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UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF LOUISIANA

IN RE: OIL SPILL BY THE OIL RIG * Docket 10-MD-2179DEEPWATER HORIZONIN THE *GULF OF MEXICO ON APRIL 20, 2010 * Section J

*Applies to: * New Orleans, Louisiana

*Docket 10-CV-02771, * March 5, 2013IN RE: THE COMPLAINT AND *PETITION OF TRITON ASSET *LEASING GmbH, et al *

*Docket 10-CV-4536, *UNITED STATES OF AMERICA v. *BP EXPLORATION & PRODUCTION, *INC., et al *

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

DAY 6, AFTERNOON SESSIONTRANSCRIPT OF NONJURY TRIAL

BEFORE THE HONORABLE CARL J. BARBIER

UNITED STATES DISTRICT JUDGE

Appearances:

For the Plaintiffs: Domengeaux Wright Roy& Edwards, LLC

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

For the Plaintiffs: Herman Herman & Katz, LLCBY: STEPHEN J. HERMAN, ESQ.820 O'Keefe AvenueNew Orleans, Louisiana 70113

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Appearances:

For the Plaintiffs: Cunningham Bounds, LLCBY: ROBERT T. CUNNINGHAM, ESQ.1601 Dauphin StreetMobile, Alabama 36604

For the Plaintiffs: Lewis Kullman Sterbcow & AbramsonBY: PAUL M. STERBCOW, ESQ.601 Poydras Street, Suite 2615New Orleans, Louisiana 70130

For the Plaintiffs: Breit Drescher Imprevento

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

For the Plaintiffs: Leger & ShawBY: WALTER J. LEGER JR., ESQ.600 Carondelet Street, 9th FloorNew Orleans, Louisiana 70130

For the Plaintiffs: Watts Guerra Craft, LLP

BY: MIKAL C. WATTS, ESQ.4 Dominion DriveBuilding 3, Suite 100San Antonio, Texas 78257

For the Plaintiffs: Williams Law Group, LLCBY: CONRAD "DUKE" WILLIAMS, ESQ.435 Corporate Drive, Suite 101Houma, Louisiana 70360

For the Plaintiffs: Thornhill Law Firm

BY: TOM THORNHILL, ESQ.1308 Ninth StreetSlidell, Louisiana 70458

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Appearances:

For the Plaintiffs: deGravelles Palmintier Holthaus& Frug, LLP

BY: JOHN W. DEGRAVELLES, ESQ.618 Main StreetBaton Rouge, Louisiana 70801

For the Plaintiffs: Williamson & RusnakBY: JIMMY WILLIAMSON, ESQ.4310 Yoakum BoulevardHouston, Texas 77006

For the Plaintiffs: Irpino Law Firm

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

For the United States U.S. Department of Justiceof America: Torts Branch, Civil Division

BY: R. MICHAEL UNDERHILL, ESQ.450 Golden Gate Avenue7-5395 Federal Bldg., Box 36028San Francisco, California 94102

For the United States U.S. Department of Justiceof America: Environment & Natural ResourcesEnvironmental Enforcement SectionBY: STEVEN O'ROURKE, ESQ.

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

Post Office Box 7611Washington, D.C. 20044

For the United States U.S. Department of Justice

of America: Torts Branch, Civil DivisionBY: JESSICA McCLELLAN, ESQ.

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

Post Office Box 14271Washington, D.C. 20004

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Appearances:

For the United States U.S. Department of Justiceof America: Fraud Section

Commercial Litigation BranchBY: DANIEL SPIRO, ESQ.

KELLEY HAUSER, ESQ.ELIZABETH YOUNG, ESQ.

Ben Franklin StationWashington, D.C. 20044

For the State of Attorney General of AlabamaAlabama: BY: LUTHER STRANGE, ESQ.

COREY L. MAZE, ESQ.

WINFIELD J. SINCLAIR, ESQ.500 Dexter AvenueMontgomery, Alabama 36130

For the State of Attorney General of LouisianaLouisiana: BY: JAMES D. CALDWELL, ESQ.

1885 North Third StreetPost Office Box 94005Baton Rouge, Louisiana 70804

For the State of Kanner & Whiteley, LLC

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

For BP Exploration & Liskow & Lewis, APLCProduction Inc., BY: DON K. HAYCRAFT, ESQ.BP America Production 701 Poydras Street, Suite 5000Company, BP PLC: New Orleans, Louisiana 70139

For BP Exploration & Kirkland & Ellis, LLP

Production Inc., BY: J. ANDREW LANGAN, ESQ.BP America Production HARIKLIA "CARRIE" KARIS, ESQ.Company, BP PLC: MATTHEW T. REGAN, ESQ.

300 N. LasalleChicago, Illinois 60654

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Appearances:

For BP Exploration & Covington & Burling, LLPProduction Inc., BY: ROBERT C. "MIKE" BROCK, ESQ.BP America Production 1201 Pennsylvania Avenue, NWCompany, BP PLC: Washington, D.C. 20004

For Transocean Holdings Frilot, LLCLLC, Transocean Offshore BY: KERRY J. MILLER, ESQ.Deepwater Drilling Inc., 1100 Poydras Street, Suite 3700Transocean Deepwater Inc.: New Orleans, Louisiana 70163

For Transocean Holdings Sutherland Asbill & Brennan, LLP

LLC, Transocean Offshore BY: STEVEN L. ROBERTS, ESQ.Deepwater Drilling Inc., RACHEL G. CLINGMAN, ESQ.Transocean Deepwater Inc.: 1001 Fannin Street, Suite 3700

Houston, Texas 77002

For Transocean Holdings Munger Tolles & Olson, LLPLLC, Transocean Offshore BY: MICHAEL R. DOYEN, ESQ.Deepwater Drilling Inc., BRAD D. BRIAN, ESQ.Transocean Deepwater Inc.: LUIS LI, ESQ.

335 S. Grand Avenue, 35th FloorLos Angeles, California 90071

For Transocean Holdings Mahtook & LafleurLLC, Transocean Offshore BY: RICHARD J. HYMEL, ESQ.Deepwater Drilling Inc., 600 Jefferson Street, Suite 1000Transocean Deepwater Inc.: Post Office Box 3089

Lafayette, Louisiana 70501

For Transocean Holdings Hughes Arrell Kinchen, LLPLLC, Transocean Offshore BY: JOHN KINCHEN, ESQ.Deepwater Drilling Inc., 2211 Norfolk, Suite 1110Transocean Deepwater Inc.: Houston, Texas 77098

For Cameron International Stone Pigman Walther Wittmann, LLCCorporation: BY: PHILLIP A. WITTMANN, ESQ.

546 Carondelet StreetNew Orleans, Louisiana 70130

OFFICIAL TRANSCRIPT

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Appearances:

For Cameron International Beck Redden & Secrest, LLPCorporation: BY: DAVID J. BECK, ESQ.

