2013-02-25 AM Transcript

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UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF LOUISIANA
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IN RE: OIL SPILL BY THE OIL

RIG DEEPWATER HORIZON IN THE
GULF OF MEXICO ON APRIL 20,
2010
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CIVIL ACTION NO. 10-MD-2179 "J"

NEW ORLEANS, LOUISIANA
MONDAY, FEBRUARY 25, 2013
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THIS DOCUMENT RELATES TO:

CASE NO. 2:10-CV-02771,
IN RE: THE COMPLAINT AND
PETITION OF TRITON ASSET
LEASING GmbH, ET AL
CASE NO. 2:10-CV-4536,
UNITED STATES OF AMERICA V.
BP EXPLORATION & PRODUCTION,
INC., ET AL
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DAY 1
MORNING SESSION
TRANSCRIPT OF NONJURY TRIAL PROCEEDINGS

HEARD BEFORE THE HONORABLE CARL J. BARBIER
UNITED STATES DISTRICT JUDGE
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OFFICIAL TRANSCRIPT
APPEARANCES:
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FOR THE PLAINTIFFS:
DOMENGEAUX WRIGHT ROY & EDWARDS

BY: JAMES P. ROY, ESQ.
556 JEFFERSON STREET, SUITE 500
POST OFFICE BOX 3668
LAFAYETTE, LA 70502
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HERMAN HERMAN & KATZ

BY: STEPHEN J. HERMAN, ESQ.
820 O'KEEFE AVENUE
NEW ORLEANS, LA 70113
CUNNINGHAM BOUNDS
BY: ROBERT T. CUNNINGHAM, ESQ.
1601 DAUPHIN STREET
MOBILE, AL 36604
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LEWIS, KULLMAN, STERBCOW & ABRAMSON

BY: PAUL M. STERBCOW, ESQ.
PAN AMERICAN LIFE BUILDING
601 POYDRAS STREET, SUITE 2615
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BREIT DRESCHER IMPREVENTO & WALKER

BY: JEFFREY A. BREIT, ESQ.
600 22ND STREET, SUITE 402
VIRGINIA BEACH, VA 23451
LEGER & SHAW

BY: WALTER J. LEGER, JR., ESQ.
600 CARONDELET STREET, 9TH FLOOR
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OFFICIAL TRANSCRIPT
APPEARANCES CONTINUED:
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WATTS, GUERRA, CRAFT

BY: MIKAL C. WATTS, ESQ.
4 DOMINION DRIVE
BUILDING 3, SUITE 100
SAN ANTONIO, TX 78257
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WILLIAMS LAW GROUP

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

BY: THOMAS THORNHILL, ESQ.
1308 NINTH STREET
SLIDELL, LA 70458
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DEGRAVELLES PALMINTIER HOLTHAUS & FRUGE

BY: JOHN W. DEGRAVELLES, ESQ.
618 MAIN STREET
BATON ROUGE, LA 70801
WILLIAMSON & RUSNAK

BY: JIMMY WILLIAMSON, ESQ.
4310 YOAKUM BOULEVARD
HOUSTON, TX 77006
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IRPINO LAW FIRM

BY: ANTHONY IRPINO, ESQ.
2216 MAGAZINE STREET
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OFFICIAL TRANSCRIPT
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FOR THE UNITED STATES

OF AMERICA:
U.S. DEPARTMENT OF JUSTICE
TORTS BRANCH, CIVIL DIVISION
BY: R. MICHAEL UNDERHILL, ESQ.
450 GOLDEN GATE AVENUE
7TH FLOOR, ROOM 5395
SAN FRANCISCO, CA 94102

ENVIRONMENT & NATURAL RESOURCES DIVISION
ENVIRONMENTAL ENFORCEMENT SECTION
BY: STEVEN O'ROURKE, ESQ.
SCOTT CERNICH, ESQ.
DEANNA CHANG, ESQ.
RACHEL HANKEY, ESQ.
A. NATHANIEL CHAKERES, ESQ.
P.O. BOX 7611
WASHINGTON, DC 20044
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TORTS BRANCH, CIVIL DIVISION
BY: JESSICA McCLELLAN, ESQ.
MICHELLE DELEMARRE, ESQ.
JESSICA SULLIVAN, ESQ.
SHARON SHUTLER, ESQ.
MALINDA LAWRENCE, ESQ.
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FRAUD SECTION
COMMERCIAL LITIGATION BRANCH
BY: DANIEL SPIRO, ESQ.
KELLEY HAUSER, ESQ.
ELIZABETH YOUNG, ESQ.
BEN FRANKLIN STATION
OFFICIAL TRANSCRIPT
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FOR THE STATE OF

ALABAMA:
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ALABAMA ATTORNEY GENERAL'S OFFICE

BY: LUTHER STRANGE, ATTORNEY GENERAL
COREY L. MAZE, ESQ.
WINFIELD J. SINCLAIR, ESQ.
500 DEXTER AVENUE
MONTGOMERY, AL 36130
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FOR THE STATE OF

LOUISIANA OFFICE
OF THE ATTORNEY
GENERAL:
STATE OF LOUISIANA
BY: JAMES D. CALDWELL,
ATTORNEY GENERAL
1885 NORTH THIRD STREET
BATON ROUGE, LA 70804
KANNER & WHITELEY

BY: ALLAN KANNER, ESQ.
DOUGLAS R. KRAUS, ESQ.
701 CAMP STREET
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FOR BP EXPLORATION &

PRODUCTION INC.,
BP AMERICA PRODUCTION
COMPANY, BP PLC:
LISKOW & LEWIS
BY: DON K. HAYCRAFT, ESQ.
ONE SHELL SQUARE
701 POYDRAS STREET
SUITE 5000
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COVINGTON & BURLING

BY: ROBERT C. MIKE BROCK, ESQ.
1201 PENNSYLVANIA AVENUE, NW
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KIRKLAND & ELLIS

BY: J. ANDREW LANGAN, ESQ.
HARIKLIA "CARRIE" KARIS, ESQ.
MATTHEW T. REGAN, ESQ.
300 N. LASALLE
CHICAGO, IL 60654
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FOR TRANSOCEAN HOLDINGS

LLC, TRANSOCEAN
OFFSHORE DEEPWATER
DRILLING INC., AND
TRANSOCEAN DEEPWATER
INC.:
FRILOT
BY: KERRY J. MILLER, ESQ.
ENERGY CENTRE
1100 POYDRAS STREET, SUITE 3700
SUTHERLAND ASBILL & BRENNAN

BY: STEVEN L. ROBERTS, ESQ.
RACHEL G. CLINGMAN, ESQ.
1001 FANNIN STREET, SUITE 3700
HOUSTON, TX 77002
MUNGER TOLLES & OLSON

BY: MICHAEL R. DOYEN, ESQ.
BRAD D. BRIAN, ESQ.
LUIS LI, ESQ.
335 SOUTH GRAND AVENUE, 35TH FLOOR
LOS ANGELES, CA 90071
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MAHTOOK & LAFLEUR

BY: RICHARD J. HYMEL, ESQ.
1000 CHASE TOWER
600 JEFFERSON STREET
LAFAYETTE, LA 70502
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HUGHES ARRELL KINCHEN

BY: JOHN KINCHEN, ESQ.
2211 NORFOLK, SUITE 1110
HOUSTON, TX 77098
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FOR CAMERON INTERNATIONAL

CORPORATION:
STONE PIGMAN WALTHER WITTMANN
BY: PHILLIP A. WITTMANN, ESQ.
546 CARONDELET STREET
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BECK REDDEN & SECREST

BY: DAVID J. BECK, ESQ.
DAVID W. JONES, ESQ.
GEOFFREY GANNAWAY, ESQ.
ALEX B. ROBERTS, ESQ.
ONE HOUSTON CENTER
1221 MCKINNEY STREET, SUITE 4500
HOUSTON, TX 77010
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FOR HALLIBURTON
ENERGY SERVICES,
INC.:
GODWIN LEWIS
BY: DONALD E. GODWIN, ESQ.
BRUCE W. BOWMAN, JR., ESQ.
FLOYD R. HARTLEY, JR., ESQ.
GAVIN HILL, ESQ.
RENAISSANCE TOWER
1201 ELM STREET, SUITE 1700
DALLAS, TX 75270
OFFICIAL TRANSCRIPT
GODWIN LEWIS
BY: JERRY C. VON STERNBERG, ESQ.
1331 LAMAR, SUITE 1665
HOUSTON, TX 77010
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FOR M-I L.L.C.:
MORGAN, LEWIS & BOCKIUS

BY: HUGH E. TANNER, ESQ.
DENISE SCOFIELD, ESQ.
JOHN C. FUNDERBURK, ESQ.
1000 LOUISIANA STREET, SUITE 4000
HOUSTON, TX 77002
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OFFICIAL COURT REPORTER:
CATHY PEPPER, CRR, RMR, CCR

CERTIFIED REALTIME REPORTER
REGISTERED MERIT REPORTER
500 POYDRAS STREET, ROOM HB406
504) 589-7779
[email protected]
PROCEEDINGS RECORDED BY MECHANICAL STENOGRAPHY.

PRODUCED BY COMPUTER.
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OFFICIAL TRANSCRIPT
TRANSCRIPT
I N D E X
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PAGE
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OPENING STATEMENTS BY MR. ROY........................
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OPENING STATEMENTS BY MR. UNDERHILL..................
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OPENING STATEMENTS BY MR. STRANGE.................... 100
OPENING STATEMENTS BY MR. CALDWELL................... 103
OPENING STATEMENTS BY MR. BRIAN...................... 111
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LUNCHEON RECESS...................................... 142
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OFFICIAL TRANSCRIPT
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P-R-O-C-E-E-D-I-N-G-S
MONDAY, FEBRUARY 25, 2013
M O R N I N G
S E S S I O N
(COURT CALLED TO ORDER)
07:22AM
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08:02AM
THE DEPUTY CLERK:
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THE COURT:
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VOICES:
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re:
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Mexico on April 20, 2010; Civil Action 10-2771, In re:
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Complaint and Petition of Triton Asset Leasing GmbH, et al.;
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Civil Action 10-4536, United States of America versus
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BP Exploration and Production, Incorporated, et al.
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those counsel who will be appearing during the trial to make an
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appearance on the record right now, please.
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MR. CUNNINGHAM:
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MR. WILLIAMS:
All rise.
All right.
Good morning, everyone.
Good morning, Your Honor.
THE COURT:
Be seated.
All right, Stephanie, you may call the case,

please.
THE DEPUTY CLERK:
Multidistrict Litigation 10-2179, In
Oil spill by the oil rig Deepwater Horizon in the Gulf of
THE COURT:
MR. ROY:
All right.
The
Counsel, I would like to have
Your Honor, Jim Roy, good morning, PSC
coliaison.
Your Honor, Robert Cunningham, PSC.

OFFICIAL TRANSCRIPT
Duke
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08:03AM
Williams, PSC.
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MR. IRPINO:
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MR. DEGRAVELLES:
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MR. STERBCOW:
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MR. HERMAN:
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for the plaintiff.
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MR. LEGER:
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MR. WILLIAMSON:
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MR. WATTS:
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MR. CERNICH:
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MR. CALDWELL:
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MR. O'ROURKE:
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MR. UNDERHILL:
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MR. KANNER:
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MR. MAZE:
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THE COURT:
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Anthony Irpino on behalf of the PSC.

John DeGravelles, PSC.
Paul Sterbcow, Your Honor, PSC.
Steve Herman
Walter Leger, Counsel for the PSC.

Jimmy Williamson, PSC.
Mikal Watts, PSC.
MR. THORNHILL:
Tom.
Thornhill, PSC.
Scott Cernich, the United States.
Buddy Caldwell, Attorney General for the
State of Louisiana.
MR. STRANGE:
Luther Strange, Attorney General, State
of Alabama.
Steve O'Rourke for the United States.
Mike Underhill on behalf of the United States of America.

MR. BREIT:
Jeffrey Breit on behalf of the PSC,
Your Honor.
Allan Kanner for the State of Louisiana.
Corey Maze for the State of Alabama.

Anyone else on the plaintiffs' side?
Let's move to the defendants.

OFFICIAL TRANSCRIPT
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08:04AM
MR. BROCK:
Mike Brock for BP.
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MR. REGAN:
Matthew Regan for BP, Your Honor.
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MS KARIS:
08:05AM
MR. LANGAN:
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MR. HAYCRAFT:
08:05AM
MR. BECK:
08:05AM
MR. ROBERTS:
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MR. MILLER:
08:05AM
MR. BRIAN:
Brad Brian, Transocean.
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MR. DOYEN:
Michael Doyen, Transocean.
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MR. Li:
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MS. CLINGMAN:
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MR. HYMEL:
Richard Hymel, Transocean.
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MR. GODWIN:
Don Godwin, Halliburton.
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MR. YORK:
Alan York, also for Halliburton.
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MR. HILL:
Gavin Hill, also form Halliburton.
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MR.:
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MR. VON STERNBERG:
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MR. TANNER:
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MS. SCOFIELD:
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MR. FUNDERBURK:
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THE COURT:
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MR. FUNDERBURK:
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THE COURT:
Hariklia Karis on behalf of BP.

Andy Langan for BP.
Don Haycraft, BP.
David Beck for Cameron.

Steve Roberts, Transocean.
Kerry Miller, Transocean.
Luis Lee, Transocean.

Rachel Clingman, Transocean.
Floyd Hartley for Halliburton.

Jerry Von Sternberg, Halliburton.
Hugh Tanner for M-I.

Denise Scofield for M-I.
John Funderburk, for M-I.
I'm sorry, what's your name, sir?
have you on my list.
What's your name?

John Funderburk.
Funderburk?
OFFICIAL TRANSCRIPT
I don't
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08:05AM
MR. FUNDERBURK:
Yes, sir.
08:05AM
THE COURT:
08:05AM
MR. WITTMANN:
08:05AM
MR. JONES:
08:06AM
MR. GANNAWAY:
08:06AM
MR. ROBERTS:
Alan Roberts for Cameron.
08:06AM
MR. KINCHEN:
John Kinchen for Transocean.
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THE COURT:
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are called opening statements by counsel for the parties.
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anticipated that these opening statements will take up the rest
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of today.
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These statements, of course, are not part of the
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evidence in this trial, but are an opportunity for counsel for
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each party to give us an overview or a preview of what they
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believe the evidence will show.
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today, we will recess the trial and resume in the morning with
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the first live witness.
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Before counsel begin their opening statements,
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however, I want to address a few matters regarding courtroom
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conduct and, also, explain some other things about the trial
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itself.
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Okay, thank you.

Phil Wittmann, Cameron.
David Jones for Cameron.

Geoff Gannaway for Cameron.
All right.
All right.
Does that cover everyone?
In a few moments, we will begin what

It's
At the conclusion of the opening statements
This is the first phase of what is expected to be

a multiphase trial.
The parties have estimated that this first

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phase will take approximately three months to complete.
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Thursday beginning at 8:00 a.m. and recessing not later than
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6:00 p.m.
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have no jury, which is customary in admiralty cases such as
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this.
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electronic devices are either turned off or placed on silent
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mode.
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and away from the courtroom doors to do so.
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maintained at all times during this lengthy trial.
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course, cannot have any sorts of verbal commenting or outbursts
08:08AM
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during the trial or during a witness's testimony, so please
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heed this caution.
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An exception is that counsel for the parties may have water at
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their tables.
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type of photographs or video anywhere in the federal courthouse
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complex is strictly prohibited.
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transmitting any part of a trial in a federal courthouse is
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prohibited.
Ordinarily, we will hold trial Monday through
This is a bench trial.
As everyone can see, we
At this time, I ask everyone to make sure that

your cell phones, laptops, iPads, tablets or any other
If you need to use your phone, please step into the hall
I also expect that proper decorum will be

We, of
No food or drinks are allowed in the courtroom.
I also remind everyone that the taking of any
Any recording, broadcasting or
These are not simply my rules.

OFFICIAL TRANSCRIPT
It is the policy
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of the judicial conference of the United States.
08:08AM
Anyone who violates these rules may be subjected
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to sanctions, including fines, seizure of the camera, phone or
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other device, and possible ejection from the courtroom and
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courthouse.
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access to the trial are set forth in the Court's Order of
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January 18, 2013, which is Record Document 8291.
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posted on the Court's public website on that date, and I
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there are audio feeds and evidence presentation screens.
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those of you who cannot get into the courtroom will nonetheless
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be able to hear the live testimony, what is occurring in this
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courtroom, and you'll be able to see whatever is on the
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evidence presentation screens at the same time.
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courthouse and in the courtroom apply to these overflow
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courtrooms as well.
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Now, I would like to give some brief context to
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this trial, primarily to help the press and public understand
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the nature of the current proceedings.
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background and do not constitute rulings or findings by the
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Court.
These rules and other matters regarding public
It's also
strongly encourage everyone to read this article.

Also, we have several overflow courtrooms where
So
The same rules about what is prohibited in the
These comments are provided merely to establish
So, for example, if my description of a particular

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08:10AM
party's role is not entirely accurate or complete, that
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statement is not binding.
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concerns the April 20, 2010 blowout, explosion and fire on the
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mobile offshore drilling unit Deepwater Horizon as it was
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preparing to temporarily abandon the Macondo well, an
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exploratory well drilled in Block 252, Mississippi Canyon, on
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the Outer Continental Shelf, approximately 50 miles south of
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Louisiana.
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sank into the Gulf of Mexico.
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months, oil continuously discharged into the Gulf before the
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well could be capped.
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via a relief well.
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this Phase One of the trial.
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claimants, include, among others, the United States of America,
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the States of Louisiana and Alabama, and numerous private
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individuals, businesses or other entities who have filed claims
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in Transocean's limitation action.
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There are also multiple defendants.
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operator and leased the Macondo prospect site from the federal
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government.
As you are all probably aware, this trial
That catastrophe took the lives of eleven men and

injured many others.
On April 22, after burning for two days, the rig
For roughly the next three
Later, the well was permanently sealed
There are a number of parties participating in

For example, the plaintiffs, or
OFFICIAL TRANSCRIPT
BP was the
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Transocean owned the Deepwater Horizon and was
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Deepwater Horizon's BOP, or blowout preventer, which was
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installed near the wellhead.
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stemming from these events were consolidated before this Court
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in what is called a multidistrict litigation, or commonly
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called an MDL.
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within this MDL:
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entities limitation action, under what is known as the
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Shipowners' Limitation of Liability Act, which I will further
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discuss in a moment; also, Case Number 10-4536, the
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United States' action for certain damages under the
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Oil Pollution Act of 1990, or also called OPA, and for civil
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penalties under Section 311 of the Clean Water Act.
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purposes including trial, as opposed to some of the other cases
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that were transferred here for pretrial purposes only under the
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MDL statute.
contracted by BP to drill the Macondo well.

Halliburton was contracted by BP to provide
cement and related services for the Macondo well.
Cameron manufactured and sold to Transocean the
M-I was contracted by BP to provide certain

drilling fluids, among other services and materials.
In August of 2010, numerous individual lawsuits
This Phase One trial concerns two of the cases

Case number 10-2771, which is the Transocean
Both of these cases are before the Court for all
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The Shipowners' Limitation of Liability Act is an
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1851 federal statute which permits a vessel owner to file a
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complaint in federal court seeking exoneration from liability
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or, alternatively, limitation of liability equal to the
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post-casualty value of the vessel, plus any pending freight.
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requirements, claims against the vessel owner pending in other
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courts are stayed, and the claims instead must be brought in
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the limitation proceeding.
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in what is called a concursus.
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third parties it believes are liable to the plaintiffs, who may
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likewise crossclaim against one another and/or counterclaim
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against the vessel owner.
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limitation complaint.
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proceeding.
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Halliburton, Cameron, M-I and others, who then cross-claimed
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against one another and counterclaimed against Transocean.
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shows that the fault causing the loss occurred without its
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privity or knowledge.
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of negligence or unseaworthiness caused the casualty and
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whether the vessel owner had knowledge or privity of these
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acts.
If the vessel owner complies with certain
In this manner, all claims are marshaled together

The vessel owner may also join
This is what happened here.
Transocean filed a
Claims were filed in the limitation
Transocean brought third-party claims against BP,
A vessel owner may limit its liability only if it
Thus, the Court must determine what acts
OFFICIAL TRANSCRIPT
19
08:14AM
The burden of proving negligence or
08:14AM
unseaworthiness is on the claimants.
08:14AM
shift to the vessel owner to prove lack of privity or
08:14AM
knowledge.
08:14AM
08:14AM
entitled to limit its liability, there would be unresolved
08:14AM
questions about what claims are subject to the limitation,
08:14AM
particularly with respect to claims under OPA.
08:14AM
08:14AM
10
in the limitation action, to simplify matters during this
08:14AM
11
trial, I will typically refer to the United States, the States
08:14AM
12
and the private plaintiffs as the plaintiffs, and I will refer
08:14AM
13
to Transocean and BP, Halliburton, Cameron and M-I as the
08:14AM
14
defendants.
08:14AM
15
08:14AM
16
claims under OPA and the Clean Water Act.
08:15AM
17
tried with Transocean's limitation action because there are
08:15AM
18
some overlapping issues, particularly whether BP or Transocean
08:15AM
19
acted with gross negligence or willful misconduct.
08:15AM
20
08:15AM
21
civil penalty for harmful discharge of oil, the maximum value
08:15AM
22
of which is determined primarily by two factors, how much oil
08:15AM
23
was discharged, and whether or not the discharger acted with
08:15AM
24
gross negligence or willful misconduct.
08:15AM
25
The burden will then
It should be noted that even if Transocean is
Although Transocean is technically the plaintiff
As mentioned, the United States' action brings

This action is being
This is because the Clean Water Act imposes a
Phase One of this trial will address fault

OFFICIAL TRANSCRIPT
20
08:15AM
determination and allocation relating to the loss of well
08:15AM
control or blowout, the ensuing fire and explosion, capsizing
08:15AM
and sinking of the Deepwater Horizon, and the initiation of the
08:15AM
release of oil from the well.
08:15AM
08:15AM
Transocean's exoneration, limitation and liability defenses, as
08:15AM
well as the issues relating to various crossclaims,
08:16AM
counterclaims, etcetera, between the various defendants.
08:16AM
08:16AM
10
losses or damages suffered by any one plaintiff will not be
08:16AM
11
determined in this phase, nor will the Court determine the
08:16AM
12
amount of any civil fines or penalties in this phase of the
08:16AM
13
trial.
08:16AM
14
08:16AM
15
to or decide in this phase issues regarding the response
08:16AM
16
efforts following the spill or the quantity of oil that escaped
08:16AM
17
before the well was capped.
08:16AM
18
later Phase Two trial.
08:16AM
19
08:16AM
20
opening statements and assigned the order in which they will
08:16AM
21
occur.
08:16AM
22
08:16AM
23
the Plaintiffs' Steering Committee will have 75 minutes of
08:16AM
24
opening statements.
08:16AM
25
45 minutes.
Phase One will also include issues related to
It is important to understand that the particular
Also, the Court will not hear evidence relating
Those issues will be subjects of a
Now, the Court has previously allocated time for
The private claimants represented here today by
The United States will then follow for
The States of Louisiana and Alabama have a total

OFFICIAL TRANSCRIPT
21
08:16AM
of 20 minutes.
Transocean then has 60 minutes, Halliburton
08:17AM
60 minutes, BP 90 minutes, Cameron 10 minutes, and M-I
08:17AM
10 minutes.
08:17AM
370 minutes, or a little over six hours.
08:17AM
08:17AM
will generally go as follows:
08:17AM
United States and the States will present evidence in support
08:17AM
of their claims against all defendants.
08:17AM
08:17AM
10
exoneration, limitation and liability defenses, as well as any
08:17AM
11
counter, cross or third-party claims against other defendants.
08:17AM
12
08:17AM
13
their evidence in support of their defenses in counter, cross
08:17AM
14
and third-party claims.
08:17AM
15
08:17AM
16
08:17AM
17
08:17AM
18
presentation.
08:18AM
19
to trial.
08:18AM
20
outside of court under oath, and those examinations were
08:18AM
21
recorded.
08:18AM
22
to the Court in advance of trial.
08:18AM
23
08:18AM
24
transcript may be introduced into evidence in lieu of having
08:18AM
25
that witness appear in person to testify live.
If my math is correct, that's a total of
During the trial, the order of proof, the order

First, the PSC, the
Second, Transocean will present evidence on its
Third, the remaining defendants shall present
And fourth, the PSC, USA and States shall present

any rebuttal evidence.
Finally, a few notes regarding evidence
The parties deposed many, many witnesses prior
This means that witnesses were questioned by counsel
Transcripts of these depositions have been submitted
During the trial, a witness's deposition
OFFICIAL TRANSCRIPT
22
08:18AM
In addition, the parties may at times play
08:18AM
08:18AM
08:18AM
08:18AM
The plan is to have Magistrate
08:18AM
Judge Sally Shushan assist the Court and the parties each
08:18AM
Thursday afternoon in marshalling the materials which were used
08:18AM
or introduced during that week.
08:18AM
08:18AM
10
electronic format and will be made available for the press and
08:18AM
11
public as follows.
08:18AM
12
During each week of the trial, the report and
08:18AM
13
rsum of each expert who testifies will be introduced into
08:19AM
14
evidence.
08:19AM
15
testimony on direct examination.
08:19AM
16
08:19AM
17
tender for filing into the record fact witness deposition
08:19AM
18
transcripts and exhibits.
08:19AM
19
objections which have been lodged by various parties.
08:19AM
20
procedure will continue through the course of the trial.
08:19AM
21
08:19AM
22
particularly, a caveat here about this.
08:19AM
23
volume of evidence that the Court has already seen and will see
08:19AM
24
during the course of this trial, some of the testimony and
08:19AM
25
exhibits that will be admitted during the trial will be
shorter video clips from certain depositions.

The parties have also prepared numerous exhibits
that will be submitted as the trial progresses.
All of the depositions and exhibits are in
The report will be a part of the expert's trial
At the first marshalling conference, the PSC will
Those will be proffered subject to

That
Let me provide the press and the public,
OFFICIAL TRANSCRIPT
Because of the sheer
23
08:19AM
admitted subject to certain objections.
That means that the
08:19AM
Court may later exclude some of this evidence and not take it
08:19AM
into consideration in reaching its decisions in this case.
08:20AM
08:20AM
just because something is mentioned in testimony or an exhibit
08:20AM
is introduced at trial, if it is subject to an objection, that
08:20AM
does not preclude the possibility of it being excluded at a
08:20AM
later date.
08:20AM
This is being done as an accommodation, again,
08:20AM
10
because of the sheer volume of evidence that the parties and
08:20AM
11
the Court are working with in this case.
08:20AM
12
08:20AM
13
deposition transcripts, related exhibits, expert reports and
08:20AM
14
rsums, and the exhibits that are marshalled each week will be
08:20AM
15
made available and posted each week on a public FTP Internet
08:20AM
16
website, which is www.MDL2179trialdocs.com.
08:21AM
17
will be posted on the Court's public website.
08:21AM
18
08:21AM
19
but it is a website where all of this information will be
08:21AM
20
posted weekly and will be available to the public or press.
08:21AM
21
08:21AM
22
public access to trial materials, you should refer to the
08:21AM
23
recent Order of the Court issued February 22nd, 2013, which
08:21AM
24
will be available on the Court's public website.
08:21AM
25
website, by the way, for the benefit of those who do not know,
So I would just caution the press and public that
All right.
Again, the plan is that all
The link to that
That is not a court-maintained website, however,
So if anyone has any further questions about
OFFICIAL TRANSCRIPT
The Court's
24
08:21AM
is www.laed.uscourts.gov.
08:21AM
08:21AM
08:21AM
08:21AM
the Court staff about this.
08:21AM
posted at the Court's website.
08:21AM
can tell you, so please do not call or contact the Court staff
08:22AM
with these questions.
08:22AM
08:22AM
10
available to the Court and to the court reporters a glossary of
08:22AM
11
certain terms and acronyms that may be used from time to time
08:22AM
12
during the trial.
08:22AM
13
08:22AM
14
highly technical industry, and there are a lot of acronyms that
08:22AM
15
will be used.
08:22AM
16
to try to avoid using acronyms as much as they can during the
08:22AM
17
trial; but, so that the press and the public can understand
08:22AM
18
what's going on, we do have a glossary that can be made
08:22AM
19
available that would be helpful.
08:22AM
20
08:22AM
21
that we have two benches in the courtroom reserved for members
08:22AM
22
of the credentialed media.
08:22AM
23
08:22AM
24
have arranged, in addition to the three normal overflow
08:22AM
25
courtrooms which we should have for the length of the trial,
If you go there, that's the Court's home page,

there is a link to MDL 2179.
Please do not, do not call the Court or contact
All information you should have is
There's really nothing else we
I should also note that the parties have made
The oil and gas industry is a specialized and
I'm going to ask the parties and the attorneys
With regard to the press corps, you will note
In addition, at least for this first week, we
OFFICIAL TRANSCRIPT
25
08:23AM
just for the week only, we've arranged for the use of Courtroom
08:23AM
C-224, which is Judge Milazzo's courtroom directly across the
08:23AM
hall from my courtroom.
08:23AM
proceeding that she had scheduled this week to another
08:23AM
courtroom to allow us to use that courtroom.
08:23AM
08:23AM
there are courtrooms available, I'll try to make another
08:23AM
district court courtroom available.
08:23AM
08:23AM
10
figured out or counted that the lawyers have enough room
08:23AM
11
between taking up most of this courtroom and three other
08:23AM
12
courtrooms that we needed space reserved for the press and
08:23AM
13
public.
08:23AM
14
08:23AM
15
could not get in this courtroom and/or would just like a more
08:23AM
16
convenient place to work, we have five tables reserved for use
08:23AM
17
by the press across the hall.
08:24AM
18
is for the public.
08:24AM
19
08:24AM
20
other overflow rooms, will have a live audio feed and evidence
08:24AM
21
screens for you to follow what's going on in this courtroom.
08:24AM
22
08:24AM
23
statements.
08:24AM
24
else that I've looked at the calendar.
08:24AM
25
announced that we would not work -- this trial, as I said, is
She's been kind enough to move one
This is going to be a week-to-week thing.
In that courtroom, it's a no lawyer zone.
If
We
So if there are any members of the press who
All right.
The rest of the seating in there
And again, that courtroom, like the
One more thing before we begin opening

I want to announce to the lawyers and to everyone
We had already
OFFICIAL TRANSCRIPT
26
08:24AM
expected to last three months.
We've already announced that we
08:24AM
would not work or hold court on the Thursday and Friday
08:24AM
immediately preceding Easter weekend.
08:24AM
08:25AM
calendar, since a lot of the attorneys and parties in this case
08:25AM
are from out of town, to accommodate them, I've decided that we
08:25AM
would also not work on the Monday right after Easter, which I
08:25AM
think is April 1, so that way you all can make travel plans so
08:25AM
you don't have to travel back -- so those of you out of town
08:25AM
10
don't have to travel back on Sunday, if you care to stay home
08:25AM
11
for that weekend.
08:25AM
12
08:25AM
13
08:25AM
14
08:25AM
15
08:25AM
16
08:25AM
17
08:25AM
18
08:25AM
19
08:25AM
20
08:25AM
21
we're gathered.
08:25AM
22
operator of the Deepwater Horizon.
08:25AM
23
their liability.
08:25AM
24
failed to discover a major gas kick and shut in the well on
08:25AM
25
April 20, 2010.
And in thinking about it and looking at the
Okay.
Does anybody have any other preliminary
matters before we begin opening statements?

All right.
statements?
Who is going to make opening
Mr. Roy?
OPENING STATEMENTS
BY MR. ROY:
I'm Jim Roy for the
Plaintiffs' Steering Committee.

Why did this terrible tragedy happen?
That's why
Let's begin with Transocean, the owner and the

They seek limitation of
The evidence is going to show Transocean
OFFICIAL TRANSCRIPT
27
08:25AM
A critical part of the temporary abandonment
08:26AM
procedure from Macondo was a negative pressure test.
08:26AM
a shared responsibility between BP and Transocean.
08:26AM
was misinterpreted.
08:26AM
well was secure and that it was safe to go forward with
08:26AM
displacement of the heavy drill mud with much lighter seawater.
08:26AM
08:26AM
will describe the failure to interpret this test correctly as a
08:26AM
gross and extreme departure from the standards of good oilfield
08:26AM
10
08:26AM
11
08:26AM
12
is over 20 barrels is code red and critical.
08:26AM
13
is described as off the chart and unprecedented, exceeding not
08:26AM
14
20 barrels, but exceeding 700 barrels, and consuming 50 minutes
08:27AM
15
of time before the kick was detected and unsuccessful efforts
08:27AM
16
made to shut it in.
08:27AM
17
08:27AM
18
discover this giant gas kick and to shut in the well was a
08:27AM
19
result of the willful failure of Transocean management to give
08:27AM
20
its Deepwater Horizon crew, and other crews on other rigs,
08:27AM
21
adequate training.
08:27AM
22
08:27AM
23
information showing that this well was flowing, this Transocean
08:27AM
24
crew, BP and Halliburton Sperry logger totally missed the kick
08:27AM
25
on April 20, 2010, that according to BP's own expert,
This was
The test
This led to the mistaken belief that the
Richard Heenan, an expert petroleum engineer,
practice.
Transocean's own standards state that a kick that
The Macondo kick
The evidence will show Transocean's failure to
The evidence shows that despite a wealth of
OFFICIAL TRANSCRIPT
28
08:27AM
Robert Grace, my dad would have caught.
08:27AM
08:27AM
responsibility at Transocean for this gross and extreme
08:27AM
departure from good oilfield practically rests with the
08:28AM
management of Transocean.
08:28AM
08:28AM
of the drill crew, including the offshore installation manager,
08:28AM
the driller, the assistant driller or the toolpusher on how to
08:28AM
interpret a negative pressure test.
08:28AM
10
Transocean's formal training, its training materials, nor its
08:28AM
11
well control handbook cover or even discuss negative pressure
08:28AM
12
tests.
08:28AM
13
08:28AM
14
crew and BP and Halliburton on April 20, 2010, to catch the
08:28AM
15
riser unloading, the kick, was no isolated event.
08:28AM
16
will show that Transocean had known for years that its rig
08:28AM
17
personnel were not adequately trained to recognize and shut in
08:28AM
18
gas kicks, especially riser unloading events like that involved
08:29AM
19
on the Deepwater Horizon disaster.
08:29AM
20
08:29AM
21
back as 2004 on another semisubmersible concluded procedures
08:29AM
22
were not set up to effectively detect kicks.
08:29AM
23
heed warnings in the drill program.
08:29AM
24
disciplined, coordinated procedures to monitor for well
08:29AM
25
influxes, and prophetically, alarms were turned off.
The evidence will show the ultimate
Transocean never specifically trained any member
Amazingly neither
The catastrophic failure of the Deepwater Horizon
The evidence
Transocean's investigation of an incident as far
The team did not
The team did not use
OFFICIAL TRANSCRIPT
29
08:29AM
By March of 2008, the situation had deteriorated
08:29AM
such that Larry McMahon, Transocean's vice-president of
08:29AM
performance, wrote an e-mail to management teams about a series
08:29AM
of recent loss-of-control-type events, including, as an
08:29AM
example, loss of well control.
08:29AM
08:30AM
cannot ignore what has happened in the area of loss of control.
08:30AM
This is very concerning to me.
08:30AM
having events at a rate that is overwhelming.
08:30AM
10
better off investing that time in the prevention side and more
08:30AM
11
effective risk assessment, as well as adherents to proceed."
08:30AM
12
08:30AM
13
do not change the way we operate, we will continue to have
08:30AM
14
these train wrecks."
08:30AM
15
08:30AM
16
following yet another riser unloading incident in February
08:30AM
17
of '09, on a Transocean rig, Transocean determined, there was
08:30AM
18
no task risk assessment performed; that Management of Change
08:31AM
19
was not adequately addressed; well control training and the
08:31AM
20
well control manual does not adequately cover the procedures
08:31AM
21
for closing in a well during a blowout situation; also, the use
08:31AM
22
of the diverter is not adequately covered.
08:31AM
23
08:31AM
24
specific training given for handling a kick in the riser and a
08:31AM
25
lack of explanation about the proper use of the diverter.
This is what he said, among other things, "We
The problem is that we are

We would be
And then McMahon prophetically concluded, "If we
That's in 2008.
A year later, in March of 2009,
The report also found that there had been no
OFFICIAL TRANSCRIPT
It
30
08:31AM
also recommended well control reference material and training
08:31AM
should adequately cover the use of the diverter and what to do
08:31AM
in the case of the riser unloading.
08:31AM
use Management of Change procedures to ensure adequate risk
08:31AM
assessments are performed.
08:32AM
08:32AM
08:32AM
08:32AM
08:32AM
10
inadequacy of crew training problems to management.
08:32AM
11
involved multiple failures to shut in the well when influxes
08:32AM
12
were clearly detected, and not shutting in the well during an
08:32AM
13
influx.
08:32AM
14
08:32AM
15
incident occurred aboard the Transocean Sedco 711, involving an
08:32AM
16
uncontrolled release of hydrocarbons on the drill floor due to
08:32AM
17
Transocean crews failure to notice kick indicators.
08:32AM
18
08:33AM
19
prophetically revealed that Transocean's mind-set is certainly
08:33AM
20
less vigilant regarding well control preparedness during the
08:33AM
21
completion phase as compared to the drilling phase.
08:33AM
22
08:33AM
23
recommendation that Transocean's well control handbook add a
08:33AM
24
section on performing fluid displacements, this was not done
08:33AM
25
until after the Deepwater Horizon catastrophe.
And rig management should
Transocean management refused to act on these

recommendations until the April 20th catastrophe.
Again, in late July of 2009, another well control
event on another Transocean rig, once again, demonstrated the
It
Just five months before this disaster.

In December of 2009, another well control
The Transocean investigation of this incident
Although the investigation again made the
OFFICIAL TRANSCRIPT
31
08:33AM
Randy Ezell, Transocean's senior toolpusher
08:33AM
aboard the Deepwater Horizon, will recall several declared well
08:33AM
control events on the Deepwater Horizon before this one where
08:33AM
hydrocarbons made it past the blowout preventer and to the
08:33AM
bottom of the rotary table thousands of feet up above on the
08:33AM
drill floor, and had the potential to endanger life in the
08:33AM
environment.
08:34AM
08:34AM
08:34AM
10
Deepwater Horizon failed to catch a gas kick for some 35 to
08:34AM
11
40 minutes.
08:34AM
12
reflected itself over years, that lack of training in kick
08:34AM
13
detection and well control was no isolated incident with
08:34AM
14
Transocean rigs, but rather was a chronic problem, allowed by
08:34AM
15
Transocean management to go uncorrected.
08:34AM
16
08:34AM
17
2010, in fact, commented, Transocean's drill crew had screwed
08:34AM
18
up by not catching it.
08:34AM
19
08:34AM
20
Transocean management itself recognized the following:
08:35AM
21
increasing trend seen in 2009 of drilling risers being either
08:35AM
22
partially or completely evacuated or unloaded."
08:35AM
23
08:35AM
24
this type of event, that's riser unloading, occurred six times
08:35AM
25
on Transocean rigs.
In fact, on March 8th of 2010, just a month

before this disaster, the Transocean crew on the
Once again, demonstrating a pattern that had
The BP well team leader at the time, in March of
In its annual well control report for 2009,

"The
Again, from December of 2008 until year end 2009,
OFFICIAL TRANSCRIPT
32
08:35AM
"It is particularly hazard," it went on, "due to
08:35AM
the uncontrolled release of mud and gas through the rotary
08:35AM
table and the potential for ignition.
08:35AM
can be avoided through the application of fundamental well
08:35AM
control practices, such as treating every positive indicator as
08:35AM
a kick, shutting in quickly, and taking returns through the
08:35AM
choke whenever in any doubt, any doubt whatsoever."
08:35AM
08:36AM
08:36AM
10
08:36AM
11
08:36AM
12
follow basic well monitoring kick detection and shut-in
08:36AM
13
procedures was well known to upper level management at
08:36AM
14
Transocean and continued unabated and uncorrected, despite
08:36AM
15
their knowledge, up to and including this tragedy.
08:36AM
16
08:36AM
17
at least the seventh that a Transocean rig had experienced in
08:36AM
18
just the previous 17 months.
08:36AM
19
led to the disaster of April 20th, 2010, which Larry McMahon,
08:36AM
20
Transocean's own vice-president operations and performance,
08:36AM
21
agreed was a train wreck of the largest magnitude.
08:37AM
22
08:37AM
23
Transocean willfully failed to adequately train its crew in
08:37AM
24
other safety critical functions.
08:37AM
25
assurance system in place aboard the Deepwater Horizon.
Riser unloading events
Transocean management knew about the widespread

nature of well control problems on its vessels, and that the
time spent on well control events had increased in 2009.
The failure of Transocean drill crews to know and
The fateful April 20th, 2010, riser unloading was
This chronic problem ultimately
The evidence is also going to show that
There was no competence
OFFICIAL TRANSCRIPT
33
08:37AM
In fact, Lloyd's Register, an entity trusted by
08:37AM
drillers across the world to tell them what their problems are,
08:37AM
Lloyd's Register issued a report covering an assessment from
08:37AM
March 9th to 26th of 2010, just weeks before this catastrophe,
08:37AM
in which it discussed Transocean's safety management and safety
08:37AM
culture.
08:37AM
08:37AM
report were the following ominous indications of training
08:37AM
failures:
08:38AM
10
they were exposed to, relating to both their job and to other
08:38AM
11
jobs in the same/adjoining work areas."
08:38AM
12
08:38AM
13
fully understood, and the subsequent control measures were not
08:38AM
14
always appropriate.
08:38AM
15
08:38AM
16
comment, "This clearly demands attention, as frontline crews
08:38AM
17
are potentially working with a mind-set that they are fully
08:38AM
18
aware of all the hazards when it's highly likely that they are
08:38AM
19
not."
08:38AM
20
08:38AM
21
short, required Transocean to appoint a designated person
08:39AM
22
ashore who has responsibility for safety on a given rig, and
08:39AM
23
has access to the highest levels of management.
08:39AM
24
08:39AM
25
Among the supervisors' comments recounted in the
"The workforce was not always aware of the hazards
"The risk posed by identified hazards were not
They don't know what they don't know."
The report concluded this section with the
The International Safety Management Code, ISM for
Gerald Canducci was Transocean's designated

person ashore for the Deepwater Horizon.
OFFICIAL TRANSCRIPT
34
08:39AM
Jeff Webster, a marine expert testifying on
08:39AM
behalf of the PSC, will testify that Mr. Canducci was not even
08:39AM
minimally competent for this job.
08:39AM
three-day course.
08:39AM
board the Deepwater Horizon.
08:39AM
responsibility for safety that management had entrusted to that
08:39AM
job.
08:39AM
08:39AM
08:40AM
10
guy, good captain, but under trained in the safety management
08:40AM
11
system of the vessel, despite the ISM requirement that he, no
08:40AM
12
one else, he be in charge of implementing it, and he had never
08:40AM
13
been trained in it adequately.
08:40AM
14
the operation of the vessel's emergency disconnect system
08:40AM
15
either.
08:40AM
16
Compounding this problem was the
08:40AM
17
Deepwater Horizon's dual command structure, which prevented
08:40AM
18
Captain Kutcha, the captain of the vessel, from activating the
08:40AM
19
emergency disconnect system until Jimmy Harold, the offshore
08:40AM
20
installation manager arrived.
08:40AM
21
08:40AM
22
been given the requisite training and authority by Transocean
08:40AM
23
management, earlier activation of this emergency disconnect
08:40AM
24
system could have averted much of the catastrophe, either
08:41AM
25
altogether or at the very least mitigating it by reducing loss
His training consisted of a
Amazingly Mr. Canducci had never been on

And this is the man with the
The captain of the Deepwater Horizon,

Carl [verbatim] Kutcha, was also woefully under trained.
Good
He had never been trained in
The evidence will show that if Captain Kutcha had
OFFICIAL TRANSCRIPT
35
08:41AM
of life, injuries, the vessel, and pollution.
08:41AM
08:41AM
Jimmy Harold's certificate did not allow him to be the OIM and
08:41AM
the person in charge on this vessel.
08:41AM
08:41AM
Yancy Keplinger had no training on the safety equipment on the
08:41AM
bridge of the vessel where he acted as senior watch keeping
08:41AM
officer and held no proper license for the job he was
08:41AM
performing.
08:41AM
10
Andrea Fleytas had ever received training on a scenario like
08:41AM
11
the one which occurred on the day of this fateful disaster
08:41AM
12
where there was a contemporaneous activation of numerous gas
08:42AM
13
detection alarms.
08:42AM
14
08:42AM
15
Transocean management failure to adequately train this crew
08:42AM
16
directly contributed to the events leading to the blowout
08:42AM
17
explosion, deaths, the loss of Deepwater Horizon, and the
08:42AM
18
ensuing pollution.
08:42AM
19
08:42AM
20
crew recklessly misused equipment by diverting the blowout
08:42AM
21
through the mud-gas separator, instead of the rig's diverter
08:42AM
22
system.
08:42AM
23
The mud-gas separator is a low-pressure system,
08:42AM
24
Judge, used to separate small amounts of gas coming up in the
08:42AM
25
mud returns and taking them out.
Amazingly, the offshore installation manager,
Senior dynamic positioning officer, DPO,
Neither he nor dynamic positioning officer
The evidence will establish that this overarching
The evidence will also show that Transocean's
It's not designed or intended
OFFICIAL TRANSCRIPT
36
08:42AM
to handle large amounts of gas or gas under high pressure in an
08:42AM
emergency.
08:42AM
Transocean's policy on this thing did dictate
08:42AM
that the gas diverter system, not the mud-gas separator, be
08:43AM
used in the event of a well control event requiring diversion
08:43AM
of large amounts of gas.
08:43AM
08:43AM
trained crew of the Deepwater Horizon failed to divert the kick
08:43AM
through the emergency diverter system, the mud-gas separator
08:43AM
10
was quickly overwhelmed by the high volume of gas and pressure
08:43AM
11
and the entire vessel was engulfed in flammable gas.
08:43AM
12
08:43AM
13
system be used instead of the mud-gas separator, the
08:43AM
14
Deepwater Horizon crew would likely have survived without
08:43AM
15
casualty and the vessel not been destroyed.
08:43AM
16
08:43AM
17
of the diverter system was once again evidence of a chronic
08:43AM
18
problem known to senior management in failure to train but
08:43AM
19
which remained uncorrected for years.
08:43AM
20
08:44AM
21
overrode several automatic functions of the integrated alarm
08:44AM
22
and control system.
08:44AM
23
may have people refer to that as the I-A-C-S or IACS or the
08:44AM
24
Kongsberg system.
08:44AM
25
The evidence will show that when the poorly
The evidence will show had the emergency diverter
This lack of adequate training in the proper use
The evidence will also show Transocean willfully
In the course of this trial, Judge, you
It's one in the same.
By overriding the automatic functions, it

OFFICIAL TRANSCRIPT
37
08:44AM
required human intervention to activate the shutdown system.
08:44AM
Specifically, the integrated alarm and control system was
08:44AM
designed to control a number of safety critical functions
08:44AM
automatically upon the detection of combustible gas, including
08:44AM
the sounding of a general alarm, and the activation of an
08:44AM
emergency shutdown system, and activation of a fire and gas
08:44AM
safety system.
08:44AM
08:44AM
08:45AM
10
which was the major potential source of gas ignition on this
08:45AM
11
rig, by closing dampers that allowed -- stopped air from
08:45AM
12
entering the room itself where the engines were, sounding
08:45AM
13
audible alarms and actually shutting down the over-speeding
08:45AM
14
engines to deny an ignition source to all the natural gas that
08:45AM
15
had set the alarms off to begin with.
08:45AM
16
08:45AM
17
alarm and control system and requiring human intervention to
08:45AM
18
activate the shutdown system, while the alarm signalling the
08:45AM
19
influx of gas would be reported to the bridge, it would no
08:45AM
20
longer automatically activate these other safety critical
08:45AM
21
functions.
08:45AM
22
on the fateful day of April 20th of 2010.
08:45AM
23
08:46AM
24
the origination point for signalling an influx of gas amazingly
08:46AM
25
had either been set into passive mode or otherwise had their
The emergency shutdown system, or ESD, as some

call it, would in turn stop gas from entering the engine room,
By Transocean's inhibiting these alarms in this
And this meant a lot when time was of the essence
In addition, many of the centers which served as
OFFICIAL TRANSCRIPT
38
08:46AM
sensors set basically into what is functionally a passive mode
08:46AM
and removed from service.
08:46AM
08:46AM
control system was Transocean company policy.
08:46AM
chief electronics technician, Mike Williams, will testify in
08:46AM
this courtroom that inhibiting the alarms was done to avoid
08:46AM
waking people up at night.
08:46AM
08:46AM
08:46AM
10
Even with the automatic function inhibited, the crew could have
08:47AM
11
activated the emergency shutdown system, but why didn't they?
08:47AM
12
08:47AM
13
mayhem on the bridge, shouts, directions being yelled that
08:47AM
14
weren't being enacted.
08:47AM
15
deer-in-the-headlights look, was overwhelmed, dazed and
08:47AM
16
confused.
08:47AM
17
08:47AM
18
requests from Chris Pleasant, another crewmember, to the
08:47AM
19
captain to allow him to activate the emergency disconnect
08:47AM
20
system before the captain finally authorized him to do it.
08:47AM
21
08:47AM
22
have activated the emergency disconnect system, but under the
08:47AM
23
then existing dual command structure, he was prevented from
08:47AM
24
doing so until the offshore installation manager, Jimmy Harold,
08:48AM
25
arrived and gave his approval.
This inhibition of the integrated alarm and

Why?
Transocean
Transocean personnel failed to activate the

emergency shutdown system fast enough to do any good.
Why?
Because after the blowout there was chaos and
Captain Kutcha had a
Even after the second explosion, it took three
During this critical time when the captain could
OFFICIAL TRANSCRIPT
39
08:48AM
Had this been done promptly, the vessel probably
08:48AM
would have been saved and pollution minimized.
08:48AM
the dysfunctional dual command structure and lack of adequate
08:48AM
training, the emergency disconnect system was not even
08:48AM
activated manually.
08:48AM
08:48AM
Deepwater Horizon, in other words, did not have overriding
08:48AM
authority and responsibility from Transocean management to take
08:48AM
the decisive action he needed to take to protect the crew, the
08:48AM
10
vessel, and the environment.
08:48AM
11
nonconformity with the ISM code and contributed significantly
08:48AM
12
to the magnitude of the disaster.
08:48AM
13
08:48AM
14
about this problem.
08:49AM
15
first days of the Deepwater Horizon's operation nine years
08:49AM
16
earlier.
08:49AM
17
08:49AM
18
organization called Det Norske Veritas or DNV, an international
08:49AM
19
respected organization that does inspections for vessel and
08:49AM
20
owners, for compliance.
08:49AM
21
responsibilities of the master and OIM were in conflict.
08:49AM
22
08:49AM
23
requiring action to be taken by August of 2002.
08:49AM
24
later, in 2009, DNV again cautioned Transocean management about
08:49AM
25
this problem.
But because of
Certainly not timely.
The evidence will show the master of the
This constituted a major
Transocean executive management had been warned

They had been warned about this since the
In the initial ISM certification by an
They identified that the authority and
DNV raised this ISM code nonconformity issue,

Seven years
The company was requested to address it.

