/20
4842/14 4842/16
possibly [2] 4794/16 4795/22
post [11] 4668/20 4670/16 4670/22
4671/13 4672/17 4844/2 4848/24
4851/19 4852/1 4852/4 4856/11
post-incident [6] 4844/2 4848/24
4851/19 4852/1 4852/4 4856/11
potential [1] 4735/10
pounds [1] 4795/9
pouring [1] 4820/12
Poydras [4] 4669/6 4671/19 4672/6
4673/19
practicable [1] 4715/5
practical [1] 4714/11
practice [4] 4701/6 4748/5 4789/20
4823/7
practices [15] 4692/1 4700/17 4700/17
4733/5 4733/14 4733/22 4733/23
4788/3 4788/5 4788/7 4788/12 4788/19
4820/5 4872/10 4872/15
pre [6] 4735/18 4735/24 4736/4 4736/6
4762/2 4762/6
pre-incident [2] 4762/2 4762/6
pre-job [1] 4735/18
pre-spud [3] 4735/24 4736/4 4736/6
precautionary [7] 4731/14 4732/3
4732/6 4732/8 4732/10 4732/14
4732/19
precede [1] 4698/7
prefer [1] 4787/18
preference [1] 4701/9
preliminary [1] 4712/25
preparation [2] 4739/6 4863/15
preparations [1] 4721/21
prepare [5] 4723/11 4766/23 4766/24
4766/25 4767/1
prepared [8] 4703/12 4712/4 4712/8
4746/6 4746/15 4747/12 4752/5
4846/10
preparing [2] 4737/8 4846/1
presence [1] 4875/17
present [3] 4738/7 4836/16 4843/10
presented [3] 4807/23 4875/1 4875/4
preservation [2] 4755/25 4756/4
president [3] 4685/21 4686/9 4687/1
press [1] 4881/14
pressure [10] 4727/3 4739/4 4740/9
4740/10 4740/22 4741/2 4741/7
4741/17 4741/25 4878/8
pressures [1] 4857/12

pressurized [1] 4822/14


pretty [3] 4681/12 4700/2 4831/24
prevent [4] 4692/2 4706/15 4719/11
4722/18
prevention [8] 4691/21 4716/14 4716/22
4717/4 4718/7 4718/15 4720/7 4720/8
preventions [6] 4716/12 4718/21
4718/22 4718/23 4719/2 4720/12
preventive [1] 4714/8
previously [1] 4676/25
primarily [1] 4719/13
primary [3] 4692/15 4717/20 4754/11
principal [2] 4853/25 4854/6
print [5] 4813/8 4848/18 4865/6 4865/7
4866/3
printed [17] 4775/10 4776/14 4777/19
4778/10 4778/13 4778/21 4779/1
4779/3 4779/4 4779/4 4779/8 4779/13
4807/4 4811/11 4865/12 4865/23
4865/25
printing [3] 4776/15 4778/2 4778/5
prints [2] 4865/9 4865/22
prior [20] 4685/19 4706/10 4746/2
4754/10 4765/2 4765/11 4765/25
4777/25 4789/6 4795/5 4795/18 4796/6
4820/12 4844/8 4852/25 4855/22
4877/4 4877/8 4878/10 4878/20
priority [1] 4692/20
probably [8] 4681/17 4707/12 4833/11
4833/11 4854/3 4858/18 4859/11
4869/18
problem [3] 4754/25 4817/23 4821/1
problems [3] 4734/9 4770/1 4873/5
procedure [6] 4711/8 4711/14 4712/11
4712/11 4733/8 4859/6
procedures [19] 4700/14 4700/16
4701/3 4701/14 4701/22 4703/10
4703/18 4709/10 4709/22 4709/25
4710/4 4711/5 4716/16 4716/19 4719/6
4734/15 4734/21 4861/1 4861/2
proceed [5] 4699/19 4700/5 4705/19
4712/15 4843/21
proceedings [3] 4673/23 4881/18
4881/23
process [15] 4682/24 4710/1 4710/1
4711/12 4712/17 4714/13 4724/1
4735/17 4817/2 4841/20 4864/10
4864/21 4865/16 4867/25 4873/11
processes [1] 4713/17
produced [1] 4807/17
product [3] 4781/22 4781/22 4783/22
production [11] 4668/10 4671/19
4671/19 4671/22 4671/22 4672/3
4672/3 4807/6 4818/18 4822/6 4855/13
products [6] 4756/1 4757/13 4796/10
4796/11 4796/14 4797/4
profile [2] 4867/14 4867/21
prognosis [1] 4723/18
program [11] 4703/25 4704/6 4704/8
4704/11 4704/17 4736/9 4736/11
4736/14 4736/17 4736/19 4736/22
programs [2] 4709/11 4857/21
progressed [1] 4853/23
progression [2] 4815/21 4858/22
projects [1] 4765/18
promotion [1] 4853/25
prompt [7] 4723/3 4723/14 4723/25
4725/11 4725/16 4733/18 4733/24
proper [3] 4692/16 4771/19 4808/8
properly [1] 4843/25
properties [2] 4790/3 4790/8
property [1] 4692/3
proportion [1] 4731/11

4767/23 4768/16 4777/22 4786/16


4786/23 4792/13 4793/12 4794/18
propriety [1] 4877/3
4795/18 4795/24 4802/1 4802/15
protect [2] 4692/2 4692/17
4814/4 4830/23 4830/25 4833/1
protection [1] 4719/9
4836/10 4836/21 4837/24 4839/11
prove [2] 4817/20 4825/12
4842/19 4848/22 4848/25 4849/1
provide [4] 4713/17 4735/5 4736/22
4862/18 4862/22 4863/4 4869/9
4848/12
4872/17
provided [5] 4719/17 4735/1 4807/10
questioning [2] 4750/16 4750/22
4869/11 4869/13
questions [37] 4675/9 4689/19 4689/21
provider [1] 4678/21
4690/15 4690/17 4696/21 4705/6
provides [2] 4681/14 4694/21
4711/5 4712/25 4728/2 4728/12
providing [3] 4681/20 4695/5 4695/10
4728/15 4728/23 4730/2 4735/3
provision [2] 4691/21 4708/1
4737/21 4737/24 4739/15 4739/20
provisions [3] 4690/21 4693/5 4742/4
4743/1 4743/3 4743/5 4751/6 4805/5
proximate [1] 4742/13
4806/23 4808/11 4823/23 4824/1
proxy [3] 4678/2 4679/20 4679/21
4824/5 4842/7 4845/5 4847/14 4851/22
PSC [1] 4676/14
4851/25 4858/1 4867/6 4874/18
public [3] 4681/18 4681/22 4681/25
questions/doubts [1] 4728/2
pull [35] 4677/23 4682/9 4683/11
queue [3] 4812/4 4812/6 4812/7
4685/11 4689/17 4690/21 4690/23
quick [2] 4744/14 4752/23
4691/16 4692/10 4700/8 4702/15
quickly [5] 4723/22 4725/14 4733/15
4704/5 4712/23 4714/15 4724/12
4749/9 4861/8
4727/9 4728/25 4738/21 4739/22
Quirk [42] 4751/13 4751/14 4751/16
4744/25 4745/10 4745/20 4746/4
4751/21 4752/5 4753/12 4753/13
4746/10 4747/9 4747/16 4747/23
4753/17 4753/23 4754/2 4758/12
4749/10 4750/9 4754/7 4812/22 4826/3 4777/3 4777/21 4779/17 4785/19
4862/6 4863/10 4879/23
4805/6 4806/25 4808/8 4808/15 4810/2
pulled [2] 4690/24 4775/6
4810/8 4814/22 4817/14 4822/3
pulling [1] 4682/23
4822/24 4824/12 4825/25 4829/1
pump [5] 4811/21 4812/8 4816/2
4829/3 4830/1 4831/19 4833/5 4834/5
4877/18 4878/17
4843/19 4845/20 4851/17 4853/10
pump's [1] 4734/20
4871/14 4873/20 4875/17 4878/22
pumped [6] 4771/24 4794/10 4794/12
4879/25
4794/20 4822/5 4877/21
Quirk's [2] 4830/15 4833/25
pumping [3] 4772/18 4773/2 4877/10
quite [2] 4821/13 4835/6
pumps [1] 4734/12
quote [1] 4842/22
purport [1] 4819/3
R
purpose [11] 4694/1 4713/15 4736/19
4736/21 4737/2 4737/6 4790/11 4795/2 RACHEL [2] 4670/15 4672/9
4846/1 4877/7 4878/2
ran [2] 4793/16 4816/4
purposes [10] 4721/3 4773/2 4774/16
Randy [1] 4739/3
4775/4 4783/4 4788/9 4810/2 4844/15 rare [2] 4724/6 4724/8
4849/15 4857/9
rated [1] 4719/10
pursuant [2] 4748/5 4748/20
rather [3] 4701/7 4789/14 4881/3
put [51] 4683/14 4697/13 4697/23
re [5] 4668/4 4668/7 4760/19 4762/23
4702/6 4721/12 4728/15 4732/15
4763/2
4755/25 4756/2 4756/5 4756/18
re-create [3] 4760/19 4762/23 4763/2
4756/24 4757/3 4764/6 4766/11 4783/6 reach [2] 4815/1 4859/7
4783/24 4784/4 4787/16 4791/22
read [29] 4700/21 4702/14 4702/16
4796/15 4796/22 4796/24 4799/14
4702/17 4713/16 4722/20 4728/4
4801/14 4802/1 4802/11 4802/18
4740/7 4741/11 4741/21 4741/22
4803/4 4803/5 4803/17 4803/18
4759/8 4788/15 4789/8 4789/8 4789/17
4804/19 4805/23 4805/24 4813/4
4790/14 4813/20 4820/7 4820/11
4814/1 4824/23 4829/10 4829/13
4826/1 4826/10 4833/5 4833/6 4833/7
4838/7 4840/18 4841/2 4842/9 4854/2
4834/7 4834/12 4835/16 4835/21
4854/2 4854/7 4866/12 4867/2 4875/14 readily [1] 4735/17
4875/22
reading [8] 4758/18 4760/9 4769/24
puts [1] 4697/12
4777/12 4834/15 4834/23 4835/8
putting [2] 4781/7 4874/24
4835/22
puzzle [1] 4782/3
reads [1] 4742/11
ready [4] 4724/2 4752/22 4762/15
Q
4858/25
Q-U-I-R-K [1] 4753/18
reaffirming [1] 4791/1
QC [1] 4873/11
realize [2] 4836/9 4842/4
qualified [1] 4859/4
realized [1] 4802/20
qualitatively [1] 4714/7
really [5] 4683/15 4688/12 4824/15
quality [1] 4806/13
4829/23 4831/11
quantities [1] 4742/14
reason [6] 4690/11 4758/19 4784/15
quarters [1] 4842/11
4803/18 4831/6 4841/25
question [41] 4695/18 4696/4 4698/7
reasonable [1] 4692/1
4698/9 4699/1 4699/6 4699/11 4700/12 reasonably [3] 4714/11 4714/24 4715/5
4727/13 4750/23 4759/22 4766/8
reasons [1] 4867/15

recall [61] 4678/6 4681/4 4681/7


4681/16 4682/23 4683/4 4696/24
4697/21 4698/4 4698/22 4700/12
4700/20 4712/10 4722/1 4729/20
4730/1 4731/16 4738/20 4745/4
4755/13 4756/15 4758/8 4758/9
4759/14 4762/15 4763/22 4765/9
4765/13 4765/22 4776/15 4778/5
4793/19 4796/23 4805/3 4823/2
4823/14 4823/20 4825/2 4829/5
4829/15 4836/20 4836/20 4837/4
4837/17 4837/18 4838/22 4838/24
4839/7 4840/20 4840/21 4841/13
4843/4 4843/5 4845/25 4855/25
4858/16 4859/9 4864/3 4869/23 4870/5
4876/14
recalled [1] 4822/18
receive [3] 4738/19 4808/25 4865/3
received [15] 4676/10 4676/16 4727/12
4727/18 4738/22 4739/9 4748/2
4748/11 4748/17 4749/2 4755/4
4770/23 4774/22 4783/11 4783/14
receiving [2] 4812/8 4849/20
recess [3] 4753/6 4753/8 4881/16
recipe [2] 4787/17 4814/8
recitation [1] 4872/12
recognition [5] 4723/2 4723/13 4723/25
4733/18 4733/24
recognize [11] 4721/14 4810/8 4812/6
4822/24 4824/21 4831/19 4845/20
4861/14 4871/14 4873/13 4874/19
recognized [1] 4734/14
recognizing [1] 4734/20
recollection [5] 4758/25 4822/13
4822/17 4823/16 4823/20
recommend [2] 4786/9 4874/24
recommended [7] 4739/17 4786/4
4786/9 4786/13 4787/9 4787/14 4823/7
recommends [1] 4790/11
reconfigure [2] 4771/22 4772/7
record [20] 4680/9 4681/11 4684/22
4686/2 4753/16 4764/6 4766/12 4770/7
4770/13 4773/15 4784/9 4792/2 4793/4
4815/21 4817/10 4817/11 4817/12
4817/17 4825/10 4881/23
recordations [1] 4696/16
recorded [1] 4673/23
records [2] 4775/18 4775/19
recreate [1] 4760/12
red [5] 4729/22 4730/14 4730/25
4731/12 4731/21
Redden [1] 4673/2
redirect [3] 4743/7 4752/14 4849/4
reduce [1] 4714/8
redundant [2] 4718/16 4719/9
refer [3] 4689/12 4717/14 4747/2
reference [1] 4729/25
referenced [1] 4676/9
referred [1] 4710/19
referring [3] 4700/23 4717/8 4860/13
refers [2] 4710/16 4729/22
reflect [1] 4861/21
reflected [2] 4813/18 4816/17
refresh [6] 4700/22 4758/25 4765/24
4822/13 4822/17 4823/16
REGAN [5] 4671/23 4676/23 4677/4
4690/12 4750/15
regard [2] 4762/4 4837/22
regarding [2] 4820/23 4841/1
regardless [8] 4694/7 4723/17 4723/17
4723/18 4751/25 4752/18 4833/12
4833/20
regards [1] 4857/6