DAVID W. JONES, ESQ.GEOFFREY GANNAWAY, ESQ.ALEX B. ROBERTS, ESQ.

1221 McKinney Street, Suite 4500Houston, Texas 77010

For Halliburton Energy Godwin Lewis, PCServices, Inc.: BY: DONALD E. GODWIN, ESQ.

BRUCE W. BOWMAN JR., ESQ.FLOYD R. HARTLEY JR., ESQ.

GAVIN HILL, ESQ.1201 Elm Street, Suite 1700Dallas, Texas 75270

For Halliburton Energy: Godwin Lewis, PCServices, Inc.: BY: JERRY C. VON STERNBERG, ESQ.

1331 Lamar, Suite 1665Houston, Texas 77010

For M-I, LLC: Morgan Lewis & BockiusBY: HUGH E. TANNER, ESQ.

DENISE SCOFIELD, ESQ.JOHN C. FUNDERBURK, ESQ.1000 Louisiana Street, Suite 4000Houston, Texas 77002

Official Court Reporter: Jodi Simcox, RMR, FCRR500 Poydras Street, Room HB-406New Orleans, Louisiana 70130(504) [email protected]

Proceedings recorded by mechanical stenography usingcomputer-aided transcription software.

OFFICIAL TRANSCRIPT

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I N D E X

Page

Miles Randal EzellCross-Examination By Mr. Hartley: 1822Cross-Examination By Mr. Brock: 1847Cross-Examination By Mr. Beck: 1880Redirect Examination By Mr. Sterbcow: 1887Redirect Examination By Ms. Clingman: 1903

Ronnie W. Sepulvado

Direct Examination By Mr. Williams: 1918Cross-Examination By Mr. Underhill: 1947Cross-Examination By Mr. Kraus: 1954

Direct Examination By Ms. Karis: 1958

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MILES RANDAL EZELL - CROSS

AFTERNOON SESSION

(March 5, 2013)

* * * * *

THE DEPUTY CLERK: All rise.

THE COURT: All right. Good afternoon, everyone,

again. Please be seated.

Let's see. Who's up next? Halliburton?

MR. GODWIN: Yes, Your Honor.

THE COURT: Okay.MR. HARTLEY: Thank you, Your Honor. Floyd Hartley

for Halliburton, I'll be taking Mr. Ezell on cross.

(WHEREUPON, MILES RANDAL EZELL, having been

previously duly sworn, testified as follows.)

CROSS-EXAMINATION

BY MR. HARTLEY:

Q. Good afternoon, Mr. Ezell.

A. Good afternoon.

Q. I want to start with the morning meeting that you had on

the morning of April 20th, 2010. I think, in response to both

Mr. Sterbcow's question and Ms. Clingman's, you said that there

was at least some discussion about the cement job. Is that

right?

A. Yes.

Q. And if I heard correctly, you said that it was deemed to

be a successful cement job?

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A. To the best of my recollection, yes.

Q. This was a BP engineer on shore that's conveying that

information?

A. My memory's not clear exactly who it was that conveyed it,

but I heard it.

Q. And as a result, that they were not going to run a cement

bond log?

A. Yes.

Q. There were cement bond log tools on the rig that morning?A. To the best of my recollection, they were still there.

Q. And there was a Schlumberger crew on the rig that morning?

A. I believe so. I think they were supposed to depart that

day.

Q. Now, having been on the Deepwater Horizon for some nine

years or so, you have had experience with cement bond logs; is

that right?

A. I mean, yes, some.

Q. It's not uncommon to run a cement bond log?

A. That's correct, it's not uncommon.

Q. Now, had one been run and an issue with either top of

cement or channeling had been identified, that would give the

crew the opportunity to run some remediation of the cement job?

A. I suppose, if that was BP's election to do that.

Q. That's not a Transocean decision?

A. No, sir, that wouldn't be.

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Q. In your experience, is it uncommon to remediate cement

jobs?

A. Is it uncommon to do what?

Q. To remediate cement jobs, run a squeeze job?

A. No, I wouldn't say it was uncommon.

Q. It's something that happens on rigs?

A. Yes, it does happen from time to time.

Q. And had a cement bond log been run that morning and an

issue identified with the cement, an opportunity to remediatethe cement in the primary casing job could have been performed?

MR. BROCK: Your Honor, objection. He's calling

now -- asking now for opinion testimony from the witness. I

object to it on that basis.

THE COURT: Your question is: Had a cement bond log

been run, could it have been --

MR. BROCK: It sounds like --

MR. HARTLEY: Based on the witness's experience on

the rig and having run CBLs and having been there for the

performance of squeeze jobs.

THE COURT: That sounds like something you ought to

be talking to the cementing experts about, though. I'm going

to sustain the objection.

BY MR. HARTLEY:

Q. You were on the Deepwater Horizon for basically its entire

life in the Gulf of Mexico?

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A. That's correct.

Q. You worked as a driller, toolpusher, and senior toolpusher

on that rig?

A. That's also correct.

Q. Okay. Now, Ms. Clingman ran through some of your

education and training with Transocean. Do you recall that?

A. Some of my training?

Q. Some of your training. For example, you've taken well

control school?A. Yes.

Q. With Transocean?

A. Yes.

Q. You've been well-control certified?

A. I have.

Q. In fact, you've been recertified about every two years

since the late '80s?

A. It's been multiple times. I don't remember exactly how

many.

Q. It's fair to say you're generally familiar with the basic

principles and concepts of well control?

A. Fair.

Q. I think, in response to Mr. Sterbcow's question this

morning, you'd mentioned that mud is the first barrier in the

well. Is that fair?

A. Yes.

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Q. If we look at TREX-1454 at 286809.

Now, when you've taken these well control schools

with Transocean, I think you said you covered in fairly great

detail the Transocean Well Control Handbook?

A. Correct.

Q. You took tests on the various sections?

A. Correct.

Q. So you are familiar with the well control manual that was

actually on the rig?A. I'm sorry. Say that again.

Q. You were familiar with the Transocean Well Control

Handbookthat was on the Deepwater Horizon?

A. Yes.

MR. HARTLEY: If we go to page 6809. Blow up the

first paragraph.

BY MR. HARTLEY:

Q. Now, I think this is consistent with what you just said --

let me know if I'm wrong about that -- that "the primary well

control is the use of wellbore fluid density to provide

sufficient hydrostatic pressure to prevent the influx of

formation fluid into the wellbore. It is of the utmost

importance that primary control is maintained at all times."

Would you agree with that?

A. Yes, I would.

Q. Before you displace that heavy mud with seawater in the

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well, you want to make sure of the well integrity; is that

fair?

