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UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF LOUISIANA

***************************************************************

IN RE: OIL SPILL BY THE OILRIG DEEPWATER HORIZON IN THEGULF OF MEXICO ON APRIL 20,2010

CIVIL ACTION NO. 10-MD-2179 "J"NEW ORLEANS, LOUISIANA

WEDNESDAY, MARCH 27, 2013, 8:00 A.M.

THIS DOCUMENT RELATES TO:

CASE NO. 2:10-CV-02771,IN RE: THE COMPLAINT ANDPETITION OF TRITON ASSETLEASING GmbH, ET AL

CASE NO. 2:10-CV-4536,

UNITED STATES OF AMERICA V.BP EXPLORATION & PRODUCTION,INC., ET AL

***************************************************************

DAY 19 MORNING SESSION

TRANSCRIPT OF NONJURY TRIAL PROCEEDINGSHEARD BEFORE THE HONORABLE CARL J. BARBIER

UNITED STATES DISTRICT JUDGE

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APPEARANCES:

FOR THE PLAINTIFFS: DOMENGEAUX WRIGHT ROY & EDWARDSBY: JAMES P. ROY, ESQ.556 JEFFERSON STREET, SUITE 500POST OFFICE BOX 3668LAFAYETTE, LA 70502

HERMAN HERMAN & KATZBY: STEPHEN J. HERMAN, ESQ.820 O'KEEFE AVENUENEW ORLEANS, LA 70113

CUNNINGHAM BOUNDSBY: ROBERT T. CUNNINGHAM, ESQ.1601 DAUPHIN STREETMOBILE, AL 36604

LEWIS, KULLMAN, STERBCOW & ABRAMSONBY: PAUL M. STERBCOW, ESQ.

PAN AMERICAN LIFE BUILDING601 POYDRAS STREET, SUITE 2615NEW ORLEANS, LA 70130

BREIT DRESCHER IMPREVENTO & WALKERBY: JEFFREY A. BREIT, ESQ.600 22ND STREET, SUITE 402VIRGINIA BEACH, VA 23451

LEGER & SHAWBY: WALTER J. LEGER, JR., ESQ.600 CARONDELET STREET, 9TH FLOORNEW ORLEANS, LA 70130

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APPEARANCES CONTINUED:

WILLIAMS LAW GROUPBY: CONRAD S. P. WILLIAMS, ESQ.435 CORPORATE DRIVE, SUITE 101HOUMA, LA 70360

THORNHILL LAW FIRMBY: THOMAS THORNHILL, ESQ.1308 NINTH STREETSLIDELL, LA 70458

DEGRAVELLES PALMINTIER HOLTHAUS & FRUGEBY: JOHN W. DEGRAVELLES, ESQ.618 MAIN STREETBATON ROUGE, LA 70801

WILLIAMSON & RUSNAKBY: JIMMY WILLIAMSON, ESQ.4310 YOAKUM BOULEVARD

HOUSTON, TX 77006

IRPINO LAW FIRMBY: ANTHONY IRPINO, ESQ.2216 MAGAZINE STREETNEW ORLEANS, LA 70130

FOR THE UNITED STATESOF AMERICA: U.S. DEPARTMENT OF JUSTICETORTS BRANCH, CIVIL DIVISIONBY: R. MICHAEL UNDERHILL, ESQ.450 GOLDEN GATE AVENUE7TH FLOOR, ROOM 5395SAN FRANCISCO, CA 94102

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U.S. DEPARTMENT OF JUSTICEENVIRONMENT & NATURAL RESOURCES DIVISIONENVIRONMENTAL ENFORCEMENT SECTIONBY: STEVEN O'ROURKE, ESQ.

SCOTT CERNICH, ESQ.DEANNA CHANG, ESQ.RACHEL HANKEY, ESQ.A. NATHANIEL CHAKERES, ESQ.

P.O. BOX 7611WASHINGTON, DC 20044

U.S. DEPARTMENT OF JUSTICETORTS BRANCH, CIVIL DIVISIONBY: JESSICA McCLELLAN, ESQ.

MICHELLE DELEMARRE, ESQ.JESSICA SULLIVAN, ESQ.SHARON SHUTLER, ESQ.MALINDA LAWRENCE, ESQ.

POST OFFICE BOX 14271WASHINGTON, DC 20044

U.S. DEPARTMENT OF JUSTICEFRAUD SECTIONCOMMERCIAL LITIGATION BRANCHBY: DANIEL SPIRO, ESQ.

KELLEY HAUSER, ESQ.ELIZABETH YOUNG, ESQ.

BEN FRANKLIN STATIONWASHINGTON, DC 20044

FOR THE STATE OFALABAMA: ALABAMA ATTORNEY GENERAL'S OFFICEBY: LUTHER STRANGE, ATTORNEY GENERAL

COREY L. MAZE, ESQ.WINFIELD J. SINCLAIR, ESQ.

500 DEXTER AVENUEMONTGOMERY, AL 36130

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FOR THE STATE OFLOUISIANA OFFICEOF THE ATTORNEYGENERAL:

STATE OF LOUISIANABY: JAMES D. CALDWELL,ATTORNEY GENERAL1885 NORTH THIRD STREETPOST OFFICE BOX 94005BATON ROUGE, LA 70804

KANNER & WHITELEYBY: ALLAN KANNER, ESQ.

DOUGLAS R. KRAUS, ESQ.701 CAMP STREETNEW ORLEANS, LA 70130

FOR BP EXPLORATION &PRODUCTION INC.,BP AMERICA PRODUCTION

COMPANY, BP PLC: LISKOW & LEWISBY: DON K. HAYCRAFT, ESQ.ONE SHELL SQUARE701 POYDRAS STREETSUITE 5000NEW ORLEANS, LA 70139

COVINGTON & BURLINGBY: ROBERT C. MIKE BROCK, ESQ.1201 PENNSYLVANIA AVENUE, NW

WASHINGTON, DC 20004

KIRKLAND & ELLISBY: J. ANDREW LANGAN, ESQ.

HARIKLIA "CARRIE" KARIS, ESQ.MATTHEW T. REGAN, ESQ.

300 N. LASALLECHICAGO, IL 60654

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FOR TRANSOCEAN HOLDINGSLLC, TRANSOCEANOFFSHORE DEEPWATERDRILLING INC., ANDTRANSOCEAN DEEPWATERINC.: FRILOT

BY: KERRY J. MILLER, ESQ.ENERGY CENTRE1100 POYDRAS STREET, SUITE 3700NEW ORLEANS, LA 70163

SUTHERLAND ASBILL & BRENNANBY: STEVEN L. ROBERTS, ESQ.