R
regimes [1] 4710/17
region [1] 4808/22
regional [1] 4703/2
regional-type [1] 4703/2
Register [1] 4749/20
regular [2] 4764/25 4873/16
regulated [1] 4710/17
regulations [4] 4692/18 4694/10
4695/25 4696/8
related [5] 4756/13 4765/23 4818/23
4821/3 4846/7
relates [2] 4744/15 4868/8
relationship [2] 4690/16 4696/24
relative [1] 4731/11
relatively [1] 4752/13
relevance [1] 4817/20
relevant [2] 4836/19 4875/21
Reliance [1] 4731/4
rely [3] 4681/19 4681/20 4681/22
relying [1] 4773/2
remain [4] 4722/14 4723/14 4763/13
4801/21
remaining [2] 4798/15 4826/15
remediated [1] 4741/8
remember [41] 4699/3 4713/1 4713/6
4730/10 4745/8 4756/15 4758/8 4761/8
4761/19 4761/19 4763/6 4763/7 4765/4
4765/13 4768/23 4768/25 4769/17
4776/4 4776/19 4776/25 4779/10
4779/14 4792/21 4792/21 4793/19
4794/21 4804/4 4823/13 4823/18
4825/20 4826/12 4836/18 4836/22
4837/6 4837/9 4838/14 4838/14
4838/25 4840/25 4841/1 4870/2
remembers [1] 4753/20
Remove [1] 4824/19
removed [2] 4804/10 4804/19
repeat [11] 4728/23 4757/23 4758/3
4758/9 4759/22 4820/10 4820/13
4822/11 4873/14 4873/19 4874/17
repeated [2] 4677/7 4873/21
rephrase [3] 4786/16 4830/5 4836/21
replace [2] 4834/9 4834/25
report [22] 4678/2 4678/7 4679/19
4743/14 4745/2 4749/20 4766/5 4766/7
4766/9 4766/14 4766/16 4766/18
4809/9 4821/23 4855/17 4867/18
4867/19 4867/22 4868/3 4868/5
4868/12 4868/14
reported [5] 4767/12 4852/4 4855/4
4855/18 4855/20
Reporter [3] 4673/18 4881/21 4881/25
reporting [2] 4809/5 4868/16
reports [6] 4684/6 4766/20 4807/9
4864/8 4868/1 4868/9
represent [12] 4677/5 4772/22 4773/3
4773/13 4776/6 4780/4 4785/4 4785/23
4790/23 4797/2 4847/9 4878/16
representation [3] 4709/16 4730/14
4780/24
representative [4] 4807/10 4807/13
4810/14 4817/3
represented [2] 4786/19 4786/24
represents [3] 4730/19 4730/21 4797/16
reproduced [3] 4811/2 4811/25 4819/24
request [23] 4798/21 4809/11 4809/12
4810/10 4810/14 4812/4 4812/5 4813/3
4813/6 4821/24 4857/14 4860/20
4864/22 4865/2 4865/3 4868/2 4868/15
4868/15 4869/7 4869/17 4870/3 4878/6
4878/11

requested [6] 4767/11 4858/15 4859/16


4864/14 4869/24 4876/7
requesting [6] 4763/22 4837/15 4865/1
4867/11 4869/11 4873/21
requests [3] 4808/25 4812/3 4864/12
require [1] 4736/4
required [3] 4699/5 4739/25 4811/8
requirement [8] 4698/20 4710/18 4723/3
4812/9 4815/7 4815/13 4815/18 4816/2
requirements [1] 4692/23
requires [2] 4698/21 4723/1
requisite [1] 4675/19
reservoir [10] 4715/22 4716/3 4716/15
4716/22 4717/4 4718/7 4718/15
4718/22 4719/2 4744/11
resources [4] 4670/13 4687/2 4692/23
4710/6
respect [47] 4677/9 4681/5 4682/18
4689/22 4691/21 4694/12 4694/16
4695/15 4696/1 4696/16 4703/24
4706/24 4707/22 4712/5 4718/24
4719/5 4720/17 4720/22 4724/11
4725/2 4725/3 4726/16 4732/24
4733/11 4734/5 4735/3 4735/24 4736/6
4736/13 4738/19 4739/14 4739/21
4741/20 4742/3 4803/16 4808/7
4846/11 4851/5 4862/9 4862/10
4862/22 4863/12 4863/15 4863/18
4863/19 4872/18 4881/6
respective [1] 4722/16
respond [1] 4723/21
response [4] 4700/12 4719/6 4721/5
4721/9
responsibilities [5] 4689/20 4708/7
4719/13 4719/20 4858/12
responsibility [21] 4692/15 4695/19
4695/22 4696/17 4708/17 4708/23
4709/5 4716/20 4717/2 4717/16
4717/20 4718/12 4718/19 4725/4
4725/7 4725/8 4725/23 4726/7 4726/13
4726/19 4726/24
responsible [16] 4691/3 4694/18
4694/24 4695/2 4695/5 4695/9 4695/12
4695/25 4696/7 4708/4 4708/11
4708/14 4722/14 4727/23 4754/13
4858/14
responsible/accountable [1] 4727/23
rest [2] 4719/19 4805/2
restart [1] 4767/23
restate [1] 4792/12
result [14] 4700/15 4712/7 4735/10
4744/22 4746/19 4749/6 4815/6
4815/12 4815/13 4815/17 4821/10
4867/16 4873/13 4874/5
resulted [1] 4734/15
results [30] 4766/5 4766/6 4766/7
4766/9 4766/12 4766/13 4767/12
4768/4 4769/4 4770/5 4775/21 4794/16
4795/16 4806/11 4809/6 4809/13
4814/23 4815/17 4821/23 4852/4
4852/6 4862/11 4865/15 4866/25
4867/4 4867/12 4867/22 4868/4
4873/18 4874/15
resume [1] 4676/22
retain [1] 4805/12
retardant [2] 4792/17 4793/1
retarded [1] 4814/9
retarder [11] 4790/3 4790/7 4812/13
4812/20 4813/1 4813/7 4813/17 4814/9
4816/3 4879/13 4879/20
retested [1] 4873/10
return [1] 4724/5
returns [3] 4724/5 4724/10 4733/15

Reudelhuber [1] 4727/18


Revette [2] 4748/14 4749/25
review [2] 4736/15 4818/22
reviewed [2] 4684/6 4876/11
reviews [1] 4698/24
revised [5] 4748/6 4748/9 4748/10
4748/21 4749/6
revision [1] 4745/22
revisions [1] 4746/18
rheologies [1] 4866/15
Rheology [2] 4794/16 4864/1
RICHARD [7] 4672/16 4822/25 4823/1
4855/21 4861/25 4862/3 4869/19
Rickey [3] 4762/25 4763/8 4763/18
rid [1] 4767/3
Ridge [1] 4683/24
rig [101] 4668/4 4679/25 4680/7
4683/19 4684/23 4684/24 4685/7
4687/15 4687/16 4688/6 4688/8
4688/12 4688/14 4688/18 4688/20
4689/22 4689/24 4690/3 4690/5 4690/7
4690/9 4691/4 4694/19 4695/6 4701/20
4703/5 4705/24 4705/25 4706/1
4710/18 4719/8 4722/9 4722/11
4722/16 4722/19 4725/22 4730/18
4730/21 4730/25 4735/18 4739/2
4742/18 4742/20 4743/24 4744/6
4750/6 4750/7 4756/14 4756/15
4756/17 4756/20 4756/23 4756/24
4757/3 4769/13 4780/20 4783/3 4784/6
4784/7 4785/9 4796/17 4796/18
4796/20 4797/25 4798/1 4798/2 4798/9
4801/4 4801/15 4801/24 4802/13
4802/13 4803/14 4803/22 4804/1
4805/19 4825/19 4831/2 4831/5 4834/9
4834/25 4838/5 4844/17 4844/21
4845/9 4846/16 4847/10 4847/11
4848/9 4848/24 4849/2 4849/11
4849/17 4850/22 4850/23 4851/4
4851/6 4851/12 4852/2 4870/23
4877/13
rig-specific [4] 4703/5 4844/21 4850/22
4850/23
right [215]
rigs [23] 4677/10 4679/23 4682/8
4685/1 4689/25 4701/7 4701/12 4706/8
4711/24 4718/24 4722/12 4725/4
4725/18 4725/19 4729/25 4730/4
4730/5 4731/11 4732/17 4737/13
4805/12 4845/1 4849/20
RIL [1] 4731/3
rise [4] 4675/5 4753/7 4753/9 4881/17
riser [25] 4711/22 4712/1 4712/9 4720/1
4732/24 4733/3 4733/9 4733/12
4733/20 4739/6 4743/17 4743/20
4743/21 4743/23 4743/24 4744/4
4744/5 4744/8 4744/13 4744/15
4744/15 4744/16 4746/15 4747/2
4747/11
risers [1] 4730/1
rising [1] 4881/3
risk [19] 4699/10 4702/10 4709/11
4709/17 4709/20 4710/20 4712/22
4713/5 4713/9 4713/12 4713/15
4713/19 4714/5 4714/6 4714/9 4714/16
4714/22 4718/24 4719/23
risks [3] 4712/15 4713/5 4715/4
RMR [4] 4673/18 4881/21 4881/24
4881/25
ROBERT [2] 4669/3 4672/3
ROBERTS [2] 4672/9 4673/4
role [5] 4688/12 4688/14 4706/25
4708/11 4821/9

R
roles [2] 4687/14 4689/20
Ron [2] 4754/17 4756/6
Ronnie [4] 4754/18 4754/19 4754/25
4755/4
Room [1] 4673/19
Rose [1] 4686/3
rotary [1] 4717/9
rotary-type [1] 4717/9
rotating [2] 4855/5 4858/8
Rouge [2] 4669/23 4671/13
rough [1] 4689/22
roughly [2] 4854/15 4878/16
routinely [1] 4815/17
Roy [2] 4668/18 4668/19
rules [2] 4692/18 4692/22
run [22] 4726/22 4765/1 4767/11
4768/14 4768/14 4768/14 4769/6
4769/6 4791/11 4791/19 4795/12
4795/14 4795/15 4806/12 4812/19
4822/19 4857/24 4858/20 4858/25
4866/14 4876/2 4880/18
running [1] 4857/21
runs [1] 4866/22
Rusnak [1] 4670/2

S
s/Jodi [1] 4881/24
SA [3] 4880/18 4880/20 4880/24
SA-541 [3] 4880/18 4880/20 4880/24
sack [5] 4812/25 4813/17 4816/4
4876/19 4877/1
safe [5] 4702/7 4732/21 4732/22
4763/23 4871/1
safely [1] 4712/19
safest [2] 4681/14 4681/21
safety [52] 4691/9 4692/13 4692/15
4692/18 4692/20 4692/22 4692/22
4692/25 4693/1 4693/2 4693/7 4693/13
4693/14 4696/20 4696/23 4697/3
4697/12 4698/24 4699/1 4699/17
4700/1 4700/1 4700/3 4700/7 4700/14
4701/10 4701/11 4701/18 4701/22
4702/8 4703/18 4703/25 4704/23
4705/11 4705/21 4706/12 4706/24
4706/25 4707/9 4707/17 4707/22
4708/4 4708/11 4708/16 4710/15
4710/18 4710/19 4713/20 4713/23
4714/12 4714/13 4722/14
said [38] 4681/5 4681/13 4683/7
4683/21 4684/14 4693/12 4695/20
4697/2 4700/15 4703/25 4706/14
4713/8 4732/11 4737/7 4741/12 4747/6
4752/12 4756/14 4756/14 4758/21
4761/21 4781/2 4784/21 4788/13
4801/15 4805/20 4819/3 4827/9 4828/4
4828/22 4839/16 4839/16 4842/22
4865/22 4866/5 4867/9 4871/17 4875/8
sake [1] 4828/21
same [85] 4676/1 4688/16 4693/12
4699/2 4699/4 4712/23 4714/5 4714/17
4718/23 4720/12 4726/14 4730/13
4731/24 4732/23 4733/11 4734/19
4744/8 4749/5 4750/13 4757/17
4771/11 4771/13 4771/14 4771/14
4771/15 4771/16 4775/10 4776/2
4776/6 4778/3 4780/1 4780/3 4780/5
4780/14 4780/15 4780/18 4780/19
4781/15 4781/16 4781/16 4781/17
4782/5 4782/12 4782/15 4782/19
4782/21 4783/18 4784/14 4784/16
4784/24 4784/25 4785/11 4785/25

4787/17 4787/17 4792/11 4799/11


4799/12 4799/13 4799/15 4799/24
4799/24 4800/10 4800/14 4800/14
4801/19 4802/16 4803/14 4803/23
4806/10 4806/11 4806/11 4809/5
4816/24 4816/24 4827/18 4832/20
4844/18 4851/2 4851/3 4852/9 4866/18
4866/19 4872/12 4878/15
sample [75] 4773/18 4773/18 4776/1
4779/22 4780/3 4780/11 4780/14
4780/15 4780/24 4781/17 4781/22
4781/24 4781/25 4782/4 4782/5
4782/15 4782/22 4783/3 4783/5
4783/14 4783/15 4783/17 4783/18
4784/14 4784/16 4784/20 4784/25
4785/8 4785/9 4785/11 4785/16
4785/24 4785/25 4797/13 4797/14
4798/16 4798/19 4799/12 4799/13
4799/15 4799/19 4799/24 4800/17
4800/21 4802/1 4802/2 4802/22
4802/25 4803/3 4803/18 4803/20
4831/4 4831/8 4844/18 4845/8 4847/7
4847/8 4847/25 4848/1 4848/8 4848/12
4848/17 4848/19 4849/2 4849/15
4850/17 4850/21 4851/2 4851/3 4851/4
4851/13 4874/3 4874/8 4874/9 4875/5
Sample ID [1] 4780/11
samples [50] 4768/9 4774/3 4782/19
4782/21 4783/16 4787/4 4787/5
4787/12 4787/17 4796/20 4796/21
4801/25 4802/10 4803/4 4803/6 4804/5
4805/4 4805/7 4805/12 4805/14
4805/18 4805/19 4805/21 4805/23
4805/23 4824/16 4824/18 4824/20
4825/5 4829/24 4831/3 4835/15
4835/22 4838/3 4838/6 4838/7 4838/13
4838/23 4839/5 4839/8 4839/18
4839/21 4840/16 4840/16 4840/17
4846/14 4847/23 4848/16 4849/12
4849/20
San [1] 4670/11
sank [1] 4742/23
save [2] 4769/4 4770/20
saw [7] 4709/10 4726/3 4738/16
4813/16 4819/11 4835/14 4850/6
say [34] 4677/10 4686/1 4691/20
4703/8 4716/25 4741/18 4745/7
4763/23 4770/7 4776/4 4778/13
4785/15 4787/13 4789/7 4790/21
4793/14 4802/8 4804/15 4804/22
4812/19 4821/5 4825/4 4826/21
4827/10 4832/8 4832/20 4836/1
4840/24 4840/24 4851/2 4858/18
4860/8 4860/13 4873/22
saying [15] 4682/24 4759/16 4759/18
4776/10 4779/8 4779/9 4781/4 4783/7
4783/13 4783/17 4785/17 4786/21
4804/15 4841/1 4845/13
says [79] 4678/24 4679/2 4679/7
4679/11 4679/15 4680/12 4683/5
4683/6 4691/7 4693/9 4698/19 4706/13
4706/17 4708/3 4708/9 4709/25
4713/17 4715/1 4715/6 4715/11
4716/18 4717/7 4718/10 4718/17
4720/9 4720/13 4726/6 4729/8 4729/14
4730/16 4730/20 4731/2 4732/20
4733/4 4733/7 4734/8 4738/24 4740/4
4740/12 4740/16 4740/20 4740/21
4740/24 4741/4 4741/9 4741/15
4741/23 4742/8 4742/16 4745/7
4745/19 4747/6 4747/15 4748/4 4749/4
4778/15 4778/18 4783/1 4783/2
4790/24 4822/15 4826/6 4826/18