OFFICIAL TRANSCRIPT
40
08:50AM
For seven years before this tragedy, this
08:50AM
critical problem had been known to Transocean executive
08:50AM
management but Transocean still had not corrected the situation
08:50AM
as of April 20th, 2010.
08:50AM
08:50AM
were poorly trained and failed to act in a timely manner.
08:50AM
the cascading alarms did sound, in fact, dynamic positioning
08:50AM
officer Andrea Fleytas failed to announce, "This is not a
08:50AM
drill," because she was too nervous.
08:50AM
10
08:50AM
11
positioning officer, Yancy Keplinger failed to intervene and
08:50AM
12
allowed this to happen.
08:50AM
13
never received training for a scenario where there was a
08:50AM
14
contemporaneous activation of numerous detections and alarms
08:51AM
15
going off.
08:51AM
16
08:51AM
17
refusal to upgrade and maintain the Deepwater Horizon blowout
08:51AM
18
preventer was also a major cause of this disaster.
08:51AM
19
preventer or BOP, is a safety critical piece of
08:51AM
20
Deepwater Horizon vessel equipment, owned by Transocean.
08:51AM
21
08:51AM
22
the main barrier protecting human life, equipment and the
08:51AM
23
environment, it must function without fail.
08:51AM
24
the field as the last line of defense to a blowout.
08:51AM
25
Other key members of the Transocean bridge team

When
Even worse, the more senior DPO, dynamic
Indeed, Keplinger agrees that he had
Transocean's design involvement and willful
The blowout
And the evidence will establish that because it's
BOPs are viewed in
Transocean participated with BP and Cameron in

OFFICIAL TRANSCRIPT
41
08:51AM
the original design of the Deepwater Horizon blowout preventer
08:51AM
and the selection and configuration of the component parts.
08:51AM
Under the drilling contract, Transocean was to furnish the
08:52AM
blowout preventer and ensure that it was adequately maintained
08:52AM
in such a condition as to permit its continuous and efficient
08:52AM
operation.
08:52AM
08:52AM
BOP on the Deepwater Horizon is a piece of Transocean
08:52AM
equipment, and we are responsible for the maintenance of that
08:52AM
10
08:52AM
11
08:52AM
12
BOP was out of certification and in violation of industry
08:52AM
13
standards.
08:52AM
14
Transocean's well control handbook required the
08:52AM
15
BOP to be able to handle the maximum pressure and temperature
08:52AM
16
conditions for any well where it was to be used.
08:52AM
17
evidence will show that this BOP could not.
08:52AM
18
08:53AM
19
for a particular well, it, Transocean, was obligated to either
08:53AM
20
change the BOP or not drill the well.
08:53AM
21
08:53AM
22
evidence will also show that if BP realized that the equipment
08:53AM
23
of the rig was not fit for the well it wanted the rig to drill,
08:53AM
24
then BP, too, had the obligation not to take that rig but to
08:53AM
25
get another or make them change it.
As stated by Transocean's CEO, Steve Newman, "The
piece of equipment."
Multiple audits warned BP and Transocean that the
Yet the
If Transocean concluded that the BOP was unfit
Now, the converse is true, too, Your Honor.
OFFICIAL TRANSCRIPT
The
42
08:53AM
Transocean knew that drilling crews frequently
08:53AM
confronted situations where the blind shear rams on the BOP
08:53AM
would encounter off-center piping.
08:53AM
upgrade the blind shear rams with better cutting blades even
08:53AM
those they were cheap, easily available and easily installed.
08:53AM
Transocean knew as early as 2001, that a single
08:53AM
blind shear ram represented a single point of failure, and knew
08:54AM
that double-blind shear rams were available and becoming more
08:54AM
common in 2009 and 2010, yet Transocean chose to continue with
08:54AM
10
08:54AM
11
08:54AM
12
failure under dynamic flow conditions.
08:54AM
13
conditions, oil, gas, high-pressure liquids or distillate
08:54AM
14
actually flowing rapidly through it and you try to close it.
08:54AM
15
That's a dynamic condition versus a static condition, it's
08:54AM
16
already closed and it's just holding the pressure back.
08:54AM
17
08:54AM
18
under these dynamic flow conditions and knew that blind shear
08:54AM
19
rams had not been tested under dynamic flow conditions, and
08:54AM
20
willfully chose not to do that testing itself to see if they
08:54AM
21
would work and under what dynamic flow conditions.
08:54AM
22
matter, there was no BOP shear testing at all.
08:55AM
23
Transocean management knew that the batteries on
08:55AM
24
the pods of the BOP could not be monitored, checked or charged
08:55AM
25
while the BOP was 5000 feet underwater on the sea floor, and
Yet Transocean chose not to
the single ram.

Transocean knew of the potential for the BOP
Dynamic flow
Transocean knew of the potential for BOP failure
OFFICIAL TRANSCRIPT
For that
43
08:55AM
knew that its maintenance and recordkeeping system regarding
08:55AM
the batteries was seriously flawed such that one could not tell
08:55AM
when the batteries had been changed.
08:55AM
change its recordkeeping system.
08:55AM
08:55AM
the cables, they are called MUX cables, that powered and
08:55AM
controlled it and give feedback to the surface and vice versa,
08:55AM
Transocean knew that by running the MUX cable through the
08:55AM
Moonpool, the hole in the rig, that it created a single failure
08:55AM
10
point if there was an explosion that could knock out both
08:55AM
11
redundant cables from the same explosion.
08:56AM
12
steps to correct that.
08:56AM
13
trigger system to the blowout preventer activation, which
08:56AM
14
Transocean, in fact, utilized on other rigs in other places in
08:56AM
15
the world.
08:56AM
16
In violation of the ISM code, the
08:56AM
17
Deepwater Horizon had not been in for drydocking inspections
08:56AM
18
and repair during its entire nine years of existence.
08:56AM
19
expert Geoff Webster says that was reckless and inexcusable.
08:56AM
20
Furthermore, Transocean had a reactive, rather
08:56AM
21
than a proactive, condition-based maintenance system, which,
08:56AM
22
from the view of Transocean Chief Mechanic Doug Brown,
08:56AM
23
translated to a run it till it breaks philosophy.
08:56AM
24
08:56AM
25
Yet Transocean did not
Transocean knew the potential danger of running
It chose not to take
It also failed to add an acoustic
PSC
Yet, barely six months before this disaster,

Paul Johnson, the Transocean Rig Manager - Performance, when
OFFICIAL TRANSCRIPT
44
08:57AM
asked about one of the Deepwater Horizon's -- when asked about
08:57AM
its readiness to commence operations, he told BP, Transocean is
08:57AM
satisfied we can start up operations safely.
08:57AM
08:57AM
up representation to BP, he was telling his own team that he
08:57AM
understood why the Deepwater Horizon was in its current bad
08:57AM
condition, a condition that Steve Bertone, the
08:57AM
Deepwater Horizon Maintenance Supervisor, had just told the
08:57AM
same Mr. Johnson the day before.
08:57AM
10
Deepwater Horizon is currently experiencing, in my opinion, is
08:57AM
11
a lack of proper maintenance on the equipment for many years
08:57AM
12
check.
08:57AM
13
induced standpoint."
08:57AM
14
08:58AM
15
time is generally taken up by repairing the equipment that was
08:58AM
16
broke."
08:58AM
17
08:58AM
18
08:58AM
19
08:58AM
20
need of repairs or maintenance performed and not enough
08:58AM
21
personnel or time to do it" -- "to throw at it."
08:58AM
22
08:58AM
23
could not be completed even by doubling the amount of workers
08:58AM
24
on the rig."
08:58AM
25
Less than a month after making that safe to start
"The issue that the
The drive behind this has been from a performance
"When the rig does receive maintenance time, that
"Once again, limping along with equipment

failures."
He goes on, "There is just too much equipment in
"The rig has an overloaded amount of work that
"The engineering department has been going down

OFFICIAL TRANSCRIPT
45
08:58AM
for some time now due to lack of knowledge, motivation and
08:58AM
supervision."
08:58AM
08:58AM
08:58AM
08:58AM
had been audited on multiple occasions and found to be
08:58AM
seriously deficient, yet Transocean never corrected the
08:59AM
deficiencies, at least not many of the substantial ones.
08:59AM
08:59AM
10
of its broken maintenance system was the blowout preventer.
08:59AM
11
Inspections following the disaster found that it had multiple
08:59AM
12
deficiencies which contributed to the blowout preventer not
08:59AM
13
properly functioning on the day of the explosion and in the
08:59AM
14
days that followed.
08:59AM
15
these deficiencies before April 20 and did not act on them.
08:59AM
16
08:59AM
17
available and safest technology.
08:59AM
18
knew this.
08:59AM
19
08:59AM
20
Inspections in 2008, '9 and spring of 2010 clearly made
08:59AM
21
Transocean and BP aware of this.
08:59AM
22
09:00AM
23
Deepwater Horizon, making over a half million dollars a day,
09:00AM
24
instead of bringing the vessel into a shipyard for repairs of
09:00AM
25
the BOP and other critical equipment.
Yet, Transocean said it was safe to start up

operations in the fall of 2009.
Transocean's condition-based maintenance system
The evidence will show one significant casualty
Both Transocean and BP knew of many of
The Deepwater Horizon BOP was not the best

Transocean, BP, and Cameron
In fact, the BOP was out of certification.
Transocean willfully continued to lease the
OFFICIAL TRANSCRIPT
46
09:00AM
No one disputes that the blowout preventer was
09:00AM
ship's equipment on the Deepwater Horizon essential to fulfill
09:00AM
its mission, and that Transocean had a responsibility to have
09:00AM
it working properly at all times in order the maintain a
09:00AM
seaworthy vessel.
09:00AM
09:00AM
maintenance problems of the Deepwater Horizon, and especially
09:00AM
the BOP.
09:00AM
chartered the Deepwater Horizon to finish the Macondo well.
09:00AM
10
09:00AM
11
drill a well, the evidence will show BP had the primary duty to
09:00AM
12
determine whether that vessel was adequate to drill that well,
09:01AM
13
including the adequacy of the operational -- or, rather, the
09:01AM
14
operational requirements of the BOP for a particular well,
09:01AM
15
pressure, temperature, the competence of the crews and
09:01AM
16
management systems such as safety management.
09:01AM
17
09:01AM
18
09:01AM
19
09:01AM
20
safety culture at Transocean was a substantial cause of this
09:01AM
21
disaster.
09:01AM
22
09:01AM
23
Transocean rigs, on October 21 of 2009, Transocean's top
09:01AM
24
executives, CEO Steve Newman and Bob Long, sent a news bulletin
09:01AM
25
out to employees of Transocean.
It did not.
By the way, BP knew about the design and
BP knew all of this and still, in late 2009,
Every time BP chartered the Deepwater Horizon to
BP alone knew what unique risks awaited in terms

of pore pressures, fracture gradients and temperatures.
The evidence will show that a longstanding failed
Following four fatalities of four different
This is what they said, among
OFFICIAL TRANSCRIPT
47
09:01AM
other things:
"Something's not right.
We're clearly not
09:01AM
executing our safety processes as well as we once thought --
09:02AM
and we need to find out why."
09:02AM
09:02AM
09:02AM
09:02AM
09:02AM
09:02AM
09:02AM
10
09:02AM
11
"There is no quick fix; we have to rebuild it."
09:02AM
12
Transocean's maintenance system had been audited
09:02AM
13
on multiple occasions and found to be woefully deficient.
09:02AM
14
evidence will show that the maintenance processes and systems
09:02AM
15
within Transocean were by no means the best in the class, yet
09:02AM
16
Transocean never corrected the major deficiencies.
09:03AM
17
09:03AM
18
brutally candid.
09:03AM
19
"We often have such a focus on saving money in the short term
09:03AM
20
that it affects the philosophy of looking after our equipment
09:03AM
21
and following our policies."
09:03AM
22
09:03AM
23
not a recent thing.
09:03AM
24
Group summed it up well in 2009, when he recognized the
09:03AM
25
difficulties Transocean had experienced with task planning and
"It is vital that we learn from these recent

experiences so that no one else is injured or killed."
"We must learn why we cannot seem to operate
without serious incidents and injury to our people."
A couple of months later, a December 2009
Transocean Engineering PowerPoint put it even more bluntly.
"We have lost our safety culture."
The
Their May 1, 2009 Asset Reliability Project was

Personnel at a division level stated that:
The lost safety culture of Transocean was clearly

Transocean's Director of the Performance
OFFICIAL TRANSCRIPT
48
09:03AM
risk management in 2004, and observed that the 2009
09:03AM
company-wide Offshore Installation Manager's survey on the same
09:03AM
subjects resonated to be many of the same results noted in
09:03AM
2005.
09:03AM
09:04AM
doing the same things over and over and expecting a different
09:04AM
result."
09:04AM
09:04AM
09:04AM
10
so poor that Transocean was only conditionally approved to work
09:04AM
11
for BP's Gulf of Mexico Strategic Performance Unit.
09:04AM
12
09:04AM
13
Deepwater Horizon was first put into service in 2001, the
09:04AM
14
evidence is going to show it had never, ever been to port for
09:04AM
15
maintenance, repairs, refitting.
09:04AM
16
years.
09:04AM
17
09:04AM
18
evidence will show that management's willful refusal to fix it
09:04AM
19
led directly to the Deepwater Horizon disaster.
09:04AM
20
09:05AM
21
09:05AM
22
09:05AM
23
09:05AM
24
09:05AM
25
His conclusion:
"The definition of insanity,
In August of 2009, a BP audit of Transocean's

Health Safety, Security and Environment management systems was
The unfortunate reality is that since the
Not one single time; nine
Transocean's safety culture was broken, and the
The Deepwater Horizon kept drilling, and BP kept

hiring.
Now, let's turn to Cameron and its blowout
preventer.
In 2007, Melvin Whitby, as Cameron's Director of
Engineering, drilling, said:
"In all cases, however, when the
OFFICIAL TRANSCRIPT
49
09:05AM
BOP is called on to function in an emergency situation, it is
09:05AM
the main barrier protecting human life, capital equipment and
09:05AM
the environment.
09:05AM
The evidence will show this blowout preventer
09:05AM
failed partly due to the serious neglect of Transocean with
09:05AM
knowledge of BP, but also due to willful decisions of Cameron.
09:05AM
09:05AM
died for not trying close the BOP shear rams fast enough
09:05AM
because they will say the blowout preventer rams were not
09:06AM
10
designed to close after the flow begins to go up into the
09:06AM
11
riser.
09:06AM
12
09:06AM
13
09:06AM
14
The evidence will show that BP, Transocean and
09:06AM
15
Halliburton personnel clearly missed the fact that a blowout
09:06AM
16
was beginning, but the evidence will also show that Transocean
09:06AM
17
personnel ultimately did try to use the blowout preventer
09:06AM
18
shear rams -- to no avail in either saving their lives or
09:06AM
19
stopping millions of gallons of oil from entering the Gulf.
09:06AM
20
09:06AM
21
09:06AM
22
09:06AM
23
09:07AM
24
09:07AM
25
Therefore, it must function without fail."
Cameron will blame the men on the drill floor who
Well, in any of the BOP materials of Cameron,

that admonition is not given.
The BOP, in other words, did not function without

fail as Cameron's Director of Engineering said it must.
There are four primary problems with Cameron's
BOP other than Transocean's neglect of it.
First, the blind shear ram cutting blades did not
cover the entire wellbore.
Cameron knew that its BOP would
OFFICIAL TRANSCRIPT
50
09:07AM
likely not be able to shear and seal drill pipe if it was off
09:07AM
center in the wellbore, a common occurrence and completely
09:07AM
foreseeable situation.
09:07AM
09:07AM
whether the blind shear rams it sold would seal under dynamic
09:07AM
flow conditions, yet Cameron sold it as a preventer.
09:07AM
09:07AM
out whether its blowout preventer blind shear rams would
09:07AM
successfully shear pipe and fully seal a well against -- and
09:07AM
10
this is the key phrase, Your Honor -- against a high pressure
09:07AM
11
dynamic flow plus an off center pipe, neither one, even though
09:07AM
12
both were known foreseeable environment conditions the BOP
09:08AM
13
could be called upon to function in.
09:08AM
14
09:08AM
15
could not monitor the batteries to see if they were charged or
09:08AM
16
dead.
09:08AM
17
09:08AM
18
the surface, 5000 feet above it.
09:08AM
19
controls that indicated to the operators on the drill floor
09:08AM
20
that the automatic emergency BOP functions were armed and
09:08AM
21
therefore available; but, if that power was on all the time, it
09:08AM
22
wouldn't tell whether or not the batteries were dead, and it
09:08AM
23
couldn't function.
09:08AM
24
09:08AM
25
The evidence will show Cameron had no idea
Cameron did not know and never even tried to find
The third problem, Cameron knew rig personnel
Cameron's signal light system was powered from

That's the power that ran the
In other words, the driller could be getting a

green, everything is okay light, and yet his batteries be
OFFICIAL TRANSCRIPT
51
09:08AM
totally dead, that he's showing it's armed.
09:08AM
09:08AM
09:09AM
09:09AM
systems were not separate emergency systems because all of them
09:09AM
would fail if a single component, the blind shear rams, failed.
09:09AM
Cameron knew of this single point failure hazard,
09:09AM
09:09AM
09:09AM
10
design, and Cameron cooperated.
09:09AM
11
shouldn't have is going to be up to Your Honor.
09:09AM
12
Now, what about Halliburton's conduct?
09:09AM
13
As the self-described world leader in cementing
09:09AM
14
09:09AM
15
09:09AM
16
contractually responsible to BP for the design, testing, and
09:09AM
17
execution of cementing the production casing, and to provide
09:10AM
18
mud pit monitoring through its Sperry division for signs of a
09:10AM
19
kick or blowout.
09:10AM
20
09:10AM
21
used for each casing string and the volumes and spacers to be
09:10AM
22
used.
09:10AM
23
BP did not tell Halliburton which cement to use.
09:10AM
24
Halliburton's contractual obligations included
09:10AM
25
The result on April 20 was the battery in the

Blue Pod was dead, and nobody knew it was dead.
The fourth issue, the multiple BOP emergency
yet willfully chose to ignore it in design and instructions.

Now, in fairness, Transocean requested that
Whether they should or
services, what were Halliburton's obligations?

The evidence will show that Halliburton was
Halliburton recommended the type of cement to be
sole responsibility for pressure testing and pumping the cement

OFFICIAL TRANSCRIPT
52
09:10AM
as well as a safety leadership role.
The contract between BP
09:10AM
and Halliburton required Halliburton to create a lightweight
09:10AM
slurry mixture with very specific characteristics.
09:10AM
09:10AM
Halliburton management the final cement slurry details at least
09:10AM
24 hours prior to BP running the production casing.
09:10AM
not.
09:10AM
09:11AM
09:11AM
10
09:11AM
11
09:11AM
12
prematurely at Macondo due to a failure of the Halliburton
09:11AM
13
cement.
09:11AM
14
09:11AM
15
Halliburton assigned cement engineer Jesse Gagliano to be
09:11AM
16
embedded in BP's Houston offices as BP's what will be described
09:11AM
17
as in-house cementing expert.
09:11AM
18
09:11AM
19
2010, both Halliburton and Gagliano had histories of problems
09:11AM
20
with BP as far as modeling inputs and timeliness were
09:11AM
21
concerned.
09:11AM
22
09:11AM
23
BP engineers voiced serious concerns -- questions about his
09:11AM
24
competency as it affected the timeliness and quality of his
09:11AM
25
reports to BP.
Halliburton was required to provide BP and
It did
Indeed, Halliburton's Jesse Gagliano never even

checked the cement test results before the blowout, despite
being notified they were ready the day before.
The evidence will show that the gas flowed
In connection with its obligations to BP,
The evidence will show that prior to April 20 of
Indeed, in the weeks leading up to the blowout,
OFFICIAL TRANSCRIPT
53
09:11AM
In fact, BP Drilling Engineer Team Leader Greg
09:12AM
Walz believed that the decision had already been made to fire
09:12AM
Gagliano from his embedded position with BP in its Houston
09:12AM
office.
09:12AM
09:12AM
provide technical supervision of Gagliano, thus leaving the
09:12AM
inadequacies of his work undetected.
09:12AM
Yet, Mr. Gagliano, in Houston, was virtually the
09:12AM
final word on what Halliburton did or did not do regarding the
09:12AM
10
09:12AM
11
09:12AM
12
supervisor, did not even know what Mr. Gagliano was doing, much
09:12AM
13
less that there was a critical cementing job about to take
09:12AM
14
place in Macondo.
09:12AM
15
The evidence will show that Halliburton created
09:12AM
16
cement that was poorly designed, not properly tested, and was
09:13AM
17
unstable.
09:13AM
18
09:13AM
19
provided a barrier to hydrocarbon flow that was high pressure,
09:13AM
20
high temperature.
09:13AM
21
09:13AM
22
which is known to present risks and potential complications not
09:13AM
23
found with conventional cement, thus requiring additional
09:13AM
24
expertise and care.
09:13AM
25
Halliburton compounded the problem by refusing to
Macondo cement job; yet he had no supervision.

In fact, Ronnie Faul, Gagliano's immediate
Cement in a well like Macondo should have
Halliburton did not provide that barrier.
The cement used at Macondo was a foam cement
The evidence will show that every investigation

OFFICIAL TRANSCRIPT
54
09:13AM
which has considered the question, except Halliburton's, and
09:13AM
every expert, except Halliburton's, who has opined about it,
09:13AM
has concluded that the Halliburton cement was poorly designed
09:13AM
and did not seal the well.
09:13AM
09:13AM
used the cement from another well, Judge, the Kodiak well.
09:13AM
That blend had been on the Deepwater Horizon since November of
09:14AM
2009, and had aged at least five months since the
09:14AM
Deepwater Horizon had left the Kodiak and come and been working
09:14AM
10
09:14AM
11
09:14AM
12
Halliburton proprietary additive called D-Air 3000, a defoamer,
09:14AM
13
emphasis, defoamer that destabilizes and is incompatible with
09:14AM
14
foam cement.
09:14AM
15
09:14AM
16
will admit that the slurry Halliburton used at Macondo would
09:14AM
17
not have included a defoamer agent, as the Kodiak did, if
09:14AM
18
Halliburton had designed the cement from scratch.
09:14AM
19
09:14AM
20
Kodiak cement on Macondo well and try to convert it to a foam
09:15AM
21
cement when it had defoamer in it?
09:15AM
22
Halliburton was able to save time and save money by doing so.
09:15AM
23
09:15AM
24
09:15AM
25
In designing the cement for Macondo, Halliburton
on the Macondo.
More significantly, Kodiak cement contained a
Halliburton's own expert, David Bolado, in fact,
So why would Halliburton risk using this leftover
The evidence will show
BP was not charged for extra testing, regardless

of the amount of testing.
Halliburton also had already given BP about
OFFICIAL TRANSCRIPT
55
09:15AM
$100,000, in fact, $139,000 credit, for that Kodiak cement that
09:15AM
went unused at the Kodiak well that was still sitting on the
09:15AM
Deepwater Horizon, so Halliburton had a monetary incentive to
09:15AM
use that stuff, to then charge BP and get paid some of what it
09:15AM
already on hand without incurring the cost of shipping new
09:15AM
stuff out there, mixing new stuff and so forth, much less
09:15AM
hauling off the leftover Kodiak.
09:15AM
09:15AM
09:15AM
10
required tests and did not have a single successful stability
09:16AM
11
test on the actual slurry pumped down the Macondo before it was
09:16AM
12
pumped.
09:16AM
13
undersupervised.
09:16AM
14
09:16AM
15
by Halliburton was essentially useless because all those tests
09:16AM
16
failed except one that was manipulated to not mimic Macondo's
09:16AM
17
downhole condition.
09:16AM
18
09:16AM
19
of tests required by the American Petroleum Institute, BP,
09:16AM
20
Halliburton itself, and the BP-Halliburton contract, and failed
09:16AM
21
to utilize standard testing protocols.
09:16AM
22
09:16AM
23
will admit the fluid loss and static gel strength development
09:16AM
24
tests were indeed important for this job, and Halliburton
09:16AM
25
failed to perform either test.
The evidence will show that Halliburton's

employees also admit that Halliburton failed to run many
Their lab was overworked, understaffed and
The evidence will also show the testing performed
Halliburton performed fewer than the full suite
In fact, Halliburton's own expert, Dr. Sam Louis,
OFFICIAL TRANSCRIPT
56
09:17AM
The evidence will show Halliburton's Sperry Sun
09:17AM
division mudloggers were not adequately trained and missed the
09:17AM
kick that blew up the Deepwater Horizon.
09:17AM
09:17AM
vessel had started on the Macondo, BP told Halliburton that one
09:17AM
of its mudloggers was not getting the job done and was not
09:17AM
getting the basics right.
09:17AM
09:17AM
09:17AM
10
09:17AM
11
09:17AM
12
undetected for 33 minutes by the Halliburton Sperry mudlogger
09:17AM
13
on duty.
09:17AM
14
Following that go kick, Halliburton-Sperry did no
09:18AM
15
lesson learned investigation and did not provide its mudloggers
09:18AM
16
with any additional training.
09:18AM
17
09:18AM
18
the Halliburton Sperry mudlogger ignored signs the well was
09:18AM
19
flowing.
09:18AM
20
09:18AM
21
that the first time he realized there was a kick was when mud
09:18AM
22
started raining down on the mudlogger's shack.
09:18AM
23
09:18AM
24
Sperry mudlogger, Joe Keith, left his mudlogger's monitoring
09:18AM
25
pit unmanned while he took a 30-minute smoke break just as the
In October of 2009, while the Marianas drilling
Halliburton pulled him from the job.
Prior to the Macondo, because BP felt

Halliburton's Sperry Sun's performance was so poor, the
evidence will show BP was considering pulling its business.
The March 8, 2010, kick on this well went
The evidence will show that on April 20 of 2010,
The Halliburton Sperry-Sun mudlogger testified
Why?
The evidence will show that the Halliburton
OFFICIAL TRANSCRIPT
57
09:18AM
well began to give clear signs that it was flowing, signs he
09:18AM
would have seen if he had been paying attention and not
09:18AM
recklessly abandoned his post.
09:18AM
Halliburton had a contractual obligation under
09:19AM
its 2009 contract with BP to provide, in connection with its
09:19AM
cement work, a complete safety analysis in writing called a
09:19AM
Basis of Design.
09:19AM
09:19AM
09:19AM
10
continuously reassess and update these risk assessments on an
09:19AM
11
ongoing basis.
09:19AM
12
09:19AM
13
President, signed that contract on April 16 of 2009, the
09:19AM
14
evidence will show that Halliburton knew it had no way of
09:19AM
15
complying with this contract provision because no such process
09:19AM
16
safety system was in place that would have been required to
09:19AM
17
fulfill this ongoing contractual requirement.
09:19AM
18
09:19AM
19
and April 20 of 2010, Halliburton did not have a formal Basis
09:20AM
20
of Design standard, nor did it have a formal Management of
09:20AM
21
Change standard, both of which are essential to timely
09:20AM
22
identification of process safety risk effectively required to
09:20AM
23
be recognized on an ongoing basis under the contract.
09:20AM
24
09:20AM
25
The April 2009 BP/Halliburton contract required

Halliburton to, among other things, continuously, emphasis,
They didn't do it.
When David King, Halliburton's Division
The evidence will show that between April of 2009
The evidence will establish that at the time of

the Macondo well blowout, Halliburton had failed to comply with
OFFICIAL TRANSCRIPT
58
09:20AM
this express contractual requirement to have in place and
09:20AM
provide complete continuing process risk analysis to BP.
09:20AM
09:20AM
updated the Basis of Design as required by its contract, it
09:20AM
would, of necessity, have identified the catastrophic risk of
09:20AM
using Kodiak blend.
09:21AM
Let's now turn our attention to BP.
09:21AM
Financial pressure drove BP to rush the
09:21AM
09:21AM
10
09:21AM
11
not have the cash to fund its commitment to pay dividends to
09:21AM
12
its shareholders.
09:21AM
13
Exploration and Production Division portion of the amount
09:21AM
14
needed to pay the dividend to be about $7 billion.
09:21AM
15
09:21AM
16
to 5 percent profit growth commitment to shareholders, BP
09:21AM
17
Exploration and Production was under pressure to raise these
09:21AM
18
dollars by driving efficiency in a year where production was
09:21AM
19
lower.
09:21AM
20
09:21AM
21
09:22AM
22
09:22AM
23
2010 was expected to be "a year where every barrel counts and
09:22AM
24
every dollars counts."
09:22AM
25
The evidence will show that if Halliburton had
completion of the Macondo well.

Because BP's production was down in 2010, BP did
The evidence will show BP calculated
In order to raise this $7 billion and meet its 4
It chose to do so by spending fewer days in the

drilling of its wells.
According to BP, without major project startups,
Macondo was more than $50 million over budget and

OFFICIAL TRANSCRIPT
59
09:22AM
behind schedule.
The Deepwater Horizon was committed to drill
09:22AM
two more wells for BP within a short time, and it had to get
09:22AM
one right away started or BP risked losing an expensive Gulf
09:22AM
lease.
09:22AM
09:22AM
placed huge financial pressure on BP rig management to cut
09:22AM
costs by cutting corners and to rush the job.
09:22AM
09:22AM
09:23AM
10
total of around 18,000 feet, in a formation known to BP for
09:23AM
11
being high pressure, high temperature, and, most importantly,
09:23AM
12
an unstable, no-salt formation.
09:23AM
13
09:23AM
14
Deepwater Exploration at BP, confirms, wells without a thick
09:23AM
15
sequence of salt require more casing for a given depth than
09:23AM
16
those that do penetrate salt.
09:23AM
17
09:23AM
18
the frac gradient is generally narrower in no-salt wells which
09:23AM
19
requires more casing.
09:23AM
20
09:23AM
21
before Macondo, but, as he says, "it had just been a few
09:24AM
22
wells."
09:24AM
23
So, with the rush of financial urgency combined
09:24AM
24
with BP concerns about the Macondo well situation, how did BP
09:24AM
25
proceed with its Macondo well?
The evidence will show BP executive management
The Macondo well bottom was under 5000 feet of

water and then another about 13,000 feet of earth below that,
As Jonathan Bellow, a BP Operations Geologist for
The drilling window between the pore pressure and
BP had drilled wells with no salt previously
OFFICIAL TRANSCRIPT
60
09:24AM
Petroleum engineering expert David Pritchard
09:24AM
09:24AM
09:24AM
Macondo kick, BP Tiger Team member Kate Paine says:
09:24AM
sure it was a lack of communication nor awareness as much as a
09:24AM
'we can get away with this' attitude."
09:24AM
09:24AM
that BP failed to disclose information to MMS that it was
09:25AM
required to disclose on an ongoing basis.
09:25AM
10
show that on multiple occasions BP falsely reported its
09:25AM
11
fracture gradients and pressure integrity test results to the
09:25AM
12
MMS by drilling ahead without a safe drilling margin and
09:25AM
13
without seeking prior MMS approval.
09:25AM
14
09:25AM
15
as the "well from hell," a "nightmare" well, and a "crazy"
09:25AM
16
well.
09:25AM
17
kicks and ten incidents of lost returns resulting in the loss
09:25AM
18
of 668,000 gallons of mud.
09:25AM
19
09:25AM
20
so many last-minute changes to the temporary abandonment
09:26AM
21
procedure plan that BP's John Guide told David Sims just
09:26AM
22
three days before the disaster, "David, over the past
09:26AM
23
four days, there has been so many last-minute changes to the
09:26AM
24
operation, that the well site leaders have finally come to
09:26AM
25
their wits' end."
says:
"BP repeatedly chose speed over safety."

When asked for feedback following the March 8th
"I'm not
Dr. Allen Huffman, a geophysicist, will testify
The evidence will
Macondo was described variously by BP personnel
In the months preceding the disaster, there were four
The push to complete the "nightmare" well caused
The quote is, "Flying by the seat of our

OFFICIAL TRANSCRIPT
61
09:26AM
pants."
09:26AM
09:26AM
huge level of paranoia from engineering leadership is driving
09:26AM
chaos.
09:26AM
me numerous times trying to make sense of all the insanity."
09:26AM
And then later he concludes, "The operation is not going to
09:26AM
succeed if we continue in this manner."
09:26AM
09:27AM
09:27AM
10
the BP operations geologist -- March 27th, Robert Bodek, a BP
09:27AM
11
operations geologist told his boss that, "If BP continued to
09:27AM
12
total depth on Macondo, it will all be in God's hands."
09:27AM
13
09:27AM
14
disaster, Bodek again told his boss that, "If they really
09:27AM
15
believe that the poor pressure can be as high as projected, we
09:27AM
16
need to start having some serious discussions about pulling the
09:27AM
17
plug early."
09:28AM
18
09:28AM
19
temporarily abandon this well, BP made a series of decisions to
09:28AM
20
save time and money but substantially increased risk and
09:28AM
21
reduced safety.
09:28AM
22
09:28AM
23
with a tieback, which it was originally designed to be until
09:28AM
24
about a month before the disaster, to save time and at least
09:28AM
25
seven to $10 million and seven to ten days in time.
"Everybody wants to do the right thing, but this
This operation is not Thunder Horse.
Brian has called
Now, put that into context, March 29th -- excuse

me -- just 22 days before the Macondo disaster Robert Bodek,
Two days later, just 22 days before the Macondo
The evidence will show that during BP's rush to
Here are some examples:
BP used a long string casing rather than a liner
OFFICIAL TRANSCRIPT
62
09:28AM
BP failed to perform a bottoms up circulation
09:28AM
09:28AM
09:28AM
originally planned -- and originally planned 21 centralizers,
09:28AM
ended up using many less.
09:28AM
09:29AM
stability test before pouring -- or allowing to pour the
09:29AM
cement.
09:29AM
09:29AM
10
12 hours after the cementing operation and refused to wait for
09:29AM
11
the cement to fully cure.
09:29AM
12
09:29AM
13
09:29AM
14
09:29AM
15
09:29AM
16
09:29AM
17
09:29AM
18
09:29AM
19
without a written procedure and with personnel who had never
09:29AM
20
been given formal training in how to perform the test.
09:29AM
21
09:30AM
22
confirm the success or failure of the cement job despite the
09:30AM
23
presence of a Schlumberger crew they had on the rig ready to
09:30AM
24
run it.
09:30AM
25
test prior to allowing Halliburton to pump its cement.

Third, BP refused to use the recommended and
BP failed to wait for the completion of the foam
Fifth, BP began its positive pressure test just
Six, BP displaced the riser before setting a real

barrier, the cement plug.
Seventh, BP displaced the riser over 3,000 feet
below the surface.
BP used a untried experimental spacer from
leftover lost circulation materials.
BP ran the safety critical negative pressure test
Tenth, BP refused to run a cement bond log to
Once again, BP did this to save time and money.

Finally, BP conducted simultaneous operations
OFFICIAL TRANSCRIPT
63
09:30AM
during the displacement without doing the required risk
09:30AM
assessment, which significantly impaired the ability to
09:30AM
recognize that a kick, a serious kick was happening.
09:30AM
09:30AM
executive management were a substantial cause of the disaster.
09:30AM
BP will place great reliance on its Bly Report to try to
09:30AM
diminish its culpability.
09:30AM
Bly Report was not as thorough as represented by BP to be.
09:30AM
09:31AM
10
open, complete and transparent investigation that would cover
09:31AM
11
everything.
09:31AM
12
investigating serious accidents, and certainly no one will
09:31AM
13
contest that this wasn't a serious accident, BP's investigation
09:31AM
14
of the Macondo disaster, the Bly Report failed to investigate
09:31AM
15
systemic management causes.
09:31AM
16
09:31AM
17
directly controlled BP's Worldwide Risk Management and
09:31AM
18
encouraged a culture which placed profit and production over
09:31AM
19
safety and protection.
09:31AM
20
09:31AM
21
Professor Bob Bea will make it clear, starting tomorrow when he
09:31AM
22
takes the stand, that effective process safety only happens if
09:31AM
23
a company creates a safety culture that reflects the
09:31AM
24
seriousness with which that company attempts to manage risks.
09:32AM
25
Effective process safety is reflected by what a
The evidence will show the actions of BP
Yet the evidence will show that the
BP's CEO Tony Hayward claimed BP conducted an
Rather, contrary to BP's standard protocol for
The evidence will show BP's executive management
Process safety and risk engineering expert
OFFICIAL TRANSCRIPT
64
09:32AM
company actually does, not what it says.
It's also reflected
09:32AM
by its commitment to learn lessons from past events.
09:32AM
commitment is critical, because in the words of Dr. Bea, "It
09:32AM
has a major effect on how the company balances between
09:32AM
production and protection."
09:32AM
09:32AM
disasters to place relatively high emphasis on short-term
09:32AM
benefits of cost and speed could cause major loss of life and
09:32AM
property.
09:32AM
10
production pressures from BP executive managers, impairs
09:32AM
11
process safety performance.
09:32AM
12
09:32AM
13
for Macondo, BP was still putting production over protection,
09:33AM
14
profits over safety.
09:33AM
15
09:33AM
16
he had two years to turn the company's financial performance
09:33AM
17
around.
09:33AM
18
issued directives to cut billions and billions of dollars from
09:33AM
19
the costs of BP operations.
09:33AM
20
09:33AM
21
$4 billion, with plans for another 1.4 billion in 2010.
09:33AM
22
resulted in massive layoffs, 20 percent of BP's entire
09:33AM
23
worldwide force.
09:33AM
24
09:33AM
25
That
Dr. Bea will explain how BP knew from previous
And that cost cutting, failure to invest, and
Nonetheless, the evidence will show that in 2010
In 2007, BP's CEO Tony Hayward acknowledged that
The evidence will show BP's executive management
From 2008 to 2009, BP management slashed costs by

This
Former BP vice-president of drilling and

completions Kevin Lacy, will describe for the Gulf of Mexico
OFFICIAL TRANSCRIPT
65
09:33AM
operating unit, incredibly pressured with respect to cost
09:33AM
production during 2008 and 2009.
09:34AM
Beginning in 2008, Lacy received directives from
09:34AM
BP's senior vice-president global projects, Neil Shaw, and CEO
09:34AM
of BP Exploration and Production, Andy Inglis, to cut the
09:34AM
costs.
09:34AM
09:34AM
the safety and technical director, 290 BP personnel, 93
09:34AM
contractors.
09:34AM
10
director, there was no one person in the Gulf of Mexico unit
09:34AM
11
whose sole job was administer or oversee process safety.
09:34AM
12
09:34AM
13
the Gulf of Mexico Drilling & Completion organization with
09:34AM
14
further cost cutting directed for 2010.
09:34AM
15
personnel lost their jobs -- or rather, saw their jobs
09:35AM
16
eliminated.
09:35AM
17
09:35AM
18
include incentives for effective measurable process safety.
09:35AM
19
BP's safety culture will be shown by the evidence, according to
09:35AM
20
BP's Kate Payne, to be a "we can get away with this" attitude.
09:35AM
21
According to Dr. Bea, a culture of entrepreneurial risk taking
09:35AM
22
and a culture of production over protection.
09:35AM
23
09:35AM
24
Patrick Hudson will testify that BP was a highly risk tolerant
09:35AM
25
culture and an opportunistic and speed-driven culture and a
One of Shaw's first decisions was to eliminate
After eliminating the safety and technical
In 2009, BP cut between 250 and 350 million from
Many key safety
Cost cutting was further incentivized but did not
Even Halliburton process safety expert
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09:35AM
culture of being loss averse rather than risk averse.
09:35AM
09:35AM
management incentivized a culture of cost cutting, profits over
09:36AM
safety, and taking high risk with a conscious disregard for
09:36AM
dire potential risks.
09:36AM
09:36AM
intentionally refused to change its past behavior and instead
09:36AM
willfully exclude its process safety requirements, its OMS
09:36AM
program, from leased vessels like the Deepwater Horizon.
09:36AM
10
09:36AM
11
this.
09:36AM
12
engineering expert, Dr. Bob Bea himself, was retained directly
09:36AM
13
and advised BP on three separate occasions, in 2001, 2002, and
09:36AM
14
2005, what it was doing wrong with process safety and what
09:36AM
15
needed to be done to correct it.
09:37AM
16
did not listen and how that was a substantial cause of the
09:37AM
17
Macondo disaster.
09:37AM
18
09:37AM
19
and systemic causes of previous disasters, major accidents, are
09:37AM
20
virtually identical to the systemic and organizational causes
09:37AM
21
of the Macondo blowout.
09:37AM
22
09:37AM
23
in 2006, that if BP did not improve its process safety, it was
09:37AM
24
going to have another disaster every 10 to 15 years.
09:37AM
25
it only took four.
In other words, the evidence will show that BP
The evidence will show BP executive management
At BP's invitation -- let's give some context to

At BP's own invitation, renowned process safety and risk
Dr. Bea will explain how BP
Dr. Bea will also explain how the organizational
BP's then head of safety, John Mogford, predicted
OFFICIAL TRANSCRIPT
In fact,
67
09:37AM
Long before the Deepwater Horizon disaster, BP
09:37AM
was aware of specific recommendations of how it could fix its
09:37AM
process safety problem in order to avoid future disasters.
09:37AM
09:38AM
executive management in London implemented the operations
09:38AM
management system, or OMS, which was indeed a comprehensive
09:38AM
management system that integrates and improves existing
09:38AM
management systems and provides the framework to achieve safe
09:38AM
and reliable operations across its worldwide operations.
09:38AM
10
09:38AM
11
failing to extend its OMS program to its leased drilling
09:38AM
12
vessels, like the Deepwater Horizon, BP failed to keep the
09:38AM
13
following factors present in previous disasters from playing a
09:38AM
14
role in Macondo:
09:38AM
15
perform effective audits, engaging in mindless, pointless and
09:38AM
16
counterproductive organizational restructuring, and failing to
09:38AM
17
maintain safety critical equipment.
09:38AM
18
09:39AM
19
management promised to change, to learn lessons.
09:39AM
20
will show that for BP's leased vessels in the Gulf of Mexico,
09:39AM
21
like the Deepwater Horizon, BP's culture regarding safety
09:39AM
22
remained the same.
09:39AM
23
09:39AM
24
Mexico drilling engineering manager, Jonathan Sprague, in fact,
09:39AM
25
received an e-mail from a lower level BP employee regarding
In an effort to improve its process safety, BP
But the evidence will show that in willfully
Ignoring process safety risks, failing to
Prior to the Macondo disaster, BP executive

The evidence
The evidence will show that when BP's Gulf of
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09:39AM
process safety, lessons learned, he passed it off as clutter.
09:39AM
09:39AM
the Deepwater Horizon and discovered an astounding 390
09:39AM
outstanding maintenance issues requiring 3,545 man-hours to
09:39AM
repair, some of which had been outstanding since another 2008
09:40AM
audit by BP.
09:40AM
09:40AM
chartering and using the Deepwater Horizon year in and year out
09:40AM
despite actual knowledge of many problems with the vessel,
09:40AM
10
keeping it at sea, driving it hard, when BP knew it should have
09:40AM
11
been taken to a shipyard for repairs.
09:40AM
12
09:40AM
13
requested to participate in a "lessons learned" inquiry in a
09:40AM
14
March 8th kick, 2010, said, "I don't think this is going to be
09:40AM
15
a lesson learned.
09:40AM
16
learned.
09:40AM
17
it look like we won't do this again.
09:40AM
18
learning."
09:40AM
19
09:40AM
20
repair cost concerns, in September 2009, BP Houston operations
09:41AM
21
engineer, Brett Cocales responded internally, "Don't worry
09:41AM
22
about this small stuff.
09:41AM
23
apart unless absolutely necessary and we are ready to kick some
09:41AM
24
serious ass.
09:41AM
25
In late 2009, BP conducted a rig safety audit of
But the evidence will show that BP kept
BP Tiger Team member Kate Payne, who being
I'm sorry to push back on the lessoned
I know you've got to get something out there to make

I don't see us really
Commenting on apartments, Deepwater Horizon
We're not going to tear anything else
Don't worry, be happy."

BP Drilling Engineer, Nicholas Lirette replied
OFFICIAL TRANSCRIPT
69
09:41AM
saying, prophetically, "This rig is not in appropriate
09:41AM
condition to start a well."
09:41AM
09:41AM
engineer, Brett Cocales, sent 15 extra centralizers to the
09:41AM
Deepwater Horizon in addition to the six already on board.
09:41AM
the extra centralizers were intended to reduce cement
09:41AM
channeling and thus reduce the risk of a blowout.
09:41AM
09:42AM
the extra centralizers not be used.
09:42AM
10
show to save time and money for BP.
09:42AM
11
09:42AM
12
another BP Houston engineer, "But who cares, it's done.
09:42AM
13
story.
09:42AM
14
09:42AM
15
implement OMS on its riskiest enterprise, deepwater drilling in
09:42AM
16
the Gulf of Mexico, played a substantial role in the disaster
09:42AM
17
at Macondo.
09:42AM
18
09:42AM
19
was lost.
09:42AM
20
in charge of process safety of the Macondo well.
09:42AM
21
09:43AM
22
09:43AM
23
MR. ROY:
09:43AM
24
THE COURT:
09:43AM
25
MR. ROY:
But of course, it did.
Just five days before the blowout, BP Houston
And
The next day BP's John Guide's boss demanded that

Why?
The evidence will
Cocales succumbed to Guide's demand and e-mailed

End of
We'll probably be fine."

Dr. Bea will explain how the failure of BP to
Whatever benefit the system might have brought

At the time of the blowout there was no individual
THE COURT:
Mr. Roy, you need to bring it to a close.
Your time is about up.

I have one-and-a-half pages, Your Honor.
Go ahead.
Dr. Bea will explain that the Macondo

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09:43AM
Drilling Team was blind to major process safety risks because
09:43AM
of the lack of OMS.
09:43AM
09:43AM
denies knowing the high risk of drilling in the Gulf of Mexico
09:43AM
prior to the Macondo disaster.
09:43AM
known the risk in the Gulf of Mexico, we would have never
09:43AM
drilled that well in the Gulf of Mexico."
09:43AM
Kevin Lacy, the former vice-president of Drilling
09:43AM
& Completions summed up the Macondo disaster best when he said,
09:43AM
10
09:43AM
11
09:44AM
12
suggest that the evidence will prove the Deepwater Horizon was
09:44AM
13
unseaworthy on April 20th of 2010, and had been for many
09:44AM
14
months, if not years, before.
09:44AM
15
it.
09:44AM
16
09:44AM
17
will also prove the negligence of BP, Transocean, Halliburton
09:44AM
18
and Cameron.
09:44AM
19
09:44AM
20
09:44AM
21
09:44AM
22
this trial will demonstrate to Your Honor why this tragedy
09:44AM
23
occurred and who is responsible.
09:44AM
24
09:44AM
25
Ironically, BP board member Sir William Castell
But he testifies, "If I had
"It was entirely preventable."

In conclusion, Your Honor, we respectfully
And Transocean and BP both knew
It will also prove the negligence -- the evidence
And finally, the evidence will prove the

defendants' gross negligence and willful and reckless conduct.
The limitation should be denied.
The evidence in
Thank you.
THE COURT:
All right.
I was planning on taking a
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71
09:44AM
break after the United States' presentation, but we are going
09:44AM
to do it right now because we have a technical problem, I
09:44AM
understand.
09:44AM
09:44AM
THE DEPUTY CLERK:
09:44AM
THE COURT:
09:44AM
a problem with the sound, and someone needs to come here and
09:45AM
fix something.
09:45AM
09:45AM
10
09:45AM
11
THE DEPUTY CLERK:
09:45AM
12
(WHEREUPON, at 9:45 a.m. the Court took a recess.)
10:03AM
13
THE COURT:
10:03AM
14
our technical problem in one of the other courtrooms repaired,
10:03AM
15
so we're ready to proceed.
10:03AM
16
10:03AM
17
10:03AM
18
10:03AM
19
Thank you, Your Honor.
10:03AM
20
Your Honor, before I start, my good friend,
10:03AM
21
Mr. Roy, asked me to say that he made a mistake that he would
10:03AM
22
like me to correct, and I certainly agree to do that.
10:03AM
23
10:03AM
24
mudlogger took a 30-minute smoke break or whatever kind of
10:03AM
25
break, and Mr. Roy indicated it should have been 10 minutes.
They still have that going on, Stephanie?

Yes, sir.
In one of the overflow courtrooms, there is
So we're going to take about a 15-minute recess

right now.
All rise.
All right.
I think they tell me we have
Mr. Underhill.
OPENING STATEMENTS
BY MR. UNDERHILL:
Good morning.
He indicated that Mr. Keith, the Sperry-Sun
OFFICIAL TRANSCRIPT
72
10:03AM
He didn't want to mislead the Court or any of the parties.
10:03AM
10:03AM
THE COURT:
10:03AM
MR. UNDERHILL:
10:03AM
10:03AM
days after the Macondo well blew out.
10:03AM
in this courtroom today, myself, my colleagues from both the
10:04AM
plaintiff and defense side, is to try to give the evidence to
10:04AM
the Court so you can decide how this tragedy happened, why it
10:04AM
10
10:04AM
11
10:04AM
12
despite BP's attempts to shift blame to other parties in this
10:04AM
13
lawsuit, by far and away, the primary fault for this disaster
10:04AM
14
lies with BP.
10:04AM
15
10:04AM
16
designed the Macondo well.
10:04AM
17
Macondo well.
10:04AM
18
10:04AM
19
that caused the blowout and disaster up on that screen,
10:04AM
20
decisions about narrow and dangerous drilling margins, about
10:04AM
21
cement design and placement, the all critical negative pressure
10:04AM
22
test you'll hear a great deal about in this case, about well
10:05AM
23
monitoring and well control, about the BOP, those decisions,
10:05AM
24
Your Honor, were made by BP.
10:05AM
25
So is that good, Jim?
Thank you.
Okay.
Your Honor, good morning.
This was the Deepwater Horizon on April 22, two

The job of the parties
happened, and who caused it to happen.