RACHEL G. CLINGMAN, ESQ.1001 FANNIN STREET, SUITE 3700HOUSTON, TX 77002

MUNGER TOLLES & OLSONBY: MICHAEL R. DOYEN, ESQ.

BRAD D. BRIAN, ESQ.

LUIS LI, ESQ.355 SOUTH GRAND AVENUE, 35TH FLOORLOS ANGELES, CA 90071

MAHTOOK & LAFLEURBY: RICHARD J. HYMEL, ESQ.1000 CHASE TOWER600 JEFFERSON STREETLAFAYETTE, LA 70502

HUGHES ARRELL KINCHENBY: JOHN KINCHEN, ESQ.2211 NORFOLK, SUITE 1110HOUSTON, TX 77098

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FOR CAMERON INTERNATIONALCORPORATION: STONE PIGMAN WALTHER WITTMANNBY: PHILLIP A. WITTMANN, ESQ.546 CARONDELET STREETNEW ORLEANS, LA 70130

BECK REDDEN & SECRESTBY: DAVID J. BECK, ESQ.

DAVID W. JONES, ESQ.GEOFFREY GANNAWAY, ESQ.

ALEX B. ROBERTS, ESQ.ONE HOUSTON CENTER1221 MCKINNEY STREET, SUITE 4500HOUSTON, TX 77010

FOR HALLIBURTONENERGY SERVICES,INC.: GODWIN LEWIS

BY: DONALD E. GODWIN, ESQ.

FLOYD R. HARTLEY, JR., ESQ.GAVIN HILL, ESQ.RENAISSANCE TOWER

1201 ELM STREET, SUITE 1700DALLAS, TX 75270.

GODWIN LEWISBY: JERRY C. VON STERNBERG, ESQ.1331 LAMAR, SUITE 1665HOUSTON, TX 77010.

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OFFICIAL COURT REPORTER: CATHY PEPPER, CRR, RMR, CCRCERTIFIED REALTIME REPORTERREGISTERED MERIT REPORTER500 POYDRAS STREET, ROOM HB406NEW ORLEANS, LA 70130(504) [email protected]

PROCEEDINGS RECORDED BY MECHANICAL STENOGRAPHY. TRANSCRIPTPRODUCED BY COMPUTER.

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I N D E X

EXAMINATIONS PAGE

NATHANIEL CHAISSON................................... 6288

DIRECT EXAMINATION BY MR. BOWMAN..................... 6289

CROSS-EXAMINATION BY MR. BREIT....................... 6330

CROSS-EXAMINATION BY MR. UNDERHILL................... 6341

CROSS-EXAMINATION BY MR. LI......................... 6354

CROSS-EXAMINATION BY MR. BROCK....................... 6364REDIRECT EXAMINATION BY MR. BOWMAN................... 6403

RICHARD STRICKLAND, Ph.D............................. 6409

VOIR DIRE EXAMINATION BY MR. HILL.................... 6410

DIRECT EXAMINATION BY MR. HILL....................... 6418

E X H I B I T S

DESCRIPTION PAGE

EXHIBITS TREX-51133, TREX-1144, TREX-4514,

TREX-52664, AND TREX-4112 WERE ADMITTED..............

6284

EXHIBIT TREX-60083 WAS ADMITTED...................... 6422

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08:05:55

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P-R-O-C-E-E-D-I-N-G-S

WEDNESDAY, MARCH 27, 2013

M O R N I N G S E S S I O N(COURT CALLED TO ORDER)

THE DEPUTY CLERK: All rise.

THE COURT: Good morning, everyone.

VOICES: Good morning, Your Honor.THE COURT: Please be seated.

All right. Do we have any preliminary matters?

MR. BRIAN: We do, Your Honor.

Brad Brian for Transocean.

I have two thumb drives that I would offer and

file and ask to be admitted.The first, Your Honor, is dated -- it says, "TO

Video Played 3/20/2013, 3/21/2013." Those were the depo clips

for Leo Lindner, Buddy Trahan, and Murray Sepulvado.

May those be admitted, Your Honor?

THE COURT: These are the clips that have been played

already, correct?MR. BRIAN: Yes.

THE COURT: Okay, those are admitted.

(WHEREUPON, the above-mentioned exhibits were

admitted.)

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MR. BRIAN: The second one, Your Honor, that I would

offer, file and ask to be admitted, the thumb drive states, "TO

Video Played 3/26/2013." That's yesterday. That's the onethat contains Mr. McKay and Mr. Johnson.

They were subject to the rulings Your Honor made,

so they were redacted per Your Honor's ruling.

So I would ask that they be admitted.

THE COURT: Very well. Those are admitted.

(WHEREUPON, the above-mentioned exhibits wereadmitted.)

MR. BRIAN: Secondly, Your Honor, we took your

admonition to heart. We went back last night, and we looked at

our exhibits to see if we would offer any complete exhibits,

and we have -- well, we circulated a list of five documents.

They are TREX-51133, TREX-1144, TREX-4514, TREX-52664, andTREX-4112.

Two of those -- well, three of those are -- one

of them is a signed statement, which we used as a cull out of

Mr. Vidrine and Mr. Kaluza. I understand there is no objection

to that. That's 51133.

The next two, TREX-1144 and 4514, are theMr. Guide e-mail that has been displayed several times and the

Mr. Cocales e-mail. We just couldn't see that they had been

admitted.

THE COURT: Are any of those voluminous?

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MR. BRIAN: No. The only one -- you had asked --

TREX-4112 that was used with Mr. Perkin on cross-examination,

it's 20 pages of a multi-length contract, so we excerpted the20 pages. So none of these would be voluminous.

THE COURT: That's fine. I don't like to put in a

voluminous document of hundreds of pages, where only a handful

of pages are necessary or used during the trial. That's all.

MR. BRIAN: I think there were some manuals and stuff

that would come in with the bundling, Your Honor, but we hadyour admonition in mind.

So I would move those five exhibits in.

THE COURT: Very well. Those are admitted.

(WHEREUPON, Exhibits TREX-51133, TREX-1144, TREX-4514,

TREX-52664, and TREX-4112 were admitted.)

MR. BRIAN: Finally, Your Honor, last evening, latelast evening we circulated our exhibits to offer for

Mr. Ambrose and a revised list for Mr. Wolfe, after meeting and

conferring with the PSC.

I think those are still under consideration by

the parties. We were not able to get that out until pretty

late.I know that the PSC has offered some exhibits,

which we're still conferring on, with respect to Mr. Young,

their cross-exam of Mr. Young.

So, subject to our offering the exhibits from

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Mr. Wolfe and Mr. Ambrose, we would rest -- we would like to

keep the record open for that purpose; but, subject to that, we

would rest our case.THE COURT: Very well, thank you.

MS. KARIS: Good morning, Your Honor.