4827/16 4827/21 4828/15 4828/19


4830/8 4831/14 4832/5 4832/7 4832/9
4832/11 4842/10 4846/22 4847/3
4847/6 4847/24 4850/24
scan [1] 4784/7
scenarios [1] 4715/11
Science [1] 4853/13
SCOFIELD [1] 4673/15
score [7] 4862/15 4862/24 4863/1
4863/13 4863/16 4863/20 4864/3
scored [2] 4862/12 4862/14
SCOTT [1] 4670/14
SCR [39] 4773/7 4773/10 4773/20
4774/1 4774/6 4774/19 4775/12
4775/16 4775/24 4779/19 4779/25
4780/2 4780/9 4783/14 4784/19
4784/22 4784/23 4785/3 4785/22
4789/25 4790/6 4790/7 4791/22
4792/17 4793/1 4804/25 4812/14
4813/1 4814/8 4828/20 4844/8 4844/14
4844/21 4845/8 4848/4 4848/23
4849/10 4850/18 4851/13
SCR-100 [6] 4784/22 4789/25 4790/7
4791/22 4792/17 4793/1
SCR-100L [28] 4773/7 4773/10 4773/20
4774/1 4774/6 4774/19 4775/12
4775/16 4775/24 4779/19 4779/25
4780/2 4780/9 4783/14 4784/19
4784/23 4785/3 4785/22 4804/25
4812/14 4813/1 4814/8 4828/20 4845/8
4848/4 4848/23 4850/18 4851/13
scratch [1] 4874/23
screen [20] 4704/10 4707/18 4759/8
4777/5 4807/16 4808/7 4809/20 4810/3
4810/8 4810/21 4811/14 4815/14
4817/9 4817/16 4819/25 4820/17
4822/9 4833/5 4834/19 4865/20
screens [1] 4717/11
sealant [7] 4779/19 4788/21 4788/22
4848/2 4851/5 4875/6 4875/8
search [2] 4812/12 4812/14
seated [2] 4675/6 4753/10
second [20] 4716/22 4728/17 4761/24
4762/9 4762/10 4775/2 4775/22
4785/20 4786/3 4797/10 4798/24
4803/12 4816/11 4825/22 4826/18
4826/23 4833/10 4846/21 4847/19
4879/6
secondary [2] 4790/3 4790/8
Secrest [1] 4673/2
secretary [1] 4845/23
section [19] 4668/5 4670/13 4671/3
4691/17 4732/23 4747/3 4788/11
4788/24 4788/24 4799/6 4800/21
4811/3 4811/17 4823/8 4823/11 4862/6
4863/6 4871/21 4872/5
Section 15 [1] 4691/17
sectors [1] 4679/5
secure [15] 4756/5 4756/13 4796/11
4801/9 4802/3 4802/10 4802/12 4803/2
4805/21 4824/16 4828/16 4838/6
4839/17 4839/18 4840/16
secured [14] 4756/2 4774/24 4782/1
4784/17 4797/4 4801/3 4801/21
4802/13 4803/6 4803/13 4805/8
4805/23 4838/24 4839/7
securing [2] 4783/9 4803/25
Sedco [3] 4734/25 4735/3 4735/9
Sedco 711 [2] 4735/3 4735/9
see [139] 4675/7 4678/17 4678/18
4684/3 4685/20 4686/9 4686/15
4687/10 4691/5 4691/10 4698/16
4699/11 4699/11 4699/20 4702/2

S
see... [124] 4702/9 4702/11 4703/8
4703/19 4703/24 4704/1 4704/10
4704/18 4704/24 4705/17 4707/13
4707/18 4707/25 4709/16 4709/19
4713/24 4714/19 4715/16 4715/24
4716/4 4716/10 4718/23 4719/5 4720/5
4720/10 4722/5 4724/15 4728/2 4728/4
4728/21 4729/4 4731/24 4733/6 4734/5
4734/17 4739/7 4745/15 4746/12
4748/2 4748/3 4748/18 4749/12
4749/16 4750/18 4750/19 4755/12
4758/6 4758/11 4758/23 4758/23
4763/19 4764/4 4767/12 4768/13
4769/21 4772/19 4773/17 4774/9
4775/21 4776/16 4777/24 4778/1
4778/15 4778/17 4778/20 4779/25
4780/2 4780/16 4784/21 4784/23
4784/23 4784/24 4784/24 4784/25
4785/2 4791/11 4796/24 4797/12
4799/16 4800/9 4800/11 4800/12
4800/13 4800/16 4802/25 4803/23
4806/17 4809/10 4809/12 4810/16
4810/20 4810/20 4810/23 4812/25
4813/11 4814/25 4816/11 4817/4
4819/22 4819/24 4820/8 4820/17
4823/3 4823/10 4825/25 4825/25
4826/6 4831/8 4833/6 4833/9 4834/11
4835/21 4842/3 4846/17 4850/16
4850/23 4851/14 4869/16 4873/2
4874/2 4874/7 4874/9 4876/21 4880/14
seeing [11] 4713/1 4721/6 4722/1
4757/22 4758/5 4758/24 4759/13
4792/21 4792/21 4794/21 4865/20
seemed [1] 4845/6
seen [16] 4704/3 4712/4 4712/6 4712/8
4734/6 4797/6 4823/11 4827/8 4827/18
4831/20 4848/20 4848/20 4849/8
4856/19 4871/18 4873/9
sees [1] 4732/10
Segment [1] 4823/7
seldom [1] 4794/9
select [2] 4868/14 4868/15
selected [2] 4812/20 4812/25
semisubmersible [1] 4680/7
semisubmersibles [1] 4715/14
Senator [2] 4700/13 4700/15
send [1] 4844/17
senior [2] 4853/24 4854/6
sense [4] 4772/12 4772/12 4780/6
4796/2
sent [7] 4676/16 4738/25 4791/12
4831/5 4831/18 4840/10 4850/2
sentence [4] 4740/21 4741/11 4741/20
4741/22
separate [3] 4770/3 4824/13 4829/9
separated [5] 4824/14 4829/6 4836/11
4836/13 4841/16
September [2] 4870/6 4870/11
September/October [2] 4870/6 4870/11
serves [1] 4701/1
service [6] 4683/17 4698/22 4698/24
4809/8 4858/15 4864/14
services [4] 4673/7 4673/12 4678/22
4853/13
SESSION [2] 4668/14 4675/2
set [10] 4692/22 4701/14 4701/21
4707/3 4739/6 4818/3 4820/8 4846/6
4867/15 4873/25
settling [8] 4762/24 4763/5 4819/22
4820/1 4820/6 4820/9 4820/14 4821/15
seven [1] 4859/11

several [4] 4844/13 4863/7 4867/13


4867/20
Severe [1] 4820/1
severity [1] 4709/20
sh [1] 4727/24
shack [3] 4717/24 4718/2 4749/25
shall [9] 4691/3 4691/25 4692/1 4692/14
4692/16 4692/17 4692/20 4692/21
4693/2
shared [1] 4680/15
shareholders [1] 4677/25
SHARON [1] 4670/21
Shaw [1] 4669/12
she [2] 4819/2 4845/24
shear [1] 4870/18
sheared [1] 4875/15
sheet [57] 4766/23 4766/24 4771/21
4772/1 4772/2 4772/3 4772/7 4772/14
4772/15 4772/17 4772/24 4772/24
4773/1 4773/5 4773/25 4774/22 4775/7
4775/10 4777/8 4777/10 4777/15
4778/3 4778/3 4778/25 4779/9 4779/13
4779/22 4780/1 4780/6 4780/22
4785/19 4792/17 4797/6 4798/25
4799/4 4810/4 4810/9 4811/3 4811/11
4811/14 4811/25 4813/5 4813/8
4813/16 4813/19 4814/22 4816/23
4819/16 4819/20 4850/14 4851/13
4865/7 4865/12 4865/21 4866/3
4872/25 4873/2
sheets [24] 4771/18 4771/21 4778/9
4807/5 4807/7 4809/21 4814/1 4817/9
4817/16 4818/5 4864/8 4865/8 4868/20
4868/22 4868/25 4869/1 4869/5
4869/16 4869/23 4870/3 4873/8 4876/6
4876/6 4876/11
shelf [15] 4758/3 4768/7 4768/15
4802/21 4804/9 4806/9 4806/10
4806/15 4824/21 4825/3 4825/8
4829/11 4829/14 4840/18 4841/3
Shell [4] 4730/7 4730/9 4731/3 4860/16
shift [6] 4821/18 4854/1 4855/6 4855/6
4858/9 4858/9
Shifting [1] 4874/18
shifts [4] 4855/5 4858/8 4858/8 4858/8
shore [1] 4710/6
shore-based [1] 4710/6
short [2] 4752/14 4881/12
shot [8] 4807/16 4810/3 4810/9 4810/21
4811/14 4819/25 4820/17 4822/9
shots [4] 4808/8 4809/20 4817/10
4817/16
should [11] 4691/20 4697/2 4699/7
4784/7 4787/10 4788/9 4789/17
4789/17 4801/21 4803/13 4821/1
shouldn't [2] 4705/19 4790/12
show [21] 4678/5 4698/7 4707/13
4709/9 4763/17 4763/25 4764/1 4777/9
4778/13 4780/17 4780/22 4784/6
4784/7 4790/15 4792/24 4808/4
4811/14 4816/22 4828/14 4837/14
4879/3
showed [13] 4719/25 4750/15 4761/4
4763/5 4764/9 4780/16 4814/7 4814/13
4838/10 4840/5 4840/6 4845/7 4850/15
showing [7] 4768/4 4773/19 4773/21
4797/4 4813/16 4822/11 4825/16
shown [21] 4685/18 4697/20 4698/2
4698/3 4698/4 4699/13 4713/1 4729/17
4732/23 4740/15 4749/13 4750/13
4766/21 4768/5 4810/13 4810/21
4811/9 4815/14 4819/16 4819/19
4842/9

shows [11] 4714/6 4774/5 4774/12


4775/9 4783/3 4792/19 4799/9 4822/9
4828/25 4833/20 4874/1
shut [14] 4725/5 4725/8 4725/13
4728/12 4731/15 4732/3 4732/6 4732/9
4732/10 4732/11 4732/14 4732/19
4734/15 4735/8
shut-in [2] 4732/10 4732/14
shut-ins [5] 4731/15 4732/3 4732/6
4732/9 4732/19
SHUTLER [1] 4670/21
shuts [1] 4744/1
shutting [1] 4733/15
SI [1] 4728/1
sic [1] 4727/25
side [18] 4686/6 4687/13 4688/20
4695/9 4702/11 4709/19 4709/20
4769/16 4769/21 4769/22 4770/5
4770/7 4770/8 4770/13 4809/19
4809/19 4842/21 4843/3
side-by-side [1] 4809/19
sideways [2] 4861/11 4861/12
signature [2] 4678/5 4715/2
signed [3] 4706/13 4714/20 4715/8
significance [1] 4839/5
signing [1] 4678/6
signs [5] 4872/2 4872/6 4872/7 4872/12
4873/4
Simcox [5] 4673/18 4673/20 4881/21
4881/24 4881/25
similar [7] 4683/15 4688/9 4716/1
4719/25 4765/18 4795/14 4812/18
Similarly [1] 4706/20
Simon [1] 4770/23
simple [3] 4736/25 4794/18 4857/18
simplified [2] 4711/11 4736/23
simplify [1] 4813/25
simply [4] 4743/21 4746/6 4814/4
4841/7
simulating [3] 4877/10 4878/3 4878/5
since [7] 4698/11 4765/1 4796/4 4816/2
4852/8 4853/21 4853/22
SINCLAIR [1] 4671/9
single [5] 4726/7 4730/25 4731/12
4732/18 4770/13
sinks [1] 4769/13
sir [20] 4748/15 4750/16 4754/4
4754/15 4754/21 4764/17 4769/14
4770/22 4771/12 4777/12 4781/2
4781/9 4802/8 4802/15 4803/16 4805/9
4818/17 4839/4 4841/19 4853/15
sit [4] 4750/19 4831/3 4831/10 4839/4
site [3] 4680/23 4705/24 4740/16
sitting [5] 4784/18 4802/21 4804/8
4825/8 4849/19
situated [1] 4689/14
situation [4] 4723/21 4744/5 4875/1
4875/4
six [12] 4725/18 4729/25 4730/4
4782/19 4782/21 4811/21 4812/9
4812/14 4815/8 4815/13 4816/2
4821/12
six-hour [3] 4811/21 4815/13 4821/12
size [4] 4730/22 4826/1 4832/2 4877/12
skipped [1] 4710/5
skipping [1] 4827/16
slice [2] 4689/17 4690/2
slide [1] 4749/20
Slidell [1] 4669/19
slightly [1] 4753/21
sling [1] 4711/9
slowly [1] 4834/13
slurries [2] 4812/15 4870/16

S
slurry [80] 4755/8 4755/11 4755/21
4757/9 4757/14 4757/19 4758/20
4758/23 4760/11 4760/12 4760/20
4761/4 4762/24 4763/2 4763/5 4763/20
4764/9 4764/18 4771/22 4771/24
4772/7 4772/8 4772/17 4775/5 4779/2
4779/6 4787/9 4788/9 4788/10 4789/11
4791/11 4791/15 4791/22 4791/22
4792/8 4794/5 4794/24 4795/8 4798/20
4809/22 4814/7 4818/8 4819/19
4819/21 4819/21 4820/8 4820/9
4820/12 4820/13 4820/14 4821/3
4821/6 4821/20 4821/23 4822/4 4822/5
4822/10 4857/5 4863/15 4870/15
4870/17 4870/17 4870/19 4870/21
4871/3 4871/3 4871/4 4871/9 4873/5
4874/21 4874/23 4877/4 4877/8
4877/20 4878/10 4878/23 4878/24
4880/6 4880/11 4880/18
so [160] 4678/10 4680/1 4680/25
4682/1 4682/3 4682/19 4684/8 4685/6
4685/10 4688/3 4688/14 4690/2 4693/6
4697/8 4697/9 4698/8 4698/10 4702/15
4703/7 4703/8 4705/3 4705/24 4709/4
4711/2 4711/25 4713/12 4715/4 4721/6
4721/21 4730/17 4731/20 4731/23
4732/2 4732/15 4733/10 4734/7
4734/11 4735/17 4736/25 4744/1
4744/4 4744/14 4746/4 4746/22 4748/9
4750/13 4752/15 4756/2 4756/8
4756/23 4756/24 4757/2 4757/12
4760/10 4761/24 4762/7 4762/20
4763/16 4763/19 4763/23 4765/24
4766/23 4768/17 4769/3 4769/25
4770/7 4770/9 4770/10 4771/18 4772/7
4773/25 4775/6 4775/9 4776/5 4777/21
4778/25 4780/8 4782/1 4784/13 4785/8
4786/7 4787/7 4789/20 4795/18
4795/24 4796/21 4798/8 4798/20
4800/3 4800/7 4800/24 4801/9 4802/4
4802/12 4803/1 4803/4 4803/8 4805/13
4805/13 4805/22 4807/24 4808/7
4810/2 4812/8 4812/14 4812/20 4814/4
4815/6 4815/20 4816/20 4820/12
4821/5 4824/17 4825/7 4826/14
4826/23 4827/10 4827/23 4828/24
4829/13 4831/8 4831/10 4831/12
4835/13 4835/18 4835/22 4836/11
4838/19 4840/4 4840/9 4840/12
4840/19 4840/22 4841/4 4842/24
4846/4 4846/17 4848/17 4852/25
4854/4 4854/8 4854/22 4860/18 4861/8
4866/12 4868/19 4870/11 4870/20
4872/17 4873/10 4874/23 4875/7
4877/1 4877/5 4877/12 4878/13
4878/17 4879/16 4880/4 4880/24
software [1] 4673/24
solely [2] 4691/3 4744/15
some [60] 4677/17 4679/13 4681/12
4686/11 4688/10 4689/3 4689/19
4689/19 4689/20 4690/15 4695/15
4697/20 4699/5 4707/10 4708/7 4710/7
4710/17 4713/1 4714/13 4720/20
4728/14 4728/23 4731/6 4737/21
4739/14 4744/5 4757/14 4757/15
4773/6 4779/2 4791/18 4794/7 4794/13
4794/18 4794/21 4802/25 4805/15
4805/15 4806/12 4808/9 4814/2
4819/17 4820/24 4821/4 4821/4
4823/18 4824/12 4837/25 4845/5
4847/23 4853/20 4853/21 4857/18