The evidence in this trial will show that,
BP was the owner of the Macondo well.
It
It was the operator of the
The evidence will show that critical decisions
We will show that a long series of missteps and

OFFICIAL TRANSCRIPT
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10:05AM
reckless decisions made by BP taken together demonstrate
10:05AM
willful misconduct.
10:05AM
10:05AM
happen to the sound?
10:05AM
everyone else can.
10:05AM
10:05AM
10:05AM
MR. GODWIN:
10:05AM
MR. UNDERHILL:
10:05AM
10
10:05AM
11
THE COURT:
10:05AM
12
MR. UNDERHILL:
10:05AM
13
THE COURT:
10:05AM
14
10:06AM
15
10:06AM
16
MR. UNDERHILL:
10:06AM
17
THE COURT:
10:06AM
18
MR. UNDERHILL:
10:06AM
19
THE COURT:
10:06AM
20
MR. UNDERHILL:
10:06AM
21
missteps and reckless decisions by BP taken together
10:06AM
22
demonstrate willful misconduct.
10:06AM
23
decisions made by BP standing alone constitute gross
10:07AM
24
negligence.
10:07AM
25
THE COURT:
Stop, I'm sorry, one second.
I can still hear you, but I'm not sure
Excuse me.
Is your Lavalier mic not working?

it is?
Did something
Is that what
Is that not working?
next to you.
It's your battery.

There might be another one right there
There is a backup.
See if the other one works.
Certainly, Your Honor.
Isn't technology wonderful, as long as it
works.
That sounds like it's working.
How are we doing?
That's better.
Thank you very much, Your Honor.
Thank you.
We will show that a long series of
We will show that individual
Especially among those individual decisions was

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10:07AM
the incomprehensible decision to declare the negative pressure
10:07AM
test a success only two hours before the first of the
10:07AM
explosions that wracked the rig.
10:07AM
10:07AM
April 20, less than an hour before oil and gas exploded in a
10:07AM
fireball aboard that rig that was up on the screen a moment
10:07AM
ago, BP Senior Drilling Engineer in Houston, Mark Hafle, and
10:07AM
its Senior Well Site Leader on the rig, Don Vidrine, had a
10:07AM
telephone conversation.
10:07AM
10
Amendment in this case.
10:07AM
11
10:07AM
12
prevented the tragedy, the need for any of us to be in this
10:07AM
13
courtroom today and for the next three months.
10:08AM
14
10:08AM
15
eleven lives, saved the Gulf, saved the people of the Gulf from
10:08AM
16
a catastrophe, despite all of the BP failures that had happened
10:08AM
17
before that day on API 20 and in the days before.
10:08AM
18
10:08AM
19
hung up the phone at 9:02 p.m., eleven men, eleven souls, had
10:08AM
20
47 minutes to live the rest of their lives, 47 minutes in which
10:08AM
21
BP failed to take any action that could have prevented that
10:08AM
22
tragedy that's on the screen and our need to be here today.
10:08AM
23
10:08AM
24
little as a ten-second phone call from Mr. Vidrine to the
10:08AM
25
toolpusher or the driller, as little as a 30=second walk down
The evidence will show that at 8:52 p.m., on
Both men subsequently took the Fifth
That conversation, we will show, should have
They had a conversation that could have saved
The evidence will show that when those two men
The evidence and testimony will show that with as
OFFICIAL TRANSCRIPT
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10:08AM
to the rig floor to those two men, the toolpusher, the driller,
10:09AM
we could have avoided all of this, all of this.
10:09AM
10:09AM
failure to take that action, that simple action, that act alone
10:09AM
constituted willful misconduct.
10:09AM
10:09AM
the record that we have, Your Honor, the best we can do as
10:09AM
attorneys is present a snapshot of the evidence to the Court;
10:09AM
but, if we're looking for a snapshot that shows how and why BP
10:09AM
10
is the primary cause for this disaster, we point to evidence of
10:09AM
11
a corporate culture of disregard for safety that laid the
10:09AM
12
foundation for all that happened on April 20 on that rig.
10:09AM
13
10:10AM
14
the well team leader for the Macondo well.
10:10AM
15
the well site leaders, Mr. Vidrine and Mr. Kaluza, reported
10:10AM
16
directly to Mr. Guide in Houston.
10:10AM
17
10:10AM
18
Guide, reported to David Sims, his boss at BP headquarters in
10:10AM
19
Houston.
10:10AM
20
10:10AM
21
days before the blowout, Guide sent Sims an extraordinary
10:10AM
22
document that explains as much as any single piece of evidence
10:10AM
23
in this entire case that Your Honor will hear why eleven men
10:10AM
24
needlessly lost their lives and why this catastrophe of an oil
10:10AM
25
spill began.
The evidence will show, Your Honor, that BP's
In an opening like this, and with the volume of
The evidence will show that BP made John Guide

It will show that
The evidence will show that the well team leader,
It will show that on April 17, 2010, only three
OFFICIAL TRANSCRIPT
76
10:10AM
Mr. Roy mentioned this e-mail.
I'll very briefly
10:10AM
going through it.
10:10AM
well site leaders had finally come to their wits end, that BP
10:11AM
well site leaders were flying by the seat of their pants.
10:11AM
10:11AM
driving chaos.
10:11AM
trying to make sense of all the insanity.
10:11AM
within three days became literal prophecy, Guide finished, "the
10:11AM
operation is not going to succeed if we continue in this
10:11AM
10
10:11AM
11
10:11AM
12
Guide's boss, responded to Guide by telling him that he had to
10:11AM
13
go to dance practice in a few minutes.
10:11AM
14
told him that the engineer who used the word "insanity" to
10:11AM
15
describe this operation needed to be reminded that, quote, it
10:11AM
16
was a great learning opportunity.
10:12AM
17
the same issues or worse exist anywhere else.
10:12AM
18
10:12AM
19
10:12AM
20
10:12AM
21
didn't succeed.
10:12AM
22
testimony of BP's own witnesses that BP should have shut down
10:12AM
23
the Macondo operation at the moment, that moment, when Guide
10:12AM
24
sent the e-mail to Sims.
10:12AM
25
On April 17, Guide told Sims that the BP
Guide described a huge level of paranoia that was

He talked about another BP Macondo engineer
In a sentence that
manner."
The evidence will show that the same day, Sims,
It will show that Sims
It will be over soon.
That
He finished by telling Guide, I'll be back soon,

and we can talk.
We are dancing to the Village People.
Well, the operation, as we know, Your Honor,

The evidence will show through the sworn
The evidence will show in Sims's own testimony

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10:12AM
that he didn't shut down the operation either after dance
10:12AM
practice or before the well blew out, even in response to words
10:12AM
like paranoia, chaos and insanity.
10:12AM
10:12AM
refused to give a straight answer in deposition to the simple
10:12AM
question of whether he and Guide, the Macondo well team leader,
10:13AM
had more responsibility for safety aboard the Deepwater Horizon
10:13AM
than the rig's cook or its bed maker.
10:13AM
10:13AM
10
that was, to use their words, flying by the seat of the pants,
10:13AM
11
had far deeper problems, that stopping the operation was not
10:13AM
12
the BP way.
10:13AM
13
10:13AM
14
people, profits before safety, and profits before the
10:13AM
15
environment.
10:13AM
16
drove its people, was, as Mr. Roy mentioned, time is money, and
10:13AM
17
every dollars counts.
10:13AM
18
10:13AM
19
be that time is money, and every dollars counts were the
10:13AM
20
bludgeons that sacrificed safety, the weapons that drove people
10:14AM
21
to save money at the cost of people's lives.
10:14AM
22
10:14AM
23
safety and what drove people to use words like "chaos" and
10:14AM
24
"insanity" to describe this high hazard, high risk BP
10:14AM
25
operation, the easiest example is the Macondo well itself.
In fact, Sims's testimony will show that he
But the evidence will show that a BP operation
The evidence will show that BP put profits before
It will show that the BP way, the way that BP
The story that will be told by this evidence will
If we want to grasp this culture of profit over
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10:14AM
The evidence will show that BP was tens of
10:14AM
millions, 50 million according to Mr. Roy, over its budget of
10:14AM
one hundred million dollars to drill the Macondo well, and that
10:14AM
it was spending nearly a million dollars a day for every day
10:14AM
the rig stayed onsite.
10:14AM
10:14AM
dollars saved for BP.
10:14AM
million.
10:14AM
10:14AM
10
have made during the last days of the rig, such as those
10:14AM
11
dealing with the cement job, with the float collar, with the
10:15AM
12
negative pressure test, with the Guide/Sims e-mail, the
10:15AM
13
evidence will show that those decisions were not made because
10:15AM
14
they would have caused delayed and, most importantly to BP,
10:15AM
15
money.
10:15AM
16
10:15AM
17
this trial make the point about profit over safety better than
10:15AM
18
anyone in this courtroom ever can or ever could."
10:15AM
19
10:15AM
20
example, one example of the culture that pervaded BP's
10:15AM
21
operation of the Macondo, the evidence will show that Mark
10:15AM
22
Hafle, the same BP engineer in Houston who talked to the rig in
10:15AM
23
its last and final hour, Hafle knew before the disaster, quote,
10:15AM
24
the cement design was on the ragged edge, closed quote -- and
10:15AM
25
pardon the language, Your Honor -- that he knew that, quote, we
So a safety corner cut, a day saved was a million

10 days, 10 million.
20 days, 20
Decisions that any safety minded company would
BP's own words:
"The evidence that we'll see in
As an example, and I stress this is only an
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10:15AM
are going to get a shitty cement job, closed quote.
That's
10:16AM
Mr. Hafle.
10:16AM
10:16AM
alarm ringing down the halls of BP headquarters, not even
10:16AM
close.
10:16AM
10:16AM
redoing it with a new cement job could have cost delays worth
10:16AM
millions of dollars to BP.
10:16AM
Instead, the evidence will show that only days
10:16AM
10
before the blowout and eleven deaths, another BP engineer in
10:16AM
11
Houston, Brett Cocales -- e-mail is up on the screen -- made
10:16AM
12
the infamous, unforgiveable statement that by the end of this
10:16AM
13
trial will stand as the summation of BP's safety culture at
10:16AM
14
Macondo:
10:16AM
15
probably be fine, and we'll get a good cement job."
10:16AM
16
10:16AM
17
was concerned about.
10:16AM
18
testimony of Dr. Allen Huffman, that BP violated mandatory
10:17AM
19
federal regulations and critical safety practices over the
10:17AM
20
course of drilling the Macondo well, regulations and safety
10:17AM
21
procedures that require operators to maintain what is called a
10:17AM
22
safe drilling margin.
10:17AM
23
10:17AM
24
means in terms of fundamental drilling and safety issues; but
10:17AM
25
what will become apparent through the evidence is that BP
The evidence will show that to BP that wasn't an
The evidence will show that doing it right and
"But who cares, it's done, end of story, will
But it wasn't only millions of dollars that BP

The evidence will also show, through the
Dr. Huffman will explain what drilling margin
OFFICIAL TRANSCRIPT
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10:17AM
drilled and pushed this well beyond safe drilling margin
10:17AM
limits, in violation of law, all because it feared that if it
10:17AM
told the MMS what it was doing on this well, MMS could shut
10:17AM
down the operation, and BP would stand to lose not only the one
10:17AM
hundred million or whatever the amount is plus that it had
10:17AM
already spent drilling Macondo, but it could loose the
10:17AM
potential of billions, that's billions with a B, billions of
10:18AM
dollars of profit from the production well they hoped to get.
10:18AM
10:18AM
10
ever begrudge BP or anyone from wanting to make a profit.
10:18AM
11
That's not an issue in the case, not even remotely.
10:18AM
12
Instead, what the evidence and the testimony will
10:18AM
13
show is that reckless actions amounting to gross negligence and
10:18AM
14
the willful misconduct were tolerated by BP, sometimes
10:18AM
15
encouraged by BP to squeeze extra profit out of every decision,
10:18AM
16
out of every well, including this well.
10:18AM
17
10:18AM
18
this well, and especially in the final days and hours of the
10:18AM
19
Deepwater Horizon, the evidence will show that at every fork in
10:18AM
20
the road, BP chose time and money over safety in the operation
10:18AM
21
of what the rig crew called this "well from hell."
10:19AM
22
10:19AM
23
needed to do have the integrity and the responsibility to own
10:19AM
24
up to the ongoing dangers and its own mistakes, just like Hafle
10:19AM
25
and Vidrine needed to do in the last hour of the rig.
Now, no plaintiff here in this courtroom will
That repeated multiple times in the operation of
Witnesses will testify in this courtroom that BP
OFFICIAL TRANSCRIPT
81
10:19AM
But it will show that BP, from company men in the
10:19AM
well to senior managers ashore, refused to deviate from a
10:19AM
course of a corporate culture of recklessness that was
10:19AM
chartered in board rooms in Houston and London.
10:19AM
10:19AM
evidence will show that their actions spoke louder than words
10:19AM
and demonstrated the same reckless behavior that's shown in the
10:19AM
words, "who cares, it's done, probably be fine," written on
10:19AM
that screen and the Guide/Sims e-mails and in Hafle's and
10:19AM
10
10:19AM
11
10:20AM
12
find that BP put people in charge of the Macondo well that
10:20AM
13
weren't functionaries.
10:20AM
14
changing oil at the BP corner service station.
10:20AM
15
BP operation, deepwater drilling of a well like Macondo that
10:20AM
16
had the destructive power to do exactly what we've seen in this
10:20AM
17
case, deaths, injuries, a rig at the bottom of the Gulf of
10:20AM
18
Mexico, economic and environmental devastation, along the swath
10:20AM
19
of Gulf Coast states and communities, and the power to cause an
10:20AM
20
oil spill that even has its own name.
10:20AM
21
10:20AM
22
tragedy of this case, and as the evidence will show, is that
10:20AM
23
the explosions, the death, everything that followed, could be
10:20AM
24
explained as being caused by some of the simple, easiest to
10:20AM
25
understand things imaginable that we'll understand in this
As people BP's men continued on that course, the
Vidrine's abdication of responsibility in the last hour.

During the course of this trial, Your Honor will
They weren't guys pumping gas and

They headed the
But the tragedy of this case, Your Honor, the
OFFICIAL TRANSCRIPT
82
10:20AM
court by the end of trial, failures that should not have
10:21AM
happened, that with even a simple amount of care should never
10:21AM
have happened.
10:21AM
10:21AM
of money saved to execute so many of the cost cutters, the cost
10:21AM
savings, the short cuts, didn't even amount to pocket change in
10:21AM
the operation of this magnitude with this many millions of
10:21AM
dollars.
10:21AM
10:21AM
10
put out its story of why this strategy happened.
10:21AM
11
Report, as Mr. Roy pointed out, that will be Exhibit 1 in this
10:21AM
12
trial.
10:21AM
13
appendices.
10:21AM
14
10:21AM
15
exhibit, all 769 of them, all the footnotes and all the fine
10:21AM
16
print, you won't find a mention, not a whisper, not a hint, of
10:21AM
17
the deeper systemic and corporate management causes, BP culture
10:22AM
18
of corporate recklessness like we see in the Guide/Sims
10:22AM
19
e-mails, the Cocales e-mail and the ones like it.
10:22AM
20
10:22AM
21
events that happened on the rig during its last few days and
10:22AM
22
hours.
10:22AM
23
will show that when BP declared the negative pressure test a
10:22AM
24
success, it was wrong, recklessly and grossly wrong.
10:22AM
25
one failed test isn't even close to being the only cause of the
At worst, the evidence will show that the amount
Now, BP published its internal investigation and

The Bly
It consists of 190 pages and another 569 pages of
But, Your Honor, if you read every page of that
Much of this trial, the evidence will look at
As for the immediate rig-based causes, the evidence
OFFICIAL TRANSCRIPT
But that
83
10:22AM
Deepwater Horizon tragedy.
10:22AM
10:22AM
taken from BP's own internal investigation, the Bly Report,
10:22AM
which claimed to trace the causes of the Deepwater Horizon
10:22AM
tragedy to a series of interrelated causes, when taken
10:22AM
together, caused the accident.
10:22AM
10:23AM
coming up, but it's the far left slice; the failure of the
10:23AM
float collar, the second from the left; the failed negative
10:23AM
10
test; the failure to monitor and control the well; all the way
10:23AM
11
to the far right, the failure of the BOP to close in the well.
10:23AM
12
Now, according to BP's own accident model, which
10:23AM
13
you see on the screen, each causation slice lined up in an
10:23AM
14
unbroken sequence and created a chain of causation, a direct
10:23AM
15
line through all of these holes that led to the disaster.
10:23AM
16
According to BP's own model, this evidence on the
10:23AM
17
screen, and according to the testimony you'll hear from the Bly
10:23AM
18
Report's namesake, if even one of the causation holes hadn't --
10:23AM
19
or slices hadn't lined up, then the Gulf oil spill never would
10:23AM
20
have happened.
10:23AM
21
10:24AM
22
been interpreted correctly by BP and it was discovered the
10:24AM
23
cement job had failed, BP's own highly respected drilling
10:24AM
24
expert, Dr. Azar, and BP's own cement expert, Mr. Calvert, will
10:24AM
25
testify that this blowout and all that followed never would
This evidence up on the screen, Your Honor, is
For example, the failure of cement, which isn't
For example, if the negative pressure test had
OFFICIAL TRANSCRIPT
84
10:24AM
have happened.
Your Honor, this is what BP's expert witnesses
10:24AM
will say.
10:24AM
10:24AM
because it, more than any one single reason, was the immediate
10:24AM
rig-based cause of this tragedy.
10:24AM
10:24AM
systemic corporate and management causes that allowed the
10:24AM
separate mechanical failures to happen, the evidence will also
10:24AM
prove BP's liability for willful misconduct.
10:24AM
10
10:24AM
11
sued BP for simple penalties under the Clean Water Act, which
10:24AM
12
is consequences for willful misconduct as well as gross
10:25AM
13
negligence.
10:25AM
14
10:25AM
15
standards as two pieces of a jigsaw puzzle, the evidence that
10:25AM
16
we'll present at trial and BP's own accident model, this model,
10:25AM
17
fit the law of willful misconduct under the Clean Water Act is
10:25AM
18
perfectly matched pieces.
10:25AM
19
10:25AM
20
Your Honor, we ask that the Court examine each piece of
10:25AM
21
evidence against the Clean Water Act's legal standard of
10:25AM
22
willful misconduct, which says that an accumulation of acts, a
10:25AM
23
chain of circumstances that were contributing causes, like
10:25AM
24
those we see in BP's own Bly Report and this model, this
10:25AM
25
accumulation of acts constitute willful misconduct even if no
We'll come back to the negative pressure test
Leaving aside the model's emission of the
United States, as Your Honor has pointed out, has
If we think of the factual evidence and the legal
When we present this evidence during the trial,
OFFICIAL TRANSCRIPT
85
10:25AM
single one of those causes was the immediate cause, and even if
10:25AM
no single one of them standing alone would rise to the level of
10:26AM
willful misconduct.
10:26AM
This legal standard of the chain of causation and
10:26AM
willful misconduct under the Clean Water Act is describing BP's
10:26AM
own accident model.
10:26AM
10:26AM
only skim the surface of the evidence that will establish BP's
10:26AM
ownership of each of these interrelated pieces of the willful
10:26AM
10
10:26AM
11
I don't think my arrow is working.
10:26AM
12
The first, on the left, Your Honor, is BP's
10:26AM
13
representation of the first causal chain in their model, which
10:26AM
14
is cement.
10:26AM
15
10:26AM
16
the well until a production rig would later come and start
10:26AM
17
pumping oil.
10:26AM
18
during trial, is to prevent oil and gas from pressuring into
10:26AM
19
the casing and causing a blowout during the temporary
10:27AM
20
abandonment.
10:27AM
21
10:27AM
22
focusing on the cement job.
10:27AM
23
disingenuous, at best.
10:27AM
24
10:27AM
25
Now, in the limited time for this opening, we can
misconduct chain of liability.

There we go.
BP was in the process of temporarily abandoning
The purpose of the cement job, as we'll hear
Now, BP will attempt to shift blame to others by

I'll suggest that that attempt is
The evidence will show that it's simply a fact

that cement jobs sometimes are unsuccessful, but a bad cement
OFFICIAL TRANSCRIPT
86
10:27AM
job doesn't equal a blowout.
10:27AM
10:27AM
provide a barrier to hydrocarbons, they test it.
10:27AM
with a negative pressure test.
10:27AM
with a negative pressure test and botched the test.
10:27AM
10:27AM
risks that compromised the cement job and that it ignored
10:27AM
warnings from Halliburton and its own in-house BP cement
10:27AM
expert.
10:28AM
10
cares, it's done, probably be fine" e-mail.
10:28AM
11
the risk as running fewer centralizers that had been
10:28AM
12
recommended by Halliburton.
10:28AM
13
10:28AM
14
that point, particularly on the cement job, witnesses will
10:28AM
15
testify that BP should have put the rig crew on heightened
10:28AM
16
alert before the negative pressure test; that BP should have
10:28AM
17
warned them, had the duty, the obligation, the responsibility
10:28AM
18
to warn them before the negative pressure test of BP's own
10:28AM
19
concerns about the cement job.
10:28AM
20
not do that.
10:28AM
21
10:28AM
22
Again, my pointer doesn't work.
10:28AM
23
the left is the flow collar, Your Honor.
10:28AM
24
10:28AM
25
Before safe operators rely upon a cement job to

They test it
BP tested the Macondo cement
The evidence will show that BP took multiple
BP's attitude was epitomized in the callous "who

It acknowledged
Considering the risks that BP had undertaken to
The evidence will show they did
BP also bears responsibility for the flow collar.

It's this second slice from
The flow collar was supposed to keep the cement

in place and prevent it from flowing back into the casing while
OFFICIAL TRANSCRIPT
87
10:29AM
the cement set up and formed a barrier to hydrocarbons.
10:29AM
10:29AM
problems in what is called converting the flow collar and
10:29AM
making it work.
10:29AM
the device.
10:29AM
increasing amounts of pressure to the flow collar.
10:29AM
10:29AM
equipment was that a critical component could fail at
10:29AM
1,300 pounds per square inch.
10:29AM
10
go to the service station, fill the tires in our car, call it
10:29AM
11
32, 40 pounds.
10:29AM
12
10:29AM
13
1,800 pounds of pressure above the 1,300-pound design
10:29AM
14
limitation.
10:29AM
15
10:30AM
16
BP's well site leaders, Mr. Kaluza, told people aboard the rig,
10:30AM
17
quote, I was afraid something had blown, close quote.
10:30AM
18
words.
10:30AM
19
10:30AM
20
engineer, Brian Morel, who was also on the rig and who has also
10:30AM
21
taken the Fifth Amendment, stated, as we see, quote, Yeah, we
10:30AM
22
blew it at 3,140.
10:30AM
23
quote.
10:30AM
24
10:30AM
25
As the witnesses will explain, BP had severe
Nine different attempts were made to convert
Each of those attempts involved applying
But one of the design limitations of the
As a point of reference, when we
1,300 pounds was the design limitation.
BP applied 3,142 pounds of pressure.
Over
Testimony will show that at that point, one of
His
The evidence will show that yet another BP
Still not sure what we blew yet, close
That's Mr. Morel.

The evidence will show that despite BP's own
concerns, as we've just seen, about having blown something, to

OFFICIAL TRANSCRIPT
88
10:30AM
use their words, BP did not standdown the operation and take
10:30AM
the time to see what they had blown.
10:30AM
10:30AM
will testify about BP's responsibility for the negative
10:30AM
pressure test, well monitoring and well response; third, fourth
10:30AM
and fifth slices of the causal chain until BP's accident model.
10:31AM
10:31AM
the central and obvious evidence.
10:31AM
three nautical miles, from the bottom of the well up to the
10:31AM
10
rig, 18,000 feet.
10:31AM
11
from here to City Park in New Orleans.
10:31AM
12
casing through 5,000 feet of ocean and marine riser, and
10:31AM
13
finally blew out on to the Deepwater Horizon before either of
10:31AM
14
BP's well site leaders were aware of the blowout.
10:31AM
15
10:31AM
16
regulation 30 C.F.R. 250.401, which required BP, required BP to
10:31AM
17
take all necessary precautions to keep the well under control
10:31AM
18
at all times.
10:31AM
19
10:31AM
20
40 barrels of oil is considered a major kick that must be
10:32AM
21
discovered in time to take action to prevent an uncontrolled
10:32AM
22
blowout.
10:32AM
23
10:32AM
24
by the moment the rig exploded a kick had become a blowout of
10:32AM
25
approximately 2,000 barrels, 84,000 gallons, 50 times more than
Dick Heenan, the United States' drilling expert,
For now it's enough to come back and point out

Oil and gas traveled
Point of reference, roughly the distance

Up 13,000 feet of well
Despite, despite the mandate of a federal
The evidence will show that a kick less than
The evidence will show that BP has admitted that
OFFICIAL TRANSCRIPT
89
10:32AM
a 40-barrel kick they considered to be a major well control
10:32AM
event.
10:32AM
10:32AM
responsibility for other causation slices, including the BOP's
10:32AM
failure to shut in the well.
10:32AM
10:32AM
Your Honor.
10:32AM
final slice.
10:32AM
10:32AM
10
already, the BOP is the last barrier to protect human life in
10:32AM
11
the environment.
10:32AM
12
without fail.
10:33AM
13
federal regulation as the operator of the Macondo well to,
10:33AM
14
quote, Maintain your BOP system to ensure that the equipment
10:33AM
15
function properly, close quote.
10:33AM
16
10:33AM
17
Transocean for the BOP, but the evidence will establish that
10:33AM
18
for five years, stemming from rig audits in 2005, 2008, and
10:33AM
19
2009, BP believed and understood that it had significant
10:33AM
20
maintenance problems with the BOP.
10:33AM
21
drilling the "well from hell," in an area with no kick
10:33AM
22
tolerance and little to no room for mistakes, BP barreled ahead
10:33AM
23
and gambled with a piece of major equipment that was the last
10:33AM
24
line of defense to protect against an uncontrolled blowout.
10:33AM
25
We'll hear other evidence concerning BP's
Since my pointer isn't working, I'll use this,

The BOP on BP's accident model is that last and
In an emergency, as Mr. Roy has pointed out
So it has to function, has to function
Precisely for that reason, BP was required by
Now, BOP -- pardon me, BP will attempt to blame
Yet, despite knowing it was
But of all the evidence the Court will hear, and

OFFICIAL TRANSCRIPT
90
10:34AM
all the different slices of the causal chain of failures in
10:34AM
BP's own accident model, the evidence will show that none was
10:34AM
so critical and none was so thoroughly and grossly botched as
10:34AM
the negative pressure test.
10:34AM
10:34AM
one test had been the done right, this one simple test, it
10:34AM
would have prevented the blowout, the deaths, and everything
10:34AM
else that followed, despite the things that had already gone
10:34AM
wrong, like the cement job.
10:34AM
10
The evidence will show that shortly before
10:34AM
11
8:00 p.m. on April 20th, BP and Transocean completed the
10:34AM
12
negative pressure test of the Macondo well's casing.
10:34AM
13
negative pressure test was a safety critical test.
10:34AM
14
safety critical test to determine whether the cement pumped
10:35AM
15
into the bottom of the hole less than 18 hours before would
10:35AM
16
stop oil and gas from pressuring into the casing, and if
10:35AM
17
unchecked, create an uncontrolled blowout.
10:35AM
18
10:35AM
19
negative pressure test, and there is simply not enough time now
10:35AM
20
to describe the different tests and all that occurred.
10:35AM
21
purposes now, the evidence will show that all BP needed to know
10:35AM
22
is what's on the right-hand side of this slide.
10:35AM
23
10:35AM
24
One, no flow out of the well when it was opened up during the
10:35AM
25
test; or, two, no pressure buildup when the well was closed in.
As even BP's own witnesses will testify, if this
The
The last
The Court will hear a great deal about the
For our
Once the test was set up, there should have been:
OFFICIAL TRANSCRIPT
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10:35AM
As witnesses will explain, this test is
10:35AM
exceedingly simple and is pass/fail.
10:35AM
It's not an essay exam.
10:36AM
present, flow or pressure buildup, the test is a failure.
10:36AM
10:36AM
pressure test monitored pressures on two pipes:
10:36AM
and the kill line.
10:36AM
10:36AM
10:36AM
10
right-hand slide has an pressure reading of zero.
10:36AM
11
other lines here that we aren't going to be going through for
10:36AM
12
the negative test.
10:36AM
13
The kill line, which they are also monitoring,
10:36AM
14
finally, is this other one here on the very right-hand side,
10:36AM
15
that on the right-hand side of the slide also has a zero
10:36AM
16
pressure reading.
10:36AM
17
To have a successful test when it was lined up
10:36AM
18
like this, the evidence will show that all BP needed to know
10:36AM
19
was that the pressure on both pipes had to be zero; repeat,
10:36AM
20
zero.
10:36AM
21
10:37AM
22
and the other pipe had pressure, like the graphic on the
10:37AM
23
left-hand side of the slide, then the test was a failure.
10:37AM
24
Because pressure potentially meant that oil and gas were
10:37AM
25
pressuring into the well and threatening to blow it out, which
It's not multiple choice.
If either of those elements are
The evidence will show that the final negative

The drill pipe
Using the example here, Your Honor, the drill

pipe is the center of the casing going up, and on this
There are
The evidence will show that if one pipe read zero
OFFICIAL TRANSCRIPT
92
10:37AM
is exactly what happened.
10:37AM
10:37AM
courtroom, Your Honor, every expert witness who will testify in
10:37AM
this courtroom, every investigative report that is admitted
10:37AM
into evidence by Your Honor in this trial, and every witness
10:37AM
who was asked the question in deposition, testified that you
10:37AM
can't have a successful negative pressure test if both
10:37AM
pressures aren't zero.
10:37AM
10:37AM
10
that this is something he would expect his first-year students
10:37AM
11
to understand.
10:38AM
12
lines, as in the graphic on the right, the evidence will show
10:38AM
13
that BP saw 1,400 pounds of pressure on the drill pipe and zero
10:38AM
14
on the kill line, what's up there on the left-hand side of the
10:38AM
15
slide.
10:38AM
16
be considered a success and that the well could be flowing.
10:38AM
17
Instead, the evidence will be undisputed that
10:38AM
18
BP's two company men, well site leaders Kaluza and Vidrine,
10:38AM
19
disregarded the differential pressure and approved the test
10:38AM
20
based upon a nonexistent theory called the bladder effect.
10:38AM
21
10:38AM
22
proposed by Transocean crewmen.
10:38AM
23
this nonexistence phenomenon, BP's two well site leaders bought
10:38AM
24
into it lock, stock and barrel.
10:38AM
25
Every fact witness who will testify in this
BP's own drilling expert, Dr. Azar, testified
But instead of pressure, zero pressure on both
That meant, without any doubt, that the test could not
Now, we expect BP to claim that the theory was

But whatever the source of
As the experts and the percipient witnesses will

OFFICIAL TRANSCRIPT
93
10:39AM
testify, without any exception, the theory is incomprehensible
10:39AM
and makes absolutely no sense from engineering, drilling or
10:39AM
even common sense perspectives.
10:39AM
10:39AM
equivocation, that no such phenomenon could be discovered.
10:39AM
fact, Mr. Bly himself is expected to testify that his
10:39AM
investigation spent approximately $10 million and used
10:39AM
approximately 50 people, yet still could find no evidence, no
10:39AM
evidence whatsoever, of the bladder effect, and that BP's well
10:39AM
10
site leaders, what they had used to justify to turn out, turned
10:39AM
11
out to be a deadly decision.
10:39AM
12
10:39AM
13
team could find no evidence this phenomenon is possible,
10:39AM
14
leaving the 1,400 psi unexplained unless it was caused by
10:39AM
15
pressure from the reservoir.
10:40AM
16
10:40AM
17
this case, looked at well site leader Kaluza's attempt to
10:40AM
18
explain the nonexistent bladder effect and summed it up here,
10:40AM
19
eloquently, with nothing but question marks, 560 of them.
10:40AM
20
10:40AM
21
leaders, who had the final authority to approve the test or
10:40AM
22
reject it, called it successful.
10:40AM
23
success despite the 1,400 on the drill pipe.
10:40AM
24
10:40AM
25
As we'll show, BP's Bly Report admits, without

In
As BP's own report explained, the investigation
One BP executive, who is expected to testify in
The evidence will show that BP's well site
They declared the test a
And the evidence will then show that BP proceeded

with its next decision, which displaced mud in the riser to
OFFICIAL TRANSCRIPT
94
10:40AM
lighter seawater and severely underbalanced the well and
10:40AM
allowed it to flow.
10:40AM
and explosions and set the rig afire like a Roman candle.
10:40AM
10:40AM
BP of the negative pressure test under these circumstances was
10:41AM
so far outside the bounds of any reasonable judgment to be
10:41AM
constituted gross negligence, but the evidence against BP will,
10:41AM
in fact, show far, far more.
10:41AM
10:41AM
10
8:52 p.m., less than an hour after the approval of the negative
10:41AM
11
pressure test, and less than an hour before the first explosion
10:41AM
12
on the rig, Hafle and Vidrine had a telephone conversation that
10:41AM
13
should have stopped the chain of events, prevented the need for
10:41AM
14
this trial.
10:41AM
15
save 11 lives and prevent the Gulf oil spill, did absolutely
10:41AM
16
nothing.
10:41AM
17
10:41AM
18
men began their call, the evidence will show and BP's Bly
10:41AM
19
Report admits, that high pressure oil began flowing into the
10:42AM
20
well approximately three miles below the rig floor on the
10:42AM
21
Deepwater Horizon.
10:42AM
22
At that same moment, according to what BP's own
10:42AM
23
documents will show, the BP man in Houston, Hafle, called the
10:42AM
24
well site leader on the rig, Vidrine, and the two men talked
10:42AM
25
for ten full minutes.
The action that set in motion the blowout
The evidence will establish that this approval by
Documents and testimony will show that at
Instead, both men, armed with knowledge that could
At 8:52, at almost the exact same moment the two
OFFICIAL TRANSCRIPT
95
10:42AM
The evidence will show that Vidrine talked to
10:42AM
Hafle about the negative pressure tests; that Vidrine told
10:42AM
Hafle that the crew had zero pressure on the kill line, but
10:42AM
that they still had pressure on the drill pipe.
10:42AM
Vidrine that he couldn't have pressure on the drill pipe and
10:42AM
zero pressure on the kill line in a test that's properly lined
10:42AM
up.
10:42AM
10:42AM
evidence concerning the actions and inactions of BP's well site
10:43AM
10
leaders, the senior drilling engineer in Houston, in that final
10:43AM
11
hour of the rig, will be among the clearest, most irrefutable
10:43AM
12
pieces of evidence in this trial that show BP's primary
10:43AM
13
responsibility for the blowout and everything that followed.
10:43AM
14
The evidence will show that BP's man in Houston,
10:43AM
15
Hafle, understood the obvious and correctly told the well site
10:43AM
16
leader on the rig that the negative pressure test that BP had
10:43AM
17
approved only an hour before couldn't be considered a success.
10:43AM
18
10:43AM
19
absolutely nothing to countermand the well site leader's
10:43AM
20
disastrous conclusion that, quote, He was fully satisfied that
10:43AM
21
the rig crew had performed a successful negative test.
10:43AM
22
10:43AM
23
believed that the cement design was on the ragged edge and had
10:43AM
24
used a swear word to describe the cement job that the negative
10:44AM
25
pressure test was supposed to be testing.
Hafle told
This exchange between these two BP men and other
But the evidence will show that Hafle did
The evidence will show that Hafle, who already
OFFICIAL TRANSCRIPT
It will show that
96
10:44AM
Hafle didn't tell Vidrine the obvious:
Full stop.
Shut it in.
10:44AM
Do it again.
10:44AM
10:44AM
10:44AM
10:44AM
evidence will show that he already knew that the final negative
10:44AM
pressure test had 1,400 on the drill pipe and zero on the kill
10:44AM
line, and he had just been told by one of BP's senior men in
10:44AM
Houston that that can't be.
10:44AM
10
10:44AM
11
BP's well site leader flunked the all-critical safety test when
10:44AM
12
he approved it shortly before 8:00 p.m.; but, worse, he was
10:44AM
13
given the right answer, the right answer by Hafle an hour
10:44AM
14
later, and he was given a chance to undo the previous
10:44AM
15
disastrous mistake he had already made.
10:44AM
16
10:45AM
17
and immediately order the test be rerun?
10:45AM
18
show that he didn't.
10:45AM
19
ordering the well shut in while he investigated what it was
10:45AM
20
doing?
10:45AM
21
10:45AM
22
toolpusher?
10:45AM
23
the rig anywhere?
10:45AM
24
10:45AM
25
The evidence will show that Hafle did nothing

like that.
Now, what about well site leader Vidrine?
The
In other words, the evidence will establish that
So did BP's well site leader get off the phone

The evidence will
Did he protect the rig and the crew by
The evidence, Your Honor, will be that he didn't.

Did he warn the driller?
Did he warn the
Did he warn anybody on the rig floor?
Anybody on
The evidence will show that he didn't.
In fact, there won't be a scrap of evidence, no

testimony, any document at all to show that Vidrine did
OFFICIAL TRANSCRIPT
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10:45AM
anything at all in that last hour after hanging up the phone
10:45AM
with Vidrine -- with Hafle, to take any action to reverse the
10:45AM
deadly blowout that was already underway miles below the floor
10:45AM
of the rig.
10:45AM
10:46AM
the evidence will show that the greatest tragedy, the saddest
10:46AM
tragedy and the tragic irony is the fact that if Hafle had
10:46AM
ordered Vidrine immediately to find the reason for the failed
10:46AM
negative test, or if Vidrine had done it on his own as he was
10:46AM
10
supposed to, the very actions that would have been taken would
10:46AM
11
have saved the rig, the men's lives and the oil spill,
10:46AM
12
prevented the oil spill.
10:46AM
13
10:46AM
14
show, that in order to re-perform the negative pressure test,
10:46AM
15
the BOP would have been shut in, just as it had been during the
10:46AM
16
earlier negative pressure test.
10:46AM
17
well before oil and gas passed above the BOP stack and barreled
10:46AM
18
up the riser like an explosive time bomb counting down to zero,
10:46AM
19
which is exactly what the well had become.
10:46AM
20
10:46AM
21
BP's two men, or either one of them had done their jobs, simple
10:47AM
22
jobs, jobs that were their responsibility, Deepwater Horizon
10:47AM
23
tragedy and an environmental disaster we call the Gulf Oil
10:47AM
24
Spill would never have happened.
10:47AM
25
In a case that is already filled with tragedy,
And the reason for that is, the evidence will
That would have shut in the
Make no mistake, the evidence will show that if
The blowout would have stopped right here at the

OFFICIAL TRANSCRIPT
98
10:47AM
end of the negative pressure test, on this slice of BP's own
10:47AM
accident model.
10:47AM
10:47AM
ended their call at 9:02 p.m., ten minutes after the well began
10:47AM
to flow.
10:47AM
the explosive mass of oil and gas didn't pass the BOP and enter
10:47AM
the riser until approximately 9:38 p.m.
10:47AM
10:47AM
10:48AM
10
conclusion of the phone call between BP Houston and its well
10:48AM
11
site leader to close in the well through normal operation of
10:48AM
12
the BOP.
10:48AM
13
10:48AM
14
hung up the phone at 9:02 p.m., the people on the rig, the rig
10:48AM
15
itself, and the Gulf and its people had 47 minutes before oil
10:48AM
16
and gas exploded out of the riser and changed, in some cases
10:48AM
17
ended, lives.
10:48AM
18
10:48AM
19
just described weren't the result of an accident, or mere
10:48AM
20
negligence or even gross negligence, which it was, but it was
10:48AM
21
the result of willful misconduct, for not only was it within
10:48AM
22
BP's power to prevent the tragedy, it was its responsibility.
10:48AM
23
Now, to be sure, BP will argue that the blowout
10:48AM
24
was the fault of the Transocean crewmen, who worked under BP's
10:48AM
25
well site leaders and followed their orders during the negative
Instead BP did nothing.
The evidence will show that Hafle and Vidrine
The evidence, such as BP's Bly Report, will show that
Witnesses will testify that that means both BP

and the rig crew would have had over a full half hour after the
The evidence will show that when BP's two men
The evidence will show that those actions we've
OFFICIAL TRANSCRIPT
99
10:49AM
pressure test that went so horribly wrong.
But the evidence
10:49AM
will show, it will be proved that if even some of those
10:49AM
Transocean crewmen bore responsibility for what happened, they
10:49AM
paid for those mistakes with their lives.
10:49AM
employed by Transocean, some not, had nothing to do with the
10:49AM
negative pressure test and made no mistakes for which they
10:49AM
could ever be held to pay.
10:49AM
10:49AM
10:49AM
10
lives when the evidence will show, without a sliver or a shadow
10:49AM
11
of a doubt, that BP could have saved them, could have saved
10:49AM
12
every plaintiff in this courtroom, every defendant in this
10:49AM
13
courtroom, the Gulf from this disaster, with something as short
10:49AM
14
as a ten-second phone call to the rig floor, to the driller,
10:50AM
15
Dewey Rivette; the toolpusher, Jason Anderson, saying something
10:50AM
16
as simple as:
10:50AM
17
10:50AM
18
willful misconduct lightly, Your Honor.
10:50AM
19
seriousness of those allegations.
10:50AM
20
11 people died as a result of multiple interconnected faults of
10:50AM
21
BP and others.
10:50AM
22
10:50AM
23
of people across the Gulf States suffered injuries to their
10:50AM
24
livelihood.
10:50AM
25
millions of people depend, directly and indirectly, for their
And other men, some
But the point is that none of them, not a single

one of those men should have paid for any mistake with their
Shut it in.
We're doing the test again.
We don't use words like gross negligence and

We understand the
But the fact that remains is
As a further consequence, many tens of thousands
The Gulf and the environment upon which tens of
OFFICIAL TRANSCRIPT
100
10:50AM
food, their livelihoods, and their recreation, as well as the
10:50AM
birds, the fish, the marine and shoreline organisms, which
10:50AM
sustains the Gulf's complex ecosystem, sustain damage and
10:51AM
injuries which are still being measured, and will be tried in
10:51AM
later phases of this trial.
10:51AM
10:51AM
people aboard the Deepwater Horizon, were caused by actions on
10:51AM
and prior to April 20th, that cannot be seen as anything but
10:51AM
utterly inexcusable behavior.
10:51AM
10
10:51AM
11
Honor.
10:51AM
12
for the benefit of the families of the men who were killed,
10:51AM
13
justice for the people of the Gulf and for the money to help
10:51AM
14
heal and restore the precious environment that sustains this
10:51AM
15
Crescent City and the states, the cities, and the communities
10:51AM
16
all across the Gulf of Mexico.
10:51AM
17
10:51AM
18
10:51AM
19
10:51AM
20
10:51AM
21
10:52AM
22
10:52AM
23
Luther Strange, the Attorney General of the State of Alabama
10:52AM
24
and the liaison counsel for the Gulf States in this historic
10:52AM
25
litigation.
These damages, and not least the deaths to the
We look forward to putting on this evidence, Your

And by the end of the phases of trial, securing answers
Thank you very much.

THE COURT:
All right.
Thank you.
Alabama.
OPENING STATEMENTS
BY MR. STRANGE:
May it please the Court, Your Honor.
I'm
It's my privilege to stand before you today on

OFFICIAL TRANSCRIPT
101
10:52AM
behalf of Alabama and its nearly five million citizens.
10:52AM
10:52AM
detail the lingering economic and environmental devastation the
10:52AM
defendants inflicted on Alabama.
10:53AM
about those damages at the appropriate time, for they are
10:53AM
indeed great.
10:53AM
10:53AM
just one issue, who was at fault for the explosion and spill
10:53AM
that caused such unprecedented and catastrophic damages to the
10:53AM
10
10:53AM
11
10:53AM
12
the interest of the United States and the private plaintiffs.
10:53AM
13
Alabama, therefore, supports and affirms the descriptions of
10:53AM
14
facts and laws so well outlined by Mr. Roy and Mr. Underhill,
10:53AM
15
and I don't plan to duplicate their efforts this morning.
10:53AM
16
10:53AM
17
case against BP:
10:53AM
18
preventable.
10:53AM
19
towards the Gulf caused the spill.
10:54AM
20
10:54AM
21
that the risks of a deep-water blowout in the Gulf of Mexico
10:54AM
22
was great.
10:54AM
23
North Sea.
10:54AM
24
10:54AM
25
In due course, Your Honor, I'll have the opportunity to
But today I'll be brief.
I'll have a great deal to say
In this phase one we address
Gulf Coast?
On this issue, Alabama's interests align perfectly with
Instead, I offer two points that summarize our collective

One, the spill was both predictable and
Two, BP's culture of corporate callousness
On this first point, the evidence will show that BP knew
In fact, it was nine times greater than in the
BP also knew, and certainly should have known before the

blowout, that the centralizers would not centralize, the cement
OFFICIAL TRANSCRIPT
102
10:54AM
will not cement, the controllers will not control, and the
10:54AM
blowout preventer would not prevent.
10:54AM
all of this, but BP was blinded by their bottom line.
10:54AM
10:54AM
10:54AM
10:54AM
Money mattered more than the environment.
10:54AM
than the thousands of jobs and businesses that were destroyed
10:55AM
all along the Gulf Coast.
10:55AM
10
lives of the 11 workers who lost their lives on the Horizon
10:55AM
11
rig.
10:55AM
12
10:55AM
13
10:55AM
14
10:55AM
15
coming weeks we will prove that BP acted with gross negligence
10:55AM
16
and willful misconduct, and that we'll prove the same level of
10:55AM
17
fault against two of BP's partners, Transocean and Halliburton.
10:55AM
18
10:55AM
19
trial to rule that all three, BP, Transocean, and Halliburton
10:55AM
20
are liable for punitive damages to the State of Alabama.
10:55AM
21
10:55AM
22
behalf of the victims of the Gulf disaster as this historic
10:56AM
23
case gets underway.
10:56AM
24
10:56AM
25
We'll show that BP knew
Which leads me, Judge, to my second point, the spill was

tragically inevitable due to BP's corporate culture.
The evidence will show that at BP money mattered most.
Money mattered more
Money even mattered more than the
Money mattered more to BP than the Gulf, much more.

Your Honor, the evidence will be clear and unmistakable,
greed devastated the Gulf.

Finally, Your Honor, I agree with Mr. Roy, that in the
For that reason, we'll ask the Court at the end of this
Again, Your Honor, it's a privilege to stand here on
Thank you.
THE COURT:
All right.
Thank you, Mr. Strange.
OFFICIAL TRANSCRIPT
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10:56AM
Mr. Caldwell.
Louisiana.
10:56AM
10:56AM
10:56AM
10:56AM
Court, I want to thank you and Magistrate Shushan and your
10:56AM
staff for consuming and exhaustive efforts in bringing this
10:56AM
landmark case to trial.
10:56AM
and those involved are all part of an effort for your entire
10:57AM
hard-working team.
10:57AM
10
10:57AM
11
McGovern and the parties for handling their clients' interests
10:57AM
12
in a professional manner, but after all, none of the lawyers so
10:57AM
13
far, as I know, were witnesses to this event.
10:57AM
14
here has a job to do.
10:57AM
15
own counsel and staff.
10:57AM
16
10:57AM
17
the benefit of the press and those who are watching, that we're
10:57AM
18
having a trial and it's important for the general public to
10:57AM
19
understand what we're doing.
10:57AM
20
10:57AM
21
as far as we're concerned, that our oil companies -- and
10:58AM
22
Louisiana is an oil and gas state -- that our companies are
10:58AM
23
conducting business in the safest possible manner.
10:58AM
24
don't do that, then it's our job as Attorney General
10:58AM
25
Luther Strange, myself, and the other lawyers, too, do what
OPENING STATEMENTS
BY MR. CALDWELL:
Your Honor, Judge Barbier, if it please the
The courtroom staff, the law clerks,
But I would also like to thank Special Master
And everybody
And having said that, I want to thank my

And we're here to do justice.
Trials are important.
This court has stated for
All citizens and workers should feel confident,
OFFICIAL TRANSCRIPT
When they
104
10:58AM
we're supposed to do so that they have to answer.
10:58AM
I have personally been executing my
10:58AM
responsibility as Attorney General from a couple of days out
10:58AM
when this rig happened, along with the other Attorney Generals
10:58AM
from the Gulf States; and with the help, I should say, of BP.
10:58AM
Mr. Jack Lynch is in the courtroom today from Texas.
10:58AM
10:58AM
knows, and in retrospect and in hindsight, is a tragic,
10:58AM
horrible event.
10:59AM
10
10:59AM
11
business, not just in the Gulf of Mexico, but in the world.
10:59AM
12
The second thing about this case is the gross
10:59AM
13
10:59AM
14
10:59AM
15
Louisiana, this was a no risk proposition for any oil to reach
10:59AM
16
Louisiana shores 48 miles away.
10:59AM
17
10:59AM
18
economy, and its ecology.
10:59AM
19
importantly, this disaster continues in various forms,
10:59AM
20
including continued pollution, higher unemployment, and the
10:59AM
21
need for increased social service.
10:59AM
22
30 miles from the door of this courthouse, Your Honor, over
11:00AM
23
212 miles of Louisiana coast are being polluted and continue to
11:00AM
24
be oiled, and in Gulf waters, especially Barataria Bay and
11:00AM
25
Breton Sound.
We worked together to try to solve what everybody
But this case is really about the cost of doing
underestimating the cost of doing that business.

For example, on the application to drill, BP told
The disaster has damaged Louisiana's people, its

I think that's clear.
But most
And today, less than
We continue to be adversely affected.