A. Yes.

Q. If there's any question about the integrity of that well

downhole, the job and make sure you get it right?

A. Yes.

Q. And that's why I think you told Mr. Sterbcow that

vigilance is absolutely necessary at that point and through the

displacement progression. Fair?A. It's necessary from a driller at all times.

Q. But even more so at this point where you're displacing and

removing the primary well control barrier?

A. It's very important.

Q. And whose decision is that to remove that primary barrier?

A. Whose decision, was your question?

Q. Yes, sir.

A. That would be something that -- that would be under BP's

decision-making process.

Q. Okay. Halliburton, for example, either the cementer or

the mud log company, they're not involved in the decision on

whether to remove the mud engaged in displacement?

MS. CLINGMAN: Your Honor, I'll object to lack of

foundation.

THE COURT: Sustained.

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BY MR. HARTLEY:

Q. In your nine years in the Gulf of Mexico on the Deepwater

Horizon, have you had an opportunity in these 50-some-odd wells

you've been on to be on tour during the displacement procedure?

A. Be on tour during displacement of?

Q. The displacement of heavy mud to seawater.

A. Yes.

Q. Have you had an opportunity to review displacement

procedures that have been provided to Transocean?A. Yes, I have reviewed displacement procedures in the past.

Q. Did you review the displacement procedure on the Deepwater

Horizon for the Macondo well?

A. On what day are you referring to?

Q. On the morning of April 20th, you attended a Transocean

meeting and then the morning meeting with BP. In either of

those meetings, was the displacement procedure discussed?

A. Not to my knowledge. It was held generally on the rig

floor.

Q. Do you recall ever having seen the displacement procedure?

A. I virtually had no input on the displacement procedure.

That was handled without me.

Q. In your experience from prior wells, these 50-odd wells

you drilled or helped drill in the Gulf of Mexico, did you have

an opportunity as a driller or a toolpusher to actually be

involved in the displacement of those wells?

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A. Yes, I have been involved.

Q. In any of those wells, did you ever see a displacement

procedure drafted by Halliburton?

A. The procedures were generally -- they generally came to us

from M-I.

Q. Not from Halliburton?

A. Not from Halliburton.

Q. And the decision to go forward with the displacement,

whether it's after a negative test or otherwise, is not onethat Halliburton, in your experience in the Gulf of Mexico, was

the one to make?

A. You're right.

Q. After the hydrostatic pressure buildup mud, I think you

told Mr. Sterbcow that the BOP is the second barrier. Is that

right?

A. Yes, in my opinion.

Q. Is that Transocean equipment?

A. It is Transocean equipment.

Q. Now, based on your experience in the Gulf of Mexico, is

Halliburton involved in either the maintenance or repair or

inspection of the BOPs?

A. No, sir, they aren't.

Q. Is Halliburton involved at all in the operation of the

BOP?

A. No, sir, they aren't.

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Q. Now, when you went through with Ms. Clingman the animation

of the drill shack, you were shown a portion of the BOP control

panel. Do you recall that?

A. I do recall seeing the BOP control panel.

Q. In what other places on the rig is there a BOP control

panel?

A. Primarily, the bridge would be the secondary.

Q. There's not one in the mud logger shack, is there?

A. No, sir.Q. The mud logger doesn't have any access to the BOP, can't

shut annulars, shut the DBRs, certainly can't shear the casing

or EDS; right?

A. Thank God, no.

Q. After the BOP -- when you were talking to Ms. Clingman,

you talked about the last line of defense once gas is in the

riser. And that's the emergency diverter system; right?

A. I'm not familiar with that term you just used there.

Q. The diverter system?

A. I thought you said emergency diverter system.

Q. Pardon me. The diverter system, you're familiar with

that?

A. Yes, I'm familiar with the diverter.

Q. And I think you characterized that as sort of the last

line of defense as you're trying to maintain control of the

well. Is that a fair characterization?

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A. Typically, yes.

Q. And again, the controls for the diverter are located in

the drill shack; right?

A. Yes.

Q. And on the bridge?

A. That's correct.

Q. The mud logger has no ability to activate the diverter?

A. No, he didn't.

Q. Nor does Halliburton's cement personnel?A. No.

Q. So in each case, the well control responsibility on the

well, as you understand it, based on your experience, lies with

Transocean to push the buttons, to pull the levers, to shut in

a well, and control it?

A. We would be the people that would shut the well down, yes.

Q. We talked to you very briefly about the negative test.

It's been covered at some length. I think you've talked about

Jimmy Harrell being adamant that one be run. Do you recall

that testimony?

A. I do.

Q. And I was curious as to why you characterized him as being

adamant. Was there some sort of dispute as to whether or not

to run a negative test?

MR. BROCK: Object to that, Your Honor. We've been

over this about three times now. Object as asked and answered.

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BY MR. HARTLEY:

Q. Do you think it was a good, sound policy to run a negative

test?

A. I do agree it was a good, sound policy.

Q. Do you have any reason to believe that the BP well site

leaders disagreed with the decision to run a negative test?

A. I don't think they disagreed, no.

Q. In the end, you understand now that there was a pressuredifferential between the reading on the drill pipe and the

reading on the kill line?

A. Yes.

Q. Now, you didn't know that when you talked to Jason

Anderson that night, did you?

A. I did not know that.

Q. Had you known that, would you have responded in a

different manner?

A. Had Jason told me he had a problem or something he

couldn't understand, I would have been right there with him.

Q. Prior to getting into a well control situation or a well

control event and addressing that, certain personnel on the rig

have a responsibility to monitor the well in an attempt to

detect the situation before it gets out of hand. Would you

agree with that?

A. Yes.

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Q. And that well monitoring responsibility lies primarily

with the Transocean drill crew?

A. Primarily.

Q. Primarily.

If we look at TREX-1453 at 48232, we've talked about

the well control handbook, Mr. Ezell. Are you also familiar

with the Deepwater Horizon Emergency Response Manual?

A. Yes.

Q. That's something that was kept on the rig?A. Yes.

Q. And what is your understanding of the purpose of the

Deepwater Horizon Emergency Response Manual?

A. It was a guide to kind of assist you in any major

emergency.

Q. And if we look at paragraph 2 in TREX-1453 in the

emergency response manual, it talks about the detection of a

kick. Do you see that section, Mr. Ezell?

A. Yes, sir.

Q. It reads: "Detection of a kick (intrusion of liquid or

gas into the wellbore) is the responsibility of the driller."

That's a statement with which you agree; right?

A. It is a driller's responsibility for kick detection.

Q. "The driller and his crew will continuously monitor the

surface system indicators (flow rate, pit level, etc.) and

break downhole indications, such as mud pressure, for signs of

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a kick."

Do you agree with that?

A. Yes.

THE COURT: I think we've tread over this ground. I

don't remember if it was this exact document, but this

testimony is repetitive. This witness has already said the

exact same things. So we need to move this along. Okay?