4858/1 4858/24 4859/23 4859/24


4866/20 4873/8 4874/18
somebody [4] 4795/22 4813/23 4818/13
4829/9
somehow [7] 4798/2 4801/22 4801/24
4802/6 4802/17 4802/18 4803/8
someone [16] 4732/10 4757/13 4757/16
4761/4 4763/17 4764/5 4779/1 4779/2
4779/5 4796/2 4802/19 4803/15
4821/18 4836/14 4867/7 4869/16
something [42] 4699/3 4705/13 4705/18
4705/25 4721/16 4724/2 4726/10
4732/11 4734/8 4743/17 4751/4 4751/5
4767/9 4769/17 4774/12 4777/6
4780/20 4781/5 4782/6 4782/17
4789/21 4790/6 4791/1 4805/6 4812/17
4821/3 4821/14 4821/19 4823/19
4824/17 4831/14 4837/15 4838/25
4841/21 4841/23 4845/9 4845/14
4849/15 4850/7 4855/6 4869/8 4876/4
something's [1] 4725/9
sometimes [3] 4707/4 4829/24 4866/22
somewhat [1] 4880/9
somewhere [9] 4761/14 4772/11 4829/1
4829/17 4851/23 4854/5 4858/18
4859/12 4859/12
soon [2] 4812/4 4867/15
sorry [29] 4698/20 4704/14 4721/13
4747/8 4756/21 4758/1 4759/4 4759/14
4759/22 4765/14 4771/12 4777/21
4778/8 4797/14 4799/22 4799/23
4800/20 4800/20 4814/3 4814/6 4839/4
4843/9 4847/20 4855/12 4860/1
4863/18 4864/16 4866/2 4870/9
sort [3] 4688/11 4736/10 4736/24
sound [3] 4686/17 4697/4 4829/3
source [6] 4741/6 4784/24 4850/24
4851/10 4851/12 4851/13
space [1] 4829/18
spaces [1] 4814/22
speak [5] 4770/4 4789/14 4819/6
4833/23 4867/6
speaking [4] 4690/3 4705/3 4736/21
4743/21
speaks [1] 4872/5
specific [36] 4695/15 4696/4 4703/5
4703/5 4707/10 4708/7 4710/4 4773/21
4774/6 4774/6 4774/19 4782/22 4787/3
4787/4 4787/9 4787/11 4792/20
4794/13 4795/14 4812/11 4812/16
4812/18 4821/3 4821/12 4838/15
4841/1 4844/21 4845/6 4845/8 4849/10
4849/10 4850/22 4850/23 4861/1
4861/2 4864/12
specifically [20] 4679/21 4695/6 4743/17
4749/21 4764/3 4766/5 4769/15 4773/6
4773/21 4774/5 4781/10 4798/19
4828/14 4838/19 4839/16 4846/18
4851/18 4868/20 4868/20 4878/7
specifics [1] 4856/18
specified [5] 4810/24 4811/8 4811/20
4815/8 4872/7
speeches [1] 4681/4
spelling [1] 4753/16
spent [1] 4780/21
SPILL [1] 4668/4
SPIRO [1] 4671/4
split [1] 4783/15
spoken [2] 4739/1 4739/3
spud [3] 4735/24 4736/4 4736/6
square [1] 4795/10
SRP [1] 4823/9
stability [16] 4759/10 4764/18 4764/20

4768/3 4770/18 4819/18 4873/3


4873/23 4873/25 4874/16 4876/3
4876/7 4876/12 4877/5 4877/8 4878/19
stable [1] 4769/5
staff [1] 4688/4
stage [1] 4727/6
standard [17] 4685/5 4685/8 4699/24
4699/25 4700/16 4701/21 4701/21
4719/2 4719/22 4719/24 4734/15
4734/21 4735/20 4740/2 4742/6
4870/15 4876/20
stands [1] 4714/10
start [5] 4698/8 4709/11 4812/21
4834/19 4834/20
started [5] 4813/3 4813/12 4813/17
4816/11 4853/4
starting [5] 4698/16 4813/7 4814/2
4814/9 4880/5
starts [3] 4698/9 4750/23 4866/18
state [9] 4671/7 4671/11 4671/15
4698/5 4699/13 4753/15 4795/9 4795/9
4824/3
stated [1] 4680/2
statement [10] 4678/2 4679/20 4679/21
4682/17 4682/24 4706/10 4706/13
4714/19 4722/22 4735/12
statements [5] 4681/20 4681/23
4681/24 4682/1 4682/2
states [19] 4668/1 4668/10 4668/15
4670/8 4670/12 4670/18 4671/2 4691/1
4691/24 4694/11 4741/13 4770/12
4803/10 4806/23 4807/1 4807/19
4832/23 4846/2 4881/21
static [2] 4771/7 4795/3
station [2] 4671/5 4719/7
statistically [1] 4729/3
Statoil [1] 4730/7
stats [1] 4809/10
status [5] 4717/5 4717/15 4717/18
4718/2 4718/6
statutory [1] 4720/25
stay [1] 4689/13
stayed [1] 4775/14
Steering [1] 4753/22
stenography [1] 4673/23
step [1] 4813/9
STEPHEN [3] 4668/23 4748/23 4749/25
steps [2] 4694/12 4741/6
Sterbcow [2] 4669/5 4669/6
STERNBERG [1] 4673/12
Steve [2] 4687/4 4727/16
STEVEN [3] 4670/14 4672/9 4676/25
sticker [2] 4833/3 4833/20
stickers [1] 4848/18
still [5] 4712/23 4798/14 4815/13
4849/14 4881/8
stock [20] 4758/20 4759/21 4759/24
4759/25 4760/2 4760/3 4760/4 4760/15
4760/16 4760/18 4760/21 4760/23
4768/7 4768/9 4782/5 4784/6 4784/20
4849/14 4851/7 4852/8
Stone [1] 4672/22
stop [10] 4700/19 4705/7 4705/8
4705/10 4705/16 4706/2 4706/22
4712/12 4735/5 4855/8
stop-the-job [4] 4705/7 4705/8 4705/10
4706/22
stopped [1] 4820/15
stopping [1] 4881/10
storage [6] 4805/11 4805/24 4805/24
4806/3 4806/19 4824/22
store [1] 4849/13
straight [2] 4687/25 4688/3

surfactant [6] 4875/22 4875/24 4876/8


4876/14 4876/18 4876/21
straightforward [1] 4737/1
surprise [1] 4689/23
strange [3] 4671/8 4770/10 4770/14
surprised [1] 4818/14
street [20] 4668/20 4669/3 4669/6
surprising [1] 4723/7
4669/10 4669/13 4669/19 4669/22
suspected [1] 4725/14
4670/6 4671/12 4671/16 4671/19
suspending [1] 4880/21
4672/6 4672/10 4672/17 4672/23
suspension [1] 4880/21
4673/5 4673/9 4673/16 4673/19
sustain [1] 4877/25
4697/10
Sustained [1] 4738/10
strength [9] 4771/7 4795/3 4819/20
Sutherland [1] 4672/8
4820/6 4820/8 4820/9 4822/12 4866/16 switch [7] 4786/3 4794/23 4828/5
4871/8
4832/16 4834/3 4836/3 4845/18
strengths [2] 4777/17 4863/22
Switching [1] 4873/7
strike [2] 4836/9 4842/13
sworn [2] 4677/1 4753/13
string [1] 4727/1
sync [1] 4820/25
strong [1] 4680/3
system [59] 4693/13 4693/14 4696/20
structural [1] 4716/8
4696/23 4697/3 4698/14 4698/25
structure [2] 4722/18 4855/4
4699/2 4699/18 4700/1 4700/2 4700/7
structured [1] 4858/5
4700/23 4700/24 4701/1 4701/4 4701/8
studies [1] 4710/24
4701/10 4701/11 4701/16 4701/22
study [1] 4715/11
4702/8 4702/20 4702/22 4703/12
stuff [2] 4757/3 4784/1
4704/23 4705/11 4705/22 4707/1
subcontractor [1] 4690/8
4707/2 4717/8 4718/8 4718/11 4718/13
subject [2] 4749/9 4796/9
4718/14 4755/12 4755/13 4755/16
subjects [2] 4786/3 4794/23
4764/2 4764/4 4766/10 4778/9 4807/14
submit [2] 4812/5 4878/11
4809/1 4809/2 4809/5 4809/7 4809/9
submits [1] 4821/24
4811/9 4812/4 4848/18 4859/2 4859/2
submitted [8] 4784/9 4784/19 4809/11
4864/25 4866/1 4867/2 4867/8 4867/14
4809/12 4812/2 4813/3 4828/11 4878/6 4868/14
submitting [3] 4857/14 4868/2 4878/11 systems [1] 4700/3
subpoena [4] 4803/10 4804/21 4836/20
T
4837/15
T-I-M-O-T-H-Y [1] 4753/18
subpoenaed [1] 4836/18
Table [2] 4790/20 4790/23
subscribe [1] 4867/18
subsea [3] 4716/23 4717/1 4747/11
take [26] 4692/16 4698/21 4712/12
Subsection [1] 4747/3
4722/17 4723/3 4740/1 4741/6 4751/20
successes [1] 4683/23
4752/5 4752/9 4753/6 4781/8 4782/4
successful [6] 4684/17 4739/4 4741/2
4783/23 4786/25 4801/9 4803/16
4741/12 4741/17 4741/24
4818/25 4838/1 4844/17 4844/18
successfully [2] 4684/10 4875/3
4849/12 4851/15 4852/23 4868/17
such [6] 4721/2 4733/14 4735/21
4878/16
4789/10 4790/24 4872/22
taken [12] 4684/18 4694/13 4706/11
sued [1] 4807/19
4721/18 4729/1 4755/7 4769/1 4781/5
sufficient [1] 4875/24
4785/5 4830/2 4830/4 4856/19
suggesting [1] 4779/5
takes [2] 4795/8 4877/18
suggests [1] 4790/11
taking [5] 4699/8 4733/15 4737/4
Suite [13] 4668/20 4669/6 4669/10
4843/19 4881/15
4669/16 4671/19 4672/6 4672/10
talk [14] 4700/7 4705/13 4712/13
4672/17 4672/20 4673/5 4673/9
4819/15 4845/9 4851/18 4856/22
4673/12 4673/16
4856/22 4858/1 4868/19 4869/18
SULLIVAN [1] 4670/20
4870/7 4873/10 4873/23
summarizes [1] 4748/13
talked [17] 4683/24 4686/11 4688/25
summary [6] 4728/15 4728/20 4731/20 4689/16 4693/10 4693/11 4694/17
4747/20 4851/18 4863/8
4694/22 4703/17 4709/23 4724/14
supervisor [2] 4748/2 4748/17
4729/19 4734/19 4844/4 4864/7 4872/3
Supervisors [1] 4749/14
4872/25
supplier [2] 4695/24 4696/3
talking [17] 4705/1 4711/8 4759/7
supply [1] 4720/10
4761/10 4761/13 4762/1 4783/10
support [2] 4686/16 4728/11
4791/18 4792/7 4793/5 4805/3 4807/25
supports [1] 4728/1
4828/17 4850/5 4858/6 4861/22
supposed [4] 4774/13 4774/16 4795/25 4877/13
4802/3
talks [1] 4729/17
supposedly [1] 4784/16
tank [5] 4773/14 4784/24 4847/8 4847/9
sure [36] 4676/21 4689/13 4701/16
4847/10
4707/1 4707/2 4707/3 4712/14 4712/19 TANNER [1] 4673/15
4714/4 4737/3 4737/6 4752/24 4771/1 task [7] 4709/11 4710/4 4711/11
4711/23 4712/3 4712/18 4712/19
4775/19 4777/6 4777/12 4784/12
4784/18 4785/7 4789/8 4796/4 4813/2 task-specific [1] 4710/4
tasked [1] 4726/12
4817/17 4818/23 4829/8 4829/19
tasted [1] 4738/17
4843/22 4848/11 4851/24 4856/17
4858/7 4860/3 4873/18 4875/3 4879/4 taught [1] 4681/25
teach [1] 4858/22
4880/17

team [11] 4681/2 4684/22 4721/5


4852/21 4856/13 4856/14 4858/9
4858/9 4860/10 4870/1 4873/17
tech [6] 4774/13 4853/24 4853/25
4874/7 4874/9 4874/14
technical [2] 4686/16 4852/21
technically [1] 4679/5
technician [16] 4779/16 4814/23 4821/9
4821/14 4821/15 4821/16 4853/23
4853/25 4858/25 4860/23 4865/11
4866/18 4866/19 4866/24 4867/1
4873/3
technicians [16] 4809/13 4855/6
4858/12 4858/17 4858/19 4858/21
4859/3 4859/10 4866/7 4867/3 4867/5
4867/22 4868/23 4872/18 4872/21
4873/12
technological [1] 4790/10
technology [7] 4680/3 4686/15 4788/20
4788/22 4789/6 4789/16 4853/14
techs [5] 4820/24 4853/24 4859/15
4866/6 4868/21
tell [29] 4701/17 4720/22 4736/25
4753/2 4760/1 4784/12 4785/15 4789/7
4793/9 4817/21 4831/10 4831/13
4833/10 4840/23 4847/3 4847/6
4847/24 4848/7 4849/9 4850/20 4851/3
4852/13 4855/10 4856/9 4861/24
4862/12 4873/20 4878/22 4881/1
telling [4] 4767/14 4784/8 4802/16
4853/6
tells [2] 4795/8 4850/23
temperature [7] 4790/9 4812/16 4877/11
4878/8 4879/10 4880/23 4881/5
temperatures [1] 4857/12
ten [6] 4696/11 4705/2 4739/3 4750/7
4750/7 4782/19
ten-year [1] 4696/11
tenure [1] 4859/18
term [4] 4690/2 4692/8 4714/12 4738/15
terms [7] 4691/12 4692/6 4693/3
4722/25 4844/10 4862/12 4874/9
territories [1] 4808/3
test [153] 4711/15 4711/19 4711/25
4712/1 4737/21 4738/4 4739/4 4739/5
4739/22 4740/1 4758/3 4758/9 4758/21
4759/10 4761/3 4761/6 4761/18
4761/25 4762/2 4762/7 4762/9 4762/11
4762/21 4762/25 4764/19 4764/22
4765/1 4767/8 4768/13 4769/7 4769/8
4770/3 4770/16 4771/4 4771/11
4771/13 4771/14 4771/15 4771/16
4774/6 4775/20 4775/21 4776/10
4776/11 4777/3 4779/6 4779/10
4779/14 4779/16 4779/25 4780/14
4781/11 4781/23 4782/11 4782/16
4784/19 4785/9 4785/20 4786/1
4791/15 4791/16 4792/1 4793/2 4793/5
4793/25 4794/12 4794/13 4794/15
4794/16 4794/17 4795/13 4795/14
4795/15 4795/17 4796/1 4799/10
4800/6 4803/11 4806/10 4806/13
4808/25 4809/5 4809/10 4809/19
4809/21 4809/22 4811/8 4811/15
4811/15 4811/21 4812/7 4812/8
4813/12 4813/17 4814/2 4814/25
4815/12 4815/17 4815/22 4816/4
4816/12 4817/1 4819/20 4820/6
4820/10 4820/15 4820/18 4820/18
4820/25 4821/2 4821/5 4821/22
4821/23 4822/19 4843/3 4862/11
4866/18 4866/23 4866/25 4867/3
4867/16 4867/16 4867/22 4868/3