OFFICIAL TRANSCRIPT
105
11:00AM
Our culture, of course, we know is unique in our
11:00AM
reliance on the Gulf; but, the other states, to a certain
11:00AM
extent, as well, our natural resources, our livelihood and
11:00AM
recreation.
11:00AM
11:00AM
it can't restore the ecosystem; but this trial can and will
11:00AM
show that BP and its contractors, all of them, all of the
11:00AM
contractors bear some responsibility.
11:00AM
negligent manner.
11:01AM
10
11:01AM
11
11:01AM
12
11:01AM
13
culture, but the law doesn't penalize culture, it penalizes
11:01AM
14
gross negligence.
11:01AM
15
of negligence.
11:01AM
16
11:01AM
17
11:01AM
18
11:01AM
19
OPA's limitation of liability, and certainly we appreciate
11:01AM
20
that.
11:01AM
21
the willful and wanton misconduct, and that this imposition of
11:01AM
22
punitive damages should be in the highest amount allowed by
11:01AM
23
law.
11:01AM
24
11:02AM
25
This trial can't bring back the 11 workers, and
They acted in a grossly
This disaster was totally and wholly avoidable,

as we heard Mr. Roy, Mr. Underhill state.
We've heard a lot about the problem of BP's
The culture, of course, causes an atmosphere
It recognizes that elevated risks warrant

elevated care.
BP has admitted liability under OPA and waived
Nevertheless, the evidence in this case is going to show
We want the Court to focus on, and we know it

will, the chaos that was BP's planning process and operations,
OFFICIAL TRANSCRIPT
106
11:02AM
and including the botched negative pressure test that we know
11:02AM
is central, a central feature, the cement job disaster, and the
11:02AM
failed control and the well response.
11:02AM
11:02AM
about that, especially in detail from Mr. Roy.
11:02AM
that much, just that show that Transocean is liable under OPA
11:02AM
jointly and severally.
11:02AM
11:02AM
11:02AM
10
11:02AM
11
11:02AM
12
Louisiana.
11:02AM
13
burned off, and no attempt was made to capture this oil.
11:03AM
14
11:03AM
15
failure to monitor the well, to control the well, and for its
11:03AM
16
conduct, along with BP's, in the negative pressure test.
11:03AM
17
11:03AM
18
negative pressure test.
11:03AM
19
September 2009 rig audit, which documented 390 jobs of overdue
11:03AM
20
and inadequate maintenance equaling 3,545 overdue hours of
11:03AM
21
maintenance that Mr. Roy referred to.
11:03AM
22
not even seaworthy.
11:03AM
23
11:03AM
24
deposition, Transocean asked its witnesses if its employees
11:03AM
25
would really act so as to endanger themselves.
What about Transocean?
Well, you've heard a lot

I won't go into
Transocean, the owner of the Deepwater Horizon,

failed to operate the vessel safely and to protect personnel
onboard and the marine environment.
Transocean oil was the first oil to reach
The first oil may be the worst oil.
It wasn't
Transocean must also be held accountable for its
BP and Transocean worked together to botch the

Prior to that, they botched the
Deepwater Horizon was
A final word about Transocean, almost every
OFFICIAL TRANSCRIPT
Well, that's
107
11:04AM
the wrong question.
The right question is did the employees do
11:04AM
the best with what Transocean made available to them, and was
11:04AM
what Transocean made available enough?
11:04AM
11:04AM
and ecological disaster could have been avoided as well by
11:04AM
Transocean.
11:04AM
11:04AM
them, if anything at all.
11:04AM
strictly, jointly and severally liable under OPA.
11:04AM
10
11:04AM
11
11:04AM
12
party to this phase of the trial, so you might want to talk
11:04AM
13
about another party, okay.
11:04AM
14
11:04AM
15
11:05AM
16
as we've seen and has been referred to, using leftover rig
11:05AM
17
blend from a prior job that contained a defoaming agent
11:05AM
18
incompatible with the slurry.
11:05AM
19
It failed to run critical safety tests to confirm
11:05AM
20
the cement stability, and without the results of that test that
11:05AM
21
showed that the slurry was also unstable.
11:05AM
22
11:05AM
23
perform the production casing cement job in accordance with the
11:05AM
24
industry accepted recommendations was another but for cause.
11:05AM
25
Each one of these things on their own could be deemed to have
The evidence will show these deaths and economic
So we've got BP and Transocean.

What about Anadarko?
Nobody said much about
Evidence will show that they're

Anadarko is
a 25 percent owner of the -THE COURT:
Mr. Caldwell, excuse me, Anadarko is not a
MR. CALDWELL:
All right, Your Honor.
Halliburton.
Halliburton was grossly negligent,
The evidence will show Halliburton failed to
OFFICIAL TRANSCRIPT
108
11:05AM
caused this disaster.
11:05AM
11:05AM
negligent.
11:05AM
it designed that for them, but did not install rechargeable
11:06AM
batteries.
11:06AM
More troubling is Cameron's system erroneously
11:06AM
led the operator to believe that the automatic emergency BOP
11:06AM
function was armed, even when the batteries were dead, and
11:06AM
could not function.
11:06AM
10
11:06AM
11
displacement procedure that was improper.
11:06AM
12
normal spacer procedure.
11:06AM
13
BP and each of every one of its contractors
11:06AM
14
violated their duties, as Mr. Underhill has stated, under
11:06AM
15
30 CFR 250.401 to take all necessary precautions to keep the
11:06AM
16
well under control at all times.
11:06AM
17
11:06AM
18
the critical warning signs and failed to take precautions that
11:07AM
19
would have delayed the completion of the well, but also would
11:07AM
20
have averted this entire environmental disaster.
11:07AM
21
11:07AM
22
with the consequences.
11:07AM
23
$50 million over budget.
11:07AM
24
ignored.
11:07AM
25
Cameron redesigned the BOP, and it was grossly

The emergency battery system for Transocean and BP,
M-I Swaco was also grossly negligent.
It had a
It did not use
Management for each of these defendants ignored
BP's team goal was to save money, and to heck

Macondo was behind schedule and some
Corners were not cut, they were
Your Honor, finally, I would like to say that

OFFICIAL TRANSCRIPT
109
11:07AM
Louisiana has been ground zero for this disaster.
11:07AM
11:07AM
shoreline -- BP refused to inspect the other half -- we've got
11:07AM
660 miles of marsh and shoreline oiled in Louisiana.
11:07AM
million barrels of oil are unaccounted for.
11:07AM
have been discovered and removed in 2012 from Louisiana's
11:08AM
shore.
11:08AM
2012 was from Louisiana's shores.
11:08AM
11:08AM
10
State of Louisiana, in our waters.
11:08AM
11
nearly one hundred percent, when you look at heavy and moderate
11:08AM
12
oiling.
11:08AM
13
11:08AM
14
weekly from Louisiana's shores and beaches in the form of oil
11:08AM
15
balls and oil mats.
11:08AM
16
11:08AM
17
million pounds of oily material from subsurface mats on Elmer's
11:08AM
18
Island.
11:09AM
19
Louisiana since 2012; but, over 9 million pounds of oil and
11:09AM
20
material collected have been removed since June of 2011 through
11:09AM
21
December 2012.
11:09AM
22
November 21st of 2012, 1,720,000 pounds have been recovered.
11:09AM
23
11:09AM
24
11:09AM
25
Based on an inspection of one-half of Louisiana
One
28 new oil mats
Since January 1, 2013, 93 percent of all oil removed in
60 percent of all Gulf oiling occurred in the

The number is even higher,
To date, retrievable, visible oil is recovered
In 2011, operations crews removed over one
2.1 million pounds of oil material has been removed in
Post-Hurricane Isaac, between September 7th and
58 percent of all wildlife injured and collected

in state identifiable waters were recovered in Louisiana.
Your Honor, finally, I know the Court has lived
OFFICIAL TRANSCRIPT
110
11:09AM
and breathed this case.
I would like to say that if we could
11:09AM
take every lawyer in this courtroom and every person that
11:09AM
wanted to out to Louisiana oil and drop them off, we'd see what
11:10AM
a 10W90 smog would look like.
11:10AM
tragedy to this very day and tomorrow.
11:10AM
11:10AM
and to judge the case on live witness testimony, not just
11:10AM
wholesale reference as well to depositions and documents.
11:10AM
sure the lawyers are going to produce that for the Court; but,
11:10AM
10
the direct and cross-examination has got to be critically
11:10AM
11
assessed by the Court in the event that there is some change in
11:10AM
12
what the Court expects.
11:10AM
13
11:10AM
14
determine the real truth in this case, that is, what happened,
11:10AM
15
why, who is responsible, and to what degree and who is still
11:10AM
16
responsible for the continuous oiling.
11:11AM
17
the one to separate the chaff from the grain and apply the law
11:11AM
18
accordingly.
11:11AM
19
11:11AM
20
11:11AM
21
11:11AM
22
11:11AM
23
11:11AM
24
11:11AM
25
The point is this a continuing
It's crucial for this Court to keep an open mind
I'm
Because it's the Court's responsibility to
In short, this Court is
We need to get to the proof, Your Honor.
The
whole world is watching what we're doing.

Again, I want to thank Your Honor for the
opportunity to address the Court.
THE COURT:
All right.
All right.
MR. BRIAN:
Thank you, Mr. Caldwell.
Transocean.
Your Honor, I'm going to put up an exhibit

OFFICIAL TRANSCRIPT
111
11:11AM
later.
May Mr. Miller approach and readjust the easel?
11:11AM
11:12AM
11:12AM
you're going to use a pad, low tech.
11:12AM
in a while in court, but that's okay.
11:12AM
11:12AM
him I could out low tech him, Your Honor.
11:12AM
OPENING STATEMENTS
11:12AM
11:12AM
10
11:12AM
11
11:12AM
12
took place on the Deepwater Horizon that explains virtually
11:12AM
13
everything you need to know about what happened on the rig that
11:12AM
14
night.
11:12AM
15
There was a conversation between Don Vidrine,
11:12AM
16
BP's onsite well site leader, and Mark Hafle, their onshore
11:12AM
17
engineer.
11:12AM
18
11:12AM
19
test.
11:12AM
20
but he thought the results were squirrelly.
11:12AM
21
Mr. Hafle, who called him back at 8:52 p.m., before the gas had
11:12AM
22
gotten above the BOP, and early enough that if they had shut
11:13AM
23
down the job then, none of us would be here today.
11:13AM
24
11:13AM
25
THE COURT:
Sure.
With all the technology we have here, Mr. Brian,
MR. BRIAN:
Okay.
Haven't seen this
Mr. Roy told me he was low tech, and I told
BY MR. BRIAN:
Your Honor, Brad Brian for Transocean.
At 8:52 p.m. on April 20, 2010, a conversation
Mr. Vidrine had supervised the negative pressure

He had declared the negative pressure test a success,
Who was Mr. Hafle?
So he called
Mr. Hafle was one of three
onshore engineers, part of the BP team.

OFFICIAL TRANSCRIPT
Mr. Hafle knew better
112
11:13AM
than anybody how problematic this well had been and the risks
11:13AM
that BP had taken.
11:13AM
11:13AM
negative pressure test is and what it should show.
11:13AM
to Mr. Vidrine, and he knew immediately that there was a
11:13AM
problem.
11:13AM
11:13AM
test results that Mr. Vidrine had explained if the test had
11:13AM
been done right.
11:13AM
10
Mark Hafle told Don Vidrine that you can't have
11:14AM
11
pressure on the drill pipe and zero pressure on the kill line
11:14AM
12
in a test that's properly lined up.
11:14AM
13
11:14AM
14
expert, the DOJ's expert, just about everybody's expert
11:14AM
15
believes that that should have shut in the well, then, shut
11:14AM
16
down the job.
11:14AM
17
11:14AM
18
did what he and the other engineers at BP had been doing for
11:14AM
19
two months in the face of risk; he did nothing.
11:14AM
20
Mr. Vidrine did worse.
11:14AM
21
phone and walked to the drill floor.
11:14AM
22
shack, and he talked to the three men on Transocean's crew.
11:14AM
23
told them to proceed with the displacement, to remove from the
11:15AM
24
well the drilling mud, the only thing that was at that point
11:15AM
25
standing in the way between those men and a blowout.
Mr. Hafle understood better than anybody what a

He listened
He told Mr. Vidrine that you could not have the
So what did they do?
Your Honor, the PSC's
If they had done that, we wouldn't be here.

But Hafle did not do that.
Instead, Mark Hafle
Mr. Vidrine got off the

He walked into the drill
OFFICIAL TRANSCRIPT
He
113
11:15AM
He left them alone in the drill shack to face
11:15AM
11:15AM
11:15AM
instructions.
11:15AM
complacent.
11:15AM
the pumps when they saw abnormalities.
11:15AM
11:15AM
what Mr. Hafle already knew, that you can't have pressure on
11:15AM
the drill pipe and zero pressure on the kill line in a test
11:15AM
10
11:15AM
11
11:15AM
12
putting too much trust in BP, and they paid for that trust with
11:16AM
13
their lives.
11:16AM
14
11:16AM
15
effort to shift the blame to the Transocean drill crew and to
11:16AM
16
avoid its indemnity obligation is shameful.
11:16AM
17
11:16AM
18
entered guilty pleas as a result of some of the conduct on
11:16AM
19
April 20, 2010, but that's where the comparison ends.
11:16AM
20
11:16AM
21
manslaughter for not only causing the largest oil spill in
11:16AM
22
history, but for causing the deaths of eleven people, including
11:16AM
23
nine of our crewmen.
11:16AM
24
11:16AM
25
those risks.
He never saw them alive again.

Transocean's drill crew followed those
They did it attentively.
They were not
Twice during the next 30 minutes they shut down
They spent crucial minutes trying to figure out
that's properly lined up.

These men on the drill crew made the mistake of
Under these facts, Your Honor, BP's continuing
Your Honor knows that both BP and Transocean have
BP pled guilty to eleven counts of seamen's
Transocean Deepwater, Inc., the employer of the

men offshore, pled guilty to one ordinary negligence
OFFICIAL TRANSCRIPT
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11:16AM
misdemeanor count for discharging oil into the Gulf.
11:17AM
11:17AM
should have investigated more in response to Mr. Vidrine's
11:17AM
instruction, and we pled guilty for that; but they put their
11:17AM
trust into BP, and they were betrayed.
11:17AM
11:17AM
Transocean defendants in this case.
11:17AM
be working alongside some of the best lawyers I've ever had the
11:17AM
privilege to work with, Kerry Miller, Steve Roberts,
11:17AM
10
Rachel Clingman, Richard Hymel; my own colleagues, Mike Doyen
11:17AM
11
and Luis LI and, back in the courtroom somewhere, John Kinchen.
11:17AM
12
11:17AM
13
the two questions Your Honor will have to decide with respect
11:17AM
14
to Transocean in, I think, Phase One of the trial:
11:17AM
15
drill crew or the company that employed them so consciously
11:18AM
16
indifferent to danger that their conduct can be deemed to be
11:18AM
17
grossly negligent; and, was the conduct of those men or the
11:18AM
18
company so deliberately deviant such that Transocean is deemed
11:18AM
19
to have committed a core breach of conduct that might
11:18AM
20
conceivably void BP's unambiguous indemnity obligation?
11:18AM
21
11:18AM
22
11:18AM
23
11:18AM
24
crew and Transocean were not consciously indifferent to danger.
11:18AM
25
Their conduct does not come close to the sort of deliberate
We have admitted, Your Honor, that our crew
Your Honor, it's my privilege to represent the

I'm honored and humbled to
I've tried to organize my opening remarks around
Was the
I would submit that the answer to both of those

questions is no.
The evidence will show at this trial that the
OFFICIAL TRANSCRIPT
115
11:18AM
misconduct that has to be shown to establish a core breach of
11:18AM
contract.
11:18AM
11:18AM
the heart of the facts that Your Honor must wrestle with in
11:18AM
answering both of those questions.
11:19AM
microcosm of what BP did wrong on this well and why we believe
11:19AM
that Transocean and our crewmen truly are victims of that
11:19AM
misconduct.
11:19AM
11:19AM
10
leader had that conversation, and they realized that the test
11:19AM
11
was no good, their instructing the crew to proceed with
11:19AM
12
displacement of the well was in utter disregard to the facts.
11:19AM
13
Nothing remotely similar was done by Transocean.
11:19AM
14
11:19AM
15
was good and relying on Mr. Vidrine?
11:19AM
16
that.
11:19AM
17
11:19AM
18
11:19AM
19
11:20AM
20
Mr. Vidrine, immediately saw a problem, and then stayed safely
11:20AM
21
onshore.
11:20AM
22
several hours for the sole purpose of getting that negative
11:20AM
23
pressure test right.
11:20AM
24
for lack of trying, and it was not for indifference.
11:20AM
25
I would submit that that 8:52 p.m. call lies at
In many ways, it's a
When the BP onshore engineer and the BP well site
Did the crew make a mistake in thinking the test

Yes.
We've admitted
In hindsight, everybody knows they made a mistake.

But did they know the test was wrong, as
Mr. Hafle indicated in those notes of his interview?
No.
Mr. Hafle had an eight-minute conversation with
The Transocean crew, by contrast, worked hard for
They didn't get it right, but it wasn't
We don't know, and we'll never know, Your Honor,

OFFICIAL TRANSCRIPT
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11:20AM
precisely what that crew was thinking because they are not here
11:20AM
to tell us.
11:20AM
putting themselves and their crew mates at risk.
11:20AM
11:20AM
fact and law, as Mr. Caldwell just tried to do, to equate the
11:20AM
conduct of the Transocean crew to the conduct of Mark Hafle,
11:20AM
who knew it was wrong and did nothing, or the conduct of
11:21AM
Don Vidrine, who was told by Mark Hafle it was wrong, and yet
11:21AM
told the crew to proceed.
11:21AM
10
11:21AM
11
Your Honor.
11:21AM
12
duty.
11:21AM
13
well.
11:21AM
14
11:21AM
15
end, the Transocean drill crew, Revette, Stephen Curtis, and
11:21AM
16
Jason Anderson, were in the drill shack.
11:21AM
17
11:21AM
18
universally admired by everyone.
11:21AM
19
shows that Transocean worked long and hard to provide this
11:21AM
20
drill crew with the training and the equipment that they needed
11:21AM
21
to do their job safely and return home.
11:21AM
22
they weren't trained properly; they died because critical
11:22AM
23
information was withheld from them.
11:22AM
24
11:22AM
25
But what we do know is they had no interest in
I would submit that it's wrong as a matter of
The Transocean crew did not go home to safety,

They did not ignore their duty.
They died doing their duty.
They did their
They died fighting the
From 6:00 p.m. that night on April 20 until the
This was a great crew, experienced, well trained,

The overwhelming evidence
Who were these three men?
They died not because
Jason Anderson had
been on the Deepwater Horizon almost 10 years, since its maiden

OFFICIAL TRANSCRIPT
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11:22AM
voyage.
Shortly before April 20, he was offered a promotion
11:22AM
precisely because he was one of the best toolpushers in the
11:22AM
company.
11:22AM
11:22AM
experience with the company.
11:22AM
Horizon almost as long as Mr. Anderson.
11:22AM
11:22AM
for Transocean for almost nine years, all but a few months of
11:22AM
which were on the Deepwater Horizon.
11:22AM
10
11:22AM
11
depositions in this case, Your Honor, we asked virtually
11:22AM
12
everyone what they thought of these men.
11:23AM
13
safety conscious people, the kinds of men you would gladly
11:23AM
14
entrust yourself, your lives to.
11:23AM
15
11:23AM
16
11:23AM
17
11:23AM
18
video clip was played.)
11:23AM
19
Q.
11:23AM
20
individuals we just talked about in terms of their safety
11:23AM
21
consciousness while you work as a well site leader on the
11:23AM
22
Deepwater Horizon?
11:23AM
23
A.
"Never had it.
11:23AM
24
Q.
"If you could turn back the clock, and if you could work
11:23AM
25
on a rig with these guys again, would you have any problem
Dewey Revette, the driller, had 23 years of

He had been on the Deepwater
Stephen Curtis, the assistant driller, had worked
These men were universally respected.
At
The answer, they were
Here is what Murray Sepulvado, one of the highest

ranked BP well site leaders, said in his deposition:
(WHEREUPON, at this point in the proceedings, a
"Did you ever have any problems with any of these
OFFICIAL TRANSCRIPT
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11:23AM
working on a rig with these guys?
11:23AM
A.
11:23AM
11:23AM
video clip ended.)
11:23AM
MR. BRIAN:
11:23AM
of the best rigs in the world.
11:23AM
challenging wells in the world.
11:23AM
11:23AM
11:23AM
10
11:23AM
11
government agencies and neutral third parties.
11:24AM
12
officials at the government, the MMS, testified that from his
11:24AM
13
experience, they're one of the best.
11:24AM
14
11:24AM
15
they said they found the rig, the overall rig in excellent
11:24AM
16
condition.
11:24AM
17
11:24AM
18
worked exclusively for BP.
11:24AM
19
best rigs in the fleet.
11:24AM
20
11:24AM
21
a tour on April 20 of the Deepwater Horizon by some senior BP
11:24AM
22
people, including a man named Pat O'Bryan.
11:24AM
23
to say about it.
11:24AM
24
11:24AM
25
"It would be my pleasure."

(WHEREUPON, at this point in the proceedings, the
The Deepwater Horizon, Your Honor, was one

It drilled some of the most
In 2009, it dug a well over 35000 feet, a record

in the world at its time, twice what the Macondo well was.
The rig was inspected hundreds of times by
One of the
When the Coast Guard inspected the rig in 2009,
BP agreed.
The Deepwater Horizon had been built for BP and
It was regarded by BP as one of the
You're going to hear testimony at the trial about
Here is what he had
At his deposition, he said, "It was the best

performing rig from a safety and a drilling performance
OFFICIAL TRANSCRIPT
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11:24AM
standpoint."
11:24AM
11:24AM
11:24AM
11:25AM
11:25AM
11:25AM
the MMS, the Coast Guard.
11:25AM
or the crew.
11:25AM
or mismanaged it.
11:25AM
10
11:25AM
11
best rig and a fine, well-trained crew on the Macondo well,
11:25AM
12
Your Honor.
11:25AM
13
equipment.
11:25AM
14
people or our equipment on the hope that we'll make zillions of
11:25AM
15
dollars by striking oil.
11:25AM
16
we want them to come back to their homes and their families.
11:25AM
17
11:26AM
18
training.
11:26AM
19
Jason Anderson, Dewey Revette and Stephen Curtis, were up to
11:26AM
20
date on their well control training courses.
11:26AM
21
11:26AM
22
IADC, which sets standards and has certified well control
11:26AM
23
training programs in companies like Exxon Mobil, Chevron, Noble
11:26AM
24
Drilling and others.
11:26AM
25
He went out on the tour because he wanted to see

what good looks like.
This crew didn't just meet industry standard.
This rig, Your Honor, was what the industry standard should be.
As of April 20, 2010, that was the view of BP,
The problem here wasn't with the rig
The problem was the well and the way BP managed
It was not an accident that Transocean had its
Transocean has only two assets, its people and its

We don't own oil and gas leases.
We don't risk our
When we send our people out to a rig,
Transocean gave its people state of the art

All three of the men in the drill shack that night,
Those courses were audited and certified by the
Many, many experts have reviewed our training

OFFICIAL TRANSCRIPT
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11:26AM
programs.
The bottom line is our training was top notch,
11:26AM
Your Honor.
11:26AM
11:26AM
saying that our training was below the standard of care in the
11:26AM
industry at that time.
11:26AM
11:26AM
to ask whether we could have done something different and
11:26AM
better?
11:26AM
when it had accidents and incidents in the past.
11:26AM
10
studied them.
11:27AM
11
new procedures.
11:27AM
12
11:27AM
13
Macondo.
11:27AM
14
the evidence in this case will show that Transocean's training
11:27AM
15
was far above the standard of care in the industry.
11:27AM
16
11:27AM
17
11:27AM
18
11:27AM
19
April 18, 2010, on the Deepwater Horizon, just two days before
11:27AM
20
the incident.
11:27AM
21
responsibilities of the crew, and they discussed the
11:27AM
22
possibility of kicks during cement jobs.
11:27AM
23
that wells have been lost due to improperly designed cement
11:27AM
24
slurries and spacers.
11:28AM
25
You're not going to find a single expert report
Now, it is, of course, proper after an accident
We've all done that.
Transocean has always done that
They have reported on them.
They've
They've instituted
They've updated their training control manual.
We all hope that lessons will be learned from

But in the world before Macondo, I would submit that
Our training programs were reinforced constantly

by drills on the rig.
Some of them weekly, others ad hoc.
For example, this is the drill report from
In this drill, they discussed the roles and
The crew was reminded
You heard Mr. Roy talk about the Sedco 711

OFFICIAL TRANSCRIPT
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11:28AM
incident that took place in the North Sea in late 2009.
He
11:28AM
suggested, and I expect to hear argument at trial, that
11:28AM
somehow, because of that incident, and because a written
11:28AM
advisory somehow didn't get to the Deepwater Horizon because
11:28AM
somebody was on vacation, that the crew somehow was complacent
11:28AM
to the fact that barriers like cement can fail.
11:28AM
11:28AM
11:28AM
11:28AM
10
Dewey Revette, Don Vidrine.
11:28AM
11
perished on April 20 were there.
11:28AM
12
11:28AM
13
example of how training at Transocean works.
11:29AM
14
the Transocean crewmen must attend well control school, get
11:29AM
15
classroom training and receive on-the-job training that is
11:29AM
16
tailored to their specific job responsibilities.
11:29AM
17
11:29AM
18
training.
11:29AM
19
years.
11:29AM
20
most of all, by drilling.
11:29AM
21
11:29AM
22
their jobs.
11:29AM
23
looking for the right stuff on April 20.
11:29AM
24
11:29AM
25
Your Honor, that is precisely what the crew was

told on April 18, 2010, two days before the incident.
Who was present?
Jason Anderson, Stephen Curtis,
In fact, nine of the 11 men who
That drill on April 18, Your Honor, is just an

To join a crew,
Once they make it to a crew, they keep on

They go back to the well control school every two
They learn on the job by teaching others and, probably
Your Honor, these men know and knew how to do

They knew what to look for, and they weren't
They knew the fundamentals.
They were preached
into them when they took the job, and that became their trade,
OFFICIAL TRANSCRIPT
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11:29AM
and they relived them and relearned them repeatedly.
11:29AM
Now, Mr. Roy talked about some other well control
11:29AM
events and suggested that that somehow shows that Transocean as
11:29AM
a company was grossly negligent, that somehow we had -- our
11:30AM
safety culture was deficient.
11:30AM
Mr. Roy, they show nothing of the sort, Your Honor.
11:30AM
11:30AM
11:30AM
11:30AM
10
Transocean worked on almost 7,000 wells worldwide.
11:30AM
11
kicks are a part of the business, Your Honor, and our goal is
11:30AM
12
to keep the kicks under 20 barrels.
11:30AM
13
11:30AM
14
control events report, and you'll see what it tracks.
11:30AM
15
tracks how the company or how the rig crews do in detecting
11:30AM
16
kicks.
11:30AM
17
11:30AM
18
corner is that the majority of the kicks are detected within
11:31AM
19
10 barrels, the vast majority within 20, and only a small
11:31AM
20
sliver exceed 30 barrels.
11:31AM
21
The plaintiffs' efforts to use a handful, I think
11:31AM
22
Mr. Roy referred to six, of well control events to suggest that
11:31AM
23
somehow the company was grossly negligent or the crew was
11:31AM
24
grossly negligent on April 20 is unfair to the evidence, it's
11:31AM
25
unfair to the company, and it's unfair to the crew.
With respect to my friend
Transocean is justifiably proud of its record on

well control.
Kicks are part of the business.

From 2005 through 2009, that five-year period,
Our goal --
This is a report that came out in 2009, well

It
What you see clustered in the lower left-hand
OFFICIAL TRANSCRIPT
123
11:31AM
Now, when a drill crew does not meet that goal,
11:31AM
which happens, the company goes out, and it investigates it, it
11:31AM
reports on it, and it takes corrective action.
11:31AM
11:31AM
the Cunningham that Mr. Roy referred to.
11:31AM
took place nine years ago, in 2004, six years before the
11:32AM
Macondo event.
11:32AM
entirely different division of the company.
11:32AM
11:32AM
10
that Mr. Roy is able to stand up and talk about these events is
11:32AM
11
because the company doesn't sweep them under the rug.
11:32AM
12
company investigations them and creates written reports and
11:32AM
13
takes action.
11:32AM
14
11:32AM
15
11:32AM
16
11:32AM
17
toolpusher, that's the -- a letter that says his conduct --
11:32AM
18
that he was complacent, and his conduct was grossly negligent.
11:32AM
19
It was recommended that he will be terminated from the company
11:32AM
20
immediately.
11:32AM
21
In every single one of the incidents that Mr. Roy
11:32AM
22
will talk about at trial, the company investigated those events
11:33AM
23
and took action.
11:33AM
24
11:33AM
25
For an example, let's look at this 2004 event on

First of all, that
It took place off the coast of Egypt, in an
But, more fundamentally, Your Honor, the reason
The
Here is the action that took place as a result

of -- oops, I went the wrong way.
This is a letter that was written to the night
That's what a safety process system is.
Now, Mr. Roy referred an e-mail by Larry McMahan,

in which he said -- talked about train wrecks.
OFFICIAL TRANSCRIPT
You'll seal
124
11:33AM
that document.
He's talking almost entirely, by the way -- he
11:33AM
uses the phrase "loss of control," and Mr. McMahan will tell
11:33AM
you that virtually all of those are loss of control of objects,
11:33AM
things falling, heavy equipment falling.
11:33AM
or two well control events that are referred to in there.
11:33AM
11:33AM
some whistleblower who feels like he's not being heard by his
11:33AM
superiors at the company.
11:33AM
the company's most senior executive in charge of training
11:33AM
10
11:33AM
11
11:33AM
12
When he felt that people were not living up to that -- to the
11:33AM
13
high standards that the company set, he took action.
11:34AM
14
with the kind of language that Mr. Roy indicated.
11:34AM
15
Transocean, that is encouraged.
11:34AM
16
11:34AM
17
Mr. McMahan, will testify at this trial, totally supported
11:34AM
18
Mr. McMahan's effort.
11:34AM
19
Mr. Newman personally got involved in connection
11:34AM
20
with some problems you'll hear about involving a rig that they
11:34AM
21
call the Arctic I with Shell.
11:34AM
22
11:34AM
23
or four people had actually been killed, not in well control
11:34AM
24
events, but on accidents on the rigs, he commissioned a
11:34AM
25
worldwide survey of the company.
I think there are one
But the point is that these are not e-mails from
This is a document by Larry McMahan,
worldwide.
His responsibility was to point out problems.
He did it
At
Steven Newman, the company's CEO, who, like
Before that, in the Fall of 2009, because three
Because that was going to
OFFICIAL TRANSCRIPT
125
11:34AM
take a while, he actually ordered an immediate worldwide
11:34AM
shutdown of the fleet to reemphasize the basics of safety.
11:34AM
Transocean does not put profit over safety.
11:34AM
Now, Mr. Roy mentioned a March 8th kick, 2010, on
11:34AM
the Deepwater Horizon.
11:35AM
detected that kick late, and that it was criticized by
11:35AM
John Guide.
11:35AM
11:35AM
11:35AM
10
evidence will be that the kick was detected within 10 to
11:35AM
11
12 barrels.
11:35AM
12
30 barrels because the crew was investigating whether the
11:35AM
13
movement of a crane on the rig could affect the pit volumes,
11:35AM
14
which it can do.
11:35AM
15
11:35AM
16
BP well site leader at the time, what he thought about the
11:35AM
17
crew's performance on March 8th.
11:35AM
18
11:35AM
19
video clip was played.)
11:35AM
20
Q.
11:35AM
21
and the driller saw something that he had concerns about and
11:35AM
22
took the time to shut the crane down and then look to see if
11:36AM
23
there was really the crane or something else going on --
11:36AM
24
A.
"Right.
11:36AM
25
Q.
" -- did you consider his response to what he was seeing
He said that the Transocean drill crew
John Guide has said that.
His testimony on that
is contradicted by every other piece of evidence.
In fact, the
It was not shut in until slightly more than
So we asked Murray Sepulvado, again, who was the
This is what he said.
(WHEREUPON, at this point in the proceedings, a
"Because of the circumstances where the crane was in use
OFFICIAL TRANSCRIPT
126
11:36AM
appropriate?
11:36AM
A.
"Yes.
11:36AM
Q.
"Do you believe that anybody there on the rig screwed up,
11:36AM
as Mr. John Guide is quoted as having said here in this
11:36AM
interview, in terms of the March 8 kick?
11:36AM
A.
11:36AM
job myself.
11:36AM
Q.
"They being the TO folks?
11:36AM
A.
"The TO folks and Halliburton."
11:36AM
10
11:36AM
11
video clip ended.)
11:36AM
12
MR. BRIAN:
11:36AM
13
audit that took place also in 2010, and said there were some
11:36AM
14
problems.
11:36AM
15
mention it, so I didn't have it to put it up.
11:36AM
16
you a few of the findings by Lloyd's audit.
11:36AM
17
11:36AM
18
Deepwater Horizon crew members surveyed believed that line
11:36AM
19
managers listened and acted on the crew's safety concern.
11:36AM
20
11:36AM
21
Deepwater Horizon crew members surveyed felt they understand
11:37AM
22
the safety procedures and hazards associated with their jobs
11:37AM
23
because of the degree of training and support they have
11:37AM
24
received, and they found the Deepwater rig safety culture to be
11:37AM
25
robust.
"Well, I was there, and I thought they done a pretty good
(WHEREUPON, at this point in the proceedings, the
Mr. Roy also talked about this Lloyd's
Well, I actually didn't think he was going to

So I'll read to
They found that 97.6 percent of the
They believe that 100 percent of the
OFFICIAL TRANSCRIPT
127
11:37AM
So, Your Honor, if we had this great rig and this
11:37AM
well-trained crew, why did the blowout take place?
11:37AM
in the end, only two reasons for that.
11:37AM
11:37AM
11:37AM
11:37AM
cement likely would fail and that the test, the negative
11:37AM
pressure test, to determine whether the cement job was good
11:37AM
had, in fact, failed, they did not give those warnings.
11:37AM
10
11:37AM
11
that BP took with the not doing the bottoms-up circulation,
11:37AM
12
using the long string instead of a liner, using the lower
11:38AM
13
number of centralizers.
11:38AM
14
the context of a well they described as one of the wells from
11:38AM
15
hell, or a "nightmare" well.
11:38AM
16
11:38AM
17
bottom hole cement critical.
11:38AM
18
show that BP did not comply with its own requirements to make
11:38AM
19
sure they had a good cement job.
11:38AM
20
11:38AM
21
cement than I will, Your Honor, but one of the critical
11:38AM
22
variables in cement is how long it takes to set, to harden.
11:38AM
23
11:38AM
24
strength tests were performed at the wrong temperature,
11:38AM
25
contrary to BP and industry standards.
There are,
First, BP took a series of unconscionable risks

with an exceptionally difficult well.
Second, instead of warning the crew that the
Now, Mr. Underhill described some of the risks
All of these decisions were made in
The risk that they took made the integrity of the

Nevertheless, the evidence will
Others in this trial will spend more time on
The evidence here will show that compressive
Other tests showed that
OFFICIAL TRANSCRIPT
128
11:38AM
the cement would not set in 24 hours.
11:38AM
11:38AM
pouring of the cement and the time that displacement was
11:39AM
started.
11:39AM
ordered the crew to proceed with displacement within 16 hours
11:39AM
of the pouring of the cement.
11:39AM
11:39AM
Halliburton; but, one thing is absolutely clear, that by
11:39AM
April 20, BP had lost faith in the Halliburton cement team.
11:39AM
10
11:39AM
11
Jesse Gagliano, who was their interface at Halliburton.
11:39AM
12
said that Jessie isn't cutting it anymore.
11:39AM
13
for this.
11:39AM
14
11:39AM
15
they said he showed a lack of understanding of the modeling.
11:39AM
16
The lab results came in at the last minute.
11:39AM
17
11:40AM
18
job, whether it's Halliburton, BP, or both, some facts are
11:40AM
19
absolutely clear:
11:40AM
20
forward with the cement job without accurate test results;
11:40AM
21
three, they went forward without waiting for the test to
11:40AM
22
harden.
11:40AM
23
11:40AM
24
11:40AM
25
Despite that, BP shortened the time between the
Rather than waiting, let's say, 24 to 48 hours, they
Now, I expect that BP's lawyer will blame this on
They referred in these documents to

They
There is no excuse
Jesse still waited until the last minute.

In another document, in their handwritten notes,
They had to QC.
Whoever is to blame, Your Honor, for the cement
One, the cement job failed; two, they went
To make matters worse, they decided not to do a

cement bond log.
Why?
Because it would cost more money.
The men who made these decisions had days to

OFFICIAL TRANSCRIPT
129
11:40AM
think about what they were doing.
This is very different from
11:40AM
the Transocean rig crew whose conduct over the course of
11:40AM
minutes is at issue in this case.
11:40AM
11:40AM
the number of centralizers, even though they'd received a
11:40AM
report from Halliburton on April 18 warning them of a severe
11:40AM
gas flow problem if they didn't use the number of centralizers
11:41AM
that BP wanted.
11:41AM
admitted that he had a conversation with Mr. Gagliano on April
11:41AM
10
19, in which Mr. Gagliano told him about this document, and yet
11:41AM
11
they did nothing.
11:41AM
12
11:41AM
13
in the case, Brett Cocales' e-mail where he says, who cares,
11:41AM
14
it's done, end of story, it will probably be fine.
11:41AM
15
11:41AM
16
I think the second, the next sentence, Your Honor, is in some
11:41AM
17
ways more telling.
11:41AM
18
stuck above the wellhead."
11:41AM
19
What he's saying is, I would rather take the risk
11:41AM
20
of getting it wrong and then having just to fix it, than taking
11:41AM
21
the additional time to get it right in the first place.
11:41AM
22
11:42AM
23
whatever you think of its merit, that risky approach that BP
11:42AM
24
took, if you're going to take those risks, you have to tell the
11:42AM
25
people sitting on top of the well, the guys who are going to
You've already heard about BP flip-flopping on
The head of BP's onshore team, Greg Walz,
That takes us to one of the most famous e-mails
There is an lot of arrogance in that e-mail; but,
"I would rather have to squeeze than get
That attitude has been widely condemned; but,
OFFICIAL TRANSCRIPT
130
11:42AM
have to deal with it in the event of a failure.
11:42AM
11:42AM
this is a risky business, and since the drill crew knew that
11:42AM
cement can fail, there is no need to tell them about the
11:42AM
extraordinary risks they were taking.
11:42AM
11:42AM
this, Your Honor.
11:42AM
report says, and I quote, BP's onshore well team refused to
11:42AM
communicate key risks of the operation to Transocean.
11:42AM
10
11:42AM
11
Transocean were grossly negligent on a negative pressure test.
11:43AM
12
Your Honor, I just would point out, you certainly can't prove
11:43AM
13
that from our guilty plea because in our guilty plea, while
11:43AM
14
we've admitted ordinary negligence, we have not admitted gross
11:43AM
15
negligence.
11:43AM
16
11:43AM
17
from the beginning to end, and they botched it up.
11:43AM
18
botched it in the planning, in the design, in interrupting the
11:43AM
19
crew, and interpreting its results.
11:43AM
20
11:43AM
21
BP changed its mind five or six times about how to do a
11:43AM
22
negative pressure test, how many to do, when to do them.
11:43AM
23
First, they were going to do one.
11:43AM
24
two.
11:43AM
25
BP's view at the time seemed to be that since
Now, this is not -- I'm not the only one saying

The PSC's expert, Professor Bea, in his
The PSC now stands up and says that both BP and
There is nothing in there that establishes.

The truth is that BP was responsible for the test
They
In the weeks leading up to April 20, Your Honor,
Then they were going to do
Then they were going to do one.

By the way, in the middle, and you'll see that
OFFICIAL TRANSCRIPT
131
11:43AM
the yellow says -- the one that's below says, monitor for
11:43AM
30 minutes.
11:44AM
to do two tests; but, in fact, their own documents make clear
11:44AM
that that was in reference to a second negative pressure test,
11:44AM
because this an e-mail from Brian Morel, April 18, where he
11:44AM
says, the plan is to do a negative test with base oil on the
11:44AM
bottom plug.
11:44AM
will be done.
11:44AM
11:44AM
10
monkeyed with the test.
11:44AM
11
unused lost circulation materials on the rig.
11:44AM
12
they were going to have to ship that back to shore and dispose
11:44AM
13
of it as hazardous waste.
11:44AM
14
11:44AM
15
money.
11:44AM
16
pumped it through the BOP in the system, they could refer to it
11:44AM
17
as circulation material, call it spacer, and then they could
11:44AM
18
just dump it overboard into the Gulf of Mexico.
11:45AM
19
11:45AM
20
the formation.
11:45AM
21
displace a well.
11:45AM
22
11:45AM
23
effect of that was, and there's all these theories about
11:45AM
24
whether it clogged the kill line and stopped the flow; but, at
11:45AM
25
a minimum, it confused the negative pressure test.
I suspect BP might argue that they never planned
Then we will displace, and a second negative test
In addition to all this confusion, they then

You see, they had 400 barrels of
Under the law,
They didn't want to do that because it would cost

So somebody at BP had this bright idea that if they
Well, this stuff had been used to patch cracks in

As far as we know, it had never been used to
You know, people have been studying what the
OFFICIAL TRANSCRIPT
132
11:45AM
All of these last minute changes by the
11:45AM
engineering people at BP had the operations people at wits end.
11:45AM
This is the e-mail you saw earlier from John Guide, where he
11:45AM
says there is so many last minute changes that they had finally
11:45AM
come to their wits end.
11:45AM
our pants."
11:45AM
operation is not going to succeed.
11:45AM
11:45AM
David Sims do about it?
Nothing.
11:45AM
10
didn't call a time-out.
He didn't say, let's talk about it.
11:45AM
11
Instead, he sent back this e-mail in which he said, if we had
11:45AM
12
more time to plan this casing job, I think all of this would
11:46AM
13
have been worked out before it got to the rig.
11:46AM
14
They actually considered an alternative, plug the
11:46AM
15
well and abandon it, but that would have cost over $10 million.
11:46AM
16
11:46AM
17
11:46AM
18
11:46AM
19
drill pipe, as was their practice when Murray Sepulvado had
11:46AM
20
been the well site leader, and they detected the abnormal
11:46AM
21
pressure on the drill pipe.
11:46AM
22
11:46AM
23
analyzing what that pressure meant when there was a change in
11:46AM
24
shifts of the two well site leaders at BP.
11:46AM
25
replaced Bob Kaluza.
The quote is, "flying by the seat of
Then he made his prophetic prediction, the
He sent that to his boss, David Sims.
What did
He didn't do anything.
He
Your Honor, they had the time, they just didn't

want to spend the money.
The crew set up the negative pressure test on the
They were in the middle of investigating and
OFFICIAL TRANSCRIPT
Don Vidrine
133
11:46AM
Don Vidrine insisted that they start the test
11:46AM
over and do it down the kill line because that's what their
11:47AM
permit had said, and instructed the crew to do it down the kill
11:47AM
line and to check for flow.
11:47AM
11:47AM
11:47AM
11:47AM
test monitored on the kill line, as reflected in a document he
11:47AM
and Mr. Kaluza signed shortly after the incident.
11:47AM
10
11:47AM
11
simple, that it's like two straws going down a glass.
11:47AM
12
see a different pressure, automatically it's a failure.
11:47AM
13
11:47AM
14
one killed the kill line, went down 5,000 feet, the drill pipe
11:47AM
15
went down 3,000 more feet, and they are in different fluids
11:47AM
16
with different pressures.
11:47AM
17
11:47AM
18
the kill line and the drill pipe.
11:47AM
19
have that different pressure?
11:48AM
20
what the -- the crew didn't miss the fact that they had
11:48AM
21
different pressure.
11:48AM
22
Mr. Vidrine told them to look for flow on the kill line, and
11:48AM
23
that was the mistake the crew made.
11:48AM
24
listened to that instruction.
11:48AM
25
The crew followed that instruction, and they

watched it for 30 minutes.
There was no flow.
Mr. Vidrine declared it a successful negative
Now, some people have said, well, this is very

If you
It's not so simple because the two straws here,
So it's not unusual to have different pressure on

The question is why do you
That's the issue.
And that's
They were trying to analyze that, but
They should not have
After Vidrine finished his call at 8:52 p.m. with

OFFICIAL TRANSCRIPT
134
11:48AM
Mr. Hafle and came to the drill pipe -- to the drill shack,
11:48AM
there were subtle signs that, with hindsight, experts now say
11:48AM
indicated a kick around 9 o'clock, slightly after 9 o'clock.
11:48AM
11:48AM
the screens that were available to Transocean, BP and
11:48AM
Halliburton; but, one thing we know for sure is that those
11:48AM
subtle signs of a kick were missed by a number of people
11:48AM
between around 9:08 and 9:14, 9:15.
11:49AM
11:49AM
10
11:49AM
11
who did take a break, a 10-minute break that Mr. Roy indicated,
11:49AM
12
and then came back to the drill shack and checked the screen
11:49AM
13
and didn't notice that.
11:49AM
14
11:49AM
15
drill floor during this time period to look at a sheen test and
11:49AM
16
check the screens.
11:49AM
17
11:49AM
18
who said in his interview that he had the screens up during his
11:49AM
19
conversation with Mr. Hafle between 8:52 and about 9 o'clock.
11:49AM
20
11:49AM
21
11:49AM
22
11:49AM
23
what they were thinking and exactly why they did what they did
11:49AM
24
because they are not here to tell us.
11:49AM
25
Your Honor, the Sperry-Sun data.
No one knows exactly how those signs appeared on
They were missed by the driller at Transocean.

They were missed by the mudlogger, Joseph Keith,
They were missed by Don Vidrine, who visited the
They were missed by Mark Hafle, who testified --
After Mr. Vidrine left the drill shack between

9:15, the crew then monitored the well.
As I said earlier, we will never know exactly
But we do have the data,
OFFICIAL TRANSCRIPT
135
11:50AM
The right four-fifths of that is the actual
11:50AM
actually Sperry-Sun data.
11:50AM
make it easier.
11:50AM
11:50AM
they are watching between 9:14 and 9:49.
11:50AM
the crew was far from being complacent.
11:50AM
11:50AM
noticed that, and they shut down three pumps to investigate.
11:50AM
They determined the problem was a popped pressure valve, so
11:50AM
10
11:50AM
11
11:50AM
12
11:50AM
13
11:50AM
14
before 9:30, they see that the kill line and the drill pipe are
11:50AM
15
acting different, that the kill line goes up and then starts to
11:50AM
16
go down, and the drill pipe is doing something different.
11:50AM
17
11:51AM
18
11:51AM
19
11:51AM
20
actually released the pressure on the drill pipe.
11:51AM
21
it dip down as a result of that.
11:51AM
22
monitoring what was going on.
11:51AM
23
Then right around 9:40, before, about 9:39, you
11:51AM
24
see the pressure on the drill pipe goes up, and then it turns
11:51AM
25
back down.
We changed the column on the left to
This is what shows you what's happening, what

What you see is that
At about 9:18, you see that blue spike.
The crew
they turned the pumps back on and the pressure rose.

The drill pipe is the red at the bottom, and the
kill line is the blue, Your Honor.
They continued to monitor.
Then, about shortly
So they shut off the pumps again.
You see that
at the top, when it goes down to the bottom.

They continued to monitor.
At about 9:36, they

You can see
That's because they were
That's an indication of a kick.

OFFICIAL TRANSCRIPT
136
11:51AM
The crew noticed that, and they did a flow check.
11:51AM
They saw that the well was flowing, so they closed the annular.
11:51AM
The flow was too strong, so closing the annular did not seal
11:51AM
the well.
11:51AM
11:51AM
11:51AM
Now, consistent with BP and Transocean policy at
11:51AM
that time, the diverter system was set by default to divert to
11:51AM
the mud-gas separator.
11:52AM
10
You don't want to just automatically divert hazardous stuff
11:52AM
11
into the sea.
11:52AM
12
11:52AM
13
separator became overwhelmed.
11:52AM
14
this case, we don't know exactly when, but there will be
11:52AM
15
evidence in this case that the crude did, in fact, then begin
11:52AM
16
to divert overboard; but, of course, by then, it was too late.
11:52AM
17
11:52AM
18
bore ram.
11:52AM
19
the force was just too great.
11:52AM
20
11:52AM
21
issue is were they consciously indifferent, were they grossly
11:52AM
22
negligent, this crew was attentive in taking responsive actions
11:52AM
23
at every step of the way in response to the indications that
11:52AM
24
they saw.
11:52AM
25
As they were trained to do, they diverted the

flow into the diverter system.
The reason for that is environmental.
Ultimately, as Mr. Roy indicated, the mud-gas

There is going to be evidence in
At about 9:46 or 9:47, they closed the variable

For a moment, the well was successfully shut in, but
My point, Your Honor, is in a case where the
In addition to activating the BOP, closing the

OFFICIAL TRANSCRIPT
137
11:52AM
annular, activating the variable bore rams, the crew did their
11:53AM
duty to alert others.
11:53AM
Mr. Vidrine, and they called the senior toolpusher, Randy
11:53AM
Ezell.
11:53AM
11:53AM
conversation with Steve Curtis:
11:53AM
in.
11:53AM
my God, and I asked did they have it shut in.
11:53AM
that Jason -- that's Jason Anderson -- was shutting it in.
11:53AM
10
said, Jason is shutting it in now.
11:53AM
11
that, we can't see out of our windows.
11:53AM
12
help.
11:53AM
13
11:53AM
14
and to help them, but he was blown back by the tremendous
11:53AM
15
explosion that then happened.
11:53AM
16
11:53AM
17
happened because BP was behind schedule and was rushing to get
11:53AM
18
this well done.
11:53AM
19
11:54AM
20
going to hear evidence in the trial, of accusations that the
11:54AM
21
crew did not act quickly or decisively enough.
11:54AM
22
Your Honor, that that's unfair.
11:54AM
23
attentive, but they were missing critical information.
11:54AM
24
11:54AM
25
They called the bridge, they called
This is Randy Ezell's testimony about his

Steve said the well is coming
We got mud blowing to the crown.
I remember thinking, oh,

Curtis told me
He
Then he made the remark

Randy, we need your
Ezell ran to put on his coveralls and his boots
None of this had to happen, Your Honor.
It
Some people have accused Transocean, and you're
I would submit,
They took action, they were
They should have been told that there was a

severe gas flow potential.
They should have been told that
OFFICIAL TRANSCRIPT
138
11:54AM
there was a grave risk that the cement may not have hardened by
11:54AM
then.
11:54AM
stable.
11:54AM
between Mr. Vidrine and Mr. Hafle at 8:52 p.m.
11:54AM
BP has tried to shift the blame by focusing now
11:54AM
on the BOP and claiming that -- by distorting facts about the
11:54AM
BOP and by distorting what happened on the rig that night.
11:54AM
PSC has sort of jumped on that bandwagon.
11:54AM
the few minutes I have left about the BOP and what happened on
11:54AM
10
11:54AM
11
11:55AM
12
details about the BOP.
I am not going to go through those
11:55AM
13
technical details now.
They are going to be presented by the
11:55AM
14
experts.
11:55AM
15
the forensic evidence found by DNV.
11:55AM
16
11:55AM
17
preventer.
11:55AM
18
just simply a copy of that, was because I'm going to show you
11:55AM
19
that the things function, and I realize that it's helpful to
11:55AM
20
have that up and in place.
11:55AM
21
11:55AM
22
it was closed by the crew that evening.
11:55AM
23
annular that you see on the chart over there that, in fact, did
11:55AM
24
close.
11:55AM
25
They should have been told that the cement might not be
They should have been told about the conversation
The
So let me talk for
the bridge crew.