MR. HARTLEY: Absolutely, Your Honor.

BY MR. HARTLEY:Q. At all times somebody is supposed to be in that Transocean

driller's chair; isn't that true, Mr. Ezell?

A. When we're connected to the wellbore, yes.

Q. And I think earlier this morning in your testimony you

said that Transocean requires at least two well control

personnel to be in that drill shack.

A. That was our procedure.

Q. Now, the mud logger is in a different sort of position in

terms of his well monitoring responsibilities and duties.

Would you agree with that?

A. I really don't know exactly what his responsibilities

would be.

Q. Do you know what information is available to the mud

logger or was available to the mud logger on the Deepwater

Horizon?

A. To the best of my knowledge, they had all the information

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that was available to us on the HITEC; and, of course, they had

other data that they were looking at.

Q. You know Joe Keith, don't you?

A. Excuse me?

Q. You know Joe Keith?

A. I do.

Q. You worked with him for quite a long time; isn't that

right?

A. Yeah. I don't know the exact amount of time, but, yes,sir, a long time.

Q. He had been on the rig since '01, '02?

A. Possibly. I can't remember exactly when he came on, but I

will agree it was a pretty good length of time.

Q. And he did a good job. You thought he was a good man,

didn't you?

A. I had no problem with Joseph Keith.

Q. You never had a situation in which Joe Keith missed a

kick, did you?

A. No, sir, not any that I'm aware of.

MR. HARTLEY: Robin, let's pull up D-8179.

BY MR. HARTLEY:

Q. Very quickly, Mr. Ezell. Ms. Clingman showed you an

animated version of the drill shack. I don't have that one,

but I've got a static display. And what I want to ask you

about, there's a screen over here on the left-hand side that's

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labeled "Drillers Sperry-Sun display."

Do you see that?

A. I do.

Q. You've talked briefly with Ms. Clingman this morning about

the information displayed on there. Can you give us some sort

of visual on what the driller would see in his A-chair looking

at that screen?

A. To be totally honest with you, we didn't use that screen a

lot. We relied heavily on the HITEC, which was in the directline of sight with the driller and the rotary table, because he

has to have the ability to monitor that information and plus

watch what's going on in front of him.

It was a peripheral-type monitor for us to kind of

support, if we needed to, what we saw.

Q. You viewed the mud logger simply as a backup to you?

A. A mud logger was a backup to me.

Q. To your knowledge, was all of the information the mud

logger had in his shack available to you on this screen in

D-8179?

A. Yes, sir, I believe he had all the information that we

had.

Q. And vice versa, you had all of the information he had?

A. No, sir, that's not the case.

Q. What information did the mud logger have that was not

available to the Transocean drill crew?

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A. I don't know the full scope of it, but there were -- there

were other parameters that were specifically part of Sperry

data that was not part of ours.

Ours had a full array, plus it also had all the

control features for the equipment. So there were differences.

Q. Are you speaking about the MWD/LWD type data?

A. I am, yes.

Q. So let me make my question a little more precise. All of

the information that the mud logging unit, the mud logger waswatching, all of that data -- pit sensors, blowout, gas

traps -- all of that information was available to the

Transocean drill crew?

A. Yeah, we had that on HITEC or the mud logger did have it.

Q. Based on the position of the drill shack and the

responsibility of the driller, is it fair to say that there

aren't operations going on on that rig floor that the driller

is not aware of?

A. Any operations that would definitely be in the driller's

line of sight -- and you can see what that would be -- would

definitely be something he would be aware of.

Q. Would the driller be aware of movement of mud between

various pits on the rig?

A. Yes, he would.

Q. Would the driller be aware of when the sand trap's being

emptied?

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A. Yes, he would. It would be a different way of discovering

that; but, yes, yes, he would be aware.

Q. Similarly, he would know if the trip tanks were being

dumped?

A. Yes, he would know that.

MR. HARTLEY: Robin, let's put up D-8180, please.

BY MR. HARTLEY:

Q. Have you been to the mud logging shack on the Deepwater

Horizon?A. In nine years, I've probably been in that shack maybe

twice. It was very rare.

Q. Do you remember the last time you were in that shack?

A. No. It could have been as much as a year prior to the

incident. But, you know, it had its own purge system with an

alarm, and you had to jump in and jump out, you know, or you

would set that off. I really had no need to go in.

Q. In D-8180, it shows, in the upper left-hand corner, an

exterior view. Does that look like the mud logging shack that

was on the Deepwater Horizon?

A. I guess. I have very little information on that, but it's

similar.

Q. In the lower right, we've pulled out a circa 2003 picture

of the Deepwater Horizon mud logging shack. Does that fairly

and accurately represent, as best you recall, what the shack

would look like from the inside?

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MS. CLINGMAN: Your Honor, I'm going to object, lack

of foundation. The witness has said he doesn't know anything

about this area in --

THE COURT: Well, I don't know if he does or he

doesn't. Have you been inside of there?

THE WITNESS: Yes, sir, I have; but it's only been a

couple of times and I don't have a real good memory of it.

THE COURT: All right.

BY MR. HARTLEY:Q. Do you have an understanding or a sense of what data is

available to the mud logger while he's on tour in terms of rig

operations?

A. I'm sure that just like we've been discussing, he was

connected with HITEC. So he had the ability to see what we

were seeing on the HITEC monitor.

Q. Was he in a position where you could see the rotary table?

A. No. He was behind the drawworks.

Q. Was he in a position to, with the exception of following

data on his screen, understand what rig operations were

underway?

MS. CLINGMAN: Objection, Your Honor, lack of

foundation as to what he would understand from the mud logger's

shack.

THE COURT: Overruled.

Can you answer that, sir?

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THE WITNESS: I'm thinking. Would you please

restate?

THE COURT: Was he in a physical position? Is that

what you mean?

MR. HARTLEY: Yes, sir.

THE COURT: Physical location?

MR. HARTLEY: Yes.

MS. CLINGMAN: He answered that question. Then he

said would he be able to understand what operations were goingon. That was the question to which I lodged an objection to.

MR. HARTLEY: Let me go at it a different way.

THE COURT: Why don't you do that. I understood the

question somewhat differently, but go ahead and ask the

question again.

BY MR. HARTLEY:

Q. In your experience as a driller toolpusher, senior

toolpusher on the Deepwater Horizon, when you're on tour in the

drill shack, do you call the mud logger and advise him of what

operations are going on on the rig?

A. The mud logger is generally always in the loop. He should

come to the pre-tower meeting to know what's going to happen

during the day.

Q. When you say he's generally always in the loop, how does

he get into the loop, with the exception of attending the

pre-tower meeting?

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A. Communication. Yeah, the driller would talk to the mud

logger.