T
test... [29] 4868/24 4873/3 4873/13
4873/14 4873/19 4873/21 4873/25
4874/1 4874/3 4874/5 4874/15 4874/16
4875/5 4876/1 4876/2 4876/3 4876/7
4877/9 4878/19 4878/22 4878/25
4879/7 4879/11 4879/14 4879/16
4880/5 4880/6 4880/17 4881/1
test/pressure [1] 4739/4
test/tests [1] 4820/18
testament [1] 4684/17
tested [14] 4761/22 4762/1 4769/9
4772/8 4772/8 4772/17 4775/15
4775/16 4775/18 4777/17 4812/15
4812/16 4812/17 4866/11
testified [4] 4677/1 4753/14 4824/12
4834/5
testify [1] 4765/10
testifying [3] 4685/17 4738/7 4872/4
testimony [28] 4675/18 4675/24 4676/16
4676/18 4682/13 4682/18 4695/16
4697/20 4697/24 4698/13 4700/10
4713/1 4720/20 4738/12 4750/21
4772/23 4773/13 4773/15 4784/8
4803/8 4807/4 4819/17 4819/18
4820/20 4822/3 4832/13 4835/18
4838/19
testing [89] 4716/23 4717/1 4720/8
4720/14 4740/18 4741/1 4741/16
4741/24 4757/14 4757/16 4757/19
4762/4 4762/24 4763/2 4763/4 4763/9
4763/20 4764/5 4764/16 4765/7
4765/23 4768/1 4768/2 4768/19
4769/11 4769/12 4770/13 4771/20
4771/23 4773/2 4774/17 4775/3
4780/12 4783/5 4788/9 4791/18 4792/9
4792/18 4792/19 4792/20 4793/15
4793/23 4807/23 4808/10 4809/18
4810/3 4810/25 4812/3 4812/21
4818/12 4819/19 4823/8 4823/11
4844/25 4844/25 4848/24 4851/19
4852/1 4855/23 4856/6 4856/11 4857/9
4857/19 4858/14 4861/1 4861/2 4861/5
4863/19 4863/24 4864/1 4864/11
4865/4 4865/14 4865/16 4865/16
4866/3 4866/23 4866/25 4867/11
4870/8 4870/14 4870/15 4870/15
4870/25 4871/8 4872/19 4872/19
4873/24 4876/12
tests [71] 4712/5 4738/13 4757/8
4757/23 4760/25 4761/1 4763/17
4763/18 4763/25 4764/8 4764/12
4765/12 4765/18 4766/4 4767/11
4769/15 4770/17 4770/21 4771/4
4771/8 4776/8 4776/16 4776/19
4776/22 4777/24 4778/6 4779/2
4788/10 4791/11 4791/19 4792/4
4792/7 4792/21 4792/22 4792/22
4793/2 4793/16 4794/3 4794/3 4794/4
4794/18 4794/19 4794/21 4806/11
4807/24 4811/11 4814/23 4817/15
4818/7 4820/18 4820/20 4820/25
4822/4 4822/9 4822/18 4842/21
4851/19 4852/4 4852/9 4858/20
4858/23 4859/1 4859/16 4864/12
4864/23 4866/8 4868/1 4868/16 4871/2
4873/9 4877/5
tests/test [1] 4820/25
Texaco [1] 4725/22
Texas [8] 4670/4 4672/10 4672/21
4673/5 4673/10 4673/13 4673/17
4852/15

text [1] 4867/17


than [21] 4684/24 4690/7 4701/7
4702/14 4730/17 4732/9 4765/21
4783/18 4783/22 4795/21 4831/6
4831/7 4835/5 4838/15 4838/25 4841/2
4854/25 4874/1 4874/16 4877/1 4881/3
Thank [25] 4675/10 4675/16 4676/24
4742/2 4742/25 4751/6 4751/8 4758/16
4760/7 4760/24 4766/2 4769/22
4771/17 4774/10 4788/24 4791/8
4797/14 4806/22 4809/14 4814/17
4817/22 4823/24 4843/12 4849/5
4864/6
that [1266]
that's [253]
their [13] 4675/20 4681/5 4687/14
4708/19 4709/6 4722/16 4727/24
4730/1 4781/21 4846/24 4847/13
4858/22 4865/6
them [52] 4677/11 4677/20 4677/21
4683/7 4683/9 4687/10 4688/25
4690/11 4693/15 4693/25 4701/10
4705/14 4707/4 4708/19 4714/1
4715/21 4723/11 4728/1 4731/6 4756/3
4756/24 4760/1 4766/14 4767/3 4767/5
4768/25 4769/9 4777/19 4794/19
4801/10 4801/10 4801/11 4803/4
4803/5 4803/5 4818/22 4819/1 4824/19
4824/19 4829/9 4838/21 4839/6 4839/6
4839/23 4839/24 4840/18 4840/19
4841/2 4841/7 4852/20 4858/22 4867/1
theme [1] 4679/19
themselves [2] 4681/24 4723/7
then [82] 4682/15 4686/8 4686/19
4688/23 4689/2 4689/8 4698/23 4699/1
4699/5 4699/7 4699/19 4700/5 4701/2
4703/4 4703/9 4704/7 4708/7 4710/4
4710/6 4710/7 4710/23 4711/5 4712/15
4714/4 4715/7 4716/12 4719/5 4721/6
4723/3 4729/25 4730/21 4734/14
4742/18 4742/23 4743/13 4744/3
4751/12 4751/14 4752/13 4756/21
4768/12 4768/17 4776/8 4776/16
4777/7 4778/13 4779/10 4780/23
4784/6 4784/12 4788/23 4792/4 4793/2
4793/9 4805/15 4805/19 4811/2 4813/8
4817/15 4821/5 4821/15 4821/17
4821/23 4828/19 4829/17 4833/11
4835/23 4851/23 4854/2 4854/5 4854/6
4854/6 4858/10 4860/5 4865/3 4866/14
4867/7 4868/14 4868/15 4871/24
4874/10 4875/5
there [175] 4678/5 4678/18 4679/17
4680/23 4681/6 4681/9 4687/23 4688/3
4690/6 4690/7 4690/11 4690/13
4690/14 4690/15 4690/18 4691/20
4694/10 4696/10 4698/20 4699/18
4699/18 4700/2 4700/4 4700/5 4700/19
4702/17 4704/10 4704/18 4705/14
4706/14 4707/15 4707/15 4710/12
4710/18 4711/14 4711/16 4711/17
4711/18 4711/20 4711/21 4711/23
4717/18 4719/6 4721/7 4722/5 4722/10
4728/1 4728/12 4728/17 4729/4
4730/17 4730/24 4732/8 4732/23
4733/8 4733/9 4734/21 4735/8 4735/9
4737/10 4738/6 4738/18 4742/17
4745/15 4751/4 4751/5 4752/4 4752/13
4754/8 4754/22 4755/15 4755/25
4757/8 4758/24 4759/7 4761/17
4762/10 4762/24 4764/5 4764/8 4770/1
4773/4 4773/17 4773/19 4776/13
4777/11 4777/15 4778/16 4778/19

4779/5 4781/18 4782/24 4782/25


4784/7 4785/2 4785/4 4787/16 4788/15
4788/24 4791/19 4796/10 4797/14
4797/16 4798/3 4798/14 4798/17
4799/19 4801/12 4804/12 4804/21
4807/23 4816/6 4817/5 4820/5 4820/11
4820/23 4821/1 4822/16 4822/18
4823/10 4825/2 4825/5 4827/11
4827/23 4829/15 4829/16 4829/21
4829/24 4835/6 4835/19 4836/25
4837/2 4837/4 4837/5 4837/6 4837/7
4837/9 4837/10 4838/1 4838/2 4838/13
4838/23 4838/24 4839/2 4839/3
4839/21 4840/13 4841/3 4841/7
4841/11 4841/15 4841/25 4842/15
4843/13 4847/10 4847/20 4847/23
4850/20 4851/1 4854/2 4857/8 4859/23
4859/24 4862/20 4863/1 4863/9 4865/5
4866/24 4871/2 4871/11 4873/5 4873/8
4875/2 4876/20 4880/4
there's [54] 4678/17 4693/6 4694/3
4697/8 4701/2 4706/12 4706/18 4708/1
4710/15 4710/20 4710/23 4714/19
4715/11 4720/4 4723/19 4723/23
4729/25 4733/24 4750/18 4750/21
4752/25 4768/1 4772/22 4782/3
4782/25 4782/25 4783/1 4783/2
4783/14 4795/21 4798/21 4806/9
4811/17 4812/7 4817/1 4817/23 4818/2
4819/21 4825/10 4826/14 4831/12
4859/2 4866/9 4866/9 4867/6 4867/7
4867/13 4867/14 4867/20 4867/20
4870/7 4870/13 4872/12 4877/3
thermal [1] 4880/12
these [47] 4683/7 4684/3 4684/3 4684/4
4684/4 4693/5 4702/23 4733/4 4742/4
4760/10 4764/12 4766/4 4769/15
4776/19 4776/19 4777/18 4777/24
4778/9 4783/9 4789/3 4789/18 4798/1
4798/9 4804/22 4805/14 4807/7 4812/3
4817/11 4818/4 4828/25 4839/12
4839/14 4840/13 4851/24 4858/19
4860/22 4861/9 4861/24 4865/23
4865/25 4866/8 4872/12 4872/18
4872/19 4873/4 4873/9 4874/15
they [127] 4677/16 4684/5 4684/8
4684/10 4685/7 4688/17 4689/14
4690/9 4690/22 4695/18 4701/16
4703/8 4705/16 4705/16 4705/17
4705/18 4705/18 4705/19 4712/12
4712/18 4712/19 4723/8 4725/5 4730/6
4732/11 4732/12 4734/10 4734/14
4737/4 4739/4 4739/5 4744/10 4749/15
4750/4 4758/5 4758/21 4758/22
4758/24 4759/12 4761/1 4761/3 4768/2
4770/25 4771/1 4771/3 4771/4 4771/4
4771/7 4771/8 4772/18 4773/1 4778/13
4783/5 4783/6 4787/4 4789/3 4793/16
4795/17 4795/18 4796/6 4799/11
4799/12 4801/1 4801/2 4801/2 4801/3
4801/3 4801/5 4803/9 4804/1 4804/5
4805/7 4806/15 4812/11 4812/14
4812/15 4813/8 4817/13 4818/2
4818/23 4819/2 4819/3 4819/3 4828/15
4828/22 4829/5 4835/14 4837/12
4838/2 4839/3 4839/17 4840/22
4846/17 4848/16 4855/17 4855/18
4858/9 4859/5 4859/16 4861/1 4861/3
4861/4 4861/6 4862/1 4865/7 4865/12
4865/15 4865/15 4866/2 4866/16
4867/2 4867/7 4867/16 4867/17
4867/18 4867/19 4869/1 4869/3 4869/7
4869/9 4869/11 4869/13 4869/17

T
they... [4] 4869/21 4872/22 4873/12
4876/5
They'd [1] 4869/18
they'll [2] 4794/16 4848/18
they're [24] 4698/23 4701/12 4701/13
4703/10 4712/13 4712/13 4712/14
4723/9 4723/10 4723/11 4724/7
4731/25 4737/8 4771/1 4818/14
4830/18 4848/16 4858/21 4862/2
4865/14 4866/14 4868/16 4869/10
4872/23
thicken [1] 4879/4
thickened [2] 4878/24 4879/2
thickening [22] 4777/16 4792/21
4792/22 4793/16 4809/22 4811/20
4813/12 4813/16 4814/25 4815/6
4816/4 4816/12 4821/13 4822/11
4822/18 4863/24 4866/14 4871/7
4879/7 4879/10 4880/1 4880/6
thickening-time [1] 4809/22
thin [6] 4761/1 4761/4 4761/18 4761/21
4762/12 4764/9
thing [11] 4699/9 4699/10 4703/23
4724/8 4726/14 4734/19 4812/10
4826/3 4832/7 4839/6 4863/7
things [25] 4677/21 4681/12 4707/1
4708/14 4710/7 4710/9 4713/9 4713/10
4717/12 4724/6 4726/15 4727/1
4731/14 4756/23 4768/17 4791/4
4798/1 4801/8 4801/9 4806/10 4843/25
4844/4 4846/6 4846/18 4856/24
think [120] 4679/24 4682/14 4683/15
4684/21 4686/20 4689/17 4689/25
4691/14 4691/14 4693/11 4695/20
4697/2 4697/3 4697/9 4698/2 4702/1
4702/13 4702/21 4703/17 4704/12
4705/3 4705/8 4705/18 4705/19
4706/25 4707/4 4708/21 4709/10
4709/22 4709/25 4710/1 4710/4 4711/5
4711/7 4711/8 4711/8 4711/9 4711/12
4711/14 4711/16 4711/17 4711/18
4711/21 4711/23 4712/2 4712/4 4712/8
4712/11 4712/12 4712/17 4712/18
4713/4 4713/8 4716/2 4717/14 4722/3
4723/6 4723/23 4723/23 4725/11
4725/16 4726/3 4729/18 4731/15
4731/23 4732/11 4732/20 4733/10
4733/17 4734/7 4737/10 4739/15
4740/15 4747/6 4749/12 4750/6 4750/7
4750/10 4750/23 4750/25 4752/3
4752/11 4752/12 4752/13 4752/25
4767/16 4767/19 4768/3 4768/17
4769/3 4770/10 4770/14 4771/24
4772/20 4772/20 4792/22 4793/15
4800/3 4803/12 4818/17 4819/5 4819/6
4820/24 4825/3 4828/25 4829/4 4839/5
4845/5 4852/12 4853/2 4856/19
4862/16 4863/2 4863/7 4864/7 4874/19
4876/15 4877/23 4879/15 4879/17
thinned [1] 4881/3
thinning [1] 4880/12
thins [1] 4880/9
third [6] 4671/12 4717/4 4728/18
4741/11 4785/19 4848/3
this [316]
Thornhill [2] 4669/18 4669/18
thorough [1] 4700/2
those [104] 4675/25 4676/6 4676/13
4676/16 4676/19 4677/20 4679/22
4681/7 4681/8 4681/16 4681/17
4681/19 4681/23 4682/2 4683/4 4684/7

4688/16 4689/5 4693/3 4695/21


4696/16 4697/3 4697/8 4698/4 4700/3
4700/4 4702/2 4702/24 4702/25 4703/2
4703/4 4710/23 4712/6 4714/7 4718/21
4718/22 4719/2 4719/12 4719/22
4720/14 4724/6 4726/7 4727/1 4729/12
4730/2 4730/4 4730/5 4731/5 4734/25
4738/8 4742/25 4750/6 4761/1 4763/25
4770/20 4770/24 4775/19 4775/22
4776/22 4791/4 4794/3 4794/19
4796/14 4798/13 4799/13 4801/8
4801/9 4801/21 4802/9 4803/4 4804/8
4805/10 4805/23 4806/7 4807/16
4817/24 4818/10 4818/14 4818/21
4819/3 4819/8 4824/13 4825/7 4828/21
4829/13 4831/24 4839/5 4840/17
4849/13 4851/1 4852/9 4854/4 4855/15
4857/11 4859/15 4860/8 4860/14
4861/21 4867/3 4868/9 4870/16
4873/17 4878/7 4881/6
though [4] 4711/2 4806/15 4815/12
4838/9
thought [8] 4705/25 4749/15 4751/11
4796/20 4814/6 4814/16 4840/19
4871/17
thoughts [1] 4841/19
thousand [1] 4844/13
three [27] 4679/1 4707/1 4713/17
4713/21 4750/6 4752/20 4772/23
4802/19 4803/10 4804/3 4804/9
4804/12 4815/4 4815/6 4827/18 4828/2
4828/3 4828/3 4828/19 4828/21
4833/17 4842/11 4854/3 4878/21
4880/13 4880/15 4881/6
three-quarters [1] 4842/11
threw [5] 4707/4 4767/5 4767/7 4769/9
4840/19
through [29] 4683/17 4688/1 4707/21
4709/5 4709/5 4716/2 4733/4 4733/13
4733/15 4733/21 4744/6 4758/12
4758/13 4760/6 4765/15 4793/21
4807/21 4809/1 4817/2 4817/5 4829/20
4829/22 4853/24 4854/4 4861/8 4863/5
4866/25 4869/5 4869/9
throughout [2] 4700/18 4865/14
thrown [1] 4840/22
Thursday [1] 4778/21
thus [1] 4675/20
Tiber [1] 4683/24
ticket [2] 4846/2 4846/7
tie [1] 4851/23
Tim [3] 4777/3 4785/19 4843/25
time [103] 4678/1 4678/25 4683/16
4686/16 4701/13 4705/14 4727/7
4727/7 4731/7 4739/12 4739/12
4751/14 4754/5 4755/7 4755/21
4755/25 4757/8 4757/17 4760/19
4761/10 4761/14 4762/18 4763/3
4763/12 4763/23 4764/4 4765/22
4767/15 4767/24 4768/6 4771/2 4771/8
4771/14 4772/5 4774/21 4777/16
4780/21 4783/8 4786/7 4786/15
4786/18 4786/24 4787/7 4789/8
4792/21 4792/22 4793/21 4793/21
4801/7 4802/19 4806/8 4806/16
4809/22 4811/21 4811/21 4812/8
4813/12 4813/17 4814/25 4814/25
4815/6 4816/2 4816/4 4816/12 4816/17
4821/13 4822/11 4822/18 4825/2
4825/3 4833/19 4837/9 4843/1 4844/7
4851/24 4853/22 4854/5 4854/19
4858/2 4858/16 4859/8 4859/12
4863/24 4866/14 4870/6 4871/7