THE COURT: Good morning.

MS. KARIS: Hariklia Karis on behalf of BP.

We have circulated and not received any

objections to the exhibits that we used with Mr. Ambrose, andso we would tender that list and offer them into the record.

THE COURT: All right. Any objections?

Without objection, those are admitted.


admitted.)

MS. KARIS: Thank you, Your Honor.THE COURT: Sure.

MR. IRPINO: Good morning, Your Honor. Anthony Irpino

for the PSC.

The same. We have our list of exhibits used in

connection with our examination of Mr. Ambrose yesterday. We

have circulated that list and have received no objections.MR. BRIAN: I'm informed we're fine. We have no

objection, Your Honor.

THE COURT: Any other objections?

Without objection, those are admitted.

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admitted.)

MR. IRPINO: We are still meeting and conferring withTransocean on Mr. Young's list. We had three or four exhibits.

We should be able to do that after the break.

MR. GODWIN: Good morning, Your Honor. Don Godwin for

Halliburton.

We have our exhibits, as well, that were used in

the cross-examination of Mr. Bill Ambrose. We have circulatedthose, Judge, and to my knowledge, no objections. We'd offer

them at this time.

THE COURT: Any objections?

All right. Without objection, those are

admitted.

(WHEREUPON, the above-mentioned exhibits wereadmitted.)

MR. GODWIN: Thank you, Judge.

MR. BROCK: Good morning, Your Honor.

THE COURT: Good morning.

MR. BROCK: We, as Your Honor knows, now have briefed

in response to our motion for sanctions positions taken by theUnited States, the states and the PSC.

We wanted to ask permission to file a short, five

pages or less, response to the various submissions to address a

few substantive points.

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THE COURT: I'll allow that. How much time do you

need?

MR. BROCK: 5 o'clock today.THE COURT: Fine.

MR. BROCK: Thank you.

MR. GODWIN: Judge, if I might briefly --

This is Don Godwin.

-- just since Mike has brought that up, we join

in the PSC's request of Your Honor that this matter notinterrupt the trial, that it be carried --

THE COURT: I don't plan to let it interrupt the trial,

so you can be assured of that.

MR. GODWIN: In terms of a hearing or whatever, we'd

ask that it be carried to the end, Your Honor.

THE COURT: I have not decided how I'm going toproceed. I wanted to wait to allow everyone to weigh in first,

and then I'll consider it.

This will allow me time over this extended break

to at least, you know, consider how to go forward, and then

we'll talk about it next week.

MR. GODWIN: Okay, Judge. Thank you, sir.THE COURT: All right. Anything else?

Let's see, where are we?

MR. BOWMAN: I think we're at our first witness. I'm

trying to get hooked up here.

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6288

THE COURT: Right. Who is your first witness?

MR. BOWMAN: Bruce Bowman for Halliburton on direct

calling Nathaniel Chaisson.THE DEPUTY CLERK: Please raise your right hand. Do

you solemnly swear that the testimony you are about to give is

the truth, the whole truth and nothing but the truth, so help

you God?

THE WITNESS: I do.

NATHANIEL CHAISSON

was called as a witness and, after being first duly sworn by

the Clerk, was examined and testified on his oath as follows:

THE DEPUTY CLERK: Please take a seat, and if you'd

state and spell your name for the record.

THE WITNESS: Nathaniel, N-A-T-H-A-N-I-E-L, James,

J-A-M-E-S, Chaisson, C-H-A-I-S-S-O-N.THE COURT: Mr. Bowman, I thought it was Chaisson, not

Chaisson, okay.

MR. BOWMAN: Okay.

THE COURT: I wanted to hear it from him, though, to

make sure. That's how I would pronounce it.

MR. BOWMAN: I believe both of you two can pronounce itmuch better than I can.

With your permission, can I call you Nate?

THE COURT: Okay.

MR. BOWMAN: Okay.

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6289

Your Honor, what we're going to try to do is to

have Nate say what he was supposed to do out there, what he

did, and then the results.THE COURT: That's fine.

DIRECT EXAMINATION

BY MR. BOWMAN:

Q. Now, again, you just stated your name.

Where do you live?

A. Currently living in Church Point, Louisiana.Q. Who do you work for?

A. Halliburton.

Q. What do you do?

A. I'm currently a cementing service coordinator.

Q. What does that mean?

A. Basically, I monitor day-to-day operations of variousoffshore rigs and platforms and coordinate the movement of

personnel, materials, and equipment to location.

Q. Going back to the April 20, 2010, time period, what were

you doing?

A. I was currently a -- well, then I was a technical

professional for Halliburton, which is essentially a cementingengineer. I was in charge of designing cement slurries and

testing, going out on the various jobs and monitoring jobs to

ensure that they were executed as designed.

Q. Okay. Now, as far as this particular slurry and this

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OFFICIAL TRANSCRIPT

6290

particular job, you did not design it, right?

A. No, I did not.

Q. You were supposed to be doing what with it?

A. Going out to the job and, once again, ensuring that the

job was performed and executed as it has been -- as it had been

designed.

Q. Okay. By the way, how did you get the educational

background, how did you learn how to do something like that?

A. Well, most of it came from on-the-job training. I do havea degree in civil engineering, which aided me in converting

over to the petroleum side; but, most of it was on-the-job

training and training within Halliburton.

Q. How long did that go on before you actually went out to

the Horizon in April?

A. Let's see. That was in 2010. I believe I started withHalliburton midway through '07, give or take. But the actual

training period was plus or minus a year.

Q. Okay. Where did you grow up? Are you from Louisiana?

A. I'm from Lafayette, born and raised, yes.

Q. You say you have a civil engineering degree. Where did

you get that from?A. The University of Louisiana at Lafayette.

Q. All right. Now, what were you supposed to do on the

Macondo well?

A. I was going out, once again, to monitor the execution of

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6291

the job, ensure that the proper chemicals and cement volumes

were pumped.

Basically, as I stated previously, just ensure thatthe job was pumped as designed.

Q. Okay. How many other -- how many people were there? In

other words, you weren't going to do this all by yourself?

A. No.

Q. So kind of tell the Judge, if you would, the process, how

many people were going to be involved.A. Okay. Well, as far as Halliburton personnel?

Q. Yes, sir.

A. There were two cementers on location, which, I believe we

have two cementers on location at all times.

There was myself, a foam team leader. There was also

two individuals in control of the nitrogen equipment as well.So it was a team effort, basically.

Q. Okay. Do you recall about when you first arrived?

A. I arrived on the 16th, about 8:00 a.m., if I remember

correctly.

Q. April 16th?

A. Yes, sir.Q. We're going to show you your tally book in a minute and go

through some stuff --

By the way, what is a tally book?