Q. And that's the requirement of a driller's job, to

communicate effectively with the mud logger, to advise him of

what's going on on the rig?

A. I don't know if it's a requirement for his job, but it's

something that we did do. We did communicate.

Q. It would be a good, safe practice to tell the mud

logger -- for example, if you're moving mud between pits, ifyou're dumping a trip tank, those sorts of operations, to tell

him would be a good, safe practice, in your experience?

A. Yes, it would be a safe practice, for sure.

Q. I want to turn briefly to this prior control event that

you talked about earlier.

Do you recall testifying that you had been briefed on

the Sedco711 event in the North Sea?

A. Yes.

Q. That's a well control event that happened on, what,

December 23 of 2009?

A. Can you show me the document to refresh my memory? I

don't remember the date exactly.

MR. HARTLEY: Absolutely. Let's show Exhibit 1523.

BY MR. HARTLEY:

Q. If we look at the upper right-hand corner, this is the

well operations group advisory issued on April 5th of 2010. Do

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you recall ever seeing this prior to April 20th of 2010?

A. No, sir, not -- not prior to.

Q. Okay. Let's look at Exhibit 926. This is -- in the upper

right-hand corner, an April 14th, 2010 advisory just issued in

the North Sea. Do you recall ever seeing this advisory prior

to April 20th, 2010?

A. No, sir. But those are so current that I don't know that

they even had a chance to go through the management process to

where they're distributed in the right places. They're verycurrent.

Q. Do you know who Bill Sannan is?

A. Yes, I do.

Q. General manager for North America Transocean at the time?

A. Yes.

Q. Do you know if he would have been the individual

responsible for circulating the April 5th global advisory?

A. I'm sorry, I don't know.

Q. Fair enough.

This morning, in testifying in response to

Mr. Sterbcow's questions, you said something to the effect,

lessons learned would not add value because the crew was

already aware of basic concepts. Do you recall that?

A. I do.

Q. Do you think it would be helpful to be reminded to

exercise additional vigilance, for example, after a negative

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test or displacing seawater?

A. I really don't think these would have been of great value

to the crew because they were a competent crew. They were well

trained, and I don't think it would have been a large value to

them.

Q. You certainly would want them to continue going through

training and progressing in their skills?

A. Right, but this is basic well control examples here.

Q. And they should have an understanding of basic wellcontrol?

A. I'm sorry, I didn't hear you.

Q. And they should have that understanding of basic well

control?

A. Yes, yes.

Q. Things like paying extra vigilance when you remove the

primary barrier in the well?

A. Yes. They were aware that barriers would fail or could

fail.

Q. Things like shutting in immediately upon detection or

suspicion of a kick?

A. They were also well aware of that.

Q. Things like at the first indication of a potential kick,

you shut the pump's flow check and then shut in, as you

discussed with Ms. Clingman?

A. They were highly aware of that as well.

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Q. In response to Mr. Sterbcow's questions, you said

something about the drill crew, that they were doing everything

within their training to keep the well under control. Do you

recall that?

A. Yeah, I believe I do.

Q. And that would be the sort of things we just discussed

about how you would appropriately respond to a well control

event. Is that what you meant?

A. I meant they exercised all the training that they had beentaught to try to get the well under control in those last few

minutes.

Q. Do you know when the drill crew first had any indication

that there may be a problem downhole?

MR. BROCK: I'm going to object on foundation.


BY MR. HARTLEY:

Q. In your discussions with Mr. Anderson or Mr. Curtis, did

they convey to you any information that would suggest when they

suspected a problem?

A. They didn't relay any of that to me, no, until the very

end.

Q. And that would be the call from Mr. Curtis?

A. It would be.

Q. That's when he told you, "Randy, we have a problem. We

have mud shooting to the crown"?

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A. Correct.

Q. You responded, "Is the well shut in?"

A. Right.

Q. He said, "Jason's shutting it in now"?

A. Yes.

Q. That would suggest at least that mud was shooting up to

the crown prior to an effort to shut in the well; right?

MS. CLINGMAN: Your Honor, I would object not only to

foundation, but this is repetitive. This is what Mr. Ezelltestified to earlier.

THE COURT: It is. I sustain the objection.

BY MR. HARTLEY:

Q. Based on your understanding of your conversation with

Mr. Curtis, when did they first attempt to shut in the well?

A. I have no idea.

Q. That shut-in process would be the two-button sequence you

discussed. It would take about 50 seconds?

A. I don't know exactly what they shut in first, to tell you

the truth.

Q. Based on your experience and your well control training

over 20-some odd years, what is the Transocean policy for the

first element to shut in -- to shut in the well?

A. They would typically close an annular, but I don't know

which one they selected.

Q. Were you familiar with the status of the BOP on the

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Deepwater Horizon as of April 20th, 2010?

A. Explain what you mean by "status."

Q. Did you know what were -- what was in each of the ram

cavities?

A. Yes, I did at that time.

Q. And you knew the lower annular had been converted to a

stripping packer in, what, 2006?

A. I'm not sure of the right date, but, yes.

Q. It had been converted to a stripping packer prior toApril 20th, 2010?

A. Yes, it had been converted prior to 2010.

Q. So you wouldn't expect the drill crew to shut that annular

in a well control event to try to contain the flood?

A. I can't answer for what the guys thought or what they

did --

Q. That's fair.

A. -- at that moment.

Q. That's fair.

Based on your experience and your training, what

would you do first in attempting to shut the well in on the

Deepwater Horizon?

A. I think that would have been a call that I would have had

made when I was on the floor that night. I mean, I don't know

that I can sit here in the courtroom and make that call here.

Q. It's tough to put yourself in their shoes.

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A. You don't know how tough it is.

MR. HARTLEY: Thank you, Mr. Ezell. I don't have any

more questions for you.

THE WITNESS: Thank you.

THE COURT: All right. BP?

MR. BROCK: Yes, sir.

Your Honor, are we good to proceed?

THE COURT: Yes.

CROSS-EXAMINATIONBY MR. BROCK:

Q. Mr. Ezell, I'm Mike Brock; and I have some questions for

you, I'm supposed to say, on cross-examination. So just

putting that in for the record.

You might see me flipping through my notes here a

bit. I had a bigger outline. Many of the questions that I had

for you have been asked, and I'm going to do my best not to go

back over material that's already been covered. So if you

would just be patient with me a little bit, I would appreciate

that.

A. Yes, sir.

Q. I understood from your testimony yesterday and today that

your recollection is that the Deepwater Horizon had drilled

about 50 wells in the Gulf of Mexico. Correct?

A. Yes, sir, 50-plus, I think.

Q. You drilled the deepest in history at the time it was

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drilled, and that was the Tiber; correct?

A. That is correct.

Q. And the deepest water depth well, which was the Walker

Ridge well?