4873/22 4877/10 4877/18 4877/21


4878/9 4878/12 4878/12 4878/14
4878/14 4879/4 4879/7 4879/10 4880/1
4880/6 4880/25 4881/4 4881/13
time's [1] 4828/21
times [8] 4692/1 4740/9 4793/16 4814/1
4829/22 4857/18 4859/21 4859/24
timingwise [1] 4792/23
Timothy [5] 4753/12 4753/13 4753/17
4779/17 4871/17
TO97 [1] 4725/22
today [18] 4677/7 4683/9 4686/12
4686/21 4687/1 4688/25 4689/20
4709/23 4728/8 4731/16 4751/22
4752/6 4764/11 4765/10 4768/14
4807/11 4839/4 4849/8
together [7] 4676/19 4683/14 4702/6
4728/16 4732/15 4742/12 4787/16
told [26] 4756/12 4757/7 4757/18
4760/25 4762/23 4766/5 4766/11
4781/25 4783/23 4784/4 4801/9
4801/13 4801/20 4802/12 4824/13
4831/7 4837/12 4837/18 4838/4 4838/7
4838/11 4838/19 4839/3 4839/17
4841/10 4842/20
tolerable [1] 4715/5
Tolles [1] 4672/12
TOM [1] 4669/18
tomorrow [1] 4881/16
Tony [19] 4756/7 4756/8 4796/25
4797/3 4802/9 4805/17 4838/6 4839/17
4839/20 4840/3 4840/4 4840/9 4840/11
4840/12 4840/15 4840/16 4840/22
4841/14 4841/24
Tony's [1] 4841/17
too [5] 4769/9 4771/4 4839/15 4847/15
4869/22
took [23] 4721/20 4733/20 4734/12
4736/12 4738/3 4738/14 4742/17
4745/4 4745/8 4746/22 4753/8 4769/8
4802/10 4803/4 4815/1 4829/1 4833/15
4838/13 4846/6 4853/6 4875/13
4881/11 4881/12
toolpusher [1] 4727/25
top [41] 4682/3 4682/6 4693/1 4702/2
4702/24 4703/16 4710/10 4740/15
4749/12 4769/20 4772/14 4775/8
4777/13 4777/13 4778/10 4779/25
4785/19 4810/8 4810/12 4810/13
4810/20 4810/20 4810/22 4811/9
4811/17 4819/22 4825/3 4825/8
4827/14 4829/14 4832/17 4835/2
4850/6 4850/16 4871/24 4874/1 4874/4
4874/10 4874/13 4874/13 4874/16
topics [1] 4720/19
Torts [2] 4670/9 4670/19
total [2] 4731/3 4864/3
totally [2] 4726/11 4818/16
totals [1] 4863/10
touch [4] 4756/3 4782/1 4801/10 4802/4
touched [2] 4738/16 4801/22
tourists [2] 4690/13 4690/14
tours [1] 4725/19
towards [2] 4829/15 4855/9
TP [1] 4739/3
track [4] 4681/11 4684/21 4708/19
4831/9
tracked [2] 4731/14 4845/14
tracking [2] 4709/6 4849/16
Trahan [1] 4687/9
train [2] 4701/9 4748/5
trained [4] 4858/20 4872/18 4872/21
4872/23

T
training [12] 4695/2 4695/6 4695/12
4716/16 4716/19 4747/20 4748/3
4748/7 4748/10 4748/14 4748/17
4749/3
transcript [2] 4668/14 4881/22
transcription [1] 4673/24
transfer [2] 4846/2 4846/8
transition [3] 4720/20 4721/7 4772/5
transitioned [1] 4720/23
transitioning [1] 4771/8
transmission [1] 4704/8
Transocean [155] 4672/5 4672/6 4672/7
4672/8 4672/9 4672/10 4672/12
4672/12 4672/13 4672/16 4672/16
4672/17 4672/19 4672/20 4672/21
4676/7 4676/8 4676/12 4677/9 4677/13
4677/16 4678/18 4678/20 4678/25
4679/3 4679/8 4679/15 4680/2 4680/15
4680/20 4681/9 4681/13 4681/20
4682/3 4682/7 4683/15 4685/15 4686/6
4689/16 4689/24 4690/16 4690/19
4691/3 4691/24 4692/13 4692/14
4693/4 4693/7 4693/13 4694/17
4694/21 4694/24 4695/2 4695/5 4695/9
4695/12 4695/19 4695/25 4696/7
4696/17 4696/24 4697/6 4697/12
4697/13 4697/13 4700/17 4700/23
4701/1 4702/19 4703/7 4703/13
4705/24 4706/5 4706/20 4707/17
4708/12 4708/25 4709/17 4712/21
4713/4 4713/9 4713/10 4713/17
4713/22 4715/19 4716/20 4717/2
4717/16 4718/12 4718/19 4719/12
4719/13 4719/20 4720/15 4722/11
4724/22 4725/4 4725/12 4725/18
4726/11 4728/6 4728/8 4728/15
4729/22 4730/18 4730/25 4731/11
4732/5 4732/17 4735/15 4735/25
4736/3 4736/14 4737/3 4737/18
4739/17 4739/24 4739/25 4740/8
4740/8 4740/17 4740/17 4740/21
4740/25 4741/5 4741/5 4741/12
4741/21 4742/4 4742/9 4743/6 4745/12
4748/5 4770/12 4784/24 4785/2
4797/24 4798/2 4798/9 4799/11 4801/4
4801/15 4801/16 4801/24 4802/13
4802/13 4803/14 4804/1 4805/19
4825/18 4830/9 4843/7 4843/14 4851/2
4851/12
Transocean's [19] 4677/9 4678/7 4681/5
4693/8 4695/8 4701/6 4701/16 4702/7
4704/23 4705/11 4718/14 4726/9
4731/7 4737/23 4739/15 4742/5
4742/12 4751/9 4830/7
trash [2] 4767/5 4767/9
treating [1] 4733/14
treatment [2] 4719/8 4719/16
trend [1] 4880/7
TREX [73] 4677/23 4678/3 4678/15
4682/9 4690/23 4690/25 4701/24
4703/21 4709/15 4714/17 4721/12
4728/14 4734/1 4744/25 4745/10
4745/20 4747/18 4747/24 4748/13
4748/23 4749/10 4749/18 4750/9
4750/11 4750/14 4758/11 4760/6
4765/15 4769/19 4772/13 4775/7
4777/2 4779/11 4779/24 4788/3
4788/21 4797/1 4798/24 4800/6 4800/7
4800/19 4809/15 4809/16 4810/5
4810/17 4811/5 4811/6 4812/22
4812/23 4813/11 4814/5 4814/20

4815/10 4815/23 4816/8 4819/13


4819/13 4822/1 4822/9 4822/22 4824/8
4824/21 4825/14 4831/16 4832/17
4845/11 4846/17 4850/11 4861/7
4861/15 4865/17 4868/6 4871/12
TREX-05593 [1] 4775/7
TREX-1356A [1] 4690/25
TREX-1356A.20.4 [1] 4690/23
TREX-1429.20.1 [1] 4750/9
TREX-1449 [2] 4703/21 4709/15
TREX-2187 [1] 4714/17
TREX-23056 [1] 4832/17
TREX-23057 [1] 4831/16
TREX-23063 [2] 4824/8 4824/21
TREX-3110 [2] 4800/6 4800/19
TREX-3110-48002.2 [1] 4800/7
TREX-37042.4.1 [1] 4809/15
TREX-37042.4.2 [1] 4810/5
TREX-3769 [2] 4861/7 4861/15
TREX-3773.1.2 [1] 4822/22
TREX-41215 [1] 4682/9
TREX-4255 [1] 4728/14
TREX-4347-1848-1 [1] 4788/3
TREX-4566 [1] 4772/13
TREX-48001 [2] 4845/11 4846/17
TREX-48002 [2] 4797/1 4825/14
TREX-48093.1.1 [1] 4734/1
TREX-48193.3.2 [1] 4810/17
TREX-48193.3.4 [1] 4812/22
TREX-48193.4.3 [1] 4811/5
TREX-48193.7.6 [1] 4815/23
TREX-48194 [1] 4822/9
TREX-48194.8.2 [1] 4822/1
TREX-48195.1.2 [1] 4815/10
TREX-48195.9.6 [1] 4819/13
TREX-4942.20 [1] 4750/14
TREX-52545 [1] 4745/10
TREX-52546 [1] 4745/20
TREX-52658.1 [1] 4747/18
TREX-52658.12 [1] 4748/13
TREX-52658.16 [1] 4748/23
TREX-52658.4 [1] 4747/24
TREX-5474 [1] 4701/24
TREX-5482.1.1.TO [1] 4749/18
TREX-5482.10.1.TO [1] 4749/10
TREX-5570 [1] 4788/21
TREX-559 [1] 4798/24
TREX-5593.3 [2] 4777/2 4779/11
TREX-5593.5 [1] 4779/24
TREX-5642 [1] 4677/23
TREX-5642.2.1 [1] 4678/15
TREX-5642.5.1 [1] 4678/3
TREX-5643 [1] 4721/12
TREX-5650 [1] 4744/25
TREX-60405 [1] 4865/17
TREX-60415 [1] 4850/11
TREX-6235 [1] 4871/12
TREX-63141 [4] 4758/11 4760/6
4765/15 4769/19
TREX-7722 [1] 4868/6
TREX-802-W [1] 4814/5
TREX-802-W.1.1 [1] 4809/16
TREX-802-W.1.6 [1] 4812/23
TREX-802-W.2.5 [1] 4811/6
TREX-802W.1.7 [2] 4813/11 4814/20
TREX-802X.1.4 [1] 4816/8
TREX-802X.16.9 [1] 4819/13
trial [4] 4668/14 4738/7 4750/21 4819/7
trick [1] 4828/8
tried [3] 4705/24 4776/9 4813/25
Trinidad [2] 4725/25 4726/1
TRITON [1] 4668/8
true [17] 4682/1 4683/9 4694/20 4697/6

4698/15 4714/3 4722/22 4725/19


4733/11 4741/21 4782/2 4791/5
4792/14 4792/16 4879/3 4881/1
4881/22
trust [7] 4696/22 4696/23 4697/8
4697/12 4697/13 4699/20 4862/11
truth [1] 4803/24
try [10] 4677/6 4682/14 4685/15 4709/4
4728/23 4754/8 4812/12 4812/15
4847/1 4878/17
trying [23] 4760/19 4763/2 4771/22
4774/11 4781/4 4785/15 4793/14
4798/5 4802/8 4804/22 4805/13
4807/18 4816/22 4817/4 4817/6
4817/19 4817/20 4818/4 4828/8 4828/8
4832/8 4839/14 4852/5
TTT [1] 4731/3
turn [24] 4678/14 4696/20 4701/23
4711/6 4712/21 4716/1 4720/2 4728/14
4729/15 4730/11 4745/6 4748/13
4748/23 4749/9 4779/24 4834/7
4836/18 4838/11 4844/3 4847/19
4848/3 4861/11 4861/11 4877/5
turned [4] 4739/5 4836/22 4839/15
4846/18
turning [1] 4846/12
turns [1] 4732/11
Turton [2] 4770/23 4775/3
twice [1] 4735/18
two [38] 4688/12 4688/15 4688/16
4693/15 4697/10 4698/2 4698/4 4700/3
4713/20 4714/1 4723/19 4734/12
4742/20 4742/22 4746/7 4746/7
4751/15 4755/15 4759/17 4760/10
4764/8 4768/25 4773/4 4780/12 4785/4
4785/21 4791/4 4792/22 4793/16
4804/3 4806/5 4822/18 4827/8 4842/7
4849/1 4849/2 4858/8 4858/8
two-way [1] 4697/10
type [9] 4679/24 4681/19 4701/20
4703/2 4717/9 4726/17 4726/21
4806/12 4821/4
typed [3] 4827/11 4845/24 4845/24
types [2] 4710/23 4718/23
typically [9] 4689/25 4690/6 4719/17
4820/25 4869/8 4869/11 4876/21
4876/25 4878/15

U
U.S [7] 4670/8 4670/12 4670/18 4671/2
4680/9 4846/19 4872/4
UCA [7] 4777/16 4792/21 4793/16
4794/15 4822/11 4822/19 4871/8
Uh [1] 4775/13
Uh-huh [1] 4775/13
ultimate [4] 4708/17 4708/23 4709/4
4817/6
ultimately [6] 4708/3 4708/11 4708/14
4741/1 4741/16 4741/24
ultradeepwater [1] 4680/6
unanticipated [2] 4723/10 4724/2
uncommon [3] 4699/22 4723/9 4724/7
uncontrolled [1] 4744/11
under [14] 4690/25 4692/12 4693/6
4694/11 4694/13 4701/16 4704/19
4713/16 4720/25 4723/13 4726/11
4759/16 4778/9 4832/13
UNDERHILL [1] 4670/9
underneath [7] 4686/3 4686/8 4686/14
4687/4 4688/23 4689/2 4701/2
understand [35] 4690/18 4690/19
4693/6 4694/10 4705/18 4706/1 4707/2
4708/10 4717/12 4721/10 4726/16