A. My tally book is somewhat of a personal journal, I guess,

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6292

would be the best way to describe it. I use it just to jot

down notes as the days progress out on the rig, capture any

modifications or deviations from the plan, capture anysignificant points that I may witness.

Q. As far as the execution of the job, was there a plan --

A. Yes.

Q. -- a written plan?

Rob, can you go to TREX-00737 and Bates numbers, last

three, 303.Now, Nate, you have seen this before, have you not?

A. Yes, I have.

Q. What did you have to do with it?

A. Well, I typed up this particular document.

Q. So you actually typed this document?

A. Yes, sir.Q. And how did you know what to put down?

A. This was a combination of the -- actually, the plan I had

received from Jesse Gagliano, the cement procedure, as well as

a meeting that had taken place on the night of the 17th, I

believe, to discuss the cement job out on the rig.

Q. A meeting. Who was at that meeting?A. Various BP personnel. Company man, who would have been

Bob Kaluza. I believe Brian Morel was also present, a BP

Drilling Engineer. Myself. Foam team leader, Paul Anderson.

The nitrogen personnel were there, as well, Jack Abey and --

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6293

I'm sorry, I can't remember the second individual's name.

There were some TO personnel present, as well. I'm

not sure who those individuals were.

Q. What was the purpose of that meeting?

A. To discuss the execution of the cement job.

Q. It was discussed, I presume?

A. Yes, it was.

Q. Well, do you remember -- let's go to -- you see Item

Number 2? It talks about how much is going to be circulated.Do you see that?

A. Yes, sir.

Q. All right. Now, when it says, "per company man," why did

you insert that?

A. Well, if you read this particular line item, with rig

pumps, pump and circulate 1100 barrels at one barrel perminute, and then 150 barrels at four barrels per minute, that

was specifically dictated to myself and the other individuals

in the room by Bob Kaluza, who was the BP company man on

location.

Q. Did you know that was nowhere close to being at

bottoms-up?A. Yes. Correct. This was not -- based upon Halliburton's

recommendation, this is not sufficient, correct.

Q. Was there some discussion at this meeting as to whether

there would be a bottoms-up or just do this?

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6294

A. Yes, there was some discussion. It was brought up that

this particular volume did not meet Halliburton's best practice

of to bottoms-up.Once again, the company man, who was Bob Kaluza at

the time, stated, this is what we're going to circulate, and

this is what we're going to move forward with.

Q. All right. Pump rates, where did the pump rates come

from?

A. This was also dictated by Bob Kaluza.Q. All right. Just generally, for Your Honor's benefit, if

you pump faster versus slower, does that have any effect on the

quality of what you're pumping down?

A. It does have an effect on the cement job, yes.

Q. How?

A. Basically, the faster you circulate a fluid or the fasteryou pump, the more -- I guess you can say the closer you get to

turbulent flow in the annulus, which helps clean out the

wellbore, helps remove some of the mud that's been in the

annulus, so that the cement can be placed correctly or placed

efficiently.

Q. Just like if you're squirting something -- you have somemud on, say, the wall, and you squirt it very lightly, it might

not knock it off; but if you squirt it really fast, it will

knock it off? Is that a decent analogy?

A. That's a good analogy, yes.

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6295

Q. You're kind of squinting, so maybe it's not too good.

Well, going one step further, what's the purpose,

what does a bottoms-up do a versus a few hundred barrels?

A. It allows you to, once again, remove some of the mud

that's been built up in the annulus.

As we all know, fluid will take the path of least

resistance. So it's in your best interest or it's in the best

interest of the cement job to remove any mud that's been

sitting there in the annulus and gelling up over time.The faster you circulate, the more -- or closer to

turbulent flow you can achieve, and better mud displacement

you'll achieve.

By displacing that mud, you allow your cement to be

placed correctly and hopefully not contaminated.

Q. I'm following the words. I want to make sure that Iunderstand it and, more importantly, the Judge does.

So you clean it out. When you say you want the

cement hopefully not to be contaminated, what are you saying?

A. Hopefully, you remove all of the previous gel mud, which

will allow your cement to be placed without being contaminated

by any of that mud that's been left in the annulus.Not only are you concerned with contamination, but as

well as channel. As I stated, fluid will take the path of

least resistance. So, if there is mud remaining in the

wellbore, in the annulus, it's a possibility that cement will

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6296

just simply pump around it, which in case will not allow you to

achieve zonal isolation, which is ultimately the goal of a

cement job.

Q. I understand. Now, if there had been a bottoms-up, full

bottoms-up or cleaning on, I think, the 16th or something of

April, why would you also need to do it before the cement job

on the 19th?

A. Simply because of the time period. That mud has been

sitting in the annulus over a matter of days or hours. As mudsits static, it begins to gel. As those gels increase, it's

just that much harder to remove that mud from the annulus.

Q. Why don't we now go to TREX-00718, starting at page 515.

Now, you recognize this document?

A. Yes, I do. This is from my tally book -- or this is my

tally book.Q. This is your tally book.

It shows, 4/16, arrive on rig. Is that when you

arrived?

A. Yes, sir. 8 o'clock a.m.

Q. All right. Now, right below that, when it says rig is

currently -- what does that say right here?A. Rig is currently on bottom -- that's abbreviated, BTTM --

circulating, getting gas back.

Q. What does it mean, getting gas back?

A. That means that as they are circulating and the mud is

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6297

being brought back to surface, there is some encapsulated gas

in that mud. That typically comes from the formation.

Q. Why did you then think it was important enough to write itdown?

A. At this particular time, I happened to walk into the

company man's office. I was just going through orientation and

introducing myself to him. I heard this being mentioned, and I

just jotted it down, just as a side note.

Q. Okay. I understand.Let's go to the other side of the page, over here. I

think this will be all the people.

Why did you write these names?

A. Honestly, it's because I got in the habit of doing this on

every job. I'm not real well with remembering names, so just

as a personal benefit to myself. I just jot down the name ofevery individual that I need to familiarize myself with for

that particular job.

Q. Okay. Company men, Don Vidrine and Bob Kaluza. Had you

ever met them before?

A. No, I have not.

Q. But you obviously met them --A. Had not.

Q. --- when you were out there, right?

A. Yes.

Q. Cementers, Mr. Tabler, Mr. Cupit, had you met them before?

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6298

A. No, I had not.

Q. Had not. First time.

Then we have Mr. Jack Elmo. Is that the person youcouldn't remember his name?

A. Yes, Elmo is the second nitrogen operator.

Q. Mr. Paul Anderson, what was his job?

A. He was the foam team leader, abbreviated FTO.

Q. What does it mean to be the foam team leader?

A. The foam team leader is the lead on location of thatparticular operation. He oversees the execution of all facets

of that particular job.