The Court is going to hear a lot of technical
Most of them are, we think, undisputed and based on
Your Honor, that's the graphic of the blowout

The reason I prepared the board over here, which is
The evidence shows that annular functioned when

This is the upper
The variable bore rams also functioned.

OFFICIAL TRANSCRIPT
139
11:55AM
But two minutes later, at about 9:47, there was
11:55AM
the powerful explosion, and that caused the rig to lose power
11:56AM
and to drift off station with pulled pipe.
11:56AM
11:56AM
blind shear rams had functioned.
11:56AM
we'll talk about it at the trial, as to when.
11:56AM
functioned as they should have functioned; but, unfortunately,
11:56AM
the extreme flow up the well had moved the pipe off center.
11:56AM
DNV found, because it moved off center, when it cut it was not
11:56AM
10
11:56AM
11
You see where the pipe is off center.
11:56AM
12
what caused it not to stop the blowout, Your Honor.
11:56AM
13
11:56AM
14
that it, in fact, functioned.
11:56AM
15
nothing to do with maintenance.
11:56AM
16
hear about batteries, it's all a red herring.
11:56AM
17
BOP functioned.
11:56AM
18
11:57AM
19
maintenance system the company used.
11:57AM
20
maintenance is used by the United States Department of Defense,
11:57AM
21
the Coast Guard, and the aircraft industry.
11:57AM
22
running your tires on your car until the treads are bare and
11:57AM
23
your tire blows out.
11:57AM
24
fixing them before they fix [verbatim].
11:57AM
25
After the explosion, it was determined that the

There is some dispute, and
We believe they
As
able to actually stop the flow of the well.

That's
The fact is that the men operated the BOP and

The piping off the side had
The evidence you're going to
The fact is the
Mr. Roy had mentioned the condition based

Well, condition based
It doesn't mean
It means keeping track of things and
The Court will hear evidence that the BOP

OFFICIAL TRANSCRIPT
140
11:57AM
received extensive and regular maintenance, including hundreds
11:57AM
of hours in January and February of 2010, before it was put
11:57AM
back in operation on the Macondo.
11:57AM
11:57AM
and maintained.
11:57AM
shear rams were tested on the morning of April 20, 2010, the
11:57AM
very day of the incident.
11:57AM
test, and they functioned during the incident.
11:57AM
11:58AM
10
happened on the bridge crew because there has been an argument
11:58AM
11
raised that somehow the crew and the captain panicked and that
11:58AM
12
they failed to disconnect immediately from the well.
11:58AM
13
11:58AM
14
of the men and the heroic actions of the men and women on the
11:58AM
15
crew that night.
11:58AM
16
Some people seem to think that the EDS button is
11:58AM
17
some sort of ejector button like you see on an Air Force F-16.
11:58AM
18
It's not.
11:58AM
19
used after you communicate with the drill crew.
11:58AM
20
11:58AM
21
the well, and they have to take actions.
11:58AM
22
before you're supposed to or without checking with them, or
11:58AM
23
when it cuts the joints and it can't cut through the joints,
11:58AM
24
you may have a rig drifting out in the Gulf of Mexico with a
11:58AM
25
wide open wellbore.
All of the major components had been inspected

The BOP was tested constantly.
The blind
They functioned then during the
So let me talk for the last few minutes on what
Your Honor, that argument disrespects the memory
It's a piece of equipment that's only designed to be
Why?
Because the drill crew is trying to control
OFFICIAL TRANSCRIPT
If you just EDS
141
11:59AM
Panicking and pushing the EDS button is not what
11:59AM
is recommended.
11:59AM
button on an F-16 before you realize that you're upside down a
11:59AM
hundred feet above ground.
11:59AM
11:59AM
there was confusion because of the dual command, is not
11:59AM
accurate.
11:59AM
Captain Kuchta was in charge.
11:59AM
members knew it.
11:59AM
10
11:59AM
11
questions of some people before deciding to EDS.
11:59AM
12
entirely appropriate in an emergency.
11:59AM
13
Captain Kuchta, and he adhered to the right procedures on the
11:59AM
14
bridge crew -- on the bridge that night, Your Honor.
11:59AM
15
12:00PM
16
well trained and that they acted properly in response to this
12:00PM
17
disaster is that every single man and woman who could have
12:00PM
18
survived did.
12:00PM
19
explosion, burning oil, the men and women on that rig sprung
12:00PM
20
into action.
12:00PM
21
12:00PM
22
literally death-defying acts of heroism.
12:00PM
23
walking, climbing, crawling on the rig to save their shipmates.
12:00PM
24
In the end, every single crew member who was not killed in the
12:00PM
25
initial explosion survived.
It's almost like if you hit the ejector seat
You have to think before you do it.
The next claim that Mr. Roy made, that somehow
Everybody knew that in case of an emergency,

He knew it, and the other crew
It was totally proper for Captain Kuchta to ask

That was
There was no panic in
Perhaps the clearest indication that the crew was
In the midst of a literal apocalypse of fire,
You will hear testimony at this trial about
OFFICIAL TRANSCRIPT
Men and women
142
12:00PM
12:01PM
deposition, Your Honor, when he was asked, "What is your
12:01PM
opinion on the performance of the Transocean crew on April 20?"
12:01PM
Answer, "I think they were heroic."
12:01PM
I think so too, Your Honor.
12:01PM
12:01PM
12:01PM
take a lunch recess before we continue with the remainder of
12:01PM
the statements.
12:01PM
10
opening statements, I calculate.
12:01PM
11
Recess until then.
12:01PM
12
THE DEPUTY CLERK:
12:01PM
13
(WHEREUPON, at 12:01 p.m. the Court was in luncheon
14
15
I think Professor Bea may have put it best at his
THE COURT:
Okay.
All right.
Thank you.
Thank you.
It's noontime.
We're going to now
I think we have about three hours left of

So let's come back at 1:30.
All rise.
recess.)
*
16
17
18
19
20
21
22
23
24
25
OFFICIAL TRANSCRIPT
143
REPORTER'S CERTIFICATE
2
3
I, Cathy Pepper, Certified Realtime Reporter, Registered
Merit Reporter, Certified Court Reporter of the State of
Louisiana, Official Court Reporter for the United States
District Court, Eastern District of Louisiana, do hereby
certify that the foregoing is a true and correct transcript to
the best of my ability and understanding from the record of the
proceedings in the above-entitled and numbered matter.
10
11
12
s/Cathy Pepper
13
Cathy Pepper, CRR, RMR, CCR

Certified Realtime Reporter
Registered Merit Reporter
Official Court Reporter
United States District Court
[email protected]
14
15
16
17
18
19
20
21
22
23
24
25
OFFICIAL TRANSCRIPT
_____
$
$10 [3] - 62:2, 93:11,
132:23
$100,000 [1] - 55:3
$139,000 [1] - 55:3
$50 [2] - 59:2, 109:2
'
'09 [1] - 29:17
'we [1] - 60:8
1
1 [5] - 1:19, 26:8,
47:17, 82:14, 109:11
1,300 [2] - 87:12,
87:14
1,300-pound [1] 87:16
1,400 [4] - 92:17,
93:18, 94:2, 96:12
1,720,000 [1] - 110:1
1,800 [1] - 87:16
1.4 [1] - 64:23
10 [9] - 21:2, 21:3,
67:1, 72:2, 78:10,
117:4, 122:23,
125:17
10-2179 [1] - 10:13
10-2771 [2] - 10:15,
17:15
10-4536 [2] - 10:17,
17:18
10-MD-2179 [1] - 1:8
10-minute [1] - 134:20
100 [3] - 3:4, 9:7,
127:2
1000 [2] - 7:4, 8:5
1001 [1] - 6:20
101 [1] - 3:8
103 [1] - 9:8
10W90 [1] - 110:8
11 [5] - 94:20, 99:25,
102:14, 105:9,
121:14
1100 [1] - 6:16
111 [1] - 9:9
1110 [1] - 7:8
12 [2] - 62:12, 125:18
1201 [2] - 6:4, 7:21
1221 [1] - 7:14
12:01 [1] - 142:22
13,000 [2] - 59:11,
88:14
1308 [1] - 3:11
1331 [1] - 7:24

142 [1] - 9:10
14271 [1] - 4:18
15 [2] - 67:2, 69:6
15-minute [1] - 71:11
16 [2] - 57:15, 128:12
1601 [1] - 2:11
1665 [1] - 7:24
17 [3] - 32:18, 75:22,
76:4
1700 [1] - 7:21
18 [7] - 15:8, 90:18,
120:23, 121:12,
121:16, 129:13,
131:12
18,000 [2] - 59:12,
88:13
1851 [1] - 18:2
1885 [1] - 5:11
19 [1] - 129:17
190 [1] - 82:15
1990 [1] - 17:20
1:30 [1] - 142:19
2
2,000 [1] - 89:3
2.1 [1] - 109:22
20 [35] - 1:6, 10:15,
16:4, 21:1, 26:25,
27:12, 27:14, 27:25,
28:14, 45:15, 51:2,
52:19, 56:19, 57:21,
64:24, 74:7, 74:19,
75:14, 78:10, 78:11,
111:15, 113:23,
116:18, 117:5,
118:25, 119:10,
121:15, 122:2,
122:16, 122:23,
123:3, 128:16,
131:2, 140:15,
142:12
20004 [1] - 6:5
2001 [3] - 42:6, 48:13,
66:15
2002 [2] - 39:23, 66:15
2004 [4] - 28:21, 48:1,
123:9, 123:11
20044 [3] - 4:13, 4:19,
4:24
2005 [4] - 48:4, 66:16,
89:21, 122:13
2006 [1] - 66:25
2007 [2] - 48:24, 64:17
2008 [9] - 29:1, 29:15,
31:23, 45:20, 64:22,
65:4, 65:5, 68:7,
89:21
2009 [36] - 29:15, 30:8,

30:14, 31:19, 31:21,
31:24, 32:10, 39:24,
42:9, 45:4, 46:8,
46:23, 47:8, 47:17,
47:24, 48:1, 48:8,
54:9, 56:6, 57:7,
57:10, 57:15, 57:21,
64:22, 65:4, 65:14,
68:4, 68:22, 89:22,
106:23, 118:12,
118:18, 121:5,
122:13, 122:17,
125:4
2010 [37] - 1:6, 10:15,
16:4, 17:10, 26:25,
27:25, 28:15, 31:8,
31:17, 32:16, 32:19,
33:4, 37:22, 40:4,
42:9, 45:20, 52:20,
56:13, 56:19, 57:21,
58:12, 58:25, 64:14,
64:23, 65:16, 68:16,
70:15, 75:22,
111:15, 113:23,
119:10, 120:23,
121:12, 125:11,
126:20, 140:11,
140:15
2011 [2] - 109:20,
109:24
2012 [5] - 109:10,
109:12, 109:23,
109:25, 110:1
2013 [5] - 1:9, 10:2,
15:8, 23:23, 109:11
20th [8] - 30:7, 32:16,
32:19, 37:22, 40:4,
70:15, 90:14, 100:13
21 [2] - 46:23, 62:6
212 [1] - 105:2
2179 [1] - 24:3
21st [1] - 110:1
22 [4] - 16:12, 61:11,
61:15, 72:7
2211 [1] - 7:8
2216 [1] - 3:22
22ND [1] - 2:19
22nd [1] - 23:23
23 [1] - 117:8
23451 [1] - 2:19
24 [3] - 52:7, 128:8,
128:11
25 [3] - 1:9, 10:2,
107:14
250 [1] - 65:14
250.401 [2] - 88:19,
108:19
252 [1] - 16:7
26 [1] - 9:5
2615 [1] - 2:15

26th [1] - 33:4
27th [1] - 61:12
28 [1] - 109:9
290 [1] - 65:10
29th [1] - 61:10
2:10-CV-02771 [1] 1:11
2:10-CV-4536 [1] 1:14
3
3 [1] - 3:4
3,000 [2] - 62:16,
133:23
3,140 [1] - 87:25
3,142 [1] - 87:15
3,545 [2] - 68:6,
106:24
30 [8] - 88:19, 105:1,
108:19, 113:9,
122:24, 125:19,
131:9, 133:14
30-minute [2] - 57:2,
72:1
300 [1] - 6:9
3000 [1] - 54:13
30=second [1] - 75:2
311 [1] - 17:21
32 [1] - 87:14
33 [1] - 56:14
335 [1] - 6:24
35 [1] - 31:10
350 [1] - 65:14
35000 [1] - 118:12
35TH [1] - 6:24
36130 [1] - 5:6
36604 [1] - 2:12
3668 [1] - 2:4
370 [1] - 21:4
3700 [2] - 6:16, 6:20
390 [2] - 68:5, 106:23
4
4 [3] - 3:4, 58:17,
64:23
40 [3] - 31:11, 87:14,
88:23
40-barrel [1] - 89:4
400 [1] - 131:17
4000 [1] - 8:5
402 [1] - 2:19
4310 [1] - 3:18
435 [1] - 3:8
45 [1] - 20:25
450 [1] - 4:5
OFFICIAL TRANSCRIPT
4500 [1] - 7:14

47 [3] - 74:22, 98:20
48 [2] - 104:20, 128:11
5
5 [1] - 58:18
5,000 [2] - 88:15,
133:22
50 [5] - 16:8, 27:15,
78:5, 89:3, 93:12
500 [3] - 2:4, 5:5, 8:9
5000 [4] - 5:22, 42:25,
50:18, 59:10
504 [1] - 8:10
5395 [1] - 4:6
556 [1] - 2:4
560 [1] - 93:23
569 [1] - 82:15
58 [1] - 110:2
589-7779 [1] - 8:10
6
60 [3] - 21:1, 21:2,
109:13
600 [3] - 2:19, 2:22,
7:4
601 [1] - 2:15
60654 [1] - 6:9
618 [1] - 3:15
660 [1] - 109:8
668,000 [1] - 60:20
6:00 [2] - 14:4, 116:18
7
7 [2] - 58:16, 58:17
7,000 [1] - 122:14
700 [1] - 27:14
701 [2] - 5:16, 5:22
70113 [1] - 2:8
70130 [5] - 2:16, 2:23,
3:22, 5:16, 8:10
70139 [1] - 5:23
70163 [1] - 6:16
70360 [1] - 3:8
70458 [1] - 3:12
70502 [2] - 2:5, 7:5
70801 [1] - 3:15
70804 [1] - 5:12
71 [1] - 9:6
711 [2] - 30:15, 121:4
75 [1] - 20:23
75270 [1] - 7:21
7611 [1] - 4:12
769 [1] - 82:18
77002 [2] - 6:20, 8:5

77006 [1] - 3:19
77010 [2] - 7:15, 7:25
77098 [1] - 7:8
78257 [1] - 3:5
7th [1] - 109:25
7TH [1] - 4:6
8
8 [2] - 56:13, 126:12
820 [1] - 2:8
8291 [1] - 15:8
84,000 [1] - 89:3
8:00 [3] - 14:3, 90:14,
96:17
8:52 [9] - 74:6, 94:15,
94:22, 111:15,
111:25, 115:7,
134:8, 135:3, 138:13
8th [5] - 31:8, 60:5,
68:16, 125:11,
125:24
9
9 [5] - 45:20, 109:23,
134:11, 135:3
90 [1] - 21:2
90071 [1] - 6:25
93 [2] - 65:10, 109:11
94005 [1] - 5:12
94102 [1] - 4:6
97.6 [1] - 126:24
9:02 [3] - 74:21, 98:9,
98:19
9:08 [1] - 134:17
9:14 [2] - 134:17,
135:14
9:15 [2] - 134:17,
135:5
9:18 [1] - 135:16
9:30 [1] - 135:23
9:36 [1] - 136:3
9:38 [1] - 98:12
9:39 [1] - 136:7
9:40 [1] - 136:7
9:45 [1] - 71:14
9:46 [1] - 137:1
9:47 [2] - 137:1,
139:10
9:49 [1] - 135:14
9TH [1] - 2:22
9th [1] - 33:4
A
a.m [2] - 14:3, 71:14
abandon [3] - 16:6,

61:21, 132:22
abandoned [1] - 57:5
abandoning [1] 85:18
abandonment [3] 27:1, 60:22, 85:23
abdication [1] - 81:13
ability [2] - 63:4, 143:8
able [7] - 15:14, 15:15,
41:15, 50:1, 54:23,
123:15, 139:19
abnormal [1] - 133:3
abnormalities [1] 113:10
aboard [7] - 30:15,
31:2, 32:25, 74:8,
77:10, 87:19, 100:12
above-entitled [1] 143:9
ABRAMSON [1] - 2:14
absolutely [6] - 68:25,
93:6, 94:20, 95:24,
128:15, 129:1
accepted [1] - 108:3
access [3] - 15:7,
23:22, 33:23
accident [12] - 63:15,
83:9, 83:15, 84:19,
85:9, 88:9, 89:10,
90:5, 98:7, 98:24,
119:14, 120:10
accidents [4] - 63:14,
66:21, 120:13, 125:6
accommodate [1] 26:6
accommodation [1] 23:9
accordance [1] 108:2
according [9] - 27:25,
58:24, 65:21, 65:23,
78:5, 83:15, 83:19,
83:20, 95:2
accordingly [1] 110:22
accountable [1] 106:18
accumulation [2] 84:25, 85:3
accurate [3] - 16:1,
129:2, 141:16
accusations [1] 138:4
accused [1] - 138:3
achieve [1] - 67:10
acknowledged [2] 64:17, 86:13
acoustic [1] - 43:12
acronyms [3] - 24:11,
24:14, 24:16
Act [9] - 17:17, 17:20,
17:21, 18:1, 19:16,
19:20, 84:14, 84:21,
85:8
act [6] - 30:6, 40:6,
45:15, 75:6, 107:4,
138:5
Act's [1] - 84:24
acted [7] - 19:19,
19:23, 35:7, 102:19,
105:12, 127:1,
141:25
acting [1] - 135:24
action [22] - 16:22,
17:16, 17:19, 19:10,
19:15, 19:16, 19:17,
39:9, 39:23, 74:23,
75:6, 88:24, 94:6,
97:7, 123:8, 123:18,
123:19, 124:3,
124:20, 138:6, 142:4
Action [2] - 10:15,
10:17
ACTION [1] - 1:8
actions [10] - 63:6,
80:16, 81:9, 95:14,
97:15, 98:23,
100:12, 137:6,
140:23, 141:5
activate [5] - 37:1,
37:18, 37:20, 38:8,
38:19
activated [3] - 38:11,
38:22, 39:5
activating [3] - 34:18,
137:9, 137:10
activation [6] - 34:23,
35:12, 37:5, 37:6,
40:14, 43:13
acts [5] - 18:22, 18:25,
84:25, 85:3, 142:6
actual [3] - 55:13,
68:11, 135:10
ad [1] - 120:21
add [2] - 30:23, 43:12
addition [7] - 22:1,
24:23, 24:24, 37:23,
69:7, 131:16, 137:9
additional [3] - 53:24,
56:18, 130:3
additive [1] - 54:13
address [5] - 13:21,
19:25, 39:25,
101:12, 111:1
addressed [1] - 29:19
adequacy [1] - 46:13
adequate [5] - 27:21,
30:4, 36:16, 39:3,
46:12
adequately [10] 28:17, 29:19, 29:20,

29:22, 30:2, 32:23,
34:13, 35:15, 41:4,
56:4
adhered [1] - 141:22
adherents [1] - 29:11
administer [1] - 65:13
admiralty [1] - 14:6
admired [1] - 116:22
admit [3] - 54:17,
55:11, 55:25
admits [2] - 93:8,
94:24
admitted [10] - 22:25,
23:1, 89:1, 92:8,
105:22, 114:6,
115:19, 129:16,
130:21
admonition [1] - 49:13
advance [1] - 21:22
adversely [1] - 105:4
advised [1] - 66:15
advisory [1] - 121:8
affect [1] - 125:20
affected [2] - 52:25,
105:4
affects [1] - 47:20
affirms [1] - 101:17
afire [1] - 94:7
afraid [1] - 87:20
afternoon [1] - 22:7
aged [1] - 54:9
agencies [1] - 118:15
agent [2] - 54:18,
107:21
ago [2] - 74:9, 123:11
agree [2] - 71:24,
102:18
agreed [2] - 32:21,
118:20
agrees [1] - 40:12
ahead [3] - 60:14,
70:1, 89:25
Air [2] - 54:13, 141:1
air [1] - 37:11
aircraft [1] - 140:5
al [2] - 10:16, 10:18
AL [4] - 1:13, 1:15,
2:12, 5:6
Alabama [10] - 11:16,
11:23, 16:20, 20:25,
100:24, 101:3,
101:6, 101:9,
101:17, 102:24
ALABAMA [2] - 5:3
Alabama's [1] 101:15
Alan [2] - 12:15, 13:6
alarm [7] - 36:21,
OFFICIAL TRANSCRIPT
37:2, 37:5, 37:17,

37:18, 38:3, 79:7
alarms [8] - 28:25,
35:13, 37:13, 37:15,
37:16, 38:6, 40:7,
40:14
alert [2] - 86:19,
137:11
ALEX [1] - 7:13
align [1] - 101:15
alive [1] - 113:6
all-critical [1] - 96:16
ALLAN [1] - 5:15
Allan [1] - 11:22
allegations [1] - 99:24
Allen [2] - 60:9, 79:21
allocated [1] - 20:19
allocation [1] - 20:1
allow [3] - 25:5, 35:3,
38:19
allowed [7] - 14:18,
31:14, 37:11, 40:12,
84:10, 94:6, 106:1
allowing [2] - 62:4,
62:9
almost [8] - 94:22,
107:2, 117:4,
117:10, 117:12,
122:14, 124:7,
141:11
alone [5] - 46:17,
73:25, 75:6, 85:5,
113:5
alongside [1] - 114:12
alternative [1] 132:21
alternatively [1] - 18:4
altogether [1] - 34:25
amazingly [4] - 28:9,
34:4, 35:2, 37:24
Amendment [2] 74:12, 87:24
America [3] - 10:17,
11:19, 16:19
AMERICA [3] - 1:14,
4:4, 5:20
AMERICAN [1] - 2:15
American [1] - 55:21
amount [10] - 20:12,
44:22, 44:23, 55:1,
58:15, 80:8, 82:5,
82:7, 82:9, 106:1
amounting [1] - 80:16
amounts [4] - 35:24,
36:1, 36:6, 87:9
Anadarko [3] - 107:11,
107:13, 107:15
analysis [2] - 57:8,
58:4
analyze [1] - 134:4
analyzing [1] - 133:6

AND [2] - 1:12, 6:13
Anderson [7] - 99:20,
116:20, 117:3,
117:10, 119:23,
121:13, 137:18
Andrea [2] - 35:10,
40:8
ANDREW [1] - 6:7
Andy [2] - 12:4, 65:7
ANGELES [1] - 6:25
announce [2] - 25:23,
40:8
announced [2] 25:25, 26:1
annual [1] - 31:19
annular [5] - 136:12,
137:10, 139:5, 139:7
Answer [1] - 142:13
answer [6] - 77:8,
96:18, 104:5,
114:25, 117:16
answering [1] - 115:9
answers [1] - 100:17
Anthony [1] - 11:2
ANTHONY [1] - 3:21
anticipated [1] - 13:11
ANTONIO [1] - 3:5
apart [1] - 68:25
apartments [1] - 68:21
API [1] - 74:19
apocalypse [1] - 142:2
apparent [1] - 80:3
appear [1] - 21:25
appearance [1] 10:21
APPEARANCES [7] 2:1, 3:1, 4:1, 5:1,
6:1, 7:1, 8:1
appeared [1] - 134:13
appearing [1] - 10:20
appendices [1] 82:16
application [2] - 32:4,
104:18
applied [1] - 87:15
apply [2] - 15:18,
110:21
applying [1] - 87:8
appoint [1] - 33:21
appreciate [1] 105:23
approach [2] - 111:5,
130:5
appropriate [5] 33:14, 69:3, 101:10,
126:8, 141:21
approval [4] - 38:25,
60:15, 94:9, 94:15
approve [1] - 93:25
approved [4] - 48:10,

92:23, 95:22, 96:17
APRIL [1] - 1:6
April [47] - 10:15,
16:4, 16:12, 26:8,
26:25, 27:25, 28:14,
30:7, 32:16, 32:19,
37:22, 40:4, 45:15,
51:2, 52:19, 56:19,
57:10, 57:15, 57:20,
57:21, 70:15, 72:7,
74:7, 75:14, 75:22,
76:4, 90:14, 100:13,
111:15, 113:23,
116:18, 117:5,
118:25, 119:10,
120:23, 121:12,
121:15, 121:16,
122:2, 123:3,
128:16, 129:13,
129:16, 131:2,
131:12, 140:15,
142:12
Arctic [1] - 125:3
area [2] - 29:7, 89:24
areas [1] - 33:11
argue [2] - 99:3, 131:9
argument [3] - 121:6,
140:19, 140:22
armed [4] - 50:20,
51:1, 94:19, 108:12
arranged [2] - 24:24,
25:1
ARRELL [1] - 7:7
arrived [2] - 34:20,
38:25
arrogance [1] - 129:22
arrow [1] - 85:14
art [1] - 119:21
article [1] - 15:10
ASBILL [1] - 6:18
ashore [3] - 33:22,
33:25, 81:5
aside [1] - 84:9
ass [1] - 69:1
assessed [1] - 110:15
assessment [4] 29:11, 29:18, 33:3,
63:4
assessments [2] 30:5, 57:12
ASSET [1] - 1:12
Asset [2] - 10:16,
47:17
assets [1] - 119:16
assigned [2] - 20:20,
52:16
assist [1] - 22:6
assistant [2] - 28:8,
117:11
associated [1] - 127:4

assurance [1] - 32:25
astounding [1] - 68:5
atmosphere [1] 105:18
attempt [5] - 85:24,
85:25, 89:19, 93:21,
106:17
attempts [4] - 64:1,
72:14, 87:7, 87:8
attend [1] - 121:18
attention [3] - 33:16,
57:4, 58:9
attentive [2] - 137:6,
138:7
attentively [1] - 113:8
attitude [4] - 60:8,
65:22, 86:12, 130:4
ATTORNEY [4] - 5:3,
5:4, 5:9, 5:11
Attorney [6] - 11:13,
11:15, 101:3, 104:3,
104:7, 104:8
attorneys [3] - 24:15,
26:5, 75:10
audible [1] - 37:13
audio [2] - 15:12,
25:20
audit [6] - 48:8, 68:4,
68:8, 106:23,
126:20, 126:23
audited [3] - 45:6,
47:12, 119:25
audits [3] - 41:11,
67:17, 89:21
August [3] - 17:10,
39:23, 48:8
authority [4] - 34:22,
39:8, 39:20, 93:25
authorized [1] - 38:20
automatic [5] - 36:21,
36:25, 38:10, 50:20,
108:11
automatically [4] 37:4, 37:20, 133:20,
136:19
avail [1] - 49:18
available [15] - 22:10,
23:15, 23:20, 23:24,
24:10, 24:19, 25:7,
25:8, 42:5, 42:8,
45:17, 50:21, 107:6,
107:7, 134:14
AVENUE [5] - 2:8, 4:5,
5:5, 6:4, 6:24
averse [2] - 66:3
averted [2] - 34:24,
108:24
avoid [4] - 24:16, 38:6,
67:5, 113:20
avoidable [1] - 105:14

avoided [3] - 32:4,
75:4, 107:9
awaited [1] - 46:17
aware [6] - 16:3, 33:9,
33:18, 45:21, 67:4,
88:17
awareness [1] - 60:7
Azar [2] - 84:2, 92:13
B
background [1] 15:24
backup [1] - 73:12
bad [2] - 44:6, 86:3
balances [1] - 64:6
balls [1] - 109:19
bandwagon [1] 138:17
Barataria [1] - 105:3
BARBIER [1] - 1:21
Barbier [1] - 103:8
bare [1] - 140:6
barely [1] - 43:24
barrel [2] - 58:25, 93:3
barreled [2] - 89:25,
97:22
barrels [12] - 27:12,
27:14, 88:23, 89:3,
109:9, 122:16,
122:23, 122:24,
125:18, 125:19,
131:17
barrier [8] - 40:22,
49:2, 53:20, 53:21,
62:15, 86:6, 87:4,
89:13
barriers [1] - 121:10
base [1] - 131:13
based [9] - 43:21,
45:5, 82:25, 84:8,
92:24, 109:6,
138:23, 140:2, 140:3
basic [1] - 32:12
basics [2] - 56:9,
125:9
Basis [3] - 57:9,
57:22, 58:6
basis [3] - 57:13,
57:25, 60:11
BATON [2] - 3:15,
5:12
batteries [9] - 42:23,
43:2, 43:3, 50:15,
50:22, 50:25, 108:9,
108:12, 139:25
battery [3] - 51:2,
73:10, 108:7
OFFICIAL TRANSCRIPT
Bay [1] - 105:3

Bea [11] - 63:23, 64:5,
64:8, 65:23, 66:14,
66:17, 66:20, 69:16,
70:2, 130:14, 142:10
BEACH [1] - 2:19
beaches [1] - 109:18
bear [1] - 105:12
bears [1] - 86:24
became [3] - 76:11,
122:4, 136:22
Beck [1] - 12:6
BECK [3] - 7:11, 7:12,
12:6
become [3] - 80:3,
89:2, 97:24
becoming [1] - 42:8
bed [1] - 77:11
BEFORE [1] - 1:21
began [6] - 57:3,
62:11, 76:2, 94:23,
94:24, 98:9
begin [7] - 13:9,
13:20, 25:22, 26:13,
26:21, 37:15, 136:24
beginning [4] - 14:3,
49:16, 65:5, 130:24
begins [1] - 49:10
begrudge [1] - 80:13
behalf [7] - 11:2,
11:19, 11:20, 12:3,
34:2, 101:6, 102:25
behavior [3] - 66:9,
81:10, 100:14
behind [4] - 44:12,
59:3, 109:1, 138:1
belief [1] - 27:4
believes [2] - 18:12,
112:19
Bellow [1] - 59:15
below [6] - 59:11,
62:17, 94:25, 97:8,
120:8, 131:8
BEN [1] - 4:24
bench [1] - 14:5
benches [1] - 24:21
benefit [4] - 23:25,
69:20, 100:17,
103:21
benefits [1] - 64:10
Bertone [1] - 44:7
best [15] - 45:16,
47:15, 70:11, 75:9,
86:1, 107:6, 114:12,
117:6, 118:10,
118:17, 118:23,
119:3, 119:15,
142:10, 143:8
betrayed [1] - 114:9
better [7] - 29:10,
42:4, 73:19, 78:20,

112:4, 112:7, 120:12
between [19] - 20:8,
25:11, 27:3, 52:2,
57:20, 59:19, 64:6,
65:14, 95:13, 98:15,
109:25, 111:19,
113:4, 128:9,
134:17, 135:3,
135:4, 135:14,
138:13
beyond [1] - 80:4
billion [4] - 58:16,
58:17, 64:23
billions [5] - 64:20,
80:10
binding [1] - 16:2
birds [1] - 100:7
bladder [3] - 92:24,
93:13, 93:22
blades [2] - 42:4,
49:24
blame [8] - 49:7,
72:14, 85:24, 89:19,
113:19, 128:14,
128:24, 138:14
blend [3] - 54:8, 58:8,
107:21
blew [6] - 56:5, 72:8,
77:5, 87:25, 88:16
blind [12] - 42:2, 42:4,
42:7, 42:8, 42:18,
49:24, 50:5, 50:8,
51:6, 70:3, 139:14,
140:14
blinded [1] - 102:7
Block [1] - 16:7
blow [1] - 92:4
blowing [1] - 137:16
blown [4] - 87:20,
88:3, 88:5, 137:23
blowout [55] - 16:4,
17:6, 20:2, 29:21,
31:4, 35:17, 35:20,
38:12, 40:17, 40:18,
40:24, 41:1, 41:4,
43:13, 45:10, 45:12,
46:1, 48:22, 49:4,
49:9, 49:15, 49:17,
50:8, 51:20, 52:10,
52:23, 58:2, 66:23,
69:5, 69:9, 69:21,
72:21, 75:23, 79:13,
84:3, 85:22, 86:4,
88:17, 88:25, 89:2,
90:2, 90:10, 90:20,
94:7, 95:18, 97:8,
98:5, 99:3, 101:25,
102:4, 102:6, 113:4,
127:9, 138:25,
139:21
blows [1] - 140:7
bludgeons [1] - 77:23
Blue [1] - 51:3
blue [2] - 135:16,
135:21
bluntly [1] - 47:9
Bly [11] - 63:8, 63:10,
63:16, 82:13, 83:6,
83:21, 85:2, 93:8,
93:10, 94:23, 98:10
board [5] - 34:5, 69:7,
70:5, 81:7, 139:1
Bob [4] - 46:24, 63:23,
66:14, 133:8
BOCKIUS [1] - 8:3
Bodek [3] - 61:11,
61:12, 61:16
Bolado [1] - 54:16
bomb [1] - 97:23
bond [2] - 62:23,
129:6
boots [1] - 137:22
BOP [53] - 17:6, 40:19,
41:8, 41:12, 41:15,
41:17, 41:18, 41:20,
42:2, 42:11, 42:17,
42:22, 42:24, 42:25,
45:16, 45:19, 45:25,
46:8, 46:14, 49:1,
49:8, 49:12, 49:20,
49:23, 49:25, 50:12,
50:20, 51:4, 72:25,
83:14, 89:10, 89:13,
89:17, 89:19, 89:20,
89:23, 97:20, 97:22,
98:11, 98:17, 108:6,
108:11, 112:1,
131:23, 137:9,
138:15, 138:16,
138:18, 138:21,
139:22, 140:1,
140:9, 140:14
BOP's [1] - 89:7
BOPs [1] - 40:23
bore [4] - 99:8, 137:2,
137:10, 139:9
boss [6] - 61:13,
61:16, 69:10, 75:20,
76:15, 132:15
botch [1] - 106:21
botched [6] - 86:8,
90:6, 106:5, 106:22,
130:24, 130:25
bottom [11] - 31:5,
59:10, 81:20, 88:12,
90:18, 102:7, 120:5,
127:24, 131:14,
135:20, 136:2
bottoms [2] - 62:3,
127:18
bottoms-up [1] 127:18
bought [1] - 93:2
BOULEVARD [1] 3:18
BOUNDS [1] - 2:10
bounds [1] - 94:11
BOWMAN [1] - 7:19
BOX [4] - 2:4, 4:12,
4:18, 5:12
BP [280] - 1:15, 5:19,
5:20, 5:20, 10:18,
12:1, 12:2, 12:3,
12:4, 12:5, 16:23,
17:2, 17:3, 17:8,
18:17, 19:13, 19:18,
21:2, 27:3, 27:24,
28:14, 31:16, 40:25,
41:11, 41:22, 41:24,
44:2, 44:5, 45:14,
45:17, 45:21, 46:6,
46:8, 46:10, 46:11,
46:17, 48:8, 48:20,
49:6, 49:14, 51:17,
51:24, 52:2, 52:5,
52:7, 52:15, 52:21,
52:24, 53:1, 53:2,
53:4, 54:25, 55:2,
55:6, 55:21, 55:22,
56:7, 56:10, 56:12,
57:7, 58:4, 58:9,
58:10, 58:12, 58:14,
58:18, 58:24, 59:4,
59:5, 59:7, 59:8,
59:12, 59:15, 59:16,
59:22, 60:1, 60:4,
60:6, 60:10, 60:12,
60:16, 61:12, 61:13,
61:21, 61:24, 62:3,
62:5, 62:8, 62:11,
62:14, 62:16, 62:18,
62:20, 62:23, 63:1,
63:2, 63:6, 63:8,
63:10, 63:11, 64:8,
64:12, 64:15, 64:21,
64:22, 65:1, 65:7,
65:10, 65:14, 66:1,
66:4, 66:8, 66:15,
66:17, 66:25, 67:3,
67:6, 67:14, 67:20,
68:2, 68:4, 68:8,
68:9, 68:12, 68:14,
68:22, 69:2, 69:5,
69:12, 69:14, 69:16,
70:5, 70:16, 70:19,
72:16, 72:17, 73:1,
73:3, 73:23, 73:25,
74:9, 74:18, 74:23,
75:11, 75:15, 75:20,
76:5, 76:6, 76:9,

76:25, 77:12, 77:15,
77:16, 77:18, 78:2,
78:4, 78:10, 78:17,
78:25, 79:6, 79:7,
79:11, 79:13, 79:19,
79:21, 80:3, 80:7,
80:13, 80:17, 80:18,
80:23, 80:25, 81:4,
81:15, 81:17, 81:18,
82:12, 82:20, 83:1,
83:25, 84:14, 85:18,
85:24, 86:7, 86:9,
86:11, 86:16, 86:18,
86:19, 86:24, 87:5,
87:15, 87:22, 88:4,
88:19, 89:1, 89:15,
89:19, 89:22, 89:25,
90:14, 90:24, 91:22,
92:17, 92:25, 93:20,
94:3, 94:10, 94:12,
95:3, 95:13, 95:21,
98:7, 98:13, 98:15,
99:3, 99:16, 100:1,
101:21, 101:24,
102:3, 102:6, 102:7,
102:10, 102:15,
102:19, 102:23,
104:9, 104:18,
105:11, 105:22,
106:21, 107:10,
108:7, 108:17,
109:7, 112:4, 112:6,
112:22, 113:16,
113:21, 113:24,
114:9, 115:10,
115:13, 117:20,
118:20, 118:21,
118:22, 119:1,
119:10, 119:12,
125:23, 127:11,
127:18, 127:25,
128:7, 128:9,
128:16, 128:25,
129:11, 129:15,
130:5, 130:17,
130:23, 131:3,
131:9, 131:22,
132:9, 133:7,
134:14, 136:16,
138:1, 138:14
BP's [90] - 27:25,
48:11, 52:17, 58:12,
60:23, 61:20, 63:11,
63:13, 63:15, 63:18,
63:19, 64:17, 64:19,
64:24, 65:6, 65:21,
65:22, 66:12, 66:13,
66:24, 67:22, 67:23,
67:25, 69:10, 72:14,
75:5, 76:25, 78:19,
OFFICIAL TRANSCRIPT
78:23, 79:16, 81:8,

83:6, 83:15, 83:19,
84:1, 84:2, 84:4,
84:12, 84:19, 85:2,
85:9, 85:12, 85:15,
86:12, 86:21, 87:19,
88:2, 88:7, 88:9,
88:17, 89:6, 89:10,
90:5, 90:8, 92:13,
92:22, 93:2, 93:8,
93:13, 93:16, 93:24,
94:23, 95:2, 95:14,
95:17, 95:19, 96:13,
96:16, 96:21, 98:1,
98:6, 98:10, 98:18,
99:2, 99:4, 101:22,
102:9, 102:21,
105:16, 106:4,
106:20, 108:25,
111:20, 113:18,
114:24, 128:14,
129:15, 130:9,
130:15
BP-Halliburton [1] 55:22
BP/Halliburton [1] 57:10
BRAD [1] - 6:23
Brad [2] - 12:9, 111:14
BRANCH [3] - 4:4,
4:15, 4:22
breach [2] - 114:23,
115:5
break [6] - 57:2, 71:3,
72:1, 72:2, 134:20
breaks [1] - 43:23
breathed [1] - 110:5
BREIT [3] - 2:18, 2:18,
11:20
Breit [1] - 11:20
BRENNAN [1] - 6:18
Breton [1] - 105:4
Brett [4] - 68:23, 69:6,
79:14, 129:20
Brian [6] - 12:9, 61:6,
87:23, 111:7,
111:14, 131:12
BRIAN [7] - 6:23, 12:9,
111:4, 111:10,
111:13, 118:9,
126:19
BRIAN.....................
[1] - 9:9
bridge [9] - 35:7,
37:19, 38:13, 40:5,
137:11, 138:19,
140:19, 141:23
brief [2] - 15:20,
101:12
briefly [1] - 76:4
bright [1] - 131:22

bring [2] - 69:23,
105:9
bringing [2] - 45:24,
103:10
brings [1] - 19:15
broadcasting [1] 14:23
Brock [1] - 12:1
BROCK [2] - 6:4, 12:1
broke [1] - 44:16
broken [2] - 45:10,
48:17
brought [3] - 18:8,
18:17, 69:20
Brown [1] - 43:22
BRUCE [1] - 7:19
brutally [1] - 47:18
Buddy [1] - 11:13
budget [3] - 59:2,
78:5, 109:2
BUILDING [2] - 2:15,
3:4
buildup [2] - 91:3,
91:8
built [1] - 118:21
bulletin [1] - 46:24
burden [2] - 19:1, 19:2
BURLING [1] - 6:3
burned [1] - 106:17
burning [2] - 16:12,
142:3
business [7] - 56:12,
104:2, 104:15,
104:17, 122:12,
122:15, 130:10
businesses [2] 16:21, 102:12
button [4] - 140:25,
141:1, 141:10,
141:12
BY [44] - 1:5, 2:3, 2:7,
2:11, 2:14, 2:18,
2:22, 3:3, 3:7, 3:11,
3:14, 3:18, 3:21, 4:5,
4:10, 4:16, 4:22, 5:4,
5:10, 5:15, 5:21, 6:4,
6:7, 6:15, 6:19, 6:23,
7:3, 7:7, 7:12, 7:18,
7:24, 8:3, 8:12, 8:13,
9:5, 9:6, 9:7, 9:8,
9:9, 26:17, 71:20,
101:1, 103:7, 111:13
C
C-224 [1] - 25:2
C.F.R [1] - 88:19
CA [2] - 4:6, 6:25
cable [1] - 43:8

cables [3] - 43:6,
43:11
calculate [1] - 142:19
calculated [1] - 58:14
Caldwell [5] - 11:13,
103:5, 107:15,
111:2, 116:9
CALDWELL [4] - 5:10,
11:13, 103:7, 107:18
CALDWELL...............
... [1] - 9:8
calendar [2] - 25:24,
26:5
CALLED [1] - 10:4
callous [1] - 86:12
callousness [1] 101:22
Calvert [1] - 84:2
camera [1] - 15:3
Cameron [24] - 12:6,
13:3, 13:4, 13:5,
13:6, 17:5, 18:18,
19:13, 21:2, 40:25,
45:17, 48:22, 49:6,
49:7, 49:12, 49:25,
50:4, 50:6, 50:7,
50:14, 51:7, 51:11,
70:20, 108:6
CAMERON [1] - 7:11
Cameron's [5] - 48:24,
49:21, 49:22, 50:17,
108:10
CAMP [1] - 5:16
candid [1] - 47:18
candle [1] - 94:8
Canducci [3] - 33:24,
34:2, 34:4
cannot [5] - 14:15,
15:13, 29:7, 47:6,
100:13
Canyon [1] - 16:7
capital [1] - 49:2
capped [2] - 16:15,
20:17
capsizing [1] - 20:2
captain [7] - 34:8,
34:10, 34:18, 38:19,
38:20, 38:21, 140:20
Captain [6] - 34:18,
34:21, 38:14,
141:17, 141:19,
141:22
capture [1] - 106:17
car [2] - 87:13, 140:6
care [6] - 26:10, 53:25,
82:5, 105:21, 120:8,
120:19
cares [5] - 69:14,
79:17, 81:11, 86:13,
129:20
Carl [1] - 34:9
CARL [1] - 1:21
CARONDELET [1] 2:22
CARRIE [1] - 6:8
cascading [1] - 40:7
Case [1] - 17:18
CASE [2] - 1:11, 1:14
case [33] - 10:11,
17:15, 23:3, 23:11,
26:5, 30:3, 72:24,
74:12, 75:25, 80:14,
81:20, 81:24, 81:25,
93:21, 97:10,
101:20, 103:1,
103:11, 104:14,
104:16, 105:24,
110:5, 110:11,
110:18, 114:11,
117:15, 120:18,
129:10, 129:20,
136:23, 136:24,
137:4, 141:16
cases [6] - 14:6,
17:14, 17:22, 17:23,
48:25, 98:21
cash [1] - 58:13
casing [14] - 51:18,
51:22, 52:7, 59:17,
59:21, 61:24, 85:22,
87:3, 88:15, 90:15,
90:19, 91:13, 108:2,
132:19
Castell [1] - 70:5
casualty [4] - 18:5,
18:23, 36:15, 45:9
catastrophe [7] 16:10, 30:7, 30:25,
33:4, 34:24, 74:18,
76:1
catastrophic [3] 28:13, 58:7, 101:14
catch [2] - 28:15,
31:10
catching [1] - 31:18
Cathy [2] - 143:3,
143:13
CATHY [1] - 8:8
Cathy_Pepper@laed
.uscourts.gov [1] 143:15
cathy_Pepper@laed.
uscourts.gov [1] 8:11
caught [1] - 28:1
causal [3] - 85:16,
88:9, 90:4
causation [5] - 83:16,
83:17, 83:21, 85:7,
89:7
caused [14] - 18:23,
60:21, 72:12, 72:21,
78:17, 82:2, 83:9,
93:18, 100:12,
101:13, 101:23,
108:5, 139:11,
139:21
causes [11] - 63:17,
66:21, 66:22, 82:20,
82:25, 83:7, 83:8,
84:10, 85:1, 85:4,
105:18
causing [4] - 18:21,
85:22, 113:25, 114:1
caution [2] - 14:17,
23:4
cautioned [1] - 39:24
caveat [1] - 22:22
CCR [2] - 8:8, 143:13
cell [1] - 14:9
cement [82] - 17:4,
51:21, 51:24, 52:1,
52:6, 52:10, 52:14,
52:16, 53:11, 53:17,
53:19, 53:22, 53:24,
54:4, 54:6, 54:7,
54:12, 54:15, 54:19,
54:21, 54:22, 55:3,
57:8, 62:4, 62:10,
62:13, 62:15, 62:23,
62:24, 69:8, 72:23,
78:14, 79:2, 79:4,
79:10, 79:18, 83:10,
84:1, 84:2, 85:17,
85:20, 85:25, 86:3,
86:5, 86:7, 86:10,
86:11, 86:17, 86:22,
87:2, 87:4, 90:12,
90:17, 96:3, 96:4,
102:4, 102:5, 106:6,
107:24, 108:2,
121:1, 121:2,
121:10, 127:14,
127:15, 127:24,
128:1, 128:3, 128:4,
128:8, 128:10,
128:13, 128:16,
128:24, 129:1,
129:2, 129:6,
130:11, 138:10,
138:11
cementing [5] - 51:14,
51:18, 52:18, 53:14,
62:12
center [7] - 42:3, 50:2,
50:11, 91:13,
139:17, 139:18,
139:20
CENTER [1] - 7:14
OFFICIAL TRANSCRIPT
centers [1] - 37:23

central [3] - 88:11,
106:6
centralize [1] - 102:4
centralizers [9] - 62:6,
69:6, 69:8, 69:11,
86:14, 102:4,
127:20, 129:12,
129:14
CENTRE [1] - 6:15
CEO [6] - 41:7, 46:24,
63:11, 64:17, 65:6,
124:23
Cernich [1] - 11:12
CERNICH [2] - 4:10,
11:12
certain [7] - 17:8,
17:19, 18:6, 22:2,
23:1, 24:11, 105:6
certainly [8] - 30:19,
39:5, 63:14, 71:24,
73:14, 102:3,
105:23, 130:19
certificate [1] - 35:3
CERTIFICATE [1] 143:1
certification [3] 39:17, 41:12, 45:19
CERTIFIED [1] - 8:8
certified [2] - 119:25,
120:1
Certified [3] - 143:3,
143:4, 143:13
certify [1] - 143:7
CFR [1] - 108:19
chaff [1] - 110:21
chain [8] - 83:17, 85:1,
85:7, 85:13, 85:16,
88:9, 90:4, 94:18
CHAKERES [1] - 4:12
challenging [1] 118:11
chance [1] - 96:19
CHANG [1] - 4:11
change [9] - 29:13,
41:20, 41:25, 43:4,
66:9, 67:21, 82:9,
110:15, 133:6
Change [3] - 29:18,
30:4, 57:23
changed [4] - 43:3,
98:21, 131:3, 135:11
changes [4] - 60:22,
60:25, 132:8, 132:11
changing [1] - 81:17
channeling [1] - 69:9
chaos [6] - 38:12,
61:6, 76:9, 77:6,
78:1, 106:4
characteristics [1] -
52:4
charge [7] - 34:12,
35:4, 55:6, 69:22,
81:15, 124:16,
141:17
charged [3] - 42:24,
50:15, 54:25
chart [2] - 27:13,
139:7
chartered [3] - 46:9,
46:10, 81:7
chartering [1] - 68:10
CHASE [1] - 7:4
cheap [1] - 42:5
check [4] - 44:12,
133:12, 134:25,
136:11
checked [3] - 42:24,
52:10, 134:21
checking [1] - 141:6
Chevron [1] - 120:2
CHICAGO [1] - 6:9
chief [1] - 38:5
Chief [1] - 43:22
choice [1] - 91:6
choke [1] - 32:7
chose [8] - 42:3, 42:9,
42:20, 43:11, 51:8,
58:22, 60:4, 80:23
Chris [1] - 38:18
chronic [3] - 31:14,
32:18, 36:17
circulation [5] - 62:3,
62:19, 127:18,
131:18, 131:24
circumstances [3] 85:1, 94:10, 126:2
cities [1] - 100:20
citizens [2] - 101:6,
103:24
City [2] - 88:14,
100:20
civil [3] - 17:20, 19:21,
20:12
Civil [2] - 10:15, 10:17
CIVIL [3] - 1:8, 4:4,
4:15
claim [2] - 92:25,
141:14
claimants [3] - 16:19,
19:2, 20:22
claimed [3] - 18:18,
63:11, 83:7
claiming [1] - 138:15
claims [12] - 16:21,
18:7, 18:8, 18:10,
18:16, 18:17, 19:7,
19:8, 19:16, 21:8,
21:11, 21:14
class [1] - 47:15
classroom [1] 121:19