4814/22 4817/9 4817/16 4819/16


4819/19 4824/4 4824/7 4825/14
understand... [24] 4737/4 4738/6 4752/2 4829/10 4829/25 4830/15 4831/15
4760/17 4762/14 4764/8 4764/10
4832/21 4833/3 4835/2 4838/10
4768/12 4773/18 4774/21 4774/24
4838/23 4840/5 4840/6 4840/10
4775/14 4775/17 4780/8 4786/17
4842/10 4842/10 4845/11 4849/22
4805/13 4807/18 4828/9 4837/13
4850/11 4850/12 4850/14 4851/24
4839/10 4839/14 4854/25 4856/9
4853/2 4853/22 4861/7 4861/18
4877/7
4863/10 4864/8 4865/8 4865/12
understanding [12] 4690/22 4691/12
4865/17 4865/21 4866/13 4867/15
4691/19 4691/20 4691/23 4692/5
4868/6 4868/20 4868/22 4868/25
4693/3 4723/24 4828/3 4837/24
4869/1 4869/5 4869/16 4869/23 4870/3
4864/19 4881/23
4871/12 4871/21 4871/23 4872/24
understood [9] 4703/14 4711/14
4873/2 4873/8 4875/7 4876/6 4876/6
4756/16 4773/4 4803/25 4827/12
4876/11 4876/16 4879/5 4879/7
4829/20 4838/2 4840/12
4879/23 4880/13 4880/15
undertake [1] 4712/18
upon [2] 4763/1 4880/5
undertaken [2] 4711/24 4712/2
upper [1] 4804/8
unfortunately [1] 4748/14
ups [2] 4801/14 4806/5
unique [3] 4723/23 4811/15 4848/12
us [11] 4680/3 4720/22 4759/5 4793/9
unit [5] 4688/1 4691/2 4691/8 4691/9
4833/14 4847/3 4847/6 4855/10 4858/4
4806/20
4861/24 4872/2
UNITED [15] 4668/1 4668/10 4668/15
use [25] 4692/1 4724/8 4727/13
4670/8 4670/12 4670/18 4671/2
4736/16 4759/21 4759/23 4760/1
4694/11 4770/11 4803/10 4806/23
4760/11 4760/15 4760/16 4760/21
4806/25 4807/19 4846/2 4881/21
4768/7 4774/3 4780/19 4783/5 4785/10
units [2] 4679/1 4679/1
4786/9 4788/13 4789/2 4809/5 4809/19
unless [7] 4734/8 4795/12 4795/14
4821/21 4846/10 4848/23 4874/20
4812/11 4812/16 4828/24 4869/7
used [97] 4675/18 4676/2 4676/15
unlikely [3] 4842/16 4842/17 4842/18
4679/19 4681/8 4681/17 4689/17
unloaded [1] 4730/1
4709/25 4717/12 4726/15 4726/18
unloading [12] 4732/24 4733/3 4733/9
4726/25 4736/14 4737/13 4738/15
4733/12 4733/20 4743/17 4743/20
4755/8 4755/12 4755/20 4755/20
4743/21 4743/24 4744/5 4744/8
4755/21 4756/1 4760/3 4760/4 4760/13
4744/13
4760/20 4763/3 4763/20 4771/10
unloads [1] 4744/15
4771/18 4771/21 4772/2 4772/4
unpumpable [1] 4815/2
4773/21 4774/6 4774/16 4774/23
unsafe [2] 4705/18 4705/25
4775/11 4776/10 4776/11 4776/17
until [13] 4763/15 4763/16 4763/24
4777/18 4777/25 4778/1 4780/11
4775/15 4787/7 4796/4 4802/18
4780/25 4781/10 4781/22 4782/5
4804/11 4853/2 4853/22 4854/19
4782/8 4782/10 4782/15 4782/22
4869/25 4881/16
4783/3 4783/24 4784/1 4784/14
unusual [4] 4770/15 4842/23 4842/24
4784/16 4784/19 4785/8 4785/9
4843/1
4785/12 4786/12 4787/6 4787/10
up [187] 4675/14 4677/23 4682/9
4787/24 4790/12 4792/9 4792/18
4682/23 4683/11 4685/11 4687/25
4793/1 4795/5 4798/22 4799/9 4801/17
4688/1 4688/1 4689/18 4690/21
4802/2 4802/5 4802/14 4802/21
4690/23 4690/24 4691/16 4692/10
4802/23 4804/25 4804/25 4807/5
4697/23 4700/8 4702/15 4704/5 4704/7 4809/8 4809/9 4810/21 4810/25
4705/4 4707/21 4709/20 4714/15
4811/12 4821/8 4835/24 4842/5
4721/12 4724/12 4727/9 4727/25
4844/14 4844/24 4849/9 4850/21
4728/25 4729/19 4734/11 4738/21
4852/8 4865/13 4865/14 4868/3
4739/10 4739/22 4744/3 4744/25
user [3] 4809/10 4867/14 4867/21
4745/10 4745/20 4746/4 4746/10
uses [2] 4864/24 4868/22
4747/9 4747/16 4747/23 4749/10
using [13] 4673/23 4681/7 4681/16
4750/9 4750/18 4751/12 4755/11
4683/4 4698/10 4698/25 4731/10
4756/12 4756/18 4756/19 4757/2
4758/3 4758/20 4768/8 4768/9 4817/14
4757/12 4758/23 4758/24 4759/9
4852/1
4759/9 4763/15 4763/16 4764/15
usually [1] 4864/14
4764/15 4766/17 4771/10 4771/18
4771/21 4772/1 4772/2 4772/2 4772/3 V
4772/7 4772/15 4772/17 4772/24
value [1] 4862/13
4772/24 4772/25 4773/5 4773/25
Vargo [1] 4822/25
4774/13 4775/4 4775/6 4775/7 4775/10 variety [1] 4864/8
4775/23 4777/8 4778/3 4778/3 4778/9 various [8] 4682/25 4684/18 4701/3
4778/13 4778/25 4779/13 4780/1
4703/9 4707/21 4818/7 4820/20
4867/15
4783/15 4792/17 4793/2 4793/23
4794/18 4795/9 4796/9 4798/6 4798/9 vast [1] 4689/23
4798/13 4798/17 4799/4 4801/7 4801/8 Vastar [1] 4692/23
verbal [3] 4709/22 4710/1 4711/17
4802/18 4804/22 4805/17 4807/5
4807/7 4809/20 4810/4 4810/9 4811/3 verbatim [2] 4772/16 4775/16
versatile [1] 4679/4
4811/11 4811/14 4811/25 4812/22
version [2] 4713/23 4748/10
4813/8 4813/16 4813/19 4814/1

versions [1] 4746/7


versus [3] 4850/3 4850/3 4875/14
very [22] 4693/1 4699/10 4710/10
4739/2 4743/11 4758/16 4768/15
4777/13 4777/13 4778/12 4778/18
4788/25 4794/9 4812/18 4823/18
4823/18 4824/2 4825/25 4827/14
4830/22 4832/5 4871/1
vessel [3] 4713/22 4716/9 4719/10
vice [2] 4686/9 4687/1
video [1] 4751/15
view [1] 4768/6
vigilance [2] 4723/1 4733/17
vigilant [1] 4723/15
Viking [48] 4755/11 4755/12 4755/13
4755/16 4763/18 4764/2 4764/4 4766/9
4766/11 4766/14 4766/17 4807/14
4807/15 4808/7 4809/1 4809/10
4809/20 4810/3 4810/8 4810/15
4810/21 4811/9 4811/17 4812/3
4815/14 4815/17 4816/23 4817/9
4817/16 4818/5 4819/25 4820/17
4822/9 4844/23 4848/18 4864/24
4865/1 4865/23 4866/1 4867/2 4867/5
4867/8 4867/12 4867/14 4868/13
4869/1 4869/6 4869/9
violated [1] 4742/5
Virginia [2] 4669/10 4669/10
virtue [1] 4715/2
viscosity [7] 4880/3 4880/5 4880/7
4880/13 4880/14 4880/15 4881/4
visit [1] 4725/18
visually [1] 4721/6
volume [4] 4812/12 4812/19 4844/10
4844/14
VON [1] 4673/12
VP [1] 4686/14

W
W.1.1 [1] 4809/16
W.1.2 [1] 4810/6
W.1.4 [1] 4810/18
W.1.6 [1] 4812/23
W.2.5 [1] 4811/6
wait [11] 4676/19 4728/2 4754/6 4754/6
4754/6 4778/7 4793/11 4834/11
4834/11 4834/18 4835/2
walk [2] 4807/20 4817/2
walked [1] 4825/4
Walker [2] 4669/9 4683/24
WALTER [1] 4669/12
Walther [1] 4672/22
want [51] 4675/13 4689/17 4690/17
4697/19 4700/7 4702/9 4703/16 4711/6
4715/21 4715/22 4733/2 4747/16
4750/9 4750/23 4751/19 4751/20
4752/21 4752/23 4766/14 4766/16
4773/6 4774/12 4777/6 4782/13
4786/16 4786/18 4787/21 4789/21
4791/11 4805/6 4818/2 4819/5 4828/21
4841/4 4841/19 4844/3 4845/9 4847/15
4849/19 4849/22 4850/1 4851/22
4851/24 4852/12 4855/8 4860/3 4861/9
4873/10 4875/7 4877/5 4881/9
wanted [23] 4685/16 4700/22 4734/2
4739/20 4757/19 4757/21 4757/23
4758/3 4758/5 4758/20 4758/22
4758/22 4759/12 4759/20 4760/1
4771/7 4794/22 4795/18 4848/11
4867/9 4869/16 4875/21 4875/23
wanting [2] 4792/20 4866/16
wants [5] 4728/3 4784/11 4796/1
4828/24 4867/6

W
warehouse [8] 4802/11 4803/5 4805/25
4806/3 4829/14 4829/17 4829/20
4841/6
was [367]
Washington [4] 4670/17 4670/22 4671/6
4672/4
wasn't [11] 4748/15 4763/12 4764/19
4782/23 4794/8 4799/25 4801/18
4804/16 4804/19 4816/3 4825/1
watch [4] 4717/20 4725/23 4726/8
4858/22
water [7] 4680/10 4681/15 4683/25
4739/6 4794/17 4866/15 4875/14
way [29] 4684/21 4688/2 4688/11
4688/13 4697/10 4697/16 4706/5
4708/15 4708/17 4726/17 4726/21
4727/3 4732/5 4737/3 4750/18 4751/24
4767/11 4768/11 4768/13 4802/24
4803/7 4807/22 4824/15 4845/13
4860/22 4867/17 4873/15 4874/11
4874/12
ways [2] 4867/13 4867/20
we [202] 4675/15 4675/17 4676/1
4676/2 4676/14 4676/22 4678/3
4678/14 4679/19 4680/16 4682/3
4682/9 4682/14 4682/20 4683/14
4683/23 4683/23 4683/24 4684/3
4686/8 4686/15 4686/19 4686/19
4687/6 4687/7 4687/13 4688/11
4688/15 4688/20 4688/20 4688/23
4689/2 4689/8 4689/13 4690/23
4692/25 4693/10 4693/11 4696/2
4696/3 4697/23 4698/8 4700/8 4700/15
4701/9 4701/10 4701/13 4701/18
4701/19 4701/20 4701/21 4702/15
4703/8 4704/13 4704/21 4706/14
4709/19 4709/23 4710/6 4711/2
4717/17 4717/25 4720/20 4722/3
4722/7 4724/12 4724/14 4724/15
4726/3 4726/12 4727/23 4728/2
4729/15 4731/3 4731/24 4732/3
4732/15 4734/19 4736/10 4739/1
4742/1 4742/10 4746/6 4746/8 4747/23
4750/13 4751/10 4751/11 4751/11
4751/12 4751/14 4751/14 4751/22
4752/3 4752/5 4752/7 4752/11 4752/25
4761/10 4761/13 4769/6 4769/11
4775/8 4779/7 4781/6 4782/4 4782/5
4783/10 4784/18 4791/17 4793/5
4798/6 4799/17 4801/13 4804/24
4805/12 4805/20 4807/3 4807/24
4808/2 4808/4 4808/8 4809/15 4810/5
4810/17 4811/5 4812/15 4812/22
4812/25 4813/11 4813/11 4813/15
4813/20 4814/4 4814/5 4814/6 4814/7
4814/11 4814/19 4814/25 4815/10
4815/23 4816/8 4816/11 4816/14
4816/25 4817/1 4817/4 4817/8 4817/10
4818/22 4818/25 4819/12 4820/17
4821/2 4822/1 4822/21 4823/4 4823/8
4826/23 4828/3 4828/5 4828/20
4828/22 4829/6 4829/11 4829/23
4831/18 4833/25 4834/1 4834/3
4834/11 4838/23 4840/15 4840/21
4844/3 4849/12 4849/13 4855/12
4856/22 4859/23 4859/24 4860/2
4860/15 4860/15 4860/16 4862/14
4863/5 4863/9 4864/7 4871/10 4872/3
4872/5 4872/9 4872/25 4873/16
4873/16 4873/19 4875/4 4877/23
4878/16 4881/12

we'd [3] 4807/20 4818/2 4878/16


we'll [9] 4676/19 4691/16 4752/14
4775/22 4784/12 4784/21 4785/7
4851/18 4851/23
we're [21] 4682/23 4701/16 4707/25
4714/4 4723/20 4723/21 4739/13
4751/13 4752/5 4761/13 4764/11
4804/22 4817/20 4817/24 4834/20
4848/11 4851/23 4871/20 4877/12
4880/17 4881/16
we've [20] 4675/18 4676/10 4676/16
4676/18 4677/7 4681/6 4694/21
4695/15 4705/1 4718/18 4718/21
4722/13 4751/24 4813/25 4817/1
4827/8 4827/18 4842/9 4843/25
4856/19
weaknesses [1] 4749/13
web [1] 4864/24
web-based [1] 4864/24
Webster [2] 4675/14 4676/10
Webster's [4] 4675/18 4675/24 4676/3
4676/3
Wednesday [1] 4802/19
week [7] 4694/6 4802/19 4804/7
4804/11 4806/2 4807/22 4831/18
weekend [3] 4786/6 4786/14 4831/3
weeks [9] 4755/4 4759/20 4761/13
4761/17 4763/19 4766/3 4767/8
4772/23 4807/8
weigh [69] 4771/10 4771/18 4771/19
4771/21 4772/1 4772/2 4772/3 4772/7
4772/15 4772/17 4772/24 4772/24
4772/25 4773/5 4773/25 4774/13
4775/7 4775/10 4775/23 4777/8 4778/3
4778/3 4778/9 4778/25 4779/13 4780/1
4792/17 4799/4 4807/5 4807/7 4809/20
4810/4 4810/9 4811/3 4811/11 4811/14
4811/25 4813/5 4813/8 4813/16
4813/19 4814/1 4814/22 4816/23
4817/9 4817/16 4818/5 4819/16
4819/19 4850/14 4864/8 4865/7 4865/8
4865/12 4865/21 4868/20 4868/22
4868/25 4869/1 4869/5 4869/16
4869/23 4870/3 4872/24 4873/2 4873/8
4876/6 4876/6 4876/11
weigh-in [2] 4816/23 4818/5
weigh-up [63] 4771/10 4771/18 4771/21
4772/1 4772/2 4772/3 4772/7 4772/15
4772/17 4772/24 4772/24 4772/25
4773/5 4773/25 4775/7 4775/10
4775/23 4777/8 4778/3 4778/3 4778/9
4778/25 4779/13 4780/1 4792/17
4799/4 4807/5 4807/7 4809/20 4810/4
4810/9 4811/3 4811/11 4811/14
4811/25 4813/8 4813/16 4813/19
4814/1 4814/22 4817/9 4817/16
4819/16 4819/19 4850/14 4864/8
4865/8 4865/12 4865/21 4868/20
4868/22 4868/25 4869/1 4869/5
4869/16 4869/23 4870/3 4872/24
4873/2 4873/8 4876/6 4876/6 4876/11
weighed [1] 4866/13
welcome [1] 4675/11
welfare [4] 4708/4 4708/12 4708/16
4722/15
well [251]
well's [2] 4807/6 4822/5
well-documented [1] 4680/5
well-monitoring [2] 4726/18 4726/24
well-performing [1] 4684/22
WellCAP [3] 4748/2 4748/17 4749/2
wells [25] 4677/14 4680/5 4680/8
4683/19 4684/3 4684/3 4684/4 4684/4