Q. He's the one sort of in charge to make sure that the foam

gets foamed and down the hole?

A. Correct. He may also help out with the actual cementing

equipment, nitrogen equipment. Those guys tend to have aknowledge of all facets of that job.

Q. All right. Then we have Mr. Jesse Gagliano.

A. Yes.

Q. You had both his cell and his home number?

A. Correct.

Q. Had you worked with him before?A. I honestly don't recall if I had worked with Jesse prior

to this job. I don't remember working with Jesse, but I'm not

sure if I had met him prior to this job.

Q. You had worked with him, but not sure you had met him?

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6299

A. I'm not sure I had worked with him, but I had met him

before.

Q. What's this last thing mean?

A. This says, "BP engineer, Brian."

Q. Brian, is that Brian Morel?

A. Yes.

Q. Is that the first time you met him?

A. Yes.

Q. Can we now go to 516. And if we can focus in on thisfirst item right there.

The Dril-Quip tool, what does that mean? What are

you saying there?

A. "Dril-Quip tool didn't shear properly. Have to RIH," run

in hole, it's an abbreviation, "and retrieve."

Q. All right. And why did you put that down?A. This is a 7:00 a.m. entry. That's typically the 7:00 a.m.

morning meeting. It's something that may have been mentioned

in the morning meeting that I noted.

Q. As far as you know, that got resolved?

A. To my knowledge, yes.

Q. Now, let's go to 517. And focus on this entry.How do you know what to write down in your book, by

the way?

A. Once again, it's -- every engineer will typically have

different ways of documenting in the tally book. I tend to

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6300

write down anything that's significant in my mind.

Q. This entry at 1800, what's that, 6 o'clock at night?

A. Yes.

Q. "May have retrieved part of Dril-Quip assembly that was

left in the hole."

What's that all about?

A. Apparently I had heard that they had retrieved what was

left in the hole, whatever part of the tool had not sheared

properly. And POOH is a abbreviation for pull out of hole.Q. All right. These things just normally happen during

cement jobs or is this a little unusual? Why did you write

this down?

A. This is prior to the cement job. Actually, the days prior

to the job, myself and the rest of the Halliburton team, we're

preparing for the actual pumping of the cement, so we'retesting equipment and checking calibrations. And as I hear any

significant points that may be going on with the well, I'll jot

them down.

Q. Let's now go to 518 of the same exhibit.

And you'll notice this date is 4/18. I want to ask

you about what's above, so what are these figures?A. Those seem to be mud volumes. Those are significant

during displacement. I was jotting those down. It seems like

I was doing calculations on when pressure indications may be

seen.

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6301

"120 barrels to diverter plus 9 barrels to DTD,"

diverter test device, "plus an additional 9 barrels to the

plug."

Q. All right. By the way, do you know at this time if you

knew whether y'all were going with eight or nine gallons of

retarder?

A. I would say no, simply because of the note I have with an

asterisk right on top, longer pump time.

Q. Yeah. What does that indicate?A. If I put an asterisk by something, that's a bit of

information I don't have at that particular time, something I

need to discuss with someone or get a clear answer on.

Q. Let's now go to 520.

And this stars on 4/19. Is this the day that you

actually did the cement job?A. Yes.

Q. Now, there is -- if we come down to the right here, this

is, what, 13 -- what does that say, 1390?

A. Looks like 1340.

Q. 1340. What are you talking about right there?

A. "Landed casing at 18,218 feet," which would have beenmeasured. Took a 10K -- "Took 10K," which basically means took

10,000 pounds of weight.


A. It means you may have bumped into something. Just

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6302

basically means the casing is seeing some resistance to hitting

bottom.

Q. And this is a casing that is coming down from the top thatyou're eventually going to be cementing around?

A. Yes, sir.

Q. So as that casing is coming down, it bumps into something

that cause it to take a 10K?

MR. BROCK: Your Honor, I'm going to object to that on

foundation. He's not been tendered as an expert, and I don'tthink a foundation has been established on this.

MR. BOWMAN: I'll rephrase it.

THE COURT: Okay.

BY MR. BOWMAN:

Q. As the casing is coming down, when you wrote "10K," what

did that mean?A. It means that it took an additional 10,000 pounds of

weight to get the casing to continue or get the casing to where

it needed to be.

THE COURT: Let me ask, one thing I'm not clear on,

Mr. Chaisson, is this something you're -- with this note here,

for example, you're being told or you're hearing somebody elsesay or is this something you're doing yourself or what?

THE WITNESS: This particular note I would have heard

someone say this. I did not witness this actual event.

THE COURT: Okay.

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6303

BY MR. BOWMAN:

Q. Do you know who you would have heard it from?

A. No. I do not recall.

Q. Now, let's go back to this whole page at 520, and without

zeroing in, we have a one, we have a two, and we go on to the

next page, which is 521, then we have a series of numbers going

up through nine. What does all that represent?

A. Okay, I was actually up on the rig floor at this

particular time.Q. What time is that?

A. And this is previous to the cement job. Myself and the

rest of the Halliburton team, and all the individuals involved

in the cement job, had been called up to the rig floor for

what's called a re-job safety meeting.

And we walked up to the rig floor. At thatparticular time, they were going into -- attempting to convert

the float collar. And what you see here, one through nine, are

the nine various attempts of trying -- attempting to convert

that float collar while we're on the rig floor.

Q. So you were actually physically on the rig floor watching

who?A. Yes, we were on the rig floor. And there was TO personnel

operating the rig, and there was also -- Bob Kaluza was on the

rig floor as well.

Q. All right. So all of this information that you're writing

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6304

down, where did you get that from?

A. This is information that I'm hearing. It's being read

from the various monitors and sensors in the actual drill shackon the rig floor.

Q. All right. And I think the judge certainly realizes that

it took nine attempts to convert the collar, right?

A. Right.

Q. Did you have anything to do with actually converting the

collar or were you just watching?A. I was just watching.

Q. All right. Let's go to page 522, which, unfortunately, is

hard to read, but I think if we can blow up this part right

here, that says what?

THE COURT: Can I ask, does he have his actual book

here?MR. BOWMAN: I don't believe so, Your Honor, sorry.

THE COURT: I was just going to suggest it might be

easier for him to read.

MR. BOWMAN: I think this is the only page like this,

Your Honor.

BY MR. BOWMAN:Q. And the entry right there has what, 1621?

A. Correct.

Q. And that says, "Floats converted."

Now, why did you write down, "Floats converted"?

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6305

A. It seems at 1621 everyone was under the impression that

the floats had converted and the rig was able to circulate

fluid, circulate mud.