A. Correct.

Q. And going into April of 2010, you-all had a history --

safety history that was very impressive in terms of not having

a lost time incident for about seven years?

A. That's also correct.Q. And the men and women of the Deepwater Horizon were very

proud of their record both in terms of performance -- that is,

drilling wells -- as well as in the area of safety?

A. Yes, sir, we were.

Q. And as you've expressed here today, the folks at BP were

also proud of the record that Transocean had developed on the

Deepwater Horizon during that period of time?

A. They were exceptionally proud of Deepwater Horizon.

Q. And on most of these wells that were drilled in the Gulf

of Mexico, Halliburton was also a partner in those endeavors

providing advice about cement?

A. That's correct.

Q. On each of these wells -- I think you said maybe one was

done for a different company; but on each of these wells, you

would be executing a BP drilling plan?

A. Correct.

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Q. And you would be working with BP well site leaders who

would be there on the Deepwater Horizon during the operations?

A. That's correct.

Q. And then you would also be interacting with different

contractors that might be there, like the mud contractor, the

cement contractor. You might have other people there to do

special tools or special tasks. But you would have a good

number of contractors that would be on the rig also?

A. That's correct, too.Q. And it was your view that the Deepwater Horizon, working

with BP and these other contractors over a long period of time,

had established a very good track record?

A. You're right.

Q. It was a good team?

A. It was a very good team.

Q. And it's important in this business, the specialty

business of deepwater drilling, that you have good cooperation

and good communication between the parties as the drilling

process is ongoing?

A. Yes.

Q. Now, you mentioned earlier today -- I believe they showed

you a document where it showed that you came on board on April

the 13th -- do you remember that -- and then would have been

there up until the 20th?

A. Yes, sir, I believe I do.

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Q. Okay. So that would have been about seven days before the

event that you had been on board?

A. Yes, sir, about that.

Q. Okay. And the records that I've looked at show that you

also were there for hitches for 1/19 -- that is, January 19th

of 2010 -- to February 8th, 2010. And then you would have also

had a hitch from March the 4th, 2010, to March the 25th, 2010.

Does that sound right?

A. Yes, sir. It's been a long time, but that sounds like itcould be possibly, yes.

Q. Your schedule would be 21 days -- well, you were on

14 days on and 14 days off? Or 21?

A. No, it would have been 21.

Q. 21, I'm sorry. Yeah, 3/4/2010 to 3/25, you would have

been on the 21-day schedule?

A. Yes, sir.

Q. Now, on those three hitches -- that is, from the time you

went to the Macondo well site up through the explosion that

took place on April the 20th -- you never felt pressure to rush

through the operations; is that correct?

A. Not at all.

Q. And at all times when you were on the Deepwater Horizon at

Macondo, you felt that Transocean and BP personnel on board the

rig were acting in a careful, safe, and prudent manner?

A. Yes, sir.

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Q. You believed that the operations on board the rig were

safe?

A. I did.

Q. I want to ask you just a couple questions about the well

control manual that we haven't covered. I'm not going to pull

it up and ask you in detail.

Is it correct that copies of the Transocean well

control manual were available on the rig floor in the

toolpusher's office, in the OIM's office, and that the drillershad individual copies of that well control manual?

A. The well control manuals were at those locations.

MR. BROCK: Now, if I could go back and just ask that

we pull up Exhibit D-365, please.

BY MR. BROCK:

Q. You were -- can you see this okay?

A. Yes, sir.

Q. Okay. You were shown a little earlier the organization

chart that covers the drilling operations. Do you remember

that? It had the OIM to the senior toolpusher, and then right

on down, toolpusher to deckpusher and driller. Do you remember

those conversations?

A. Yes, I do, sir.

Q. Now, this, in fact, is the Transocean Deepwater Horizon

organizational chart for the entire rig, isn't it?

A. I'm not sure it's for the entire rig.

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Q. Okay. Well, it takes into account, at least on the

left-hand side over there, the marine operations, it has the

drilling operations, and then it has "Maintenance" and

"Materials" over on the right-hand side, if you look at the

lines reporting directly to the OIM. Do you see that?

A. Yes, it does have quite a few more positions on this one.

Q. Right. Than the one that you looked at earlier?

A. Yes.

Q. And you would agree that the OIM was the person who was incharge of the Deepwater Horizon rig?

A. The OIM was the PIC when we were drilling.

Q. He was in charge of the rig, wasn't he?

A. Yes, he was the PIC.

Q. The good news is that every one of these pages I'm turning

is one where I'm not asking questions, so just hang with me

here.

A. That is good news.

Q. All right. Just a couple more details on the driller's

obligations in terms of shutting in the well.

You would agree that the driller, the moment he or

she sees a hydrocarbon influx, would want to start controlling

the well?

A. Yes.

Q. And that you do not wait to see how the situation develops

before you exercise well control?

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A. Well control should be -- the first thing on a driller's

mind would be minimize the influx, shut it in as soon as

possible.

Q. Do you agree with my statement that you shouldn't wait to

see how the situation develops before you implement your well

control measures?

A. No, you shouldn't wait to see how it develops.

Q. Right. Thank you.

And the reason for that is that if you shut in thewell quickly, it will minimize the influx of formation fluids?

A. Correct.

Q. And the purpose of shutting in the well immediately is to

keep hydrocarbons below the BOP?

A. To minimize the influx.

Q. I think you've said this, and I apologize for asking it

again, but just in case.

Do you agree that nothing is more important than well

control, that that is the primary goal of the Transocean crew?

MS. CLINGMAN: I'm going to object that it's been

asked and answered, but maybe not --

THE COURT: All right. I'll let him answer. That's

fine.

THE WITNESS: Can I answer it?

THE COURT: Yes.

THE WITNESS: Would you state it again?

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BY MR. BROCK:

Q. Yes. I'll be happy to.

You would agree that nothing is more important than

well control? That's your primary goal?

A. Well control is a primary goal.

Q. Now, you've talked a little bit about certification for

well control in the period of 2001 to 2010. I wanted just to

ask you a few follow-up questions about that, sir.

If we could turn to TREX-52652, please.Do you see this is "Fundamental Well Control

Course-Content and Objectives"? Do you see that?

A. Yes, sir.

Q. Then if we look at 526521.2, if you could pull that out,

please.

Do you see this is going over the areas of

instruction, evaluation, and testing?

A. Yes. Give me just a moment to fully read it here.

Q. Sure.

A. (Witness reviews document.)

Okay.

Q. Okay. Actually, I have one here that's not highlighted.

Do you see the section "Formation Fracture Pressures"? Do you

see that? Fourth bullet --

A. Yes, I do. I do.

Q. -- fourth bullet down?

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And is there a section there, "Why's and When's of

FIT and LOT Procedure"?