Clean [7] - 17:21,
19:16, 19:20, 84:14,
84:21, 84:24, 85:8
clear [7] - 57:3, 63:23,
102:16, 104:22,
128:15, 129:1,
131:10
clearest [2] - 95:16,
141:24
clearly [6] - 30:12,
33:16, 45:20, 47:1,
47:23, 49:15
CLERK [5] - 10:7,
10:13, 71:7, 71:13,
142:21
clerks [1] - 103:11
clients' [1] - 103:15
climbing [1] - 142:7
CLINGMAN [2] - 6:19,
12:12
Clingman [2] - 12:12,
114:14
clip [4] - 117:22,
118:8, 126:1, 126:18
clips [1] - 22:2
clock [1] - 118:3
clogged [1] - 132:6
close [13] - 42:14,
49:8, 49:10, 69:23,
79:8, 83:3, 83:14,
87:20, 87:25, 89:18,
98:16, 115:4, 139:8
closed [7] - 42:16,
79:2, 79:4, 91:4,
136:11, 137:1, 139:6
closing [4] - 29:21,
37:11, 136:12, 137:9
clustered [1] - 122:21
clutter [1] - 68:3
Coast [6] - 81:22,
101:14, 102:13,
118:18, 119:11,
140:5
coast [2] - 105:2,
123:12
Cocales [5] - 68:23,
69:6, 69:13, 79:14,
82:22
Cocales' [1] - 129:20
Code [1] - 33:20
code [4] - 27:12,
39:11, 39:22, 43:16
coliaison [1] - 10:23
collar [7] - 78:14,
83:12, 86:25, 87:1,
87:2, 87:6, 87:9
colleagues [2] - 72:9,
114:14
collected [2] - 109:24,

110:2
collective [1] - 101:20
column [1] - 135:11
combined [1] - 59:25
combustible [1] - 37:4
coming [4] - 35:24,
83:11, 102:18,
137:15
command [4] - 34:17,
38:23, 39:3, 141:15
commence [1] - 44:2
comment [1] - 33:16
commented [1] 31:17
commenting [2] 14:15, 68:21
comments [2] - 15:23,
33:7
COMMERCIAL [1] 4:22
commissioned [1] 125:6
commitment [4] 58:13, 58:18, 64:4,
64:5
committed [2] - 59:3,
114:23
Committee [2] 20:23, 26:19
common [3] - 42:9,
50:2, 93:7
commonly [1] - 17:12
communicate [2] 130:16, 141:3
communication [1] 60:7
communities [2] 81:22, 100:21
companies [3] 103:25, 104:1, 120:2
company [28] - 38:4,
39:25, 48:2, 63:25,
64:1, 64:3, 64:6,
78:12, 81:4, 92:22,
114:19, 114:22,
117:7, 117:9, 122:8,
122:19, 123:2,
123:4, 123:7,
123:13, 123:16,
123:17, 123:24,
124:2, 124:15,
124:20, 125:7, 140:3
COMPANY [1] - 5:20
company's [3] 64:18, 124:16,
124:23
company-wide [1] 48:2
compared [1] - 30:21
comparison [1] 113:23

competence [2] 32:24, 46:15
competency [1] 52:25
competent [1] - 34:3
complacent [4] 113:9, 121:9,
123:23, 135:15
complaint [2] - 18:3,
18:16
COMPLAINT [1] - 1:12
Complaint [1] - 10:16
complete [6] - 14:1,
16:1, 57:8, 58:4,
60:21, 63:12
completed [2] - 44:23,
90:14
completely [2] 31:22, 50:2
Completion [1] 65:15
completion [4] 30:21, 58:11, 62:8,
108:23
Completions [1] 70:11
completions [1] - 65:2
complex [2] - 14:23,
100:8
compliance [1] 39:20
complications [1] 53:23
complies [1] - 18:6
comply [2] - 58:2,
127:25
complying [1] - 57:17
component [3] - 41:2,
51:6, 87:11
components [1] 140:13
compounded [1] 53:6
compounding [1] 34:16
comprehensive [1] 67:8
compressive [1] 128:5
compromised [1] 86:10
COMPUTER [1] - 8:13
conceivably [1] 114:24
concern [1] - 127:1
concerned [3] - 52:22,
79:20, 103:25
concerning [3] - 29:8,
OFFICIAL TRANSCRIPT
89:6, 95:14
concerns [8] - 16:4,
17:14, 52:24, 60:1,
68:22, 86:22, 88:3,
126:3
concluded [5] - 28:21,
29:12, 33:15, 41:18,
54:4
concludes [1] - 61:8
conclusion [5] 13:17, 48:5, 70:13,
95:25, 98:15
concursus [1] - 18:11
condemned [1] 130:4
condition [12] - 41:5,
42:15, 43:21, 44:7,
45:5, 55:19, 69:4,
118:20, 140:2, 140:3
condition-based [2] 43:21, 45:5
conditionally [1] 48:10
conditions [8] - 41:16,
42:12, 42:13, 42:18,
42:19, 42:21, 50:6,
50:12
conduct [15] - 13:22,
51:13, 70:22,
106:20, 113:22,
114:20, 114:21,
114:23, 115:4,
116:10, 116:11,
123:22, 123:23,
129:9
conducted [3] - 63:2,
63:11, 68:4
conducting [1] - 104:2
conference [2] - 15:1,
22:16
confident [1] - 103:24
configuration [1] 41:2
confirm [2] - 62:24,
107:24
confirms [1] - 59:16
conflict [1] - 39:21
confronted [1] - 42:2
confused [2] - 38:16,
132:7
confusion [2] 131:16, 141:15
connection [3] 52:15, 57:7, 125:1
CONRAD [1] - 3:7
conscious [2] - 66:6,
117:17
consciously [3] 114:19, 115:3, 137:5
consciousness [1] -
117:25
consequence [1] 100:2
consequences [2] 84:15, 109:1
consider [1] - 126:7
consideration [1] 23:3
considered [6] - 54:2,
88:23, 89:4, 92:20,
95:22, 132:21
considering [2] 56:12, 86:16
consisted [1] - 34:3
consistent [1] 136:16
consists [1] - 82:15
consolidated [1] 17:11
constantly [2] 120:20, 140:14
constitute [3] - 15:24,
73:25, 85:3
constituted [3] 39:10, 75:7, 94:12
consuming [2] 27:14, 103:10
contact [2] - 24:4,
24:7
contained [2] - 54:12,
107:21
contemporaneous [2]
- 35:12, 40:14
contest [1] - 63:15
context [4] - 15:20,
61:10, 66:12, 127:21
Continental [1] - 16:8
continue [8] - 22:20,
29:13, 42:9, 61:9,
76:12, 105:2, 105:4,
142:17
CONTINUED [6] - 3:1,
4:1, 5:1, 6:1, 7:1, 8:1
continued [7] - 32:14,
45:22, 61:13, 81:8,
104:24, 135:22,
136:3
continues [1] - 104:23
continuing [3] - 58:4,
110:8, 113:18
continuous [2] - 41:5,
110:20
continuously [3] 16:14, 57:11, 57:12
contract [10] - 41:3,
52:2, 55:22, 57:7,
57:10, 57:15, 57:17,
57:25, 58:6, 115:6
contracted [3] - 17:2,
17:3, 17:8
contractors [4] 65:11, 105:11,

105:12, 108:17
contractual [4] 51:25, 57:6, 57:19,
58:3
contractually [1] 51:17
contradicted [1] 125:16
contrary [2] - 63:13,
128:7
contrast [1] - 115:25
contributed [3] 35:16, 39:11, 45:12
contributing [1] - 85:1
control [48] - 20:2,
28:11, 29:4, 29:5,
29:7, 29:19, 29:20,
30:1, 30:9, 30:14,
30:20, 30:23, 31:3,
31:13, 31:19, 32:5,
32:9, 32:10, 33:13,
36:5, 36:22, 37:2,
37:3, 37:17, 38:4,
41:14, 72:25, 83:13,
88:20, 89:4, 102:5,
106:7, 106:19,
108:20, 119:24,
120:1, 120:15,
121:18, 121:22,
122:7, 122:12,
122:18, 123:1,
124:8, 124:9,
124:11, 125:5, 141:5
controlled [2] - 43:7,
63:19
controllers [1] - 102:5
controls [1] - 50:19
convenient [1] - 25:16
conventional [1] 53:24
conversation [12] 74:11, 74:13, 74:16,
94:17, 111:15,
111:19, 115:14,
115:23, 129:16,
135:3, 137:15,
138:12
converse [1] - 41:21
convert [2] - 54:21,
87:7
converting [1] - 87:6
cook [1] - 77:11
cooperated [1] - 51:11
coordinated [1] 28:24
copy [1] - 139:2
core [2] - 114:23,
115:5
COREY [1] - 5:4

Corey [1] - 11:23
corner [3] - 78:9,
81:17, 122:22
corners [2] - 59:9,
109:2
corporate [7] - 75:13,
81:6, 82:20, 82:21,
84:10, 101:22, 102:9
CORPORATE [1] - 3:8
CORPORATION [1] 7:11
corps [1] - 24:20
correct [5] - 21:3,
43:12, 66:17, 71:24,
143:7
corrected [3] - 40:3,
45:7, 47:16
corrective [1] - 123:8
correctly [3] - 27:8,
83:25, 95:20
cost [17] - 55:7, 64:10,
64:11, 65:3, 65:16,
65:19, 66:5, 68:22,
77:24, 79:10, 82:8,
104:14, 104:17,
129:6, 131:22,
132:22
costs [4] - 59:9, 64:21,
64:22, 65:8
counsel [9] - 10:19,
10:20, 13:10, 13:14,
13:20, 14:19, 21:19,
101:4, 103:19
Counsel [1] - 11:7
count [1] - 114:5
counted [1] - 25:10
counter [2] - 21:11,
21:13
counterclaim [1] 18:14
counterclaimed [1] 18:19
counterclaims [1] 20:8
countermand [1] 95:24
counterproductive [1]
- 67:18
counting [1] - 97:23
counts [5] - 58:25,
59:1, 77:20, 77:22,
113:24
couple [2] - 47:8,
104:7
course [17] - 13:13,
14:15, 22:20, 22:24,
34:4, 36:22, 69:4,
79:23, 81:6, 81:8,
81:14, 101:7, 105:5,
105:18, 120:10,
129:9, 136:25
courses [2] - 119:24,
119:25
Court [43] - 15:25,
17:11, 17:22, 18:22,
20:11, 20:14, 20:19,
21:22, 22:6, 22:23,
23:2, 23:11, 23:23,
24:4, 24:5, 24:7,
24:10, 71:14, 72:3,
72:11, 75:10, 84:23,
90:3, 90:21, 101:2,
102:22, 103:9,
106:3, 110:4,
110:10, 110:13,
110:15, 110:16,
110:20, 111:1,
138:20, 140:9,
142:22, 143:4,
143:5, 143:6,
143:14, 143:15
COURT [28] - 1:1, 8:8,
10:4, 10:8, 10:10,
10:19, 11:24, 12:22,
12:25, 13:2, 13:8,
69:23, 70:1, 71:2,
71:8, 71:15, 72:5,
73:5, 73:13, 73:15,
73:19, 73:21,
100:23, 103:4,
107:15, 111:2,
111:6, 142:15
court [9] - 18:3, 21:20,
23:18, 24:10, 25:8,
26:2, 82:4, 103:20,
111:9
Court's [8] - 15:7,
15:9, 23:17, 23:24,
24:2, 24:6, 110:17
court-maintained [1] 23:18
courthouse [5] 14:22, 14:24, 15:5,
15:18, 105:1
courtroom [32] 13:21, 14:12, 14:18,
15:4, 15:13, 15:15,
15:18, 24:21, 25:2,
25:3, 25:5, 25:8,
25:9, 25:11, 25:15,
25:19, 25:21, 38:6,
72:9, 74:15, 78:21,
80:12, 80:25, 92:7,
92:8, 99:17, 99:18,
103:11, 104:10,
110:6, 114:15
Courtroom [1] - 25:1
courtrooms [7] 15:11, 15:19, 24:25,
OFFICIAL TRANSCRIPT
25:7, 25:12, 71:8,

71:16
courts [1] - 18:8
cover [6] - 13:8, 28:11,
29:20, 30:2, 49:25,
63:12
coveralls [1] - 137:22
covered [1] - 29:22
covering [1] - 33:3
COVINGTON [1] - 6:3
cracks [1] - 132:1
CRAFT [1] - 3:3
crane [4] - 125:20,
126:2, 126:4, 126:5
crawling [1] - 142:7
crazy [1] - 60:17
create [2] - 52:3, 90:20
created [3] - 43:9,
53:16, 83:17
creates [2] - 63:25,
123:17
credentialed [1] 24:22
credit [1] - 55:3
Crescent [1] - 100:20
crew [85] - 27:20,
27:24, 28:7, 28:14,
30:10, 31:9, 31:17,
32:23, 35:16, 35:20,
36:8, 36:14, 38:10,
39:9, 62:25, 80:24,
86:18, 95:8, 96:1,
96:23, 98:14, 113:1,
113:7, 113:15,
113:19, 114:6,
114:19, 115:3,
115:15, 115:18,
115:25, 116:5,
116:7, 116:10,
116:13, 116:14,
116:19, 116:21,
116:24, 119:8,
119:12, 119:15,
120:25, 121:1,
121:9, 121:11,
121:17, 121:21,
123:3, 123:5, 123:6,
125:13, 125:19,
126:25, 127:3,
127:9, 127:13,
128:12, 129:9,
130:10, 131:1,
133:1, 133:11,
133:13, 134:3,
134:6, 135:5,
135:15, 135:17,
136:10, 137:6,
137:10, 138:5,
138:19, 139:6,
140:19, 140:20,
140:24, 141:3,
141:4, 141:17,
141:23, 141:24,
142:8, 142:12
crew's [2] - 125:24,
127:1
crewmember [1] 38:18
crewmen [6] - 93:1,
99:4, 99:8, 114:2,
115:11, 121:18
crews [8] - 27:20,
30:17, 32:11, 33:16,
42:1, 46:15, 109:20,
122:19
critical [27] - 27:1,
27:12, 32:24, 37:3,
37:20, 38:21, 40:2,
40:19, 45:25, 53:14,
62:20, 64:5, 67:19,
72:20, 72:23, 79:22,
87:11, 90:6, 90:16,
90:17, 96:16,
107:23, 108:22,
117:2, 127:24,
128:3, 138:7
critically [1] - 110:14
criticized [1] - 125:13
cross [4] - 18:18,
21:11, 21:13, 110:14
cross-claimed [1] 18:18
cross-examination [1]
- 110:14
crossclaim [1] - 18:13
crossclaims [1] - 20:7
crown [1] - 137:16
CRR [2] - 8:8, 143:13
crucial [2] - 110:10,
113:11
crude [1] - 136:24
culpability [1] - 63:9
culture [29] - 33:6,
46:20, 47:10, 47:22,
48:17, 63:20, 63:25,
65:21, 65:23, 65:24,
66:2, 66:3, 66:5,
67:23, 75:13, 77:25,
78:23, 79:16, 81:6,
82:20, 101:22,
102:9, 105:5,
105:17, 105:18,
122:9, 127:6
Cunningham [2] 10:24, 123:10
CUNNINGHAM [3] 2:10, 2:11, 10:24
cure [1] - 62:13
current [2] - 15:22,
44:6
Curtis [6] - 116:19,

117:11, 119:23,
121:14, 137:15,
137:17
customary [1] - 14:6
cut [8] - 59:8, 64:20,
65:7, 65:14, 78:9,
109:2, 139:18, 141:7
cuts [2] - 82:9, 141:7
cutters [1] - 82:8
cutting [8] - 42:4,
49:24, 59:9, 64:11,
65:16, 65:19, 66:5,
128:19
D
D-Air [1] - 54:13
dad [1] - 28:1
DALLAS [1] - 7:21
damage [1] - 100:8
damaged [1] - 104:21
damages [7] - 17:19,
20:10, 100:11,
101:10, 101:14,
102:24, 106:1
dampers [1] - 37:11
dance [2] - 76:16, 77:4
dancing [1] - 76:22
danger [3] - 43:5,
114:20, 115:3
dangerous [1] - 72:22
dangers [1] - 81:2
DANIEL [1] - 4:22
data [3] - 135:8, 135:9,
135:11
date [4] - 15:9, 23:8,
109:17, 119:24
DAUPHIN [1] - 2:11
David [10] - 12:6, 13:4,
54:16, 57:14, 60:3,
60:23, 60:24, 75:20,
132:15, 132:16
DAVID [2] - 7:12, 7:12
DAY [1] - 1:19
days [25] - 16:12,
39:15, 45:14, 58:22,
60:24, 60:25, 61:11,
61:15, 62:2, 69:5,
72:8, 74:19, 75:23,
76:11, 78:10, 78:13,
79:12, 80:21, 82:24,
104:7, 120:23,
121:12, 129:7
dazed [1] - 38:15
DC [4] - 4:13, 4:19,
4:24, 6:5
dead [6] - 50:16,
50:22, 51:1, 51:3,
108:12
deadly [2] - 93:15,
97:8
deal [4] - 72:24, 90:21,
101:9, 130:8
dealing [1] - 78:14
DEANNA [1] - 4:11
death [2] - 82:1, 142:6
death-defying [1] 142:6
deaths [7] - 35:17,
79:13, 81:20, 90:10,
100:11, 107:8, 114:1
December [4] - 30:14,
31:23, 47:8, 109:25
decide [3] - 20:15,
72:11, 114:17
decided [2] - 26:6,
129:5
deciding [1] - 141:20
decision [5] - 53:3,
74:3, 80:19, 93:15,
94:4
decisions [15] - 23:3,
49:6, 61:21, 65:9,
72:20, 72:22, 72:25,
73:3, 73:23, 73:25,
74:2, 78:12, 78:16,
127:20, 129:7
decisive [1] - 39:9
decisively [1] - 138:5
declare [1] - 74:3
declared [5] - 31:2,
83:1, 94:1, 111:23,
133:15
decorum [1] - 14:13
deemed [3] - 108:4,
114:20, 114:22
deep [1] - 101:25
deep-water [1] 101:25
deeper [2] - 77:14,
82:20
deepwater [2] - 69:17,
81:18
DEEPWATER [3] 1:5, 6:13, 6:14
Deepwater [82] 10:14, 16:5, 17:1,
17:6, 20:3, 26:22,
27:20, 28:14, 28:19,
30:25, 31:2, 31:3,
31:10, 32:25, 33:25,
34:5, 34:8, 34:17,
35:17, 36:8, 36:14,
39:7, 39:15, 40:17,
40:20, 41:1, 41:8,
43:17, 44:1, 44:6,
44:8, 44:10, 45:16,
45:23, 46:2, 46:7,
46:9, 46:10, 48:13,

48:19, 48:20, 54:8,
54:10, 55:5, 56:5,
59:3, 59:16, 66:11,
67:3, 67:14, 67:23,
68:5, 68:10, 68:21,
69:7, 70:14, 72:7,
77:10, 80:22, 83:4,
83:7, 88:16, 95:1,
98:2, 100:12,
106:12, 106:25,
111:16, 114:3,
117:4, 117:9,
117:13, 118:1,
118:9, 118:21,
118:25, 120:23,
121:8, 125:12,
126:25, 127:3, 127:6
deer [1] - 38:15
deer-in-theheadlights [1] 38:15
default [1] - 136:17
defendant [1] - 99:17
defendants [10] 11:25, 16:23, 19:14,
20:8, 21:8, 21:11,
21:12, 101:9,
108:21, 114:11
defendants' [1] 70:22
Defense [1] - 140:4
defense [3] - 40:24,
72:10, 90:2
defenses [3] - 20:6,
21:10, 21:13
deficiencies [4] 45:8, 45:12, 45:15,
47:16
deficient [3] - 45:7,
47:13, 122:9
definition [1] - 48:5
defoamer [4] - 54:13,
54:14, 54:18, 54:22
defoaming [1] 107:21
defying [1] - 142:6
DeGravelles [1] - 11:3
DEGRAVELLES [3] 3:14, 3:14, 11:3
degree [2] - 110:19,
127:5
delayed [2] - 78:17,
108:23
delays [1] - 79:10
DELEMARRE [1] 4:16
deliberate [1] - 115:4
deliberately [1] 114:22
OFFICIAL TRANSCRIPT
demand [1] - 69:13

demanded [1] - 69:10
demands [1] - 33:16
demonstrate [3] 70:24, 73:3, 73:24
demonstrated [2] 30:10, 81:10
demonstrating [1] 31:11
denied [1] - 70:23
denies [1] - 70:6
DENISE [1] - 8:4
Denise [1] - 12:20
deny [1] - 37:14
Department [1] 140:4
DEPARTMENT [4] 4:4, 4:8, 4:15, 4:21
department [1] - 44:25
departure [2] - 27:9,
28:4
deposed [1] - 21:18
deposition [9] - 21:23,
22:17, 23:13, 77:8,
92:10, 107:3,
117:20, 119:3,
142:11
depositions [5] 21:21, 22:2, 22:9,
110:12, 117:15
depth [2] - 59:17,
61:14
DEPUTY [5] - 10:7,
10:13, 71:7, 71:13,
142:21
describe [6] - 27:8,
65:2, 76:18, 78:2,
90:23, 96:4
described [8] - 27:13,
51:14, 52:17, 60:16,
76:8, 98:24, 127:17,
127:21
describing [1] - 85:8
description [1] - 15:25
descriptions [1] 101:17
Design [3] - 57:9,
57:22, 58:6
design [13] - 40:16,
41:1, 46:6, 51:8,
51:11, 51:17, 72:23,
79:2, 87:10, 87:14,
87:16, 96:3, 130:25
designated [2] 33:21, 33:24
designed [11] - 35:25,
37:3, 49:10, 53:17,
54:4, 54:19, 61:25,
72:18, 108:8, 121:2,
141:2
designing [1] - 54:6

despite [15] - 27:22,
32:14, 34:11, 52:10,
62:24, 68:11, 72:14,
74:18, 88:2, 88:18,
89:23, 90:11, 94:2,
128:9
destabilizes [1] 54:14
destroyed [2] - 36:15,
102:12
destructive [1] - 81:19
Det [1] - 39:18
detail [2] - 101:7,
106:9
details [3] - 52:6,
138:21, 138:22
detect [1] - 28:22
detected [6] - 27:15,
30:12, 122:22,
125:13, 125:17,
133:3
detecting [1] - 122:19
detection [4] - 31:13,
32:12, 35:13, 37:4
detections [1] - 40:14
deteriorated [1] - 29:1
determination [1] 20:1
determine [6] - 18:22,
20:11, 46:12, 90:17,
110:18, 127:15
determined [5] 19:22, 20:11, 29:17,
135:18, 139:13
devastated [1] 102:17
devastation [2] 81:21, 101:8
development [1] 56:1
deviant [1] - 114:22
deviate [1] - 81:5
device [2] - 15:4, 87:8
devices [1] - 14:10
Dewey [4] - 99:20,
117:8, 119:23,
121:14
DEXTER [1] - 5:5
Dick [1] - 88:6
dictate [1] - 36:3
died [6] - 49:8, 99:25,
116:16, 116:25,
117:1
different [16] - 46:22,
48:6, 87:7, 90:4,
90:23, 120:11,
123:13, 129:8,
133:20, 133:23,
133:24, 133:25,
134:2, 134:4,
135:24, 135:25
differential [1] - 92:23
difficult [1] - 127:12
difficulties [1] - 47:25
diminish [1] - 63:9
dip [1] - 136:5
dire [1] - 66:7
direct [3] - 22:15,
83:17, 110:14
directed [1] - 65:16
directions [1] - 38:13
directives [2] - 64:20,
65:5
directly [7] - 25:2,
35:16, 48:19, 63:19,
66:14, 75:18, 100:5
director [2] - 65:10,
65:12
Director [3] - 47:23,
48:24, 49:21
disaster [42] - 28:19,
30:13, 31:9, 32:19,
35:11, 39:12, 40:18,
43:24, 45:11, 46:21,
48:19, 60:18, 60:24,
61:11, 61:16, 62:1,
63:7, 63:16, 66:19,
67:1, 67:3, 67:20,
69:18, 70:7, 70:11,
72:15, 72:21, 75:12,
79:1, 83:18, 98:3,
99:18, 103:1,
104:21, 104:23,
105:14, 106:6,
107:9, 108:5,
108:24, 109:5, 142:1
disasters [4] - 64:9,
66:21, 67:5, 67:15
disastrous [2] - 95:25,
96:20
discharge [1] - 19:21
discharged [2] 16:14, 19:23
discharger [1] - 19:23
discharging [1] 114:5
disciplined [1] - 28:24
disclose [2] - 60:10,
60:11
disconnect [7] 34:14, 34:19, 34:24,
38:19, 38:22, 39:4,
140:21
discover [2] - 26:24,
27:18
discovered [5] - 68:5,
83:25, 88:24, 93:9,
109:10
discuss [2] - 17:18,
28:11
discussed [3] - 33:5,
120:24, 120:25
discussions [1] 61:18
disingenuous [1] 86:1
displace [2] - 131:14,
132:3
displaced [3] - 62:14,
62:16, 94:4
displacement [7] 27:6, 63:3, 108:15,
113:2, 115:16,
128:10, 128:12
displacements [1] 30:24
dispose [1] - 131:19
dispute [1] - 139:14
disputes [1] - 46:1
disregard [3] - 66:6,
75:13, 115:16
disregarded [1] 92:23
disrespects [1] 140:22
distance [1] - 88:13
distillate [1] - 42:13
distorting [2] 138:15, 138:16
District [3] - 143:6,
143:15
DISTRICT [3] - 1:1,
1:2, 1:22
district [1] - 25:8
diversion [1] - 36:5
divert [4] - 36:8,
136:17, 136:19,
136:25
diverted [1] - 136:14
diverter [10] - 29:22,
29:25, 30:2, 35:21,
36:4, 36:9, 36:13,
36:17, 136:15,
136:17
diverting [1] - 35:20
dividend [1] - 58:16
dividends [1] - 58:13
DIVISION [3] - 4:4,
4:9, 4:15
division [4] - 47:18,
51:19, 56:4, 123:13
Division [2] - 57:14,
58:15
DNV [5] - 39:18,
39:22, 39:24,
138:24, 139:18
Document [1] - 15:8
document [7] - 75:24,
97:5, 124:7, 124:15,
128:21, 129:17,
133:16
DOCUMENT [1] - 1:10
documented [1] 106:23
documents [5] 94:14, 95:3, 110:12,
128:17, 131:10
DOJ's [1] - 112:18
dollars [14] - 45:23,
58:20, 59:1, 64:20,
77:20, 77:22, 78:6,
78:7, 78:10, 79:11,
79:19, 80:11, 82:11,
119:19
DOMENGEAUX [1] 2:3
DOMINION [1] - 3:4
DON [1] - 5:21
Don [10] - 12:5, 12:14,
74:10, 111:19,
112:14, 116:12,
121:14, 133:7,
133:9, 134:23
DONALD [1] - 7:18
done [23] - 23:9,
30:24, 38:6, 39:1,
56:8, 66:17, 69:14,
79:17, 81:11, 86:13,
90:9, 97:14, 98:1,
112:13, 112:20,
115:17, 120:11,
120:12, 126:13,
129:21, 131:15,
138:2
door [1] - 105:1
doors [1] - 14:12
double [1] - 42:8
double-blind [1] 42:8
doubling [1] - 44:23
doubt [4] - 32:7,
92:19, 99:16
Doug [1] - 43:22
DOUGLAS [1] - 5:15
down [26] - 37:13,
44:25, 55:13, 56:24,
58:12, 75:2, 76:25,
77:4, 79:7, 80:7,
97:23, 112:2,
112:20, 113:9,
126:4, 133:10,
133:11, 133:19,
133:22, 133:23,
135:17, 135:25,
136:2, 136:5, 136:9,
141:12
downhole [1] - 55:19
Doyen [2] - 12:10,
114:14
OFFICIAL TRANSCRIPT
DOYEN [2] - 6:23,

12:10
DPO [2] - 35:5, 40:10
Dr [14] - 55:24, 60:9,
64:5, 64:8, 65:23,
66:14, 66:17, 66:20,
69:16, 70:2, 79:21,
80:1, 84:2, 92:13
DRESCHER [1] - 2:18
drift [1] - 139:12
drifting [1] - 141:8
drill [61] - 17:2, 27:6,
28:7, 28:23, 30:16,
31:6, 31:17, 32:11,
40:9, 41:20, 41:23,
46:11, 46:12, 49:7,
50:1, 50:19, 59:4,
78:6, 91:10, 91:12,
92:17, 94:2, 95:9,
95:10, 96:12,
104:18, 112:15,
112:25, 113:5,
113:7, 113:13,
113:15, 113:19,
114:19, 116:19,
116:20, 116:24,
119:22, 120:22,
120:24, 121:16,
123:6, 125:12,
130:10, 133:2,
133:4, 133:22,
134:1, 134:9,
134:21, 134:24,
135:4, 135:20,
135:23, 135:25,
136:4, 136:8, 141:3,
141:4
drilled [5] - 16:7,
59:22, 70:9, 80:4,
118:10
driller [11] - 28:8,
50:24, 75:2, 75:3,
97:1, 99:19, 117:8,
117:11, 126:3,
134:18
drillers [1] - 33:2
Drilling [7] - 53:2,
65:15, 69:2, 70:3,
70:11, 74:9, 120:3
DRILLING [1] - 6:13
drilling [35] - 16:5,
17:9, 30:21, 31:21,
41:3, 42:1, 48:20,
48:25, 56:6, 58:23,
59:19, 60:14, 65:1,
67:13, 68:1, 69:17,
70:6, 72:22, 79:23,
79:25, 80:1, 80:2,
80:4, 80:9, 81:18,
84:1, 88:6, 89:24,
10
92:13, 93:6, 95:15,

113:3, 119:4, 121:24
drills [1] - 120:21
drinks [1] - 14:18
DRIVE [2] - 3:4, 3:8
drive [1] - 44:12
driven [1] - 66:2
driving [4] - 58:20,
61:5, 68:12, 76:9
drop [1] - 110:7
drove [4] - 58:10,
77:19, 77:23, 78:1
drydocking [1] - 43:17
dual [4] - 34:17, 38:23,
39:3, 141:15
due [9] - 30:16, 32:1,
45:1, 49:5, 49:6,
52:13, 101:7, 102:9,
121:2
dug [1] - 118:12
Duke [1] - 10:25
dump [1] - 131:25
duplicate [1] - 101:19
during [36] - 10:20,
14:14, 14:16, 19:10,
21:5, 21:23, 22:8,
22:12, 22:24, 22:25,
24:12, 24:16, 29:21,
30:13, 30:20, 38:21,
43:18, 61:20, 63:3,
65:4, 78:13, 81:14,
82:24, 84:22, 85:21,
85:22, 91:3, 97:20,
99:5, 113:9, 121:1,
134:24, 135:2,
140:16, 140:17
duties [1] - 108:18
duty [7] - 46:11, 56:15,
86:20, 116:15,
116:16, 137:11
dynamic [12] - 35:5,
35:9, 40:7, 40:10,
42:12, 42:15, 42:18,
42:19, 42:21, 50:5,
50:11
dysfunctional [1] 39:3
E
e-mail [14] - 29:3,
68:2, 76:3, 77:2,
78:15, 79:14, 82:22,
86:13, 124:5,
129:20, 129:22,
131:12, 132:10,
132:18
e-mailed [1] - 69:13
e-mails [4] - 81:12,
82:22, 124:13,
129:19
early [3] - 42:6, 61:19,
112:1
earth [1] - 59:11
easel [1] - 111:5
easier [1] - 135:12
easiest [2] - 78:3, 82:2
easily [2] - 42:5
Easter [2] - 26:3, 26:7
EASTERN [1] - 1:2
Eastern [1] - 143:6
ecological [1] - 107:9
ecology [1] - 104:22
economic [3] - 81:21,
101:8, 107:8
economy [1] - 104:22
ecosystem [2] - 100:8,
105:10
edge [2] - 79:2, 96:3
EDS [4] - 140:25,
141:6, 141:10,
141:20
EDWARDS [1] - 2:3
effect [5] - 64:6,
92:24, 93:13, 93:22,
132:5
effective [5] - 29:11,
63:24, 64:2, 65:20,
67:17
effectively [2] - 28:22,
57:24
efficiency [1] - 58:20
efficient [1] - 41:5
effort [4] - 67:6,
103:12, 113:19,
124:25
efforts [5] - 20:16,
27:16, 101:19,
103:10, 122:25
Egypt [1] - 123:12
eight [1] - 115:23
eight-minute [1] 115:23
either [12] - 14:10,
31:21, 34:15, 34:25,
37:25, 41:19, 49:18,
56:2, 77:4, 88:16,
91:7, 98:1
ejection [1] - 15:4
ejector [2] - 141:1,
141:11
electronic [2] - 14:10,
22:10
electronics [1] - 38:5
elements [1] - 91:7
elevated [2] - 105:20,
105:21
eleven [8] - 16:10,
74:17, 74:21, 75:25,
79:13, 113:24, 114:1

eliminate [1] - 65:9
eliminated [1] - 65:18
eliminating [1] - 65:11
ELIZABETH [1] - 4:23
ELLIS [1] - 6:7
ELM [1] - 7:21
Elmer's [1] - 109:21
eloquently [1] - 93:23
embedded [2] - 52:17,
53:4
emergency [22] 34:14, 34:19, 34:23,
36:2, 36:9, 36:12,
37:6, 37:8, 38:9,
38:11, 38:19, 38:22,
39:4, 49:1, 50:20,
51:4, 51:5, 89:12,
108:7, 108:11,
141:16, 141:21
emission [1] - 84:9
emphasis [3] - 54:14,
57:11, 64:9
employed [2] - 99:10,
114:19
employee [1] - 68:2
employees [4] - 46:25,
55:11, 107:3, 107:5
employer [1] - 114:3
enacted [1] - 38:14
encounter [1] - 42:3
encourage [1] - 15:10
encouraged [3] 63:20, 80:18, 124:22
end [17] - 31:23, 61:2,
69:14, 76:5, 79:15,
79:17, 82:4, 98:6,
100:16, 102:22,
116:19, 127:10,
129:21, 130:24,
132:9, 132:12, 142:8
endanger [2] - 31:6,
107:4
ended [5] - 62:7, 98:9,
98:22, 118:8, 126:18
ends [1] - 113:23
ENERGY [2] - 6:15,
7:17
ENFORCEMENT [1] 4:9
engaging [1] - 67:17
engine [1] - 37:9
engineer [13] - 27:7,
52:16, 68:23, 69:6,
69:14, 76:9, 76:17,
78:25, 79:13, 87:23,
95:15, 111:21,
115:13
Engineer [3] - 53:2,
69:2, 74:9
Engineering [3] 47:9, 48:25, 49:21

engineering [8] 44:25, 60:3, 61:5,
63:22, 66:14, 68:1,
93:6, 132:9
engineers [3] - 52:24,
112:4, 112:22
engines [2] - 37:12,
37:14
engulfed [1] - 36:11
ensuing [2] - 20:2,
35:18
ensure [3] - 30:4,
41:4, 89:17
enter [1] - 98:11
entered [1] - 113:22
entering [3] - 37:9,
37:12, 49:19
enterprise [1] - 69:17
entire [7] - 36:11,
43:18, 49:25, 64:24,
75:25, 103:12,
108:24
entirely [5] - 16:1,
70:12, 123:13,
124:7, 141:21
entities [2] - 16:21,
17:16
entitled [2] - 19:6,
143:9
entity [1] - 33:1
entrepreneurial [1] 65:23
entrust [1] - 117:18
entrusted [1] - 34:6
ENVIRONMENT [1] 4:9
Environment [1] 48:9
environment [11] 31:7, 39:10, 40:23,
49:3, 50:12, 77:18,
89:14, 100:4,
100:19, 102:11,
106:14
ENVIRONMENTAL [1]
- 4:9
environmental [5] 81:21, 98:3, 101:8,
108:24, 136:18
epitomized [1] - 86:12
equal [2] - 18:4, 86:4
equaling [1] - 106:24
equate [1] - 116:9
equipment [24] - 35:6,
35:20, 40:20, 40:22,
41:9, 41:10, 41:22,
44:11, 44:15, 44:17,
44:19, 45:25, 46:2,
OFFICIAL TRANSCRIPT
47:20, 49:2, 67:19,

87:11, 89:17, 90:1,
116:24, 119:17,
119:18, 124:10,
141:2
equivocation [1] 93:9
erroneously [1] 108:10
escaped [1] - 20:16
ESD [1] - 37:8
especially [6] - 28:18,
46:7, 74:2, 80:21,
105:3, 106:9
ESQ [55] - 2:3, 2:7,
2:11, 2:14, 2:18,
2:22, 3:3, 3:7, 3:11,
3:14, 3:18, 3:21, 4:5,
4:10, 4:10, 4:11,
4:11, 4:12, 4:16,
4:16, 4:17, 4:17,
4:18, 4:22, 4:23,
4:23, 5:4, 5:5, 5:15,
5:15, 5:21, 6:4, 6:7,
6:8, 6:8, 6:15, 6:19,
6:19, 6:23, 6:23,
6:24, 7:3, 7:7, 7:12,
7:12, 7:13, 7:13,
7:18, 7:19, 7:19,
7:20, 7:24, 8:3, 8:4,
8:4
essay [1] - 91:7
essence [1] - 37:21
essential [2] - 46:2,
57:23
essentially [1] - 55:17
establish [9] - 15:23,
35:14, 40:21, 58:1,
85:11, 89:20, 94:9,
96:15, 115:5
establishes [1] 130:22
estimated [1] - 13:25
et [2] - 10:16, 10:18
ET [2] - 1:13, 1:15
etcetera [1] - 20:8
evacuated [1] - 31:22
evening [1] - 139:6
event [12] - 28:16,
30:9, 31:24, 36:5,
89:5, 103:17,
104:13, 110:15,
123:9, 123:12, 130:8
events [18] - 17:11,
28:19, 29:4, 29:9,
31:3, 32:3, 32:10,
35:16, 64:4, 82:24,
94:18, 122:7,
122:18, 123:1,
123:15, 124:3,
11
124:11, 125:6
evidence [195] - 13:14,
13:16, 15:12, 15:16,
20:14, 21:7, 21:9,
21:13, 21:16, 21:17,
21:24, 22:14, 22:23,
23:2, 23:10, 25:20,
26:23, 27:17, 27:22,
28:2, 28:16, 32:22,
34:21, 35:14, 35:19,
36:7, 36:12, 36:17,
36:20, 39:6, 40:21,
41:17, 41:22, 45:9,
46:11, 46:19, 47:14,
48:14, 48:18, 49:4,
49:14, 49:16, 50:4,
51:16, 52:12, 52:19,
53:16, 54:1, 54:22,
55:10, 55:16, 56:3,
56:12, 56:19, 56:25,
57:16, 57:20, 58:1,
58:5, 58:14, 59:7,
60:11, 61:20, 63:6,
63:9, 63:18, 64:14,
64:19, 65:21, 66:4,
66:8, 67:12, 67:21,
67:25, 68:9, 69:11,
70:14, 70:19, 70:21,
70:23, 72:10, 72:13,
72:20, 74:6, 74:20,
74:25, 75:5, 75:10,
75:12, 75:15, 75:19,
75:24, 76:14, 76:24,
77:3, 77:12, 77:16,
77:21, 78:4, 78:16,
78:19, 78:24, 79:6,
79:9, 79:12, 79:20,
80:3, 80:15, 80:22,
81:9, 81:25, 82:7,
82:23, 82:25, 83:5,
83:19, 84:11, 84:17,
84:18, 84:22, 84:24,
85:11, 86:2, 86:9,
86:22, 87:22, 88:2,
88:11, 88:22, 89:1,
89:6, 89:20, 90:3,
90:5, 90:13, 90:24,
91:9, 91:22, 91:25,
92:9, 92:16, 92:21,
93:12, 93:13, 93:17,
93:24, 94:3, 94:9,
94:12, 94:23, 95:6,
95:14, 95:17, 95:19,
95:23, 96:2, 96:8,
96:11, 96:15, 96:22,
96:25, 97:3, 97:4,
97:11, 97:18, 97:25,
98:8, 98:10, 98:18,
98:23, 99:6, 99:15,
100:15, 101:24,
102:10, 102:16,
105:24, 107:8,
107:12, 108:1,
115:2, 116:23,
120:18, 123:4,
125:16, 125:17,
127:24, 128:5,
136:22, 136:24,
138:4, 138:24,
139:5, 139:24, 140:9
exact [1] - 94:22
exactly [7] - 81:19,
92:5, 97:24, 134:13,
135:6, 135:7, 136:23
exam [1] - 91:7
examination [2] 22:15, 110:14
examinations [1] 21:20
examine [1] - 84:23
example [14] - 15:25,
16:18, 29:5, 78:3,
78:22, 78:23, 83:10,
83:24, 91:12,
104:18, 120:22,
121:17, 123:9
examples [1] - 61:23
exceed [1] - 122:24
exceeding [2] - 27:13,
27:14
exceedingly [1] - 91:6
excellent [1] - 118:19
except [3] - 54:2, 54:3,
55:18
exception [2] - 14:19,
93:5
exceptionally [1] 127:12
exchange [1] - 95:13
exclude [2] - 23:2,
66:10
excluded [1] - 23:8
exclusively [1] 118:22
excuse [4] - 61:10,
73:7, 107:15, 128:19
execute [1] - 82:8
executing [2] - 47:2,
104:6
execution [1] - 51:18
executive [12] - 39:13,
40:2, 59:7, 63:7,
63:18, 64:12, 64:19,
66:8, 67:7, 67:20,
93:20, 124:16
executives [1] - 46:24
exhaustive [1] 103:10
Exhibit [1] - 82:14
exhibit [3] - 23:6,
82:18, 111:5
exhibits [6] - 22:3,

22:9, 22:18, 22:25,
23:13, 23:14
exist [1] - 76:20
existence [1] - 43:18
existing [2] - 38:23,
67:9
exoneration [3] - 18:3,
20:6, 21:10
expect [5] - 14:13,
92:14, 92:25, 121:6,
128:14
expected [5] - 13:24,
26:1, 58:25, 93:10,
93:20
expecting [1] - 48:6
expects [1] - 110:16
expensive [1] - 59:5
experience [2] 117:9, 118:17
experienced [3] 32:17, 47:25, 116:21
experiences [1] - 47:5
experiencing [1] 44:10
experimental [1] 62:18
expert [26] - 22:13,
23:13, 27:7, 27:25,
34:1, 43:19, 52:18,
54:3, 54:16, 55:24,
60:3, 63:22, 65:25,
66:14, 84:2, 84:4,
86:12, 88:6, 92:7,
92:13, 112:18,
120:7, 130:14
expert's [1] - 22:14
expertise [1] - 53:25
experts [4] - 93:4,
120:4, 134:10,
138:23
explain [10] - 13:22,
64:8, 66:17, 66:20,
69:16, 70:2, 80:1,
87:5, 91:5, 93:22
explained [3] - 82:2,
93:16, 112:12
explains [2] - 75:24,
111:16
explanation [1] 29:25
exploded [3] - 74:7,
89:2, 98:21
EXPLORATION [2] 1:15, 5:19
Exploration [5] 10:18, 58:15, 58:19,
59:16, 65:7
exploratory [1] - 16:7
explosion [14] - 16:4,
20:2, 35:17, 38:17,

43:10, 43:11, 45:13,
94:16, 101:13,
137:24, 139:11,
139:13, 142:3, 142:9
explosions [3] - 74:5,
82:1, 94:7
explosive [2] - 97:23,
98:11
exposed [1] - 33:10
express [1] - 58:3
extend [1] - 67:13
extensive [1] - 140:10
extent [1] - 105:7
extra [5] - 54:25, 69:6,
69:8, 69:11, 80:18
extraordinary [2] 75:23, 130:12
extreme [3] - 27:9,
28:3, 139:17
Exxon [1] - 120:2
Ezell [3] - 31:1,
137:13, 137:22
Ezell's [1] - 137:14
F
F-16 [2] - 141:1,
141:12
face [2] - 112:23,
113:5
fact [36] - 22:17, 31:8,
31:17, 33:1, 40:7,
43:14, 45:19, 49:15,
53:2, 53:12, 54:16,
55:3, 55:24, 67:2,
68:1, 77:7, 86:2,
92:6, 93:10, 94:13,
97:4, 97:12, 99:24,
102:1, 116:9,
121:10, 121:14,
125:16, 127:16,
131:10, 134:3,
136:24, 139:7,
139:22, 139:23,
139:25
factors [2] - 19:22,
67:15
facts [6] - 101:18,
113:18, 115:8,
115:16, 128:25,
138:15
factual [1] - 84:17
fail [9] - 40:23, 49:3,
49:21, 51:6, 87:11,
89:15, 121:10,
127:14, 130:11
failed [35] - 26:24,
31:10, 32:23, 36:8,
OFFICIAL TRANSCRIPT
38:8, 40:6, 40:8,

40:11, 43:12, 46:20,
49:5, 51:6, 55:11,
55:18, 55:22, 56:2,
58:2, 60:10, 62:3,
62:8, 63:16, 67:14,
74:23, 83:3, 83:12,
84:1, 97:13, 106:7,
106:13, 107:23,
108:1, 108:22,
127:16, 129:1,
140:21
failing [3] - 67:13,
67:16, 67:18
failure [28] - 27:8,
27:17, 27:19, 28:13,
30:17, 32:11, 35:15,
36:18, 42:7, 42:12,
42:17, 43:9, 51:7,
52:13, 62:24, 64:11,
69:16, 75:6, 83:10,
83:11, 83:13, 83:14,
89:8, 91:8, 92:2,
106:19, 130:8,
133:20
failures [7] - 30:11,
33:9, 44:18, 74:18,
82:4, 84:11, 90:4
fairness [1] - 51:10
faith [1] - 128:16
fall [1] - 45:4
Fall [1] - 125:4
falling [2] - 124:10
falsely [1] - 60:12
families [2] - 100:17,
119:20
famous [1] - 129:19
FANNIN [1] - 6:20
far [14] - 28:20, 52:21,
72:15, 77:14, 83:11,
83:14, 94:11, 94:13,
103:17, 103:25,
120:19, 132:2,
135:15
fast [2] - 38:9, 49:8
fatalities [1] - 46:22
fateful [3] - 32:16,
35:11, 37:22
Faul [1] - 53:12
fault [6] - 18:21,
19:25, 72:15, 99:4,
101:13, 102:21
faults [1] - 99:25
feared [1] - 80:5
feature [1] - 106:6
February [3] - 23:23,
29:16, 140:11
FEBRUARY [2] - 1:9,
10:2
federal [8] - 14:22,
12
14:24, 16:24, 18:2,

18:3, 79:22, 88:18,
89:16
feed [1] - 25:20
feedback [2] - 43:7,
60:5
feeds [1] - 15:12
feet [14] - 31:5, 42:25,
50:18, 59:10, 59:11,
59:12, 62:16, 88:13,
88:14, 88:15,
118:12, 133:22,
133:23, 141:13
felt [3] - 56:10, 124:19,
127:3
few [10] - 13:9, 13:21,
21:17, 59:23, 76:16,
82:24, 117:12,
126:23, 138:18,
140:18
fewer [3] - 55:20,
58:22, 86:14
field [1] - 40:24
fifth [1] - 88:9
Fifth [3] - 62:11,
74:11, 87:24
fifths [1] - 135:10
fighting [1] - 116:16
figure [1] - 113:11
figured [1] - 25:10
file [1] - 18:2
filed [3] - 16:21, 18:15,
18:16
filing [1] - 22:17
fill [1] - 87:13
filled [1] - 97:10
final [10] - 52:6, 53:10,
79:1, 80:21, 89:11,
91:9, 93:25, 95:15,
96:11, 107:2
finally [12] - 21:17,
38:20, 61:1, 63:2,
70:21, 76:5, 88:16,
91:18, 102:18,
109:4, 110:4, 132:11
financial [4] - 58:10,
59:8, 59:25, 64:18
findings [2] - 15:24,
126:23
fine [7] - 69:15, 79:18,
81:11, 82:18, 86:13,
119:15, 129:21
fines [2] - 15:3, 20:12
finish [1] - 46:9
finished [3] - 76:11,
76:21, 134:8
fire [5] - 16:4, 20:2,
37:6, 53:3, 142:2
fireball [1] - 74:8
FIRM [2] - 3:10, 3:21
first [23] - 13:19,

13:24, 14:1, 21:6,
22:16, 24:23, 39:15,
48:13, 49:24, 56:23,
65:9, 74:4, 85:15,
85:16, 92:14, 94:16,
101:24, 106:15,
106:16, 123:10,
127:11, 130:3, 131:5
first-year [1] - 92:14
fish [1] - 100:7
fit [2] - 41:23, 84:20
five [8] - 25:16, 30:13,
54:9, 69:5, 89:21,
101:6, 122:13, 131:3
five-year [1] - 122:13
fix [6] - 47:11, 48:18,
67:4, 71:10, 130:2,
140:8
fixing [1] - 140:8
flammable [1] - 36:11
flawed [1] - 43:2
fleet [2] - 118:23,
125:9
Fleytas [2] - 35:10,
40:8
flip [1] - 129:11
flip-flopping [1] 129:11
float [2] - 78:14, 83:12
floor [12] - 30:16, 31:6,
42:25, 49:7, 50:19,
75:3, 94:25, 97:2,
97:8, 99:19, 112:25,
134:24
FLOOR [3] - 2:22, 4:6,
6:24
flopping [1] - 129:11
flow [29] - 42:12,
42:18, 42:19, 42:21,
49:10, 50:6, 50:11,
53:20, 86:24, 87:1,
87:2, 87:6, 87:9,
91:2, 91:8, 94:6,
98:10, 129:14,
132:6, 133:12,
133:14, 134:5,
136:10, 136:12,
136:15, 138:9,
139:17, 139:19
flowed [1] - 52:12
flowing [8] - 27:23,
42:14, 56:21, 57:3,
87:3, 92:20, 94:24,
136:11
Floyd [1] - 12:17
FLOYD [1] - 7:19
fluid [2] - 30:24, 55:25
fluids [2] - 17:9,
133:23
flunked [1] - 96:16

flying [3] - 76:6,
77:13, 132:12
Flying [1] - 61:2
foam [4] - 53:22,
54:15, 54:22, 62:8
focus [2] - 47:19,
106:3
focusing [2] - 85:25,
138:14
folks [2] - 126:15,
126:16
follow [3] - 20:24,
25:21, 32:12
followed [8] - 45:14,
82:1, 84:3, 90:11,
95:18, 99:5, 113:7,
133:13
following [10] - 20:16,
29:16, 31:20, 33:8,
45:11, 46:22, 47:21,
56:16, 60:5, 67:15
follows [2] - 21:6,
22:11
food [2] - 14:18, 100:6
footnotes [1] - 82:18
FOR [9] - 2:3, 4:3, 5:3,
5:8, 5:19, 6:12, 7:11,
7:17, 8:3
force [2] - 64:25,
137:3
Force [1] - 141:1
foregoing [1] - 143:7
forensic [1] - 138:24
foreseeable [2] - 50:3,
50:12
fork [1] - 80:22
form [2] - 12:16,
109:18
formal [4] - 28:10,
57:21, 57:22, 62:22
format [1] - 22:10
formation [3] - 59:12,
59:14, 132:2
formed [1] - 87:4
former [2] - 65:1,
70:10
forms [1] - 104:23
forth [2] - 15:7, 55:8
forward [4] - 27:5,
100:15, 129:2, 129:3
foundation [1] - 75:14
four [8] - 46:22, 49:22,
60:18, 60:25, 67:2,
125:5, 135:10
four-fifths [1] - 135:10
fourth [3] - 21:15,
51:4, 88:8
frac [1] - 59:20
fracture [2] - 46:18,
60:13
framework [1] - 67:10
FRANCISCO [1] - 4:6
FRANKLIN [1] - 4:24
FRAUD [1] - 4:21
freight [1] - 18:5
frequently [1] - 42:1
Friday [1] - 26:2
friend [2] - 71:22,
122:10
FRILOT [1] - 6:14
frontline [1] - 33:16
FRUGE [1] - 3:14
FTP [1] - 23:15
fulfill [2] - 46:2, 57:19
full [4] - 55:20, 95:5,
96:6, 98:14
fully [5] - 33:13, 33:17,
50:9, 62:13, 95:25
function [13] - 38:10,
40:23, 49:1, 49:3,
49:20, 50:13, 50:23,
89:14, 89:18,
108:12, 108:13,
139:3
functionally [1] - 38:1
functionaries [1] 81:16
functioned [9] - 139:5,
139:9, 139:14,
139:16, 139:23,
140:1, 140:16,
140:17
functioning [1] 45:13
functions [6] - 32:24,
36:21, 36:25, 37:3,
37:21, 50:20
fund [1] - 58:13
fundamental [2] 32:4, 80:2
fundamentally [1] 123:14
fundamentals [1] 122:3
FUNDERBURK [4] 8:4, 12:21, 12:24,
13:1
Funderburk [3] 12:21, 12:24, 12:25
furnish [1] - 41:3
furthermore [1] 43:20
future [1] - 67:5
G
Gagliano [10] - 52:9,
52:16, 52:20, 53:4,
OFFICIAL TRANSCRIPT
53:7, 53:9, 53:13,