Q. How did you hear that?

A. Once again, just sitting -- standing back on the rig floor

and monitoring and listening to what's going on and jotting

down notes.

Q. All right. Now, did you hear anyone talk about, after the

conversion, anything unusual?A. Yes. It was noted that the circulating pressure, once the

floats had converted, or once the rig was able to circulate,

circulating pressure seemed to be low.

And I heard Bob Kaluza mention after witnessing --

after monitoring the circulating pressure, he made the

statement that, you know, "I need to make a phone call. We mayhave blown something higher up in the casing."

Q. Now, was he asking you that or is that something you just

heard?

A. That was just something I heard.

Q. And so what happened after that?

A. At that time, there were phone calls made. Thecirculating pressure continued to be monitored at various

rates. At one point they switched mud pumps, from one rig pump

to the other, monitored pressure as well at various rates. And

more phone calls were made.

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6306

Ultimately, walked back up on the rig floor and we

were told, "Hey, let's move forward with the cement job. We're

going to circulate and move forward with the cement job."

Q. Can we put this whole page back up for a second. And I

think we can blow this up.

Different pump?

A. Yes.

Q. That's an indication of what you were just telling the

judge that --A. Correct.

Q. -- everybody was trying to see if they went to a different

pump if the pressure would be higher?

A. Correct. At that point in time, they attempted to use --

to circulate with a different rig pump and monitored and

recorded pressures and rates to see if it would be anydifferent from the original rig pump they used.

Q. Did it make any difference?

A. Not -- not much of a difference, as I recall.

Q. All right. Did you call anybody during this period of

time?

A. I did speak with Jesse Gagliano at some point in time inthis process.

Q. What did you tell him?

A. Just informed him of what was going on, just to keep him

in the loop of activities prior to the cement job.

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6307

Q. And what did he tell you?

A. Basically just, "Okay, just keep me informed. Continue to

document what's going on. If anything else drastic occurs, youknow, just give me a call."

Q. All right. Let's go to page 523.

Is this when you start the cement job?

A. This is the circulation prior to the cement job.

Q. Circulation prior to it. All right.

And who told you to circulate?A. Well, Halliburton didn't actually perform the circulation.

After phone calls had been made, or in the process of, I'm

assuming, company men and Brian Morel making phone calls,

myself and the rest of the Halliburton team walked off the rig

floor for a minute.

Upon returning to the rig floor, I was told byDon Vidrine, "Look, we're going to circulate 110 barrels, and

then we're going to go into performing the cement job."

Q. So Mr. Vidrine is the one that told you, you were going to

be doing the job?

A. Correct.

THE COURT: Mr. Bowman, it's just been noted thatyou've been -- you're calling out, apparently, the Bates page

numbers.

MR. BOWMAN: What I've been calling out is, yes,

Your Honor, the last three digits.

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6308

THE COURT: The problem is, that's not the way we have

been doing it. We're trying to be consistent throughout this

trial. I think it's better if you use the TREX number and --that one that's on the screen now appears to be TREX-718-009.

MR. BOWMAN: Yes.

THE COURT: So it might be helpful to use that. If you

also want to refer to the Bates number, that's fine, but we

have to go back and retrace our steps here.

MR. BOWMAN: All right. Okay. Thank you, Your Honor.BY MR. BOWMAN:

Q. So now, you're staring -- when do you actually start the

cement job?

A. I would have to look at the -- later on in the tally book.

Q. All right. Can we show the whole page. See if that helps

you.A. It seems near 1928, third entry.

Q. Here?

A. We're blowing through nitrogen lines to pressure test

nitrogen lines. Typically the official start of a cement job

is with a pressure test of lines, so I would say 1928 would be

the -- officially the start of the cement job.Q. All right. There is a -- can we go back to the page, full

page.

And there is indication about bumping a plug. Do you

see that?

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6309

A. No, this is actually, once again, attempting to pressure

test the nitrogen lines. On the first attempt, there was a --

the line was plugged somehow, so they broke the line down,cleared it out and pressure tested again to 5,000 psi.

Q. Okay. Let's go to -- Rob, if you can give me 526, and

I'll call out the correct number. This is TREX-00718-012.

If we go to an entry, 29, what does that say?

A. Here I'm documenting the actual pumping of mud to displace

the cement. And here at 029, this entry says, "Bump bottomplug."


A. This means that the bottom plug -- we're assuming the

bottom plug has landed onto the float collar.

Q. How do you know that?

A. By pressure indication.Q. So show the whole page again, if you would.

And at 019, it says, "Got returns."

How do you know that?

A. Any information on returns I would have had to have

received from another individual because my equipment doesn't

have the capability of monitoring mud returns.Q. So who would have told you that?

A. That would have either come from the person working for

Sperry, who was Cathleenia Williams. Or during the cement job,

everyone has radios, basically walkie-talkies, and there is one

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6310

on the rig floor, and on occasion I would call to the rig floor

and ask, "Hey, are you guys getting returns? Are you seeing

full returns?" And I would get a response. Can't be certainwho was on the other side of the radio, but the radio was on

rig floor.

Q. All right. And I forgot to ask you one other item. Let's

to go the whole page again.

And right here, what does this say? "Bump top plug."

A. "Bump top plug."Q. What that does that mean?

A. Once again, a pressure indication that the top plug has

landed on the float collar, which is, for all intents and

purposes, the end of the cement job.

Q. What time was that?

A. This is -- I don't know. I need you to display the fulltally book again.

It seems to be between 037 and 043.

Q. All right. So, basically, that's the end of the cement

job?

A. Correct. The cement is in place. You can no longer

circulate through the casing and up the annulus at this point.Q. And what do you do then?

A. Depending on the job type, this particular job, if it's a

liner, then you go through the process of pulling the running

tool and circulating, etcetera.

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6311

Q. Let's go to page 527, which is TREX-00718-013.

And this is the -- seems to be the last entry. What

does this say?

A. This is the last entry at 0730. This is at the morning

meeting of that particular morning. It says -- I jotted down a

note here that the rig is going to be testing casing at

9:15 a.m. They're saying that's the 500 psi time on cement.

Q. Who told you that?

A. This was just said in the particular meeting. I'm notsure who made the comment.

Q. You didn't make the comment, did you?

A. No, I did not.

Q. So who was at this meeting?

A. The morning meetings typically included the company men,

the BP engineer, Brian Morel, TO personnel, Halliburtonpersonnel, and also individuals on the call. They would call

in to this meeting from town. I'm not sure who would call in.

Q. All right. So do you know who actually made this -- who

actually said 500 psi by 9:15?

A. No, I do not.

Q. We know it wasn't you?A. Correct.

Q. And you don't remember it being anyone else with

Halliburton, do you?