A. Yes.

Q. What is the FIT procedure?

A. That's formation and integrity.

Q. Test?

A. And leak-off test procedure.

Q. And was this part of the course material that would be

included in your well control training?A. If we look back, I believe this was entitled "Fundamental

Well Control Training." It was not the supervisory training.

Q. In supervisory training, would you receive training in FIT

and LOT procedures?

A. To some degree, but it's not outlined as we're looking at

here.

Q. It would be at a different format and at a higher level?

A. It would be at some format, yes. I can't remember exactly

what.

Q. Did you receive training on the why's and when's of the

FIT and LOT procedures?

A. Yes, to some degree. Of course, that's our client or the

oil company that actually, you know, handles that particular

procedure there, both -- what we get is kind of an overview,

just kind of a global view of why this is happening.

Q. Okay. Thank you.

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Let me ask you to turn -- or let's -- or I'm going to

turn now to one section from the well control handbook,

TREX-1454. And if we can go to call-out 14.2.

And I'm not going to cover this in detail, but I just

need to show you this for the next one.

Do you see here, on the first one, it says, "It is

the responsibility of the driller to shut in the well as

quickly as possible if a kick is indicated or suspected"?

Do you see that?A. Yes, sir, I do see that.

Q. All right. Now, if we go down to 1454215.1, I want to ask

you a couple of questions about this section.

It says: "The driller has full authority to flow

check or shut in the well, as he sees fit, and is expected to

fully investigate any occurrence which deviates from a stable

trend."

Do you see that?

A. I do.

Q. Now, you've talked about a little bit about flow check

today. You've described that. I'm not going to ask you to go

back into that. But if the driller sees an occurrence which

deviates from the stable trend, how does he reach out to others

on the rig to conduct the flow check?

A. I'm not really with your question there when you say

"reach out to others."

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Q. Yes. So let's go back to this.

You've described what a flow check is. How does the

driller check flow if there has been an occurrence which

deviates from a stable trend?

A. Well, he would typically shut his pumps down, pick up to

where the tool joints are not located in an annular or ram, and

he would check at that point to see if the well was flowing.

Q. And would he do that himself? Would he make a personal

observation to see if the well was flowing, or would he asksomeone to do it, typically?

A. It depends. There is a CCTV that could show the flow

line, which he could actually see that. Or he had the ability

to ask a checker hand to do a flow check for him.

Q. Okay. Could you do a flow check by walking out to the

rotary table and looking down the hole?

A. You could, but that would be something a driller wouldn't

do.

Q. Could he ask someone to go out there, shine a flashlight

down and see if a well is flowing?

A. We used to do it in the old days like that.

Q. Sure.

The driller does not need permission from BP to

conduct a flow check; is that right?

A. That's right, he doesn't need permission.

Q. Just so that we're all clear on this, the first thing that

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you do to conduct a flow check is to shut down the pumps;

right?

A. That would be your first step.

Q. Right. And if the pumps are shut down, the well should be

static?

A. Correct.

Q. If it's flowing, if you're -- if the flow is coming back,

then you have a situation that you have to deal with?

A. You do have a situation you have to deal with andunderstand, for sure.

Q. If you'll just be patient with me, we're saving time here.

So sorry about that.

A. Okay. Good. No problem.

Q. You've mentioned this. Let me just go back over it a

little more.

The Sperry-Sun mud loggers monitored information on a

continuous basis throughout the well; correct?

A. Yes.

Q. And part of their roles and responsibilities were to

record pit volume totals for the purpose of monitoring the

well?

A. That's my understanding.

Q. Did you understand that the Sperry-Sun mud logger's sole

obligation on the Deepwater Horizon was to monitor the pit

volumes and other information and data that the driller was

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looking at?

A. I'm not so sure it was their sole obligation, but I do

know they had a large part to play in that.

Q. As the senior toolpusher on board the Deepwater Horizon,

you expected someone from Sperry-Sun in the mud logger's unit

to be monitoring the data at all times?

A. Yes.

Q. And the mud logger is supposed to call the rig floor to

notify someone if he takes a break or leaves the mud loggershack?

A. That is correct.

Q. All right. Let's look at Exhibit 1454.215.3, please.

This is a document we haven't looked at today.

You see there at the top where it says: "Recognizing

the signs of an influx and acting with the necessary speed to

minimize it requires constant, accurate observation and

recording of the mud volume, weight, and relevant parameters."

Do you see that?

A. I do.

Q. And then it comes down and talks about "the crucial

feature being the communication triangle between the driller,

the mud loggers, and the derrickman/mud engineer in the mud

pits."

Do you see that?

A. Yes, sir, I do.

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Q. And then it goes on to talk about how important it is to

maintain communication between those three points of contact.

Do you see that?

A. I do.

Q. The driller would be the Transocean driller; correct?

A. Correct.

Q. Mud loggers in this particular case would be the

Sperry-Sun mud loggers?

A. Correct.Q. And the derrickman would be the Transocean derrickman?

A. Correct.

Q. BP is not in this particular communication triangle, are

they?

A. Not in what I'm looking at, no, sir.

Q. Now, on the Deepwater Horizon on the 18th, 19th, and

20th -- let me just take a step back.

You know who Ms. Kathleen Willis was, don't you -- or

is?

A. Yes, sir. I believe she worked for Sperry-Sun for a

length of time on the rig.

Q. Okay. And to the best of your recollection, did

Ms. Willis ever express to you any concerns about her ability

to monitor the pits or the mud?

A. No, sir, not to me.

Q. She never came to you on the 18th, 19th, or 20th to

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express any concerns regarding her ability to do her job?

A. No, sir.

Q. She never came to you and expressed any concerns about the

safety of the operations on board the rig?

A. Not at all.

Q. You also know Mr. Joseph Keith, as you referenced here

today?

A. I do.

Q. He was a mud logger on the Deepwater Horizon, been there agood while?

A. That's correct.

Q. On the evening of April the 20th, did he ever express any

concerns to you about the safety of the operations on board the

rig?

A. No, he did not.

Q. Or did he ever say to you, as the senior toolpusher, that

he had any concerns regarding the ability to do his job?

A. No, sir, he didn't.

Q. Switching now to a few questions about the negative test.

Just telling you what I'm going to.

It would be typical, in your experience, for

Transocean personnel to express their views on whether or not a

negative test was successful?

A. They would express their view to the well site leader, of

course.

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Q. And if they saw something wrong or anything that was out

of the ordinary with a negative test, you would expect them to

stop and determine what was wrong before proceeding to the next

step?

A. If they recognized that there was a problem, yes, I would

expect them to stop.

Q. As the senior toolpusher on board the Deepwater Horizon,

you would expect any of your drillers, assistant drillers, or

toolpushers to halt the procedure if they saw anything thatconcerned them at all with respect to the negative pressure

test?