128:18, 129:16,
129:17
Gagliano's [1] - 53:12
gallons [3] - 49:19,
60:20, 89:3
gambled [1] - 90:1
GANNAWAY [2] 7:13, 13:5
Gannaway [1] - 13:5
gas [44] - 24:13,
26:24, 27:18, 28:18,
31:10, 32:2, 35:12,
35:21, 35:23, 35:24,
36:1, 36:4, 36:6,
36:9, 36:10, 36:11,
36:13, 37:4, 37:6,
37:9, 37:10, 37:14,
37:19, 37:24, 42:13,
52:12, 74:7, 81:16,
85:21, 88:11, 90:19,
92:3, 97:22, 98:11,
98:21, 104:1,
111:25, 119:17,
129:14, 136:18,
136:21, 138:9
GATE [1] - 4:5
gathered [1] - 26:21
Gavin [1] - 12:16
GAVIN [1] - 7:20
gel [1] - 55:25
general [2] - 37:5,
103:22
GENERAL [3] - 5:4,
5:9, 5:11
General [5] - 11:13,
11:15, 101:3, 104:3,
104:7
GENERAL'S [1] - 5:3
generally [3] - 21:6,
44:15, 59:20
Generals [1] - 104:8
Geoff [2] - 13:5, 43:19
GEOFFREY [1] - 7:13
Geologist [1] - 59:15
geologist [2] - 61:12,
61:13
geophysicist [1] 60:9
Gerald [1] - 33:24
giant [1] - 27:18
given [9] - 29:24,
33:22, 34:22, 49:13,
55:2, 59:17, 62:22,
96:18, 96:19
gladly [1] - 117:17
glass [1] - 133:19
global [1] - 65:6
glossary [2] - 24:10,
24:18
13
GmbH [2] - 1:13,

10:16
goal [4] - 108:25,
122:14, 122:15,
123:6
God [1] - 137:17
God's [1] - 61:14
GODWIN [5] - 7:18,
7:18, 7:23, 12:14,
73:10
Godwin [1] - 12:14
GOLDEN [1] - 4:5
government [3] 16:25, 118:15,
118:16
Grace [1] - 28:1
gradient [1] - 59:20
gradients [2] - 46:18,
60:13
grain [1] - 110:21
GRAND [1] - 6:24
graphic [3] - 92:1,
92:16, 138:25
grasp [1] - 77:25
grave [1] - 138:10
great [10] - 63:8,
72:24, 76:19, 90:21,
101:9, 101:11,
102:1, 116:21,
127:8, 137:3
greater [1] - 102:1
greatest [1] - 97:11
greed [1] - 102:16
green [1] - 50:25
Greg [2] - 53:2, 129:15
gross [15] - 19:19,
19:24, 27:9, 28:3,
70:22, 73:25, 80:16,
84:15, 94:12, 98:25,
99:22, 102:19,
104:16, 105:18,
130:21
grossly [13] - 83:2,
90:6, 105:12,
107:19, 108:6,
108:14, 114:21,
122:8, 123:2, 123:3,
123:23, 130:18,
137:5
ground [2] - 109:5,
141:13
GROUP [1] - 3:7
Group [1] - 47:24
growth [1] - 58:18
Guard [3] - 118:18,
119:11, 140:5
GUERRA [1] - 3:3
Guide [16] - 60:23,
75:15, 75:18, 75:20,
75:23, 76:4, 76:8,
76:11, 76:15, 76:21,

77:1, 77:9, 125:14,
125:15, 126:11,
132:10
Guide's [3] - 69:10,
69:13, 76:15
Guide/Sims [3] 78:15, 81:12, 82:21
guilty [6] - 113:22,
113:24, 114:4,
114:8, 130:20
GULF [1] - 1:6
Gulf [44] - 10:14,
16:13, 16:14, 48:11,
49:19, 59:6, 65:2,
65:12, 65:15, 67:22,
67:25, 69:18, 70:6,
70:8, 70:9, 74:17,
81:20, 81:22, 83:22,
94:20, 98:3, 98:20,
99:18, 100:3, 100:4,
100:18, 100:21,
101:4, 101:14,
101:23, 101:25,
102:13, 102:15,
102:17, 103:1,
104:9, 104:15,
105:3, 105:6,
109:13, 114:5,
131:25, 141:8
Gulf's [1] - 100:8
guy [1] - 34:10
guys [4] - 81:16,
118:4, 118:5, 130:7
H
Hafle [37] - 74:9,
78:25, 79:1, 79:5,
81:2, 94:17, 95:3,
95:7, 95:8, 95:9,
95:20, 95:23, 96:2,
96:6, 96:8, 96:18,
97:7, 97:12, 98:8,
111:20, 111:25,
112:3, 112:4, 112:7,
112:14, 112:21,
113:12, 115:22,
115:23, 116:10,
116:12, 134:9,
135:1, 135:3, 138:13
Hafle's [1] - 81:12
half [5] - 45:23, 69:25,
98:14, 109:6, 109:7
hall [3] - 14:11, 25:3,
25:17
HALLIBURTON [1] 7:17
Halliburton [71] 12:14, 12:15, 12:16,
12:17, 12:18, 17:3,

18:18, 19:13, 21:1,
27:24, 28:14, 49:15,
51:16, 51:21, 51:24,
52:3, 52:5, 52:6,
52:13, 52:16, 52:20,
53:6, 53:10, 53:16,
53:21, 54:4, 54:6,
54:13, 54:17, 54:19,
54:20, 54:23, 55:2,
55:5, 55:11, 55:17,
55:20, 55:22, 56:2,
56:7, 56:9, 56:14,
56:16, 56:20, 56:22,
57:1, 57:6, 57:11,
57:16, 57:21, 58:2,
58:5, 62:4, 65:25,
70:20, 86:11, 86:15,
102:21, 102:23,
107:19, 108:1,
126:16, 128:15,
128:16, 128:18,
128:25, 129:13,
134:15
Halliburton's [12] 51:13, 51:15, 51:25,
52:9, 54:2, 54:3,
54:16, 55:10, 55:24,
56:3, 56:11, 57:14
Halliburton-Sperry [1]
- 56:16
halls [1] - 79:7
hand [8] - 55:7, 90:25,
91:14, 91:18, 91:19,
92:2, 92:18, 122:21
handbook [3] - 28:11,
30:23, 41:14
handful [1] - 122:25
handle [2] - 36:1,
41:15
handling [2] - 29:24,
103:15
hands [1] - 61:14
handwritten [1] 128:21
hanging [1] - 97:6
HANKEY [1] - 4:11
happy [1] - 69:1
hard [4] - 68:12,
103:13, 115:25,
116:23
hard-working [1] 103:13
harden [2] - 128:4,
129:4
hardened [1] - 138:10
HARIKLIA [1] - 6:8
Hariklia [1] - 12:3
harmful [1] - 19:21
Harold [2] - 34:19,
38:24
Harold's [1] - 35:3
HARTLEY [1] - 7:19
Hartley [1] - 12:17
hauling [1] - 55:9
HAUSER [1] - 4:23
HAYCRAFT [2] - 5:21,
12:5
Haycraft [1] - 12:5
Hayward [2] - 63:11,
64:17
hazard [3] - 32:1,
51:8, 78:2
hazardous [2] 131:20, 136:19
hazards [4] - 33:9,
33:12, 33:18, 127:4
HB406 [1] - 8:9
head [2] - 66:24,
129:15
headed [1] - 81:17
headlights [1] - 38:15
headquarters [2] 75:21, 79:7
heal [1] - 100:19
Health [1] - 48:9
hear [18] - 15:14,
20:14, 72:24, 73:6,
75:25, 83:20, 85:20,
89:6, 90:3, 90:21,
118:24, 121:6,
125:2, 138:4,
138:20, 139:25,
140:9, 142:5
heard [6] - 105:15,
105:16, 106:8,
121:4, 124:14,
129:11
HEARD [1] - 1:21
heart [1] - 115:8
heavy [3] - 27:6,
109:15, 124:10
heck [1] - 108:25
heed [2] - 14:17, 28:23
Heenan [2] - 27:7,
88:6
heightened [1] - 86:18
held [3] - 35:8, 99:12,
106:18
hell [4] - 60:17, 80:24,
89:24, 127:22
help [5] - 15:21,
100:19, 104:9,
137:21, 137:23
helpful [2] - 24:19,
139:3
hereby [1] - 143:6
Herman [1] - 11:5
HERMAN [4] - 2:7,
2:7, 11:5
OFFICIAL TRANSCRIPT
heroic [2] - 140:23,

142:13
heroism [1] - 142:6
herring [1] - 139:25
high [16] - 36:1, 36:10,
42:13, 50:10, 53:20,
53:21, 59:13, 61:17,
64:9, 66:6, 70:6,
78:2, 94:24, 124:20
high-pressure [1] 42:13
higher [2] - 104:24,
109:14
highest [3] - 33:23,
106:1, 117:20
highly [4] - 24:14,
33:18, 66:1, 84:1
Hill [1] - 12:16
HILL [2] - 7:20, 12:16
himself [2] - 66:14,
93:10
hindsight [3] - 104:12,
115:20, 134:10
hint [1] - 82:19
hiring [1] - 48:21
historic [2] - 101:4,
103:1
histories [1] - 52:20
history [1] - 114:1
hit [1] - 141:11
hoc [1] - 120:21
hold [2] - 14:2, 26:2
holding [1] - 42:16
HOLDINGS [1] - 6:12
hole [3] - 43:9, 90:18,
127:24
holes [2] - 83:18,
83:21
HOLTHAUS [1] - 3:14
home [4] - 24:2,
26:10, 116:14,
116:25
homes [1] - 119:20
Honor [98] - 10:9,
10:22, 10:24, 10:25,
11:4, 11:5, 11:10,
11:18, 11:21, 12:2,
26:18, 41:21, 50:10,
51:12, 69:25, 70:13,
70:24, 71:21, 71:22,
72:6, 73:1, 73:14,
73:20, 75:5, 75:9,
75:25, 76:23, 79:3,
81:14, 81:24, 82:17,
83:5, 84:4, 84:13,
84:23, 85:15, 87:1,
89:10, 91:12, 92:7,
92:9, 96:25, 99:23,
100:16, 101:2,
101:7, 102:16,
14
102:18, 102:25,
103:8, 105:1,
107:18, 109:4,
110:4, 110:23,
110:25, 111:4,
111:11, 111:14,
112:17, 113:18,
113:21, 114:6,
114:10, 114:17,
115:8, 116:4,
116:15, 117:15,
118:9, 119:9,
119:16, 120:6,
121:11, 121:16,
121:25, 122:10,
122:15, 123:14,
127:8, 128:3,
128:24, 129:23,
130:14, 130:19,
131:2, 132:24,
135:9, 135:21,
137:4, 137:25,
138:6, 138:25,
139:21, 140:22,
141:23, 142:11,
142:14
HONORABLE [1] 1:21
honored [1] - 114:11
hope [2] - 119:18,
120:16
hoped [1] - 80:11
Horizon [76] - 10:14,
16:5, 17:1, 20:3,
26:22, 27:20, 28:14,
28:19, 30:25, 31:2,
31:3, 31:10, 32:25,
33:25, 34:5, 34:8,
35:17, 36:8, 36:14,
39:7, 40:17, 40:20,
41:1, 41:8, 43:17,
44:6, 44:8, 44:10,
45:16, 45:23, 46:2,
46:7, 46:9, 46:10,
48:13, 48:19, 48:20,
54:8, 54:10, 55:5,
56:5, 59:3, 66:11,
67:3, 67:14, 67:23,
68:5, 68:10, 68:21,
69:7, 70:14, 72:7,
77:10, 80:22, 83:4,
83:7, 88:16, 95:1,
98:2, 100:12,
102:14, 106:12,
106:25, 111:16,
117:4, 117:10,
117:13, 118:1,
118:9, 118:21,
118:25, 120:23,
121:8, 125:12,
126:25, 127:3
HORIZON [1] - 1:5
Horizon's [4] - 17:6,
34:17, 39:15, 44:1
horrible [1] - 104:13
horribly [1] - 99:6
Horse [1] - 61:6
HOUMA [1] - 3:8
hour [11] - 74:7, 79:1,
81:3, 81:13, 94:15,
94:16, 95:16, 95:22,
96:18, 97:6, 98:14
hours [15] - 21:4, 52:7,
62:12, 68:6, 74:4,
80:21, 82:25, 90:18,
106:24, 116:1,
128:8, 128:11,
128:12, 140:11,
142:18
house [2] - 52:18,
86:11
HOUSTON [7] - 3:19,
6:20, 7:8, 7:14, 7:15,
7:25, 8:5
Houston [17] - 52:17,
53:4, 53:9, 68:22,
69:5, 69:14, 74:9,
75:18, 75:21, 78:25,
79:14, 81:7, 95:3,
95:15, 95:19, 96:14,
98:15
Hudson [1] - 66:1
Huffman [3] - 60:9,
79:21, 80:1
huge [3] - 59:8, 61:5,
76:8
HUGH [1] - 8:3
Hugh [1] - 12:19
HUGHES [1] - 7:7
human [5] - 37:1,
37:17, 40:22, 49:2,
89:13
humbled [1] - 114:11
hundred [4] - 78:6,
80:8, 109:15, 141:13
hundreds [2] - 118:14,
140:10
hung [2] - 74:21,
98:19
Hurricane [1] - 109:25
hydrocarbon [1] 53:20
hydrocarbons [4] 30:16, 31:4, 86:6,
87:4
HYMEL [2] - 7:3, 12:13
Hymel [2] - 12:13,
114:14
I
IACS [2] - 36:23
IADC [1] - 120:1
idea [2] - 50:4, 131:22
identical [1] - 66:22
identifiable [1] - 110:3
identification [1] 57:24
identified [3] - 33:12,
39:20, 58:7
ignition [3] - 32:3,
37:10, 37:14
ignore [3] - 29:7, 51:8,
116:15
ignored [4] - 56:20,
86:10, 108:21, 109:3
ignoring [1] - 67:16
IL [1] - 6:9
imaginable [1] - 82:3
immediate [5] - 53:12,
82:25, 84:7, 85:4,
125:8
immediately [7] 26:3, 96:22, 97:13,
112:9, 115:24,
123:25, 140:21
impaired [1] - 63:4
impairs [1] - 64:12
implement [1] - 69:17
implemented [1] 67:7
implementing [1] 34:12
important [4] - 20:9,
56:1, 103:20, 103:22
importantly [3] 59:13, 78:17, 104:23
imposes [1] - 19:20
imposition [1] 105:25
IMPREVENTO [1] 2:18
improper [1] - 108:15
improperly [1] - 121:2
improve [2] - 66:25,
67:6
improves [1] - 67:9
IN [3] - 1:5, 1:5, 1:12
in-house [2] - 52:18,
86:11
inactions [1] - 95:14
inadequacies [1] 53:8
inadequacy [1] 30:10
inadequate [1] 106:24
INC [5] - 1:15, 5:19,
6:13, 6:14, 7:18

Inc [1] - 114:3
incentive [1] - 55:5
incentives [1] - 65:20
incentivized [2] 65:19, 66:5
inch [1] - 87:12
incident [12] - 28:20,
29:16, 30:15, 30:18,
31:13, 120:24,
121:5, 121:7,
121:12, 133:17,
140:16, 140:17
incidents [4] - 47:7,
60:19, 120:13, 124:1
include [3] - 16:19,
20:5, 65:20
included [2] - 51:25,
54:18
including [14] - 15:3,
17:23, 28:7, 29:4,
32:15, 37:4, 46:13,
80:19, 89:7, 104:24,
106:5, 114:1, 119:1,
140:10
incompatible [2] 54:14, 107:22
incomprehensible [2]
- 74:3, 93:5
Incorporated [1] 10:18
increased [3] - 32:10,
61:22, 104:25
increasing [2] - 31:21,
87:9
incredibly [1] - 65:3
incurring [1] - 55:7
indeed [6] - 40:12,
52:9, 52:23, 56:1,
67:8, 101:11
indemnity [2] 113:20, 114:24
indicated [8] - 50:19,
71:25, 72:2, 115:22,
124:21, 134:11,
134:20, 136:21
indication [2] - 136:9,
141:24
indications [2] - 33:8,
137:7
indicator [1] - 32:5
indicators [1] - 30:17
indifference [1] 116:3
indifferent [3] 114:20, 115:3, 137:5
indirectly [1] - 100:5
individual [4] - 17:10,
69:21, 73:24, 74:2
individuals [2] -
OFFICIAL TRANSCRIPT
16:21, 117:24
induced [1] - 44:13
industry [10] - 24:13,
24:14, 41:12, 108:3,
119:8, 119:9, 120:9,
120:19, 128:7, 140:5
inevitable [1] - 102:9
inexcusable [2] 43:19, 100:14
infamous [1] - 79:15
inflicted [1] - 101:9
influx [3] - 30:13,
37:19, 37:24
influxes [2] - 28:25,
30:12
information [6] 23:19, 24:5, 27:23,
60:10, 117:2, 138:7
Inglis [1] - 65:7
inhibited [1] - 38:10
inhibiting [2] - 37:16,
38:6
inhibition [1] - 38:3
initial [2] - 39:17,
142:9
initiation [1] - 20:3
injured [3] - 16:11,
47:5, 110:2
injuries [4] - 35:1,
81:20, 100:3, 100:9
injury [1] - 47:7
inputs [1] - 52:21
inquiry [1] - 68:15
insanity [6] - 48:5,
61:7, 76:10, 76:17,
77:6, 78:2
insisted [1] - 133:9
inspect [1] - 109:7
inspected [3] 118:14, 118:18,
140:13
inspection [1] - 109:6
inspections [4] 39:19, 43:17, 45:11,
45:20
install [1] - 108:8
installation [4] - 28:7,
34:20, 35:2, 38:24
Installation [1] - 48:2
installed [2] - 17:7,
42:5
instead [16] - 18:8,
35:21, 36:13, 45:24,
66:9, 79:12, 80:15,
92:15, 92:21, 94:19,
98:7, 101:20,
112:21, 127:13,
127:19, 132:18
Institute [1] - 55:21
instituted [1] - 120:14
15
instructed [1] - 133:11

instructing [1] 115:15
instruction [3] 114:8, 133:13, 134:7
instructions [2] 51:9, 113:8
integrated [3] - 36:21,
37:2, 38:3
integrates [1] - 67:9
integrity [3] - 60:13,
81:1, 127:23
intended [2] - 35:25,
69:8
intentionally [1] - 66:9
interconnected [1] 99:25
interest [2] - 101:16,
116:6
interests [2] - 101:15,
103:15
interface [1] - 128:18
internal [2] - 82:12,
83:6
internally [1] - 68:23
international [1] 39:18
International [1] 33:20
INTERNATIONAL [1] 7:11
Internet [1] - 23:15
interpret [2] - 27:8,
28:9
interpreted [1] - 83:25
interpreting [1] 131:1
interrelated [2] - 83:8,
85:12
interrupting [1] 130:25
intervene [1] - 40:11
intervention [2] 37:1, 37:17
interview [3] - 115:22,
126:12, 135:2
introduced [4] 21:24, 22:8, 22:13,
23:6
invest [1] - 64:11
investigate [2] 63:16, 135:18
investigated [3] 96:24, 114:7, 124:2
investigates [1] 123:7
investigating [3] 63:14, 125:19, 133:5
investigation [11] 28:20, 30:18, 30:22,
54:1, 56:17, 63:12,

63:15, 82:12, 83:6,
93:11, 93:16
investigations [1] 123:17
investigative [1] 92:8
investing [1] - 29:10
invitation [2] - 66:12,
66:13
involved [5] - 28:19,
30:11, 87:8, 103:12,
125:1
involvement [1] 40:16
involving [2] - 30:15,
125:2
iPads [1] - 14:9
ironically [1] - 70:5
irony [1] - 97:12
Irpino [1] - 11:2
IRPINO [3] - 3:21,
3:21, 11:2
irrefutable [1] - 95:16
Isaac [1] - 109:25
Island [1] - 109:22
ISM [6] - 33:20, 34:11,
39:11, 39:17, 39:22,
43:16
isolated [2] - 28:15,
31:13
issue [9] - 39:22, 44:9,
51:4, 80:14, 101:13,
101:15, 129:10,
134:2, 137:5
issued [3] - 23:23,
33:3, 64:20
issues [8] - 19:18,
20:5, 20:7, 20:15,
20:17, 68:6, 76:20,
80:2
itself [8] - 13:23,
31:12, 31:20, 37:12,
42:20, 55:22, 78:3,
98:20
J
Jack [1] - 104:10
JAMES [2] - 2:3, 5:10
January [3] - 15:8,
109:11, 140:11
Jason [8] - 99:20,
116:20, 117:3,
119:23, 121:13,
137:18, 137:19
Jeff [1] - 34:1
JEFFERSON [2] - 2:4,
7:4
Jeffrey [1] - 11:20

JEFFREY [1] - 2:18
JERRY [1] - 7:24
Jerry [1] - 12:18
Jesse [4] - 52:9,
52:16, 128:18,
128:20
JESSICA [2] - 4:16,
4:17
Jessie [1] - 128:19
jigsaw [1] - 84:18
Jim [3] - 10:22, 26:18,
72:4
JIMMY [1] - 3:18
Jimmy [4] - 11:8,
34:19, 35:3, 38:24
job [46] - 33:10, 34:3,
34:7, 35:8, 53:11,
53:14, 56:1, 56:8,
56:9, 59:9, 62:24,
65:13, 72:8, 78:14,
79:4, 79:10, 79:18,
84:1, 85:20, 85:25,
86:4, 86:5, 86:10,
86:17, 86:22, 90:12,
96:4, 103:18, 104:3,
106:6, 107:21,
108:2, 112:2,
112:20, 116:25,
121:19, 121:20,
121:23, 122:4,
126:14, 127:15,
128:1, 128:25,
129:1, 129:2, 132:19
jobs [12] - 33:11,
65:17, 86:3, 98:1,
98:2, 102:12,
106:23, 121:1,
122:1, 127:4
Joe [1] - 57:1
JOHN [3] - 3:14, 7:7,
8:4
John [13] - 11:3,
12:21, 12:24, 13:7,
60:23, 66:24, 69:10,
75:15, 114:15,
125:14, 125:15,
126:11, 132:10
Johnson [2] - 43:25,
44:9
join [2] - 18:12, 121:17
jointly [2] - 106:11,
107:13
joints [2] - 141:7
Jonathan [2] - 59:15,
68:1
JONES [2] - 7:12, 13:4
Jones [1] - 13:4
Joseph [1] - 134:19
JR [3] - 2:22, 7:19,
7:19
Judge [7] - 22:6, 25:2,
35:24, 36:22, 54:7,
102:8, 103:8
judge [1] - 110:11
JUDGE [1] - 1:22
judgment [1] - 94:11
judicial [1] - 15:1
July [1] - 30:8
jumped [1] - 138:17
June [1] - 109:24
jury [1] - 14:6
JUSTICE [4] - 4:4, 4:8,
4:15, 4:21
justice [2] - 100:18,
103:19
justifiably [1] - 122:11
justify [1] - 93:14
K
Kaluza [5] - 75:17,
87:19, 92:22, 133:8,
133:17
Kaluza's [1] - 93:21
KANNER [3] - 5:14,
5:15, 11:22
Kanner [1] - 11:22
KARIS [2] - 6:8, 12:3
Karis [1] - 12:3
Kate [3] - 60:6, 65:22,
68:14
KATZ [1] - 2:7
keep [7] - 67:14, 87:2,
88:20, 108:19,
110:10, 121:21,
122:16
keeping [3] - 35:7,
68:12, 140:7
Keith [3] - 57:1, 71:25,
134:19
KELLEY [1] - 4:23
Keplinger [3] - 35:6,
40:11, 40:12
kept [3] - 48:20, 68:9
Kerry [2] - 12:8,
114:13
KERRY [1] - 6:15
Kevin [2] - 65:2, 70:10
key [4] - 40:5, 50:10,
65:16, 130:16
kick [36] - 26:24,
27:11, 27:13, 27:15,
27:18, 27:24, 28:15,
29:24, 30:17, 31:10,
31:12, 32:6, 32:12,
36:8, 51:20, 56:5,
56:13, 56:16, 56:23,
60:6, 63:5, 68:16,
OFFICIAL TRANSCRIPT
68:25, 88:22, 88:23,

89:2, 89:4, 89:24,
125:11, 125:13,
125:17, 126:12,
134:11, 134:16,
136:9
kicks [9] - 28:18,
28:22, 60:19, 121:1,
122:12, 122:15,
122:16, 122:20,
122:22
kill [18] - 91:11, 91:17,
92:18, 95:8, 95:11,
96:12, 112:15,
113:13, 132:6,
133:10, 133:11,
133:16, 133:22,
134:1, 134:5,
135:21, 135:23,
135:24
killed [5] - 47:5,
100:18, 125:5,
133:22, 142:8
Kinchen [2] - 13:7,
114:15
KINCHEN [3] - 7:7,
7:7, 13:7
kind [3] - 25:3, 72:1,
124:21
kinds [1] - 117:17
King [1] - 57:14
KIRKLAND [1] - 6:7
knock [1] - 43:10
knowing [2] - 70:6,
89:23
knowledge [8] 18:22, 18:24, 19:4,
32:15, 45:1, 49:6,
68:11, 94:19
known [10] - 17:16,
28:16, 32:13, 36:18,
40:2, 50:12, 53:23,
59:12, 70:8, 102:3
knows [4] - 104:12,
113:21, 115:20,
134:13
Kodiak [9] - 54:7,
54:10, 54:12, 54:18,
54:21, 55:3, 55:4,
55:9, 58:8
Kongsberg [1] - 36:24
KRAUS [1] - 5:15
Kuchta [3] - 141:17,
141:19, 141:22
KULLMAN [1] - 2:14
Kutcha [4] - 34:9,
34:18, 34:21, 38:14
16
L
L.L.C [1] - 8:3
LA [14] - 2:5, 2:8, 2:16,
2:23, 3:8, 3:12, 3:15,
3:22, 5:12, 5:16,
5:23, 6:16, 7:5, 8:10
lab [2] - 55:14, 128:23
lack [11] - 19:3, 29:25,
31:12, 36:16, 39:3,
44:11, 45:1, 60:7,
70:4, 116:3, 128:22
Lacy [3] - 65:2, 65:5,
70:10
LAFAYETTE [2] - 2:5,
7:5
LAFLEUR [1] - 7:3
laid [1] - 75:13
LAMAR [1] - 7:24
landmark [1] - 103:11
LANGAN [2] - 6:7,
12:4
Langan [1] - 12:4
language [2] - 79:3,
124:21
laptops [1] - 14:9
large [2] - 36:1, 36:6
largest [2] - 32:21,
113:25
Larry [4] - 29:2, 32:19,
124:5, 124:15
LASALLE [1] - 6:9
last [19] - 26:1, 40:24,
60:22, 60:25, 78:13,
79:1, 81:3, 81:13,
82:24, 89:10, 89:13,
90:1, 90:16, 97:6,
128:20, 128:23,
132:8, 132:11,
140:18
last-minute [2] 60:22, 60:25
late [6] - 30:8, 46:8,
68:4, 121:5, 125:13,
136:25
Lavalier [1] - 73:8
law [8] - 80:5, 84:20,
103:11, 105:17,
106:2, 110:21,
116:9, 131:18
LAW [3] - 3:7, 3:10,
3:21
LAWRENCE [1] - 4:18
laws [1] - 101:18
lawsuit [1] - 72:15
lawsuits [1] - 17:10
lawyer [3] - 25:9,
110:6, 128:14
lawyers [6] - 25:10,
25:23, 103:16,
104:4, 110:13,
114:12
layoffs [1] - 64:24
Leader [2] - 53:2,
74:10
leader [17] - 31:16,
51:14, 75:16, 75:20,
77:9, 93:21, 95:4,
95:21, 96:10, 96:16,
96:21, 98:16,
111:20, 115:14,
117:25, 125:23,
133:3
leader's [1] - 95:24
leaders [14] - 61:1,
75:17, 76:5, 76:6,
87:19, 88:17, 92:22,
93:2, 93:14, 93:25,
95:15, 99:5, 117:20,
133:7
leadership [2] - 52:2,
61:5
leading [3] - 35:16,
52:23, 131:2
leads [1] - 102:8
learn [5] - 47:4, 47:6,
64:4, 67:21, 121:23
learned [6] - 56:17,
68:3, 68:15, 68:17,
68:18, 120:16
learning [2] - 68:20,
76:19
lease [2] - 45:22, 59:6
leased [4] - 16:24,
66:11, 67:13, 67:22
leases [1] - 119:17
LEASING [1] - 1:13
Leasing [1] - 10:16
least [8] - 24:23,
32:17, 34:25, 45:8,
52:6, 54:9, 62:1,
100:11
leaving [3] - 53:7,
84:9, 93:18
led [5] - 27:4, 32:19,
48:19, 83:18, 108:11
Lee [1] - 12:11
left [14] - 54:10, 57:1,
83:11, 83:12, 85:15,
87:1, 92:2, 92:18,
113:5, 122:21,
135:4, 135:11,
138:18, 142:18
left-hand [3] - 92:2,
92:18, 122:21
leftover [4] - 54:21,
55:9, 62:19, 107:20
legal [3] - 84:18,
84:24, 85:7
LEGER [3] - 2:21,

2:22, 11:7
Leger [1] - 11:7
length [1] - 24:25
lengthy [1] - 14:14
less [11] - 30:20, 44:4,
53:14, 55:8, 62:7,
74:7, 88:22, 90:18,
94:15, 94:16, 104:25
lesson [2] - 56:17,
68:17
lessoned [1] - 68:17
lessons [5] - 64:4,
67:21, 68:3, 68:15,
120:16
letter [2] - 123:21,
123:22
level [7] - 32:13,
47:18, 61:5, 68:2,
76:8, 85:5, 102:20
levels [1] - 33:23
LEWIS [5] - 2:14, 5:20,
7:18, 7:23, 8:3
LI [2] - 6:24, 114:15
Li [1] - 12:11
Liability [2] - 17:17,
18:1
liability [11] - 18:3,
18:4, 18:20, 19:6,
20:6, 21:10, 26:23,
84:12, 85:13,
105:22, 105:23
liable [4] - 18:12,
102:24, 106:10,
107:13
liaison [1] - 101:4
license [1] - 35:8
lies [2] - 72:16, 115:7
lieu [1] - 21:24
LIFE [1] - 2:15
life [6] - 31:6, 35:1,
40:22, 49:2, 64:10,
89:13
light [2] - 50:17, 50:25
lighter [2] - 27:6, 94:5
lightly [1] - 99:23
lightweight [1] - 52:3
likely [4] - 33:18,
36:14, 50:1, 127:14
likewise [1] - 18:13
limit [2] - 18:20, 19:6
limitation [16] - 16:22,
17:16, 18:4, 18:9,
18:16, 19:7, 19:10,
19:17, 20:6, 21:10,
26:22, 70:23, 87:14,
87:17, 105:23
Limitation [2] - 17:17,
18:1
limitations [1] - 87:10
limited [1] - 85:10

limits [1] - 80:5
limping [1] - 44:17
line [24] - 40:24,
83:18, 90:2, 91:11,
91:17, 92:18, 95:8,
95:11, 96:13, 102:7,
112:15, 113:13,
120:5, 126:25,
132:6, 133:10,
133:12, 133:16,
133:22, 134:1,
134:5, 135:21,
135:23, 135:24
lined [6] - 83:16,
83:22, 91:21, 95:11,
112:16, 113:14
liner [2] - 61:24,
127:19
lines [2] - 91:15, 92:16
lingering [1] - 101:8
link [2] - 23:16, 24:3
liquids [1] - 42:13
Lirette [1] - 69:2
LISKOW [1] - 5:20
list [1] - 12:23
listen [1] - 66:18
listened [3] - 112:8,
127:1, 134:7
literal [2] - 76:11,
142:2
literally [1] - 142:6
Litigation [1] - 10:13
LITIGATION [1] - 4:22
litigation [2] - 17:12,
101:5
live [6] - 13:19, 15:14,
21:25, 25:20, 74:22,
110:11
lived [1] - 110:4
livelihood [2] - 100:4,
105:7
livelihoods [1] - 100:6
lives [15] - 16:10,
49:18, 74:17, 74:22,
76:1, 77:24, 94:20,
97:16, 98:22, 99:9,
99:15, 102:13,
102:14, 113:17,
117:18
living [1] - 124:19
LLC [1] - 6:12
Lloyd's [4] - 33:1,
33:3, 126:19, 126:23
lock [1] - 93:3
lodged [1] - 22:19
log [2] - 62:23, 129:6
logger [1] - 27:24
London [2] - 67:7,
81:7
OFFICIAL TRANSCRIPT
longstanding [1] 46:19

look [11] - 38:15,
68:19, 82:23,
100:15, 109:15,
110:8, 122:1, 123:9,
126:4, 134:5, 134:24
looked [2] - 25:24,
93:21
looking [4] - 26:4,
47:20, 75:11, 122:2
looks [1] - 119:7
loose [1] - 80:9
LOS [1] - 6:25
lose [2] - 80:7, 139:11
losing [1] - 59:5
loss [13] - 18:21, 20:1,
29:4, 29:5, 29:7,
35:1, 35:17, 55:25,
60:19, 64:10, 66:3,
124:8, 124:9
loss-of-control-type
[1] - 29:4
losses [1] - 20:10
lost [11] - 47:10,
47:22, 60:19, 62:19,
65:17, 69:21, 76:1,
102:14, 121:2,
128:16, 131:18
louder [1] - 81:9
Louis [1] - 55:25
LOUISIANA [5] - 1:2,
1:8, 5:8, 5:10, 8:5
Louisiana [20] - 11:14,
11:22, 16:9, 16:20,
20:25, 103:5, 104:1,
104:19, 104:20,
105:2, 106:16,
109:5, 109:6, 109:8,
109:14, 109:23,
110:3, 110:7, 143:5,
143:6
Louisiana's [4] 104:21, 109:10,
109:12, 109:18
low [4] - 35:23, 111:8,
111:10, 111:11
low-pressure [1] 35:23
lower [4] - 58:21, 68:2,
122:21, 127:19
Luis [2] - 12:11,
114:15
LUIS [1] - 6:24
lunch [1] - 142:17
LUNCHEON [1] - 9:10
luncheon [1] - 142:22
LUTHER [1] - 5:4
Luther [3] - 11:15,
101:2, 104:4
17
Lynch [1] - 104:10
M
M-I [3] - 12:19, 12:20,
12:21
Macondo [68] - 16:6,
16:24, 17:2, 17:4,
27:2, 27:12, 46:9,
52:13, 53:11, 53:15,
53:19, 53:22, 54:6,
54:11, 54:17, 54:21,
55:13, 56:7, 56:10,
58:2, 58:11, 59:2,
59:10, 59:23, 60:1,
60:2, 60:6, 60:16,
61:11, 61:14, 61:15,
63:16, 64:15, 66:19,
66:23, 67:16, 67:20,
69:19, 69:22, 70:2,
70:7, 70:11, 72:8,
72:17, 72:18, 72:19,
75:16, 76:9, 77:1,
77:9, 78:3, 78:6,
78:24, 79:17, 79:23,
80:9, 81:15, 81:18,
86:7, 89:16, 90:15,
109:1, 118:13,
119:15, 120:17,
123:12, 140:12
Macondo's [1] - 55:19
MAGAZINE [1] - 3:22
Magistrate [2] - 22:5,
103:9
magnitude [3] - 32:21,
39:12, 82:10
MAHTOOK [1] - 7:3
maiden [1] - 117:4
mail [14] - 29:3, 68:2,
76:3, 77:2, 78:15,
79:14, 82:22, 86:13,
124:5, 129:20,
129:22, 131:12,
132:10, 132:18
mailed [1] - 69:13
mails [4] - 81:12,
82:22, 124:13,
129:19
MAIN [1] - 3:15
main [2] - 40:22, 49:2
Maintain [1] - 89:17
maintain [4] - 40:17,
46:4, 67:19, 79:24
maintained [4] 14:14, 23:18, 41:4,
140:14
Maintenance [1] 44:8
maintenance [20] -
41:9, 43:1, 43:21,

44:11, 44:14, 44:20,
45:5, 45:10, 46:7,
47:12, 47:14, 48:15,
68:6, 89:23, 106:24,
106:25, 139:24,
140:3, 140:4, 140:10
major [14] - 26:24,
37:10, 39:10, 40:18,
47:16, 58:24, 64:6,
64:10, 66:21, 70:3,
88:23, 89:4, 90:1,
140:13
majority [2] - 122:22,
122:23
maker [1] - 77:11
MALINDA [1] - 4:18
man [6] - 34:5, 68:6,
95:3, 95:19, 119:1,
142:1
man-hours [1] - 68:6
manage [1] - 64:1
managed [1] - 119:12
Management [5] 29:18, 30:4, 33:20,
57:22, 63:19
management [44] 27:19, 28:5, 29:3,
30:3, 30:6, 30:11,
31:15, 31:20, 32:8,
32:13, 33:5, 33:23,
34:6, 34:10, 34:23,
35:15, 36:18, 39:8,
39:13, 39:24, 40:3,
42:23, 46:16, 48:1,
48:9, 52:6, 59:7,
59:8, 63:7, 63:17,
63:18, 64:19, 64:22,
66:5, 66:8, 67:7,
67:8, 67:9, 67:10,
67:21, 82:20, 84:10,
108:21
management's [1] 48:18
manager [5] - 28:7,
34:20, 35:2, 38:24,
68:1
Manager [1] - 43:25
Manager's [1] - 48:2
managers [3] - 64:12,
81:5, 127:1
mandate [1] - 88:18
mandatory [1] - 79:21
manipulated [1] 55:18
manner [7] - 18:10,
40:6, 61:9, 76:13,
103:16, 104:2,
105:13
manslaughter [1] -
113:25
manual [2] - 29:20,
120:15
manually [1] - 39:5
manufactured [1] 17:5
March [13] - 29:1,
29:15, 31:8, 31:16,
33:4, 56:13, 60:5,
61:10, 61:12, 68:16,
125:11, 125:24,
126:12
margin [4] - 60:14,
79:25, 80:1, 80:4
margins [1] - 72:22
Marianas [1] - 56:6
marine [4] - 34:1,
88:15, 100:7, 106:14
Mark [8] - 74:9, 78:24,
111:20, 112:14,
112:21, 116:10,
116:12, 135:1
marks [1] - 93:23
marsh [1] - 109:8
marshaled [1] - 18:10
marshalled [1] - 23:14
marshalling [2] - 22:7,
22:16
mass [1] - 98:11
massive [1] - 64:24
master [2] - 39:6,
39:21
Master [1] - 103:14
matched [1] - 84:21
material [5] - 30:1,
109:21, 109:22,
109:24, 131:24
materials [7] - 17:9,
22:7, 23:22, 28:10,
49:12, 62:19, 131:18
mates [1] - 116:7
math [1] - 21:3
mats [3] - 109:9,
109:19, 109:21
matter [3] - 42:22,
116:8, 143:9
mattered [5] - 102:10,
102:11, 102:13,
102:15
matters [5] - 13:21,
15:6, 19:10, 26:13,
129:5
Matthew [1] - 12:2
MATTHEW [1] - 6:8
maximum [2] - 19:21,
41:15
mayhem [1] - 38:13
MAZE [2] - 5:4, 11:23
Maze [1] - 11:23
McCLELLAN [1] -
4:16
McGovern [1] - 103:15
MCKINNEY [1] - 7:14
McMahan [4] - 124:6,
124:8, 124:15,
124:24
McMahan's [1] 124:25
McMahon [3] - 29:2,
29:12, 32:20
MDL [4] - 17:13,
17:15, 17:25, 24:3
mean [1] - 140:5
means [6] - 21:19,
23:1, 47:15, 80:2,
98:13, 140:7
meant [4] - 37:21,
92:3, 92:19, 133:6
measurable [1] 65:20
measured [1] - 100:9
measures [1] - 33:13
Mechanic [1] - 43:22
MECHANICAL [1] 8:12
mechanical [1] 84:11
media [1] - 24:22
meet [3] - 58:17,
119:8, 123:6
Melvin [1] - 48:24
member [5] - 28:6,
60:6, 68:14, 70:5,
142:8
members [6] - 24:21,
25:14, 40:5, 126:25,
127:3, 141:18
memory [1] - 140:22
men [38] - 16:10, 49:7,
74:11, 74:20, 74:21,
75:3, 75:25, 81:4,
81:8, 92:22, 94:19,
94:23, 95:4, 95:13,
96:13, 98:1, 98:18,
99:9, 99:14, 100:17,
113:1, 113:4,
113:15, 114:4,
114:21, 117:3,
117:14, 117:16,
117:17, 119:22,
121:15, 121:25,
129:7, 139:22,
140:23, 142:3, 142:6
men's [1] - 97:16
mention [2] - 82:19,
126:22
mentioned [6] - 19:15,
23:5, 76:3, 77:19,
125:11, 140:2
mere [1] - 98:24
OFFICIAL TRANSCRIPT
merely [1] - 15:23

Merit [2] - 143:4,
143:14
merit [1] - 130:5
MERIT [1] - 8:9
Mexico [18] - 10:15,
16:13, 48:11, 65:2,
65:12, 65:15, 67:22,
68:1, 69:18, 70:6,
70:8, 70:9, 81:21,
100:21, 101:25,
104:15, 131:25,
141:8
MEXICO [1] - 1:6
MI [6] - 8:3, 17:8,
18:18, 19:13, 21:2,
108:14
mic [1] - 73:8
MICHAEL [2] - 4:5,
6:23
Michael [1] - 12:10
MICHELLE [1] - 4:16
microcosm [1] 115:10
middle [2] - 131:7,
133:5
midst [1] - 142:2
might [6] - 69:20,
73:11, 107:16,
114:23, 131:9,
138:11
MIKAL [1] - 3:3
Mikal [1] - 11:9
Mike [4] - 11:19, 12:1,
38:5, 114:14
Milazzo's [1] - 25:2
miles [8] - 16:8, 88:12,
94:25, 97:8, 104:20,
105:1, 105:2, 109:8
Miller [3] - 12:8, 111:5,
114:13
MILLER [2] - 6:15,
12:8
million [19] - 45:23,
59:2, 62:2, 65:14,
78:5, 78:6, 78:7,
78:10, 78:11, 80:8,
93:11, 101:6, 109:2,
109:9, 109:21,
109:22, 109:23,
132:23
millions [6] - 49:19,
78:5, 79:11, 79:19,
82:10, 100:5
mimic [1] - 55:18
mind [4] - 30:19,
33:17, 110:10, 131:3
mind-set [2] - 30:19,
33:17
minded [1] - 78:12
18
mindless [1] - 67:17

minimally [1] - 34:3
minimized [1] - 39:2
minimum [1] - 132:7
minute [7] - 60:22,
60:25, 115:23,
128:20, 128:23,
132:8, 132:11
minutes [27] - 20:23,
20:25, 21:1, 21:2,
21:3, 21:4, 27:15,
31:11, 56:14, 72:2,
74:22, 76:16, 95:5,
98:9, 98:20, 113:9,
113:11, 129:10,
131:9, 133:14,
138:18, 139:10,
140:18
misconduct [20] 19:19, 19:24, 73:4,
73:24, 75:7, 80:17,
84:12, 84:15, 84:20,
84:25, 85:3, 85:6,
85:8, 85:13, 99:1,
99:23, 102:20,
105:25, 115:5,
115:12
misdemeanor [1] 114:5
misinterpreted [1] 27:4
mislead [1] - 72:3
mismanaged [1] 119:13
miss [1] - 134:3
missed [8] - 27:24,
49:15, 56:4, 134:16,
134:18, 134:19,
134:23, 135:1
missing [1] - 138:7
mission [1] - 46:3
Mississippi [1] - 16:7
missteps [2] - 73:2,
73:23
mistake [8] - 71:23,
96:20, 97:25, 99:14,
113:15, 115:18,
115:20, 134:6
mistaken [1] - 27:4
mistakes [4] - 81:2,
89:25, 99:9, 99:11
misused [1] - 35:20
mitigating [1] - 34:25
mixing [1] - 55:8
mixture [1] - 52:4
MMS [7] - 60:10,
60:14, 60:15, 80:6,
118:16, 119:11
Mobil [1] - 120:2
MOBILE [1] - 2:12
mobile [1] - 16:5

mode [3] - 14:11,
37:25, 38:1
model [11] - 83:15,
83:19, 84:19, 84:20,
85:2, 85:9, 85:16,
88:9, 89:10, 90:5,
98:7
model's [1] - 84:9
modeling [2] - 52:21,
128:22
moderate [1] - 109:15
Mogford [1] - 66:24
moment [8] - 17:18,
74:8, 77:1, 89:2,
94:22, 95:2, 137:2
moments [1] - 13:9
MONDAY [2] - 1:9,
10:2
Monday [2] - 14:2,
26:7
monetary [1] - 55:5
money [21] - 47:19,
54:23, 61:22, 63:1,
69:12, 77:19, 77:22,
77:24, 78:18, 80:23,
82:8, 100:18,
102:10, 102:11,
102:13, 102:15,
108:25, 129:6,
131:22, 132:25
monitor [7] - 28:24,
50:15, 83:13,
106:19, 131:8,
135:22, 136:3
monitored [4] - 42:24,
91:10, 133:16, 135:5
monitoring [7] 32:12, 51:19, 57:2,
72:25, 88:8, 91:17,
136:6
monkeyed [1] 131:17
MONTGOMERY [1] 5:6
month [3] - 31:8, 44:4,
62:1
months [13] - 14:1,
16:14, 26:1, 30:13,
32:18, 43:24, 47:8,
54:9, 60:18, 70:16,
74:15, 112:23,
117:13
Moonpool [1] - 43:9
Morel [3] - 87:23,
88:1, 131:12
MORGAN [1] - 8:3
MORNING [1] - 1:19
morning [13] - 10:8,
10:9, 10:22, 10:25,
11:5, 11:10, 11:18,

13:18, 26:18, 71:21,
72:6, 101:19, 140:15
most [11] - 25:11,
59:13, 78:17, 95:16,
102:10, 104:22,
118:10, 121:24,
124:16, 129:19,
138:23
motion [1] - 94:6
motivation [1] - 45:1
move [2] - 11:25, 25:3
moved [2] - 139:17,
139:18
movement [1] 125:20
MR [68] - 9:5, 9:6, 9:7,
9:8, 9:9, 10:22,
10:24, 10:25, 11:2,
11:3, 11:4, 11:5,
11:7, 11:8, 11:9,
11:10, 11:12, 11:13,
11:15, 11:17, 11:18,
11:20, 11:22, 11:23,
12:1, 12:2, 12:4,
12:5, 12:6, 12:7,
12:8, 12:9, 12:10,
12:11, 12:13, 12:14,
12:15, 12:16, 12:17,
12:18, 12:19, 12:21,
12:24, 13:1, 13:3,
13:4, 13:5, 13:6,
13:7, 26:17, 69:25,
70:2, 71:20, 72:6,
73:10, 73:11, 73:14,
73:18, 73:20, 73:22,
101:1, 103:7,
107:18, 111:4,
111:10, 111:13,
118:9, 126:19
MS [3] - 12:3, 12:12,
12:20
mud [16] - 27:6, 32:2,
35:21, 35:23, 35:25,
36:4, 36:9, 36:13,
51:19, 56:23, 60:20,
94:4, 113:3, 136:18,
136:21, 137:16
mud-gas [7] - 35:21,
35:23, 36:4, 36:9,
36:13, 136:18,
136:21
mudlogger [6] 56:14, 56:20, 56:22,
57:1, 72:1, 134:19
mudlogger's [2] 56:24, 57:1
mudloggers [3] 56:4, 56:8, 56:18
multidistrict [2] -
10:13, 17:12
multiphase [1] - 13:25
multiple [12] - 16:23,
30:11, 41:11, 45:6,
45:11, 47:13, 51:4,
60:12, 80:20, 86:9,
91:6, 99:25
MUNGER [1] - 6:22
Murray [3] - 117:19,
125:22, 133:2
must [10] - 18:8,
18:22, 40:23, 47:6,
49:3, 49:21, 88:23,
106:18, 115:8,
121:18
MUX [2] - 43:6, 43:8
N
name [3] - 12:22,
12:23, 81:23
named [1] - 119:1
namesake [1] - 83:21
narrow [1] - 72:22
narrower [1] - 59:20
NATHANIEL [1] - 4:12
natural [2] - 37:14,
105:7
NATURAL [1] - 4:9
nature [2] - 15:22,
32:9
nautical [1] - 88:12
near [1] - 17:7
nearly [3] - 78:7,
101:6, 109:15
necessary [3] - 68:25,
88:20, 108:19
necessity [1] - 58:7
need [13] - 14:11,
44:20, 47:3, 61:18,
69:23, 74:14, 74:24,
94:18, 104:25,
110:23, 111:17,
130:11, 137:20
needed [10] - 25:12,
39:9, 58:16, 66:17,
76:18, 81:1, 81:3,
90:24, 91:22, 116:25
needlessly [1] - 76:1
needs [1] - 71:9
negative [52] - 27:2,
28:9, 28:11, 62:20,
72:23, 74:3, 78:15,
83:1, 83:12, 83:24,
84:6, 86:7, 86:8,
86:19, 86:21, 88:7,
90:7, 90:15, 90:16,
90:22, 91:9, 91:16,
92:11, 94:10, 94:15,
OFFICIAL TRANSCRIPT
95:7, 95:21, 96:1,