A. No, sir.

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6312

Q. By the way, did anyone, Mr. Morel, Mr. Kaluza, anyone ever

ask you how long they should wait on cement?

A. No. They did not, no.

Q. Did you ever hear them asking anyone from Halliburton how

long they should wait on cement?

A. No, I did not.

Q. Did you ever hear that discussed at all?

A. No, sir.

Q. Now, later on -- and this is, what, 7:30 meeting in themorning of the 20th?

A. Yes.

Q. And what did you do later that day?

A. After this particular meeting, I went back into the room,

continued to pack my bag and wait on the helicopter flight to

fly back in.Q. And you got on a helicopter flight so you were not on the

rig when it exploded.

A. Correct. If I recall correctly, we flew out sometime

around noon, and we were back home for -- about 1:00 p.m. that

day on the 20th.

Q. Were there Schlumberger people that were going to run theCDL on the same flight that you were on?

A. I don't recall.

Q. You don't recall?

A. No, sir.

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6313

Q. Actually, before the cement job, was there ever any

discussion with anyone on the rig about centralizers?

A. Yes.

Q. And who was that discussion with?

A. I personally had a discussion with Brian Morel and

Don Vidrine.

Q. Concerning what about centralizers?

A. In this case, the decision not to run 21 centralizers. I

was under the impression going out to the rig that there wereto be 21 centralizers on the casing. I later learned, while

being on the rig, that a decision had been made not to

run 15 additional centralizers and only run six.

Q. Did that concern you?

A. Yes, it did.

Q. All right. And did you voice that concern to someone fromBP?

A. I did have a conversation with Brian and Don Vidrine, yes.

Q. What did they tell you?

A. They simply informed me that, yes, that decision had been

made not to run the 15 additional centralizers, and they were

going to move forward with only six.Q. And did you let anyone know that decision?

A. Yes. I did make a call to Jesse Gagliano.

Q. And what did he say?

A. He seemed a bit upset about the decision. He said there

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6314

had been some previous talks during the design phase of the

job, and that individuals within BP were aware of, I guess, the

impact on the cement job.

Q. And what's the possible impact when you say impact?

MR. BROCK: Your Honor, I'm going to object to this as

being hearsay. I think Mr. Gagliano will be appearing, I

think, next week to testify and we can hear what he said at

that point.

THE COURT: You're asking this witness to say whatMr. Gagliano said to somebody else?

MR. BOWMAN: No. The question, I think, was: What

would be the effect of not having the right number of

centralizers?

MR. BROCK: On that one he said that he does not have

an opinion on that for this particular job because he was notinvolved in that, so I object on foundation.

MR. BOWMAN: That's not what he said at all.

THE COURT: Go ahead and reask the question, and let's

see what it is.

BY MR. BOWMAN:

Q. All right. Nate, what would the effect of not having the21 centralizers have been on this job?

MR. BROCK: I object on foundation.

THE WITNESS: On this particular job, based solely upon

looking at the simulations with and without the additional

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6315

centralizers, without the additional centralizers or the lack

of the additional 15 centralizers, would result in channeling.

BY MR. BOWMAN:

Q. If we go to TREX-00717-421, then I'll call out the correct

number. And this is TREX-00717.

All right. And have you seen this before?

A. Yes, I have.

Q. And what is it?

A. This is an e-mail which was sent out by Jesse Gaglianothat contained lab tests and an ISM report.

Q. We will look at those lab tests and the ISM report. Can

we blow up all of this. Make it a little bigger.

All right. Now, first one is Anthony Cupit,

Brett Cocales.

Do you know who Brett Cocales is?A. No, I do not.

Q. Don Vidrine, you know who he was, right?

A. Yes, sir.

Q. John Guide, do you know who John Guide was?

A. No, I did not.

Q. Murray Sepulvado, do you know who he was?A. I did not know at the time. No, I did not.

Q. And Ronald Sepulvado?

A. No, I did not.

Q. Mark Hafle, do you know who he was?

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6316

A. No.

Q. Greg Walz?

A. No.

Q. Let's look at the next page, which is 467, and this is

TREX-00717-002.

And what is this?

A. This is a lab test.

Q. Lab test. Okay. So this was sent to you and all those

other people, right?A. Correct.

Q. And the date of the e-mail, of course, was April 18th, on

Sunday, right?

A. Correct.

Q. And this lab test is actually two pages, the next page

being 467, which is TREX-00717-003.And that lab test shows a series of tests on the

particular slurry, right?

A. That is correct.

Q. And can we go back to 002.

And this shows a nine-gallon retarder. Do you see

that?A. Yes. Nine gallons of SCR-100L, which is the retarder

used.

Q. Do you recall when it was that you learned that it would

be nine versus eight gallons?

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6317

A. No. I do not recall the specific date. I want to say it

was the 17th or 18th.

Q. How did you find out?

A. I remember Brian Morel having some question about the pump

time and he didn't feel comfortable with the amount of pump

time on the eight-gallon test, so he asked about a nine-gallon

test.

Q. Did he tell you then they were going to use the

nine gallons?A. I did, at some point, find out that nine gallons of

SCR-100L was going to be used on this particular job, yes.

Q. And this particular page has a thickening time. You don't

need to blow it up. You can see that thickening time.

What is thickening time for the Court?

A. That is the time in which the cement is no longer deemedpumpable. It's ultimately the longest time period you have to

get the cement in place.

Q. That's the 7:37?

A. That is correct, 7 hours and 37 minutes.

Q. All right. Now, I notice -- let's go to the second page

now, which is 003, and it shows a series of tests.Then, unfortunately, it has a graph that is not

legible right now. Do you remember what that graph was?

A. Yes. This seems to be the thickening time test. The

graph of the actual -- of the actual pump time test itself.

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6318

Q. And let's go to the next page. That would be 004. That's

another graph. This one you can actually read a little bit.

What's this graph?

A. This is the graph of the compressive strength test, the

UCA chart --

Q. Yes, sir.

A. -- as we call it. It shows the compressive strength

development over time of this particular cement slurry.

Q. All right. So could you read this graph?A. I could make it out. I can't read it.

Q. When you actually received it, was it in a form that you

could read?

A. Yes.

Q. Now, what's the importance of a UCA test?

A. Once again, it shows the compressive strength developmentover time of the cement slurry being pumped.

Q. All right. Now, I noticed that there is not -- you have

all these tests here. There is not a foam stability test, is

there?

A. No, there is not.

Q. So all the people receiving this showed these tests, butno foam stability test.

A. Correct.

Q. You knew this was a foam job. Did you ask anybody about a

foam test?

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6319

A. No, I did not.

Q. Why was that?

A. I relied on Jesse Gagliano's testing, and I assumed thathe had tested for foam stability. That's typically the first

test that is performed when pumping a foam job.