A. That's correct, they would have.

Q. You were asked some questions earlier today about whether

or not you had heard of the terms "bladder effect" or "annular

compression." Do you recall that being asked of you?

A. Yes, sir, I do.

Q. And you said that you had not heard of the term bladder

effect; correct?

A. That's correct.

Q. You had heard of the term annular compression?

A. I think I have, but, I mean, it's not a common

terminology. It would usually come from, possibly, a BP

engineer or something like that.

Q. Let me just -- let me just ask a couple questions here.

You don't recall specifically who has used the term

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annular compression in your presence, as you sit here today, do

you?

A. No, sir, I don't remember who's ever even used that term.

Q. I just want to confirm with you, though, that prior to

April 20th, 2010, you had heard the term annular compression in

connection with the work that you did on the Deepwater Horizon?

A. It seemed like annular compression has come about at some

point. I don't know how or where it was associated -- but not

bladder effect.Q. I understood you to say that you had not heard of bladder

effect. I just want to confirm that you had heard the term

annular compression. True?

A. I think I have.

Q. Now, you talked a little bit about the test -- the

negative pressure test that was conducted at the Kodiak well

just prior to the Deepwater Horizon coming to --

THE COURT: We lost something here.

THE DEPUTY CLERK: I'm sorry, Judge.

THE COURT: We'll take about a 10-minute recess.

(WHEREUPON, the Court took a recess.)

THE DEPUTY CLERK: All rise.

THE COURT: All right. Please be seated. I had a

technical problem where my computer got turned off,

disconnected or something, but we're back in business now.

All right, Mr. Brock.

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MR. BROCK: May we proceed, Your Honor?

THE COURT: Yes.

BY MR. BROCK:

Q. Mr. Ezell, just before the break we had introduced the

Kodiak well as the next topic. Do you remember that?

A. Yes.

Q. So let me get you to turn -- let us pull up right here

Exhibit 34651.1. Can you see that this is a Daily Drilling

Report for Macondo 727 No. 2?A. Yes, sir, I can.

Q. Okay. And the Daily Drilling Report is signed here by Don

Vidrine, and by, it says, Miles Ezell. But you go by Randy;

correct?

A. That's correct.

Q. And that would be normal protocol for you and the well

site leader, to sign off on the daily drilling report?

A. Correct.

MR. BROCK: And if we come down a little bit to

33261.1 -- I'm sorry. This is the next exhibit. Go back to

the one before, please. 34652.1, which is a pull-out of the

daily drilling report. Okay.

BY MR. BROCK:

Q. And do you see here that the notes record that a pre-job

safety meeting was conducted with regard to the negative

pressure test and displacing the riser? Do you see that?

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A. Yes, sir, I do.

Q. And that's similar to the process that you've described

for the court today in terms of what happened at Macondo, that

when you start an important task like this, you'll stop and

have a safety meeting and talk about what you're about to do?

A. Yes, sir, that's correct.

Q. Now, if you look at the next exhibit, which is

Exhibit 3326 -- can you read that okay? Probably better now.

A. Yeah, it's better now, for sure.Q. All right. You see that this is from the Deepwater

Horizon assistant driller to the Deepwater Horizon toolpusher,

and it's dated January 28th, 2010. Do you see that?

A. Yes, sir, I do.

Q. Okay. And it says: "The message is ready to be sent with

the following file or link attachments"; and then it says

"negative test while displacing." Do you see that?

A. Yes, sir.

Q. And you would have been a toolpusher on the Deepwater

Horizon during this period of time?

A. Yes, sir, the senior toolpusher.

Q. The senior toolpusher. Yes, sir.

Then if we go to the next exhibit, which is 3326.2.1,

do you see that that is the negative test while displacing?

A. Yes, sir. I see it.

Q. And that sets out ten steps there coming down the page.

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Do you see that?

A. Yes, sir.

Q. And Step No. 8, if you look at Step No. 8, it says:

"Monitor for pressure buildup, 15 minutes." Do you see that?

A. I do.

Q. Is this a test of pressure for pressure on the drill pipe?

A. I'm not sure.

Q. Do you see where it says "displace down drill pipe with

seawater to the top of stack"?A. Yes, I do.

Q. And then it calls for monitoring pressure buildup for

15 minutes; correct?

A. That's what it says.

Q. Now, if we go now to 76521.2, do you see that this is the

Daily Drilling Report for January 29th, 2010?

A. Yes.

Q. And if we go now to 76522.1, do you see that it describes

the conduct of the negative test from 1200 hours to 12:30 there

on the left-hand side?

A. I do.

Q. And it describes "performing the negative test, closed the

upper annular, differential pressure, Halliburton bled off the

pressure, monitored for 15 minutes, good test"; correct?

A. I see that, yes.

Q. You're also familiar with a written negative pressure test

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that was aboard the Deepwater Horizon; correct?

A. It's according to which one you're talking about.

Q. There was a written negative pressure test that was

developed by Jason Anderson and Murry Sepulvado?

A. I know the one you're referring to.

Q. And you would describe that as a one-page type document?

A. Yes, that's correct.

Q. And to your recollection, it was one form of a negative

test?A. Yes, that's a good statement, I believe.

Q. And it was formulated or prepared jointly by Jason

Anderson and Murry Sepulvado?

A. Yeah. I don't know exactly what role Jason played in

that, but he definitely was involved.

Q. Okay. Do you recall having told us that the only one you

could talk about was one that Murry and Jason had designed out?

A. I believe I did say that.

Q. Now, I want to show you an e-mail from toolpusher,

Deepwater Horizon rig, to George Coltrin, dated October 19th,

2005, please. Do you see this is a note from toolpusher,

Deepwater Horizon rig, to George Coltrin, dated October 15th,

2005?

A. Yes.

Q. This would be a note from the toolpusher on the rig to

George; correct?

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A. I mean, it appears that way.

Q. And does it say, "Here is the procedure for performing the

negative. We would like to incorporate the negative test into

the displacement. From an operational standpoint, this

procedure makes the test much faster and easier to perform

versus performing it with base oil, where the base oil has to

be reversed out and then handled on the surface"? Do you see

that?

A. I do.Q. This is a suggestion from Transocean to BP about the

conduct of the negative test?

A. I'm not really sure exactly who with Transocean suggested

this, if any.

Q. Have you seen this before?

A. No, sir, I haven't. I don't recall it.

Q. That's fine, sir. Thank you.

On the evening of the 20th -- taking you to a

different topic, now. I apologize -- you were aware that

fluids had leaked past the annular in the BOP stack during the

first negative test; right?

A. The one that was aborted?

Q. I'm talking about the first negative test that was being

conducted at about the time you came into the room and there

was some discussion going on.

A. Yes. That was the one that was aborted.

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