4684/7 4684/19 4685/5 4685/8 4694/13


4723/17 4724/1 4724/6 4725/22 4726/5
4726/7 4729/4 4729/12 4730/6 4732/17
4736/24 4857/1
went [13] 4678/7 4683/17 4716/2
4756/23 4772/1 4791/15 4791/23
4802/7 4829/22 4830/12 4831/13
4846/7 4854/4
were [219]
weren't [6] 4749/14 4771/23 4784/5
4789/6 4801/2 4804/5
west [1] 4852/17
what [278]
what's [11] 4712/14 4717/12 4774/16
4816/20 4817/6 4817/20 4853/12
4863/3 4866/10 4868/24 4870/16
whatever [9] 4722/17 4751/18 4752/15
4758/6 4784/15 4802/23 4805/1 4805/7
4829/6
whatsoever [1] 4733/16
Wheeler [1] 4689/3
when [102] 4677/13 4680/23 4683/7
4684/5 4688/9 4688/13 4693/1 4720/23
4721/5 4722/22 4723/10 4725/18
4725/21 4727/23 4733/23 4734/12
4734/20 4737/7 4743/21 4743/23
4743/25 4755/24 4757/2 4757/7
4757/12 4757/18 4759/19 4759/23
4760/25 4761/22 4761/24 4762/1
4762/1 4762/23 4762/24 4763/24
4766/3 4767/14 4768/18 4768/25
4770/7 4771/3 4771/3 4774/21 4775/2
4775/21 4777/23 4778/13 4783/9
4783/11 4783/14 4784/19 4786/18
4786/23 4787/2 4787/7 4787/13
4794/10 4803/8 4803/25 4805/17
4805/19 4813/3 4815/1 4829/21
4829/23 4831/2 4833/23 4833/23
4834/8 4834/16 4834/24 4836/16
4836/22 4838/6 4842/3 4842/20 4846/8
4846/10 4848/16 4848/17 4852/23
4853/15 4853/17 4858/21 4859/14
4860/8 4860/13 4865/22 4865/23
4865/25 4866/24 4869/25 4870/5
4871/11 4872/3 4872/3 4873/12
4873/21 4873/25 4878/3 4878/9
whenever [1] 4733/16
where [56] 4687/23 4688/17 4689/8
4689/14 4698/21 4703/25 4707/5
4708/20 4709/6 4718/3 4728/2 4732/10
4744/5 4745/6 4748/2 4750/19 4770/25
4771/1 4773/19 4777/12 4778/17
4778/18 4781/5 4793/15 4805/2
4805/10 4805/12 4806/2 4806/17
4814/22 4817/24 4821/11 4821/11
4821/14 4822/15 4824/4 4824/6
4824/23 4828/9 4829/23 4833/7 4846/5
4850/17 4852/13 4852/16 4854/11
4857/13 4866/11 4866/17 4867/9
4867/18 4869/3 4873/9 4874/15 4875/1
4875/4
WHEREUPON [4] 4676/25 4753/8
4753/13 4881/18
whether [39] 4681/22 4684/8 4693/15
4695/18 4696/22 4713/4 4736/13
4736/25 4739/11 4757/15 4762/20
4764/5 4769/4 4782/7 4785/10 4793/17
4804/16 4806/13 4813/5 4814/4
4820/23 4821/10 4821/17 4821/18
4821/20 4825/2 4829/15 4840/22
4842/21 4845/6 4849/9 4850/21
4858/24 4859/5 4875/21 4878/23
4879/3 4880/24 4881/1

W
which [64] 4677/25 4680/3 4680/7
4689/14 4689/18 4690/25 4691/2
4691/17 4692/13 4698/22 4698/24
4703/25 4704/7 4704/12 4705/5
4706/10 4707/5 4719/15 4728/25
4731/3 4732/5 4741/7 4741/22 4742/11
4747/17 4758/11 4764/9 4772/13
4773/9 4774/1 4774/5 4775/7 4776/8
4778/3 4779/24 4785/9 4785/22
4790/22 4792/17 4797/4 4799/1
4799/13 4800/21 4801/16 4807/14
4809/22 4812/19 4815/1 4818/11
4819/3 4822/4 4823/8 4826/11 4831/15
4832/13 4832/17 4832/17 4833/22
4844/24 4849/13 4851/11 4853/25
4854/7 4879/10
while [9] 4680/8 4692/20 4740/22
4777/16 4829/4 4830/18 4831/5
4840/10 4842/15
Whiteley [1] 4671/15
who [51] 4689/13 4694/7 4700/13
4706/1 4726/7 4726/12 4727/18
4730/10 4734/3 4736/22 4738/6 4738/7
4738/7 4738/13 4751/1 4752/18 4756/8
4757/5 4761/18 4779/4 4789/11
4795/17 4810/14 4810/24 4833/15
4837/2 4837/3 4837/7 4837/9 4838/4
4838/11 4839/11 4840/2 4852/25
4855/4 4855/17 4855/19 4860/1 4860/3
4860/8 4860/13 4861/17 4861/24
4864/12 4864/18 4865/9 4866/4
4866/18 4866/19 4868/1 4868/22
who's [2] 4751/9 4795/25
whoever [2] 4781/21 4782/16
whole [2] 4740/7 4825/2
whom [5] 4695/6 4735/22 4852/18
4867/3 4869/17
whose [2] 4723/19 4773/15
why [27] 4676/19 4724/3 4751/3
4758/19 4770/2 4779/3 4779/4 4780/21
4792/12 4792/20 4803/17 4804/7
4804/12 4804/13 4805/15 4815/20
4832/13 4835/4 4839/14 4842/12
4848/15 4851/8 4853/6 4866/21
4870/25 4874/11 4880/10
will [23] 4681/20 4699/2 4699/3 4699/17
4704/21 4722/10 4722/14 4736/25
4738/6 4745/9 4752/13 4752/20
4778/13 4780/4 4789/3 4789/3 4789/12
4810/12 4819/6 4820/10 4833/6
4834/13 4843/15
Williams [2] 4669/15 4669/15
Williamson [2] 4670/2 4670/3
window [1] 4811/21
WINFIELD [1] 4671/9
Winslow [1] 4687/9
wish [1] 4676/2
within [9] 4695/21 4702/19 4707/9
4709/17 4755/4 4808/5 4859/3 4860/10
4867/8
without [6] 4676/6 4765/18 4777/24
4823/2 4862/18 4863/4
witness [20] 4675/9 4735/22 4735/25
4738/3 4738/7 4751/10 4753/11
4753/12 4807/2 4807/16 4808/4 4808/9
4819/7 4819/8 4834/12 4843/11
4846/24 4847/13 4881/11 4881/15
witnesses [3] 4738/13 4773/15 4786/12
Wittmann [2] 4672/22 4672/23
Woelfel [2] 4727/16 4727/21
wondering [2] 4770/11 4880/24

word [4] 4709/25 4770/14 4801/23


4819/10
worded [1] 4824/15
words [12] 4679/9 4681/7 4681/8
4681/16 4681/17 4683/4 4683/7 4697/4
4698/23 4699/3 4702/2 4769/17
wordwide [1] 4724/18
work [12] 4692/21 4701/18 4701/25
4708/24 4711/8 4725/21 4766/23
4766/24 4859/9 4860/15 4860/16
4877/24
worked [5] 4693/13 4734/4 4735/5
4829/21 4858/17
workforce [2] 4858/5 4859/10
working [13] 4680/8 4687/19 4701/16
4708/5 4708/12 4730/9 4730/10
4732/17 4790/7 4829/9 4845/23 4858/8
4869/25
works [11] 4687/24 4697/16 4706/6
4707/17 4717/23 4730/7 4730/7 4730/8
4730/8 4730/8 4864/22
worksheet's [1] 4866/12
world [13] 4677/13 4679/4 4690/1
4693/18 4694/8 4697/17 4700/18
4710/17 4715/19 4726/5 4735/20
4860/11 4863/4
world's [2] 4677/17 4678/20
world-class [1] 4863/4
worldwide [3] 4678/22 4702/24 4703/1
would [204] 4675/17 4675/20 4676/8
4680/25 4681/18 4681/18 4684/23
4687/25 4689/23 4689/24 4691/23
4695/17 4696/17 4703/4 4705/8
4706/10 4706/22 4707/20 4711/14
4711/16 4711/17 4711/17 4711/18
4711/18 4711/20 4711/21 4711/23
4711/25 4712/2 4717/14 4718/23
4719/17 4720/15 4721/6 4721/10
4721/22 4727/12 4730/18 4731/21
4733/11 4734/15 4735/10 4735/25
4736/6 4738/12 4748/9 4748/20 4750/1
4751/11 4751/15 4751/21 4753/22
4754/25 4755/19 4756/3 4758/11
4760/20 4766/20 4768/4 4770/12
4771/18 4775/7 4777/5 4778/1 4778/10
4779/11 4779/24 4781/5 4781/17
4781/20 4782/1 4783/7 4783/21
4783/21 4785/19 4786/25 4787/18
4787/23 4788/7 4788/12 4789/10
4789/14 4789/16 4789/18 4790/12
4790/22 4791/4 4791/10 4791/11
4791/13 4792/23 4792/23 4794/3
4794/3 4794/4 4794/10 4794/15
4795/14 4795/17 4795/19 4798/3
4798/4 4799/1 4799/15 4800/21 4801/9
4801/10 4801/10 4801/20 4802/4
4806/7 4806/14 4806/14 4806/15
4806/19 4808/4 4808/8 4809/10
4809/19 4810/24 4812/5 4812/6 4812/6
4812/9 4812/11 4812/14 4812/15
4812/19 4813/8 4813/8 4815/1 4817/10
4818/11 4818/13 4818/13 4819/7
4820/5 4820/15 4820/25 4821/13
4821/15 4821/15 4821/16 4824/23
4825/8 4829/24 4831/4 4831/13
4833/18 4837/8 4842/12 4842/12
4844/14 4844/23 4846/17 4849/13
4850/20 4852/25 4854/19 4854/22
4858/18 4860/22 4862/11 4862/11
4862/22 4864/9 4864/18 4864/20
4865/3 4865/3 4865/7 4866/11 4866/12
4866/17 4866/17 4867/7 4867/11
4868/13 4869/7 4869/17 4869/19

4872/24 4873/2 4873/5 4874/2 4874/5


4874/7 4874/8 4874/13 4874/14
4874/17 4874/23 4875/4 4875/5
4875/12 4878/11 4878/15 4878/16
4878/16 4878/22 4879/3 4879/17
4881/1 4881/4
wouldn't [5] 4684/25 4787/21 4789/13
4803/17 4874/4
wrap [1] 4781/4
Wright [1] 4668/18
write [6] 4722/9 4766/17 4768/21
4770/13 4865/15 4872/24
writing [2] 4678/6 4765/18
writings [1] 4850/9
written [11] 4682/17 4709/22 4709/23
4710/2 4711/18 4712/4 4755/15
4763/17 4766/17 4767/2 4850/7
wrong [3] 4687/24 4723/20 4783/6
wrote [3] 4727/15 4727/21 4763/9

Y
Yancy [1] 4689/10
yeah [25] 4682/1 4695/8 4695/20
4701/9 4702/21 4708/21 4710/25
4711/11 4717/25 4729/24 4735/12
4735/20 4736/21 4742/19 4742/22
4776/4 4777/14 4800/1 4800/3 4805/17
4829/4 4871/17 4877/17 4879/1
4880/16
year [14] 4696/11 4730/18 4730/21
4730/24 4731/24 4732/2 4732/6
4732/16 4759/16 4763/15 4856/15
4859/21 4859/25 4870/9
years [16] 4750/7 4750/8 4759/17
4763/11 4765/1 4768/25 4794/11
4794/14 4802/19 4804/9 4829/16
4831/20 4859/9 4859/12 4859/23
4859/24
yes [368]
yesterday [1] 4751/12
yet [6] 4676/19 4762/7 4779/6 4797/4
4817/14 4818/16
Yoakum [1] 4670/3
you [1091]
you'd [2] 4780/16 4798/17
you'll [4] 4798/8 4798/20 4849/3
4875/15
you're [30] 4675/11 4681/22 4683/19
4692/8 4694/13 4705/14 4708/23
4710/5 4735/17 4735/22 4737/12
4759/7 4767/14 4774/21 4777/12
4781/4 4781/5 4786/17 4790/4 4793/9
4793/9 4795/6 4808/15 4809/2 4812/13
4822/7 4832/8 4833/5 4835/6 4868/9
you've [15] 4681/13 4689/21 4706/8
4710/24 4774/22 4796/5 4805/15
4807/7 4807/7 4843/3 4848/20 4849/8
4853/20 4853/21 4856/19
you-all [2] 4757/21 4774/2
YOUNG [2] 4671/5 4689/9
younger [3] 4749/14 4749/15 4750/1
your [203] 4675/8 4675/9 4675/13
4675/18 4676/1 4676/7 4676/24 4678/1
4678/5 4680/1 4681/4 4682/12 4682/13
4685/23 4689/16 4690/22 4691/12
4691/19 4692/5 4693/3 4694/7 4697/3
4698/13 4699/20 4700/7 4700/10
4701/15 4705/13 4706/8 4706/10
4706/25 4713/2 4713/13 4718/24
4722/5 4724/5 4725/18 4725/19 4726/3
4726/15 4734/4 4741/10 4743/5
4743/10 4747/17 4750/24 4751/7
4751/11 4751/16 4751/18 4751/22

Y
your... [152] 4752/3 4752/9 4752/11
4752/14 4753/11 4753/15 4753/20
4754/25 4757/3 4757/13 4758/25
4759/8 4760/12 4760/14 4762/7
4764/19 4764/21 4765/24 4766/5
4766/12 4767/8 4767/9 4767/20 4768/4
4768/4 4768/18 4768/25 4773/18
4774/3 4774/24 4775/4 4775/17
4775/23 4776/8 4776/11 4776/16
4778/6 4778/9 4779/10 4780/12
4780/23 4781/21 4782/1 4783/24
4784/4 4784/17 4785/19 4788/18
4789/10 4791/17 4791/20 4792/6
4793/13 4796/11 4796/15 4796/22
4797/12 4797/17 4799/14 4799/22
4800/5 4800/9 4800/13 4800/24 4801/3
4801/3 4801/14 4801/21 4802/1 4802/4
4803/8 4804/11 4805/5 4805/8 4805/14
4806/5 4806/20 4806/22 4806/24
4807/6 4807/15 4807/20 4807/21
4808/2 4809/17 4816/21 4816/25
4817/8 4817/18 4817/22 4818/1
4818/11 4818/16 4818/18 4818/22
4820/4 4822/13 4822/17 4823/16
4823/23 4824/2 4824/4 4825/9 4825/12
4828/10 4828/11 4830/25 4832/13
4833/5 4834/2 4835/18 4837/24
4838/19 4839/10 4843/6 4843/8
4843/15 4843/18 4844/1 4844/2
4846/24 4847/13 4847/16 4848/12
4849/1 4849/5 4849/8 4849/17 4852/5
4852/25 4856/10 4856/23 4856/25
4857/15 4858/13 4859/10 4859/18
4863/6 4863/12 4863/15 4863/20
4864/3 4864/18 4867/21 4867/22
4873/20 4875/19 4876/20 4877/5
4877/22 4880/14 4881/8
Your Honor [6] 4751/7 4751/11 4751/22
4752/3 4752/14 4849/1
yourself [6] 4685/20 4752/15 4765/8
4770/20 4776/17 4850/1

Z
zero [1] 4704/20
zone [13] 4729/22 4730/15 4730/25
4731/12 4731/21 4734/10 4779/19
4788/21 4788/22 4848/2 4851/5 4875/5
4875/8

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