Q. Okay, let's go now to 005. What is it?

A. This is OptiCem report, a simulation report.

Q. Yes, sir. That was attached to this e-mail, also. Did

you look at it?A. Yes, I did.

Q. Can we go to Bates Number 434.

MR. BROCK: Can you call a page on that, also?

MR. BOWMAN: Page 18.

MR. BROCK: Thank you.

BY MR. BOWMAN:Q. This is TREX-00717-008 -- no, let's see. Let's go to --

it's 434, sorry. You know, I'm looking at it -- I have a lot

of 434's here. Sorry, Rob.

Well, let's look at this. One place in that is on

page 18, there is something that shows gas flow potential.

739.18, thank you. Let's try that, Rob.Okay, you see that?

A. Yes.

Q. It shows a 10.29. What does that mean to you?

A. 10.29 gas flow potential means that it's in a severe range

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6320

of the probability of gas or hydrocarbon being able to flow

through the cement once it's in place.

Q. Is foam cement used in part when you want to try tocontrol a high gas flow potential?

A. Yes. It is.

Q. Did this particular OptiCem also show a high likelihood of

channeling, do you recall?

A. Is this the particular OptiCem with the six centralizers?

Q. This is one of the --A. I believe it is, yes. Yes, with the high gas flow

potential. Yes, this OptiCem does show channeling.

Q. You got this right before the cement job, correct?

A. Correct.

Q. Mr. Vidrine, Mr. Sepulvado and all those other people

would have received it at the same time, as far as you know?A. As far as I know, yes.

Q. Of course, Mr. Vidrine is the one that told you, go ahead

and pump the job, right?

A. That is correct.

Q. Now, after the job, what do you do? Or is that too open a

question? What are you supposed to do after the job?A. Immediately after a cement job is done, I'll complete the

post-job report. I'll then send it to the Account Rep, who was

Jesse Gagliano in this case. He reviews it and makes changes

and sends it on to his customer.

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6321

At that point, you know, the job is complete.

Q. Okay. We'll look at the post-job report in just a second.

You actually did two here?

A. Yes.

Q. Explain to the Court why.

A. Well, the first version of the post-job report was done

prior to me leaving the rig on the 20th.

The second version occurred, I believe, on the 21st.

I was called back into the office to -- really notmake modifications, but make an addition to my job log because

of the event, the blowout.

The blowout had taken place. My supervisor,

Michael Serio, asked me to come in and include every detail

from my tally book that I could possibly include in the

post-job report.Q. I'm just going to ask you about the -- I'll say the second

one. Someone else can ask you about the first, if they want.

Can we go to TREX-00713.

This is an e-mail from you to Jesse Gagliano and

Mr. Serio. You just mentioned Mr. Serio. Who was he?

A. Michael Serio was the lead technical professional inLafayette at the time. He was my manager at that time.

Q. All right. Let's go to page 646.

This is your event, right? You're writing down --

what all are you writing down there?

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6322

A. Yes, this is my job log, basically writing down

significant points.

It tends to pretty match up with -- it tends to matchup pretty much with the tally book. It's just significant

points throughout each day and things that pertain to the

cement job.

Q. All right.

MR. BOWMAN: Your Honor, may I have one second to

confer with my videographer because we have a lot of duplicatenumbers here?

MR. BROCK: I was going to mention, they all have

646 --

MR. BOWMAN: That's what I just noticed.

MR. BROCK: -- but call the page number.

MR. BOWMAN: That's what I just noticed.THE AUDIO/VIDEO TECHNICIAN: Just call the page number.

BY MR. BOWMAN:

Q. Okay, so let's go to page 2.

All right. Now, I want to ask you, first of all,

what is this whole page supposed to indicate?

A. Here, it's just a -- I guess, a -- just a sheet filledwith data of fluids being pumped, wellbore geometry

information, circulation data, etcetera.

Q. Let me ask you about this one thing. It says, estimated

TOC. That's top of cement?

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6323

A. Yes, estimated top of cement.

Q. Why does it say estimated?

A. This is the planned top of cement based upon the plannedjob in the proposal.

Q. All right. Because is there any way you can actually know

what the top of cement is?

A. In this particular case, no. It's estimated based on

fluids being pumped, volumes being pumped.

Q. In other words, if it was all pumped the way it wassupposed to, it would come all the way down, then it would go

up the annulus, and it would go up to that height?

A. Correct. That's assuming it pumps out the bottom of the

casing, up the annulus.

This is assuming you have a perfectly gauged -- I

guess, a perfect hole size, hole diameter, one hole diameter.This is assuming you've estimated the correct excess amount.

It's an estimated calculation.

Q. All right. There is no way -- well, is there any way you

can actually know for sure how high the cement was?

A. Yes.

Q. How do you know?A. You'd have to perform a cement bond log to do so.

Q. We all know one wasn't performed. So was there any way,

without performing one, anyone would know actually how high the

cement was?

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6324

A. Not to my knowledge, no.

Q. Let's go to page 6. Could we just blow this up.

MR. BROCK: Could we read the number into the record?MR. BOWMAN: This is 00713-007, Your Honor.

BY MR. BOWMAN:

Q. This is looking like it's pretty close to the end of the

job; is it?

A. Yes. This is on the 20th, correct. The morning of the

20th.Q. This is where you say, bottom plug bumped, top plug

bumped, right?

A. Correct.

Q. We've already seen those notations in your tally book?

A. That is correct.

Q. This last entry says, "check floats, bled back fivebarrels, floats held."

Now, what does it mean, bled back five barrels?

A. In order to check the floats -- after the top plug bumps,

you still have -- you're holding -- and the rig's holding

pressure on the casing, that pressure is bled back, released.

In releasing that pressure, you're going to get someflow back of volume. That flow back is typically taken back to

the cementing unit into the measuring tanks, where that volume

can be measured.

In this particular case, five barrels was measured

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6325

back to the cementing measuring tanks. It was then deemed that

the floats were holding as they were supposed to, and the

cement job was done.

Q. Now, how was it deemed the floats were holding? Did you

go look at them?

A. No, I did not witness this event. No, I did not.

Q. Who did?

A. Outside of the -- I can't be certain who was up there

because I was not in the cementing room when that occurred.Q. That's what someone told you; is that basically it?

A. Yes.

Q. Let's now go to page 7, which is TREX-00713-008.

Is this basically your conclusion?

A. Yes, it is. It's significant points from the job.

Q. Okay. It was pumped as planned. Full returns.That says full returns. Were you measuring returns?

A. No, I was not. I would have --

Q. Who was looking at that?

A. I would have gotten this data, once again, from

Cathleenia, who works for Sperry, as well as individuals on the

rig floor who were monitoring ret

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