96:4, 96:11, 97:14,
97:19, 97:21, 98:6,
99:5, 99:11, 106:5,
106:20, 106:22,
111:22, 111:23,
112:8, 116:1,
127:14, 130:18,
131:4, 131:11,
131:13, 131:14,
132:7, 133:1, 133:15
neglect [2] - 49:5,
49:23
negligence [20] 18:23, 19:1, 19:19,
19:24, 70:18, 70:19,
70:22, 74:1, 80:17,
84:16, 94:12, 98:25,
99:22, 102:19,
105:18, 105:19,
114:4, 130:21,
130:22
negligent [11] 105:13, 107:19,
108:7, 108:14,
114:21, 122:8,
123:2, 123:3,
123:23, 130:18,
137:6
Neil [1] - 65:6
nervous [1] - 40:9
neutral [1] - 118:15
never [22] - 28:6, 34:4,
34:12, 34:13, 40:13,
45:7, 47:16, 48:14,
50:7, 52:9, 62:22,
70:8, 82:5, 83:23,
84:3, 98:4, 113:6,
116:4, 118:2, 131:9,
132:2, 135:6
nevertheless [2] 105:24, 127:24
new [5] - 55:7, 55:8,
79:10, 109:9, 120:15
New [1] - 88:14
NEW [9] - 1:8, 2:8,
2:16, 2:23, 3:22,
5:16, 5:23, 6:16,
8:10
Newman [4] - 41:7,
46:24, 124:23, 125:1
news [1] - 46:24
next [8] - 16:13, 69:10,
73:12, 74:15, 94:4,
113:9, 129:23,
141:14
Nicholas [1] - 69:2
night [8] - 38:7,
111:18, 116:18,
119:22, 123:21,
19
138:16, 140:24,
141:23
nightmare [3] - 60:17,
60:21, 127:22
nine [9] - 39:15, 43:18,
48:15, 87:7, 102:1,
114:2, 117:12,
121:14, 123:11
NINTH [1] - 3:11
NO [3] - 1:8, 1:11, 1:14
no-salt [2] - 59:14,
59:20
Noble [1] - 120:2
nobody [2] - 51:3,
107:11
nonconformity [2] 39:11, 39:22
none [6] - 90:5, 90:6,
99:13, 103:16,
112:2, 137:25
nonetheless [2] 15:13, 64:14
nonexistence [1] 93:2
nonexistent [2] 92:24, 93:22
NONJURY [1] - 1:20
noontime [1] - 142:16
NORFOLK [1] - 7:8
normal [3] - 24:24,
98:16, 108:16
Norske [1] - 39:18
North [2] - 102:1,
121:5
NORTH [1] - 5:11
notch [1] - 120:5
note [2] - 24:9, 24:20
noted [2] - 19:5, 48:3
notes [3] - 21:17,
115:22, 128:21
nothing [15] - 24:6,
93:23, 94:21, 95:24,
96:8, 98:7, 99:10,
112:23, 115:17,
116:11, 122:10,
129:18, 130:22,
132:16, 139:24
notice [2] - 30:17,
134:22
noticed [2] - 135:17,
136:10
notified [1] - 52:11
November [2] - 54:8,
110:1
Number [1] - 17:18
number [8] - 16:17,
17:15, 37:3, 109:14,
127:20, 129:12,
129:14, 134:16
numbered [1] - 143:9
numerous [6] - 16:20,

17:10, 22:3, 35:12,
40:14, 61:7
NW [1] - 6:4
O
O'Bryan [1] - 119:1
o'clock [3] - 134:11,
134:12, 135:3
O'KEEFE [1] - 2:8
O'ROURKE [2] - 4:10,
11:17
O'Rourke [1] - 11:17
oath [1] - 21:20
objection [1] - 23:7
objections [2] - 22:19,
23:1
objects [1] - 124:10
obligated [1] - 41:19
obligation [5] - 41:24,
57:6, 86:20, 113:20,
114:24
obligations [3] 51:15, 51:25, 52:15
observed [1] - 48:1
obvious [3] - 88:11,
95:20, 96:6
occasions [4] - 45:6,
47:13, 60:12, 66:15
occur [1] - 20:21
occurred [7] - 18:21,
30:15, 31:24, 35:11,
70:25, 90:23, 109:13
occurrence [1] - 50:2
occurring [1] - 15:14
ocean [1] - 88:15
October [2] - 46:23,
56:6
OF [14] - 1:2, 1:6,
1:12, 1:14, 1:20, 4:4,
4:8, 4:15, 4:21, 5:3,
5:8, 5:9, 5:10
off-center [1] - 42:3
offer [1] - 101:20
offered [1] - 117:5
office [1] - 53:5
OFFICE [5] - 2:4, 4:18,
5:3, 5:8, 5:12
officer [5] - 35:5, 35:8,
35:9, 40:8, 40:11
offices [1] - 52:17
OFFICIAL [1] - 8:8
Official [2] - 143:5,
143:14
officials [1] - 118:16
offshore [6] - 16:5,
28:7, 34:19, 35:2,
38:24, 114:4
OFFSHORE [1] - 6:13

Offshore [1] - 48:2
often [1] - 47:19
Oil [2] - 17:20, 98:3
OIL [2] - 1:5
oil [51] - 10:14, 16:14,
19:21, 19:22, 20:4,
20:16, 24:13, 42:13,
49:19, 74:7, 76:1,
81:17, 81:23, 83:22,
85:20, 85:21, 88:11,
88:23, 90:19, 92:3,
94:20, 94:24, 97:16,
97:17, 97:22, 98:11,
98:20, 103:25,
104:1, 104:19,
106:15, 106:16,
106:17, 109:9,
109:11, 109:17,
109:18, 109:19,
109:22, 109:23,
110:7, 113:25,
114:5, 119:17,
119:19, 131:13,
142:3
oiled [2] - 105:3, 109:8
oilfield [2] - 27:9, 28:4
oiling [3] - 109:13,
109:16, 110:20
oily [1] - 109:21
OIM [2] - 35:3, 39:21
OLSON [1] - 6:22
ominous [1] - 33:8
OMS [5] - 66:10, 67:8,
67:13, 69:17, 70:4
ON [1] - 1:6
on-the-job [1] 121:19
onboard [1] - 106:14
once [8] - 30:9, 31:11,
36:17, 44:17, 47:2,
63:1, 91:1, 121:21
One [5] - 16:18, 17:14,
19:25, 20:5, 114:18
one [79] - 18:13,
18:19, 20:10, 25:3,
25:22, 31:3, 34:12,
35:11, 36:24, 43:2,
44:1, 45:9, 46:1,
47:5, 48:15, 50:11,
55:18, 56:7, 59:5,
63:14, 65:9, 65:12,
69:25, 71:8, 71:16,
73:5, 73:11, 73:13,
78:6, 78:23, 80:7,
83:3, 83:21, 84:7,
85:4, 85:5, 87:10,
87:18, 90:9, 91:2,
91:18, 91:25, 93:20,
96:13, 98:1, 99:14,
101:12, 101:21,
108:4, 108:17,
109:6, 109:8,
109:15, 109:20,
110:21, 112:3,
114:4, 117:6,
117:19, 118:10,
118:15, 118:17,
118:22, 124:1,
124:11, 127:21,
128:3, 128:15,
129:1, 129:19,
130:13, 131:5,
131:6, 131:8,
133:22, 134:13,
134:15
ONE [2] - 5:21, 7:14
one-and-a-half [1] 69:25
one-half [1] - 109:6
ones [2] - 45:8, 82:22
ongoing [5] - 57:13,
57:19, 57:25, 60:11,
81:2
onshore [6] - 111:20,
112:4, 115:13,
115:25, 129:15,
130:15
onsite [2] - 78:8,
111:20
oops [1] - 123:20
OPA [6] - 17:20, 19:8,
19:16, 105:22,
106:10, 107:13
OPA's [1] - 105:23
open [3] - 63:12,
110:10, 141:9
opened [1] - 91:2
opening [13] - 13:10,
13:11, 13:17, 13:20,
20:20, 20:24, 25:22,
26:13, 26:14, 75:8,
85:10, 114:16,
142:19
OPENING [10] - 9:5,
9:6, 9:7, 9:8, 9:9,
26:16, 71:19,
100:25, 103:6,
111:12
operate [3] - 29:13,
47:6, 106:13
operated [1] - 139:22
operating [1] - 65:3
operation [26] - 34:14,
39:15, 41:6, 61:1,
61:6, 61:8, 62:12,
76:12, 76:18, 76:23,
77:1, 77:4, 77:12,
77:14, 78:3, 78:24,
80:7, 80:20, 80:23,
OFFICIAL TRANSCRIPT
81:18, 82:10, 88:4,

98:16, 130:16,
132:14, 140:12
operational [2] 46:13, 46:14
Operations [1] - 59:15
operations [15] 32:20, 44:2, 44:3,
45:4, 61:12, 61:13,
63:2, 64:21, 67:7,
67:11, 68:22, 106:4,
109:20, 132:9
operator [5] - 16:24,
26:22, 72:18, 89:16,
108:11
operators [3] - 50:19,
79:24, 86:5
opined [1] - 54:3
opinion [2] - 44:10,
142:12
opportunistic [1] 66:2
opportunity [4] 13:14, 76:19, 101:7,
111:1
opposed [1] - 17:23
order [8] - 20:20, 21:5,
46:4, 58:17, 67:5,
96:22, 97:19
Order [2] - 15:7, 23:23
ORDER [1] - 10:4
ordered [3] - 97:13,
125:8, 128:12
ordering [1] - 96:24
orders [1] - 99:5
ordinarily [1] - 14:2
ordinary [2] - 114:4,
130:21
organisms [1] - 100:7
organization [3] 39:18, 39:19, 65:15
organizational [3] 66:20, 66:22, 67:18
organize [1] - 114:16
original [1] - 41:1
originally [3] - 61:25,
62:6
origination [1] - 37:24
ORLEANS [9] - 1:8,
2:8, 2:16, 2:23, 3:22,
5:16, 5:23, 6:16,
8:10
Orleans [1] - 88:14
otherwise [1] - 37:25
outbursts [1] - 14:15
Outer [1] - 16:8
outlined [1] - 101:18
outside [2] - 21:20,
94:11
outstanding [2] -
20
68:6, 68:7
over-speeding [1] 37:13
overall [1] - 118:19
overarching [1] 35:15
overboard [2] 131:25, 136:25
overdue [2] - 106:23,
106:24
overflow [5] - 15:11,
15:18, 24:24, 25:20,
71:8
overlapping [1] 19:18
overloaded [1] - 44:22
overriding [2] - 36:25,
39:7
overrode [1] - 36:21
oversee [1] - 65:13
overview [1] - 13:15
overwhelmed [3] 36:10, 38:15, 136:22
overwhelming [2] 29:9, 116:22
overworked [1] 55:14
own [37] - 27:11,
27:25, 32:20, 44:5,
54:16, 55:24, 66:13,
76:25, 77:3, 78:19,
81:1, 81:2, 81:23,
83:6, 83:15, 83:19,
84:1, 84:2, 84:19,
85:2, 85:9, 86:11,
86:21, 88:2, 90:5,
90:8, 92:13, 93:16,
95:2, 97:14, 98:6,
103:19, 108:4,
114:14, 119:17,
127:25, 131:10
owned [2] - 17:1,
40:20
owner [12] - 18:2,
18:6, 18:7, 18:11,
18:14, 18:20, 18:24,
19:3, 26:21, 72:17,
106:12, 107:14
owners [1] - 39:20
ownership [1] - 85:12
P
p.m [16] - 14:4, 74:6,
74:21, 90:14, 94:15,
96:17, 98:9, 98:12,
98:19, 111:15,
111:25, 115:7,
116:18, 134:8,
138:13, 142:22
P.O [1] - 4:12
pad [1] - 111:8
page [2] - 24:2, 82:17
PAGE [1] - 9:3
pages [3] - 69:25,
82:15
paid [4] - 55:6, 99:9,
99:14, 113:16
Paine [1] - 60:6
PALMINTIER [1] 3:14
PAN [1] - 2:15
panic [1] - 141:21
panicked [1] - 140:20
panicking [1] - 141:10
pants [4] - 61:3, 76:7,
77:13, 132:13
paranoia [3] - 61:5,
76:8, 77:6
pardon [2] - 79:3,
89:19
Park [1] - 88:14
part [8] - 13:13, 14:24,
22:14, 27:1, 103:12,
112:4, 122:12,
122:15
partially [1] - 31:22
participate [1] - 68:15
participated [1] 40:25
participating [1] 16:17
particular [4] - 15:25,
20:10, 41:19, 46:14
particularly [5] - 19:8,
19:18, 22:22, 32:1,
86:17
parties [19] - 13:10,
13:25, 14:19, 16:17,
18:12, 21:18, 22:1,
22:3, 22:6, 22:19,
23:10, 24:9, 24:15,
26:5, 72:3, 72:8,
72:14, 103:15,
118:15
partly [1] - 49:5
partners [1] - 102:21
parts [1] - 41:2
party [6] - 13:15,
18:17, 21:11, 21:14,
107:16, 107:17
party's [1] - 16:1
pass [1] - 98:11
pass/fail [1] - 91:6
passed [2] - 68:3,
97:22
passive [2] - 37:25,
38:1
past [5] - 31:4, 60:24,
64:4, 66:9, 120:13

Pat [1] - 119:1
patch [1] - 132:1
Patrick [1] - 66:1
pattern [1] - 31:11
paul [1] - 11:4
PAUL [1] - 2:14
Paul [1] - 43:25
pay [3] - 58:13, 58:16,
99:12
paying [1] - 57:4
Payne [2] - 65:22,
68:14
penalize [1] - 105:17
penalizes [1] - 105:17
penalties [3] - 17:21,
20:12, 84:14
penalty [1] - 19:21
pending [2] - 18:5,
18:7
penetrate [1] - 59:18
PENNSYLVANIA [1] 6:4
People [1] - 76:22
people [38] - 36:23,
38:7, 47:7, 74:17,
77:17, 77:19, 77:23,
78:1, 81:8, 81:15,
87:19, 93:12, 98:19,
98:20, 99:25, 100:3,
100:5, 100:12,
100:18, 104:21,
114:1, 117:17,
119:1, 119:16,
119:18, 119:19,
119:21, 124:19,
125:5, 130:7, 132:4,
132:9, 133:18,
134:16, 138:3,
140:25, 141:20
people's [1] - 77:24
PEPPER [1] - 8:8
Pepper [3] - 143:3,
143:12, 143:13
per [1] - 87:12
percent [9] - 58:18,
64:24, 107:14,
109:11, 109:13,
109:15, 110:2,
126:24, 127:2
percipient [1] - 93:4
perfectly [2] - 84:21,
101:15
perform [6] - 56:2,
62:3, 62:22, 67:17,
97:19, 108:2
performance [9] 29:3, 32:21, 44:12,
56:11, 64:13, 64:18,
119:4, 125:24,
142:12
Performance [3] 43:25, 47:24, 48:11
performed [7] - 29:18,
30:5, 44:20, 55:17,
55:20, 96:1, 128:6
performing [3] 30:24, 35:9, 119:4
perhaps [1] - 141:24
period [2] - 122:13,
134:24
perished [1] - 121:15
permanently [1] 16:15
permit [2] - 41:5,
133:11
permits [1] - 18:2
person [6] - 21:25,
33:21, 33:25, 35:4,
65:12, 110:6
personally [2] - 104:6,
125:1
personnel [12] 28:17, 38:8, 44:21,
47:18, 49:15, 49:17,
50:14, 60:16, 62:21,
65:10, 65:17, 106:13
perspectives [1] 93:7
pervaded [1] - 78:23
Petition [1] - 10:16
PETITION [1] - 1:12
petroleum [2] - 27:7,
60:3
Petroleum [1] - 55:21
Phase [6] - 16:18,
17:14, 19:25, 20:5,
20:18, 114:18
phase [9] - 13:24,
14:1, 20:11, 20:12,
20:15, 30:21,
101:12, 107:16
phases [2] - 100:10,
100:16
phenomenon [3] 93:2, 93:9, 93:17
Phil [1] - 13:3
philosophy [2] 43:23, 47:20
phone [10] - 14:11,
15:3, 74:21, 75:1,
96:21, 97:6, 98:15,
98:19, 99:19, 112:25
phones [1] - 14:9
photographs [1] 14:22
phrase [2] - 50:10,
124:8
piece [8] - 40:19, 41:8,
41:10, 75:24, 84:23,
OFFICIAL TRANSCRIPT
90:1, 125:16, 141:2

pieces [4] - 84:18,
84:21, 85:12, 95:17
pipe [27] - 50:1, 50:9,
50:11, 91:10, 91:13,
91:25, 92:1, 92:17,
94:2, 95:9, 95:10,
96:12, 112:15,
113:13, 133:2,
133:4, 133:22,
134:1, 134:9,
135:20, 135:23,
135:25, 136:4,
136:8, 139:12,
139:17, 139:20
pipes [2] - 91:10,
91:23
piping [2] - 42:3,
139:23
pit [3] - 51:19, 57:2,
125:20
place [17] - 25:16,
32:25, 53:15, 57:18,
58:3, 63:8, 64:9,
87:3, 111:16, 121:5,
123:11, 123:12,
123:19, 126:20,
127:9, 130:3, 139:4
placed [3] - 14:10,
59:8, 63:20
placement [1] - 72:23
places [1] - 43:14
plaintiff [6] - 11:6,
19:9, 20:10, 72:10,
80:12, 99:17
PLAINTIFFS [1] - 2:3
plaintiffs [5] - 16:18,
18:13, 19:12, 101:16
plaintiffs' [2] - 11:24,
122:25
Plaintiffs' [2] - 20:23,
26:19
plan [6] - 22:5, 23:12,
60:23, 101:19,
131:13, 132:19
planned [3] - 62:6,
131:9
planning [4] - 47:25,
71:2, 106:4, 130:25
plans [2] - 26:8, 64:23
play [1] - 22:1
played [3] - 69:18,
117:22, 126:1
playing [1] - 67:15
PLC [1] - 5:20
plea [2] - 130:20
pleas [1] - 113:22
Pleasant [1] - 38:18
pleasure [1] - 118:6
pled [3] - 113:24,
21
114:4, 114:8
plug [4] - 61:19,
62:15, 131:14,
132:21
plus [3] - 18:5, 50:11,
80:8
pocket [1] - 82:9
Pod [1] - 51:3
pods [1] - 42:24
point [24] - 37:24,
42:7, 43:10, 51:7,
75:12, 78:20, 86:17,
87:12, 87:18, 88:10,
88:13, 99:13,
101:24, 102:8,
110:8, 113:3,
117:21, 118:7,
124:13, 124:18,
125:25, 126:17,
130:19, 137:4
pointed [3] - 82:14,
84:13, 89:12
pointer [2] - 86:25,
89:9
pointless [1] - 67:17
points [1] - 101:20
policies [1] - 47:21
policy [4] - 14:25,
36:3, 38:4, 136:16
polluted [1] - 105:2
Pollution [1] - 17:20
pollution [4] - 35:1,
35:18, 39:2, 104:24
poor [3] - 48:10,
56:11, 61:17
poorly [4] - 36:7, 40:6,
53:17, 54:4
popped [1] - 135:18
pore [2] - 46:18, 59:19
port [1] - 48:14
portion [1] - 58:15
posed [1] - 33:12
position [1] - 53:4
positioning [4] - 35:5,
35:9, 40:7, 40:11
positive [2] - 32:5,
62:11
possibility [2] - 23:7,
121:1
possible [3] - 15:4,
93:17, 104:2
post [3] - 18:5, 57:5,
109:25
POST [3] - 2:4, 4:18,
5:12
post-casualty [1] 18:5
post-Hurricane [1] 109:25
posted [5] - 15:9,
23:15, 23:17, 23:20,

24:6
potential [10] - 31:6,
32:3, 37:10, 42:11,
42:17, 43:5, 53:23,
66:7, 80:10, 138:9
potentially [2] - 33:17,
92:3
pounds [10] - 87:12,
87:14, 87:15, 87:16,
92:17, 109:21,
109:22, 109:23,
110:1
pour [1] - 62:9
pouring [3] - 62:9,
128:10, 128:13
power [6] - 50:18,
50:21, 81:19, 81:22,
99:2, 139:11
powered [2] - 43:6,
50:17
powerful [1] - 139:11
PowerPoint [1] - 47:9
POYDRAS [4] - 2:15,
5:22, 6:16, 8:9
practically [1] - 28:4
practice [4] - 27:10,
76:16, 77:5, 133:2
practices [2] - 32:5,
79:22
preached [1] - 122:3
precautions [3] 88:20, 108:19,
108:22
preceding [2] - 26:3,
60:18
precious [1] - 100:19
precisely [4] - 89:15,
116:5, 117:6, 121:11
preclude [1] - 23:7
predictable [1] 101:21
predicted [1] - 66:25
prediction [1] - 132:13
preliminary [1] - 26:12
prematurely [1] 52:13
prepared [2] - 22:3,
139:1
preparedness [1] 30:20
preparing [1] - 16:6
presence [1] - 62:25
present [11] - 21:7,
21:9, 21:12, 21:16,
53:23, 67:15, 75:10,
84:19, 84:22, 91:8,
121:13
presentation [4] 15:12, 15:16, 21:18,
71:3
presented [1] - 138:22
president [5] - 29:2,
32:20, 65:1, 65:6,
70:10
President [1] - 57:15
press [11] - 15:21,
22:10, 22:21, 23:4,
23:20, 24:17, 24:20,
25:12, 25:14, 25:17,
103:21
pressure [97] - 27:2,
28:9, 28:11, 35:23,
36:1, 36:10, 41:15,
42:13, 42:16, 46:15,
50:10, 52:1, 53:20,
58:10, 58:19, 59:8,
59:13, 59:19, 60:13,
61:17, 62:11, 62:20,
72:23, 74:3, 78:15,
83:1, 83:24, 84:6,
86:7, 86:8, 86:19,
86:21, 87:9, 87:15,
87:16, 88:8, 90:7,
90:15, 90:16, 90:22,
91:3, 91:8, 91:10,
91:14, 91:20, 91:23,
92:1, 92:3, 92:11,
92:15, 92:17, 92:23,
93:19, 94:10, 94:16,
94:24, 95:7, 95:8,
95:9, 95:10, 95:11,
95:21, 96:5, 96:12,
97:19, 97:21, 98:6,
99:6, 99:11, 106:5,
106:20, 106:22,
111:22, 111:23,
112:8, 112:15,
113:12, 113:13,
116:2, 127:15,
130:18, 131:4,
131:11, 132:7,
133:1, 133:4, 133:6,
133:20, 133:25,
134:2, 134:4,
135:18, 135:19,
136:4, 136:8
pressured [1] - 65:3
pressures [5] - 46:18,
64:12, 91:10, 92:12,
133:24
pressuring [3] 85:21, 90:19, 92:4
pretrial [1] - 17:24
pretty [1] - 126:13
prevent [6] - 85:21,
87:3, 88:24, 94:20,
99:2, 102:6
preventable [2] 70:12, 101:22
prevented [7] - 34:17,

38:23, 74:14, 74:23,
90:10, 94:18, 97:17
preventer [18] - 17:6,
31:4, 40:18, 40:19,
41:1, 41:4, 43:13,
45:10, 45:12, 46:1,
48:23, 49:4, 49:9,
49:17, 50:6, 50:8,
102:6, 139:1
prevention [1] - 29:10
preview [1] - 13:15
previous [5] - 32:18,
64:8, 66:21, 67:15,
96:19
previously [2] - 20:19,
59:22
primarily [2] - 15:21,
19:22
primary [5] - 46:11,
49:22, 72:15, 75:12,
95:17
print [1] - 82:19
Pritchard [1] - 60:3
private [4] - 16:20,
19:12, 20:22, 101:16
privilege [4] - 101:5,
102:25, 114:10,
114:13
privity [3] - 18:22,
18:24, 19:3
proactive [1] - 43:21
problem [22] - 29:8,
31:14, 32:18, 34:16,
36:18, 39:14, 39:25,
40:2, 50:14, 53:6,
67:5, 71:4, 71:9,
71:16, 105:16,
112:10, 115:24,
118:4, 119:11,
119:12, 129:14,
135:18
problematic [1] 112:5
problems [14] - 30:10,
32:9, 33:2, 46:7,
49:22, 52:20, 68:11,
77:14, 87:6, 89:23,
117:23, 124:18,
125:2, 126:21
procedure [6] - 22:20,
27:2, 60:23, 62:21,
108:15, 108:16
procedures [9] 28:21, 28:24, 29:20,
30:4, 32:13, 79:24,
120:15, 127:4,
141:22
proceed [7] - 29:11,
60:2, 71:17, 113:2,
OFFICIAL TRANSCRIPT
115:15, 116:13,
128:12
proceeded [1] - 94:4
proceeding [3] - 18:9,
18:17, 25:4
proceedings [6] 15:22, 117:21,
118:7, 125:25,
126:17, 143:9
PROCEEDINGS [3] 1:20, 8:12, 10:1
process [23] - 57:17,
57:24, 58:4, 63:22,
63:24, 64:2, 64:13,
65:13, 65:20, 65:25,
66:10, 66:13, 66:16,
66:25, 67:5, 67:6,
67:16, 68:3, 69:22,
70:3, 85:18, 106:4,
124:3
processes [2] - 47:2,
47:14
produce [1] - 110:13
PRODUCED [1] - 8:13
production [13] 51:18, 52:7, 58:12,
58:20, 63:20, 64:7,
64:12, 64:15, 65:4,
65:24, 80:11, 85:19,
108:2
Production [4] 10:18, 58:15, 58:19,
65:7
PRODUCTION [3] 1:15, 5:19, 5:20
professional [1] 103:16
Professor [3] - 63:23,
130:14, 142:10
proffered [1] - 22:18
profit [8] - 58:18,
63:20, 77:25, 78:20,
80:11, 80:13, 80:18,
125:10
profits [5] - 64:16,
66:5, 77:16, 77:17
program [3] - 28:23,
66:11, 67:13
programs [3] - 120:2,
120:5, 120:20
progresses [1] - 22:4
prohibited [3] - 14:23,
14:25, 15:17
Project [1] - 47:17
project [1] - 58:24
projected [1] - 61:17
projects [1] - 65:6
promised [1] - 67:21
promotion [1] - 117:5
promptly [1] - 39:1
22
proof [2] - 21:5,

110:23
proper [7] - 14:13,
29:25, 35:8, 36:16,
44:11, 120:10,
141:19
properly [9] - 45:13,
46:4, 53:17, 89:18,
95:11, 112:16,
113:14, 117:1,
141:25
property [1] - 64:11
prophecy [1] - 76:11
prophetic [1] - 132:13
prophetically [4] 28:25, 29:12, 30:19,
69:3
proposed [1] - 93:1
proposition [1] 104:19
proprietary [1] - 54:13
prospect [1] - 16:24
protect [5] - 39:9,
89:13, 90:2, 96:23,
106:13
protecting [2] - 40:22,
49:2
protection [4] - 63:21,
64:7, 64:15, 65:24
protocol [1] - 63:13
protocols [1] - 55:23
proud [1] - 122:11
prove [9] - 19:3,
70:14, 70:18, 70:19,
70:21, 84:12,
102:19, 102:20,
130:19
proved [1] - 99:7
provide [12] - 17:3,
17:8, 22:21, 51:18,
52:5, 53:7, 53:21,
56:17, 57:7, 58:4,
86:6, 116:23
provided [2] - 15:23,
53:20
provides [1] - 67:10
proving [1] - 19:1
provision [1] - 57:17
PSC [18] - 10:22,
10:24, 11:1, 11:2,
11:3, 11:4, 11:7,
11:8, 11:9, 11:11,
11:20, 21:6, 21:15,
22:16, 34:2, 43:18,
130:17, 138:17
PSC's [2] - 112:17,
130:14
psi [1] - 93:18
public [15] - 15:6,
15:9, 15:21, 22:11,
22:21, 23:4, 23:15,

23:17, 23:20, 23:22,
23:24, 24:17, 25:13,
25:18, 103:22
published [1] - 82:12
pulled [2] - 56:9,
139:12
pulling [2] - 56:12,
61:18
pump [1] - 62:4
pumped [4] - 55:13,
55:14, 90:17, 131:23
pumping [3] - 52:1,
81:16, 85:20
pumps [4] - 113:10,
135:17, 135:19,
136:1
punitive [2] - 102:24,
106:1
purpose [2] - 85:20,
116:1
purposes [3] - 17:23,
17:24, 90:24
push [2] - 60:21,
68:17
pushed [1] - 80:4
pushing [1] - 141:10
put [14] - 47:9, 48:13,
61:10, 77:16, 81:15,
82:13, 86:18, 111:4,
114:8, 125:10,
126:22, 137:22,
140:11, 142:10
putting [4] - 64:15,
100:15, 113:16,
116:7
puzzle [1] - 84:18
Q
QC [1] - 128:23
quality [1] - 52:25
quantity [1] - 20:16
questioned [1] - 21:19
questions [8] - 19:7,
23:21, 24:8, 52:24,
114:17, 115:1,
115:9, 141:20
quick [1] - 47:11
quickly [3] - 32:6,
36:10, 138:5
quote [15] - 61:2,
76:18, 79:1, 79:2,
79:3, 79:4, 87:20,
87:24, 88:1, 89:17,
89:18, 95:25,
130:15, 132:12
quoted [1] - 126:11
R
RACHEL [2] - 4:11,
6:19
Rachel [2] - 12:12,
114:14
ragged [2] - 79:2, 96:3
raining [1] - 56:24
raise [2] - 58:17, 58:19
raised [2] - 39:22,
140:20
ram [4] - 42:7, 42:10,
49:24, 137:2
rams [14] - 42:2, 42:4,
42:8, 42:19, 49:8,
49:9, 49:18, 50:5,
50:8, 51:6, 137:10,
139:9, 139:14,
140:15
ran [3] - 50:18, 62:20,
137:22
Randy [4] - 31:1,
137:12, 137:14,
137:20
ranked [1] - 117:20
rapidly [1] - 42:14
rate [1] - 29:9
rather [10] - 31:14,
43:20, 46:13, 61:24,
63:13, 65:17, 66:3,
128:11, 129:24,
130:1
re [3] - 10:14, 10:15,
97:19
RE [2] - 1:5, 1:12
re-perform [1] - 97:19
reach [2] - 104:20,
106:15
reaching [1] - 23:3
reactive [1] - 43:20
read [4] - 15:10,
82:17, 91:25, 126:22
readiness [1] - 44:2
reading [2] - 91:14,
91:20
readjust [1] - 111:5
ready [4] - 52:11,
62:25, 68:25, 71:17
real [2] - 62:15, 110:18
reality [1] - 48:12
realize [2] - 139:3,
141:12
realized [3] - 41:22,
56:23, 115:14
really [6] - 24:6, 61:16,
68:19, 104:14,
107:4, 126:5
REALTIME [1] - 8:8
Realtime [2] - 143:3,
143:13
reason [8] - 84:7,
89:15, 97:13, 97:18,
102:22, 123:14,
136:18, 139:1
reasonable [1] - 94:11
reasons [1] - 127:10
reassess [1] - 57:12
rebuild [1] - 47:11
rebuttal [1] - 21:16
receive [2] - 44:14,
121:19
received [7] - 35:10,
40:13, 65:5, 68:2,
127:6, 129:12,
140:10
recent [4] - 23:23,
29:4, 47:4, 47:23
recess [6] - 13:18,
71:11, 71:14,
142:17, 142:20,
142:23
RECESS....................
................. [1] - 9:10
recessing [1] - 14:3
rechargeable [1] 108:8
reckless [6] - 43:19,
70:22, 73:3, 73:23,
80:16, 81:10
recklessly [3] - 35:20,
57:5, 83:2
recklessness [2] 81:6, 82:21
recognize [2] - 28:18,
63:5
recognized [3] 31:20, 47:24, 57:25
recognizes [1] 105:20
recommendation [1] 30:23
recommendations [3]
- 30:7, 67:4, 108:3
recommended [6] 30:1, 51:21, 62:5,
86:15, 123:24,
141:11
Record [1] - 15:8
record [6] - 10:21,
22:17, 75:9, 118:12,
122:11, 143:8
RECORDED [1] - 8:12
recorded [1] - 21:21
recording [1] - 14:23
recordkeeping [2] 43:1, 43:4
recounted [1] - 33:7
recovered [3] 109:17, 110:1, 110:3
OFFICIAL TRANSCRIPT
recreation [2] - 100:6,

105:8
red [3] - 27:12,
135:20, 139:25
REDDEN [1] - 7:11
redesigned [1] - 108:6
redoing [1] - 79:10
reduce [2] - 69:8, 69:9
reduced [1] - 61:23
reducing [1] - 35:1
redundant [1] - 43:11
reemphasize [1] 125:9
refer [5] - 19:11,
19:12, 23:22, 36:23,
131:23
reference [5] - 30:1,
87:12, 88:13,
110:12, 131:11
referred [7] - 106:25,
107:20, 123:1,
123:10, 124:5,
124:11, 128:17
refitting [1] - 48:15
reflected [4] - 31:12,
64:2, 64:3, 133:16
reflects [1] - 63:25
refusal [2] - 40:17,
48:18
refused [9] - 30:6,
62:5, 62:12, 62:23,
66:9, 77:8, 81:5,
109:7, 130:15
refusing [1] - 53:6
Regan [1] - 12:2
REGAN [2] - 6:8, 12:2
regard [1] - 24:20
regarded [1] - 118:22
regarding [9] - 13:21,
15:6, 20:15, 21:17,
30:20, 43:1, 53:10,
67:23, 68:2
regardless [1] - 54:25
Register [2] - 33:1,
33:3
REGISTERED [1] - 8:9
Registered [1] - 143:3
registered [1] - 143:14
regular [1] - 140:10
regulation [2] - 88:19,
89:16
regulations [2] 79:22, 79:23
reinforced [1] - 120:20
reject [1] - 94:1
related [3] - 17:4,
20:5, 23:13
RELATES [1] - 1:10
relating [4] - 20:1,
20:7, 20:14, 33:10
23
relatively [1] - 64:9

relearned [1] - 122:5
release [3] - 20:4,
30:16, 32:2
released [1] - 136:4
Reliability [1] - 47:17
reliable [1] - 67:11
reliance [2] - 63:8,
105:6
relief [1] - 16:16
relived [1] - 122:5
rely [1] - 86:5
relying [1] - 115:19
remainder [1] - 142:17
remained [2] - 36:19,
67:24
remaining [1] - 21:12
remains [1] - 99:24
remark [1] - 137:19
remarks [1] - 114:16
remember [1] - 137:16
remind [1] - 14:21
reminded [2] - 76:18,
121:1
remotely [2] - 80:14,
115:17
remove [1] - 113:2
removed [6] - 38:2,
109:10, 109:11,
109:20, 109:22,
109:24
RENAISSANCE [1] 7:20
renowned [1] - 66:13
repair [3] - 43:18,
68:7, 68:22
repaired [1] - 71:16
repairing [1] - 44:15
repairs [4] - 44:20,
45:24, 48:15, 68:13
repeat [1] - 91:23
repeated [1] - 80:20
repeatedly [2] - 60:4,
122:5
replaced [1] - 133:8
replied [1] - 69:2
Report [9] - 63:8,
63:10, 63:16, 82:14,
83:6, 85:2, 93:8,
94:24, 98:10
report [15] - 22:12,
22:14, 29:23, 31:19,
33:3, 33:8, 33:15,
92:8, 93:16, 120:7,
120:22, 122:17,
122:18, 129:13,
130:15
Report's [1] - 83:21
reported [5] - 37:19,
60:12, 75:17, 75:20,
120:14
REPORTER [3] - 8:8,
8:8, 8:9
Reporter [7] - 143:3,
143:4, 143:5,
143:13, 143:14,
143:14
REPORTER'S [1] 143:1
reporters [1] - 24:10
reports [4] - 23:13,
53:1, 123:8, 123:17
represent [1] - 114:10
representation [2] 44:5, 85:16
represented [3] 20:22, 42:7, 63:10
requested [3] - 39:25,
51:10, 68:15
requests [1] - 38:18
require [2] - 59:17,
79:24
required [16] - 33:21,
37:1, 41:14, 52:3,
52:5, 55:12, 55:21,
57:10, 57:18, 57:24,
58:6, 60:11, 63:3,
88:19, 89:15
requirement [3] 34:11, 57:19, 58:3
requirements [4] 18:7, 46:14, 66:10,
127:25
requires [1] - 59:21
requiring [5] - 36:5,
37:17, 39:23, 53:24,
68:6
requisite [1] - 34:22
rerun [1] - 96:22
reserved [3] - 24:21,
25:12, 25:16
reservoir [1] - 93:19
resonated [1] - 48:3
resources [1] - 105:7
RESOURCES [1] - 4:9
respect [4] - 19:8,
65:3, 114:17, 122:9
respected [3] - 39:19,
84:1, 117:14
respectfully [1] 70:13
responded [2] - 68:23,
76:15
response [8] - 20:15,
77:5, 88:8, 106:7,
114:7, 126:7, 137:7,
141:25
responsibilities [3] 39:21, 120:25,
121:20
responsibility [22] 27:3, 28:3, 33:22,

34:6, 39:8, 46:3,
52:1, 77:10, 81:1,
81:13, 86:20, 86:24,
88:7, 89:7, 95:18,
98:2, 99:2, 99:8,
104:7, 105:12,
110:17, 124:18
responsible [6] - 41:9,
51:17, 70:25,
110:19, 110:20,
130:23
responsive [1] - 137:6
rest [3] - 13:11, 25:17,
74:22
restore [2] - 100:19,
105:10
restructuring [1] 67:18
rests [1] - 28:4
result [9] - 27:19,
48:7, 51:2, 98:24,
99:1, 99:25, 113:22,
123:19, 136:5
resulted [1] - 64:24
resulting [1] - 60:19
results [9] - 48:3,
52:10, 60:13,
107:24, 111:24,
112:12, 128:23,
129:2, 131:1
resume [1] - 13:18
retained [1] - 66:14
retrievable [1] 109:17
retrospect [1] - 104:12
return [1] - 116:25
returns [3] - 32:6,
35:25, 60:19
revealed [1] - 30:19
reverse [1] - 97:7
Revette [4] - 116:19,
117:8, 119:23,
121:14
reviewed [1] - 120:4
RICHARD [1] - 7:3
Richard [3] - 12:13,
27:7, 114:14
rig [89] - 10:14, 16:12,
28:17, 29:17, 30:3,
30:9, 32:17, 33:22,
37:11, 41:23, 41:24,
43:9, 44:14, 44:22,
44:24, 50:14, 59:8,
62:25, 68:4, 69:3,
74:5, 74:8, 74:10,
75:3, 75:14, 78:8,
78:13, 78:25, 80:24,
81:3, 81:20, 82:24,
82:25, 84:8, 85:19,

86:18, 87:19, 87:23,
88:13, 89:2, 89:21,
94:7, 94:17, 94:25,
95:4, 95:16, 95:21,
96:1, 96:23, 97:2,
97:3, 97:9, 97:16,
98:14, 98:19, 99:19,
102:14, 104:8,
106:23, 107:20,
111:17, 118:4,
118:5, 118:14,
118:18, 118:19,
119:4, 119:9,
119:11, 119:15,
119:19, 120:21,
122:19, 125:2,
125:20, 126:10,
127:6, 127:8, 129:9,
131:18, 132:20,
138:16, 139:11,
141:8, 142:3, 142:7
Rig [1] - 43:25
RIG [1] - 1:5
rig's [2] - 35:21, 77:11
rig-based [2] - 82:25,
84:8
right-hand [4] - 90:25,
91:14, 91:18, 91:19
rigs [8] - 27:20, 31:14,
31:25, 43:14, 46:23,
118:10, 118:23,
125:6
ringing [1] - 79:7
rise [4] - 10:7, 71:13,
85:5, 142:21
riser [16] - 28:15,
28:18, 29:16, 29:24,
30:3, 31:24, 32:3,
32:16, 49:11, 62:14,
62:16, 88:15, 94:5,
97:23, 98:12, 98:21
risers [1] - 31:21
Risk [1] - 63:19
risk [30] - 29:11,
29:18, 30:4, 33:12,
48:1, 54:20, 57:12,
57:24, 58:4, 58:7,
61:22, 63:3, 63:22,
65:23, 66:1, 66:3,
66:6, 66:13, 69:9,
70:6, 70:8, 78:2,
86:14, 104:19,
112:23, 116:7,
119:17, 127:23,
130:2, 138:10
risked [1] - 59:5
riskiest [1] - 69:17
risks [17] - 46:17,
53:23, 64:1, 66:7,
OFFICIAL TRANSCRIPT
67:16, 70:3, 86:10,

86:16, 101:25,
105:20, 112:5,
113:6, 127:11,
127:17, 130:6,
130:12, 130:16
risky [2] - 130:5,
130:10
Rivette [1] - 99:20
RMR [2] - 8:8, 143:13
road [1] - 80:23
ROBERT [2] - 2:11,
6:4
Robert [4] - 10:24,
28:1, 61:11, 61:12
Roberts [3] - 12:7,
13:6, 114:13
ROBERTS [4] - 6:19,
7:13, 12:7, 13:6
robust [1] - 127:7
role [4] - 16:1, 52:2,
67:16, 69:18
roles [1] - 120:24
Roman [1] - 94:7
Ronnie [1] - 53:12
room [4] - 25:10, 37:9,
37:12, 89:25
ROOM [2] - 4:6, 8:9
rooms [2] - 25:20,
81:7
rose [1] - 135:19
rotary [2] - 31:5, 32:2
ROUGE [2] - 3:15,
5:12
roughly [2] - 16:13,
88:13
Roy [32] - 10:22,
26:15, 26:18, 69:23,
71:23, 72:2, 76:3,
77:19, 78:5, 82:14,
89:12, 101:18,
102:18, 105:15,
106:9, 106:25,
111:10, 121:4,
122:6, 122:10,
123:1, 123:10,
123:15, 124:2,
124:5, 124:21,
125:11, 126:19,
134:20, 136:21,
140:2, 141:14
ROY [6] - 2:3, 2:3,
10:22, 26:17, 69:25,
70:2
ROY....................... [1]
- 9:5
rug [1] - 123:16
rule [1] - 102:23
rules [4] - 14:25, 15:2,
15:6, 15:17
24
rulings [1] - 15:24

run [5] - 43:23, 55:11,
62:23, 63:1, 107:23
running [5] - 43:5,
43:8, 52:7, 86:14,
140:6
rush [4] - 58:10, 59:9,
59:25, 61:20
rushing [1] - 138:1
RUSNAK [1] - 3:17
rsum [1] - 22:13
rsums [1] - 23:14
S
s/Cathy [1] - 143:12
sacrificed [1] - 77:23
saddest [1] - 97:11
safe [8] - 27:5, 44:4,
45:3, 60:14, 67:10,
79:25, 80:4, 86:5
safely [4] - 44:3,
106:13, 115:24,
116:25
safest [2] - 45:17,
104:2
safety [81] - 32:24,
33:5, 33:22, 34:6,
34:10, 35:6, 37:3,
37:7, 37:20, 40:19,
46:16, 46:20, 47:2,
47:10, 47:22, 48:17,
52:2, 57:8, 57:18,
57:24, 60:4, 61:23,
62:20, 63:21, 63:22,
63:24, 63:25, 64:2,
64:13, 64:16, 65:10,
65:11, 65:13, 65:16,
65:20, 65:21, 65:25,
66:6, 66:10, 66:13,
66:16, 66:24, 67:1,
67:5, 67:6, 67:16,
67:19, 67:23, 68:3,
68:4, 69:22, 70:3,
75:13, 77:10, 77:17,
77:23, 78:1, 78:9,
78:12, 78:20, 79:16,
79:22, 79:23, 80:2,
80:23, 90:16, 90:17,
96:16, 107:23,
116:14, 117:17,
117:24, 119:4,
122:9, 124:3, 125:9,
125:10, 127:1,
127:4, 127:6
Safety [2] - 33:20,
48:9
Sally [1] - 22:6
salt [5] - 59:14, 59:17,
59:18, 59:20, 59:22

Sam [1] - 55:24
same/adjoining [1] 33:11
SAN [2] - 3:5, 4:6
sanctions [1] - 15:3
sank [1] - 16:13
satisfied [2] - 44:3,
95:25
save [10] - 54:23,
61:22, 62:1, 63:1,
69:12, 77:24, 94:20,
108:25, 142:7
saved [10] - 39:2,
74:16, 74:17, 78:9,
78:10, 82:8, 97:16,
99:16
saving [2] - 47:19,
49:18
savings [1] - 82:9
saw [9] - 65:17, 92:17,
113:6, 113:10,
115:24, 126:3,
132:10, 136:11,
137:8
scenario [2] - 35:10,
40:13
schedule [3] - 59:3,
109:1, 138:1
scheduled [1] - 25:4
Schlumberger [1] 62:25
school [2] - 121:18,
121:22
Scofield [1] - 12:20
SCOFIELD [2] - 8:4,
12:20
SCOTT [1] - 4:10
Scott [1] - 11:12
scrap [1] - 97:4
scratch [1] - 54:19
screen [9] - 72:21,
74:8, 74:24, 79:14,
81:12, 83:5, 83:16,
83:20, 134:21
screens [6] - 15:12,
15:16, 25:21,
134:14, 134:25,
135:2
screwed [2] - 31:17,
126:10
Sea [2] - 102:2, 121:5
sea [3] - 42:25, 68:12,
136:20
seal [6] - 50:1, 50:5,
50:9, 54:5, 124:7,
136:13
sealed [1] - 16:15
seamen's [1] - 113:24
seat [5] - 61:2, 76:6,
77:13, 132:12,
141:11
seated [1] - 10:10
seating [1] - 25:17
seawater [2] - 27:6,
94:5
seaworthy [2] - 46:5,
107:1
second [13] - 21:9,
38:17, 73:5, 75:1,
83:12, 86:25, 99:19,
102:8, 104:16,
127:13, 129:23,
131:11, 131:14
SECREST [1] - 7:11
Section [1] - 17:21
section [2] - 30:24,
33:15
SECTION [2] - 4:9,
4:21
secure [1] - 27:5
securing [1] - 100:16
Security [1] - 48:9
Sedco [2] - 30:15,
121:4
see [31] - 14:5, 15:15,
22:23, 42:20, 50:15,
68:19, 73:13, 78:19,
82:21, 83:16, 85:2,
87:24, 88:5, 110:7,
119:6, 122:18,
122:21, 126:4,
131:7, 131:17,
133:20, 135:14,
135:16, 135:23,
136:1, 136:4, 136:8,
137:20, 139:7,
139:20, 141:1
seeing [1] - 126:7
seek [1] - 26:22
seeking [2] - 18:3,
60:15
seem [2] - 47:6,
140:25
seizure [1] - 15:3
selection [1] - 41:2
self [1] - 51:14
self-described [1] 51:14
semisubmersible [1] 28:21
send [1] - 119:19
Senior [2] - 74:9,
74:10
senior [12] - 31:1,
35:5, 35:7, 36:18,
40:10, 65:6, 81:5,
95:15, 96:13, 119:1,
124:16, 137:12
sense [4] - 61:7,
76:10, 93:6, 93:7

sensors [1] - 38:1
sent [6] - 46:24, 69:6,
75:23, 77:2, 132:15,
132:18
sentence [2] - 76:10,
129:23
separate [5] - 35:24,
51:5, 66:15, 84:11,
110:21
separator [7] - 35:21,
35:23, 36:4, 36:9,
36:13, 136:18,
136:22
September [3] - 68:22,
106:23, 109:25
Sepulvado [3] 117:19, 125:22,
133:2
sequence [2] - 59:17,
83:17
series [6] - 29:3,
61:21, 73:2, 73:22,
83:8, 127:11
serious [8] - 47:7,
49:5, 52:24, 61:18,
63:5, 63:14, 63:15,
69:1
seriously [2] - 43:2,
45:7
seriousness [2] 64:1, 99:24
served [1] - 37:23
service [5] - 38:2,
48:13, 81:17, 87:13,
104:25
services [3] - 17:4,
17:9, 51:15
SERVICES [1] - 7:17
SESSION [1] - 1:19
set [16] - 15:7, 28:22,
30:19, 33:17, 37:15,
37:25, 38:1, 87:4,
91:1, 94:6, 94:7,
124:20, 128:4,
128:8, 133:1, 136:17
sets [1] - 120:1
setting [1] - 62:14
seven [4] - 39:23,
40:1, 62:2
seventh [2] - 32:17,
62:16
several [4] - 15:11,
31:2, 36:21, 116:1
severally [2] - 106:11,
107:13
severe [3] - 87:5,
129:13, 138:9
severely [1] - 94:5
shack [8] - 56:24,
OFFICIAL TRANSCRIPT
113:1, 113:5,
116:20, 119:22,
134:10, 134:21,
135:4
shadow [1] - 99:15
shall [2] - 21:12, 21:15
shameful [1] - 113:20
shared [1] - 27:3
shareholders [2] 58:14, 58:18
SHARON [1] - 4:17
Shaw [1] - 65:6
SHAW [1] - 2:21
Shaw's [1] - 65:9
shear [16] - 42:2, 42:4,
42:7, 42:8, 42:18,
42:22, 49:8, 49:18,
49:24, 50:1, 50:5,
50:8, 50:9, 51:6,
139:14, 140:15
sheen [1] - 134:24
sheer [2] - 22:22,
23:10
Shelf [1] - 16:8
SHELL [1] - 5:21
Shell [1] - 125:3
shift [5] - 19:3, 72:14,
85:24, 113:19,
138:14
shifts [1] - 133:7
ship [1] - 131:19
ship's [1] - 46:2
shipmates [1] - 142:7
Shipowners' [2] 17:17, 18:1
shipping [1] - 55:7
shipyard [2] - 45:24,
68:13
shitty [1] - 79:4
shore [2] - 109:11,
131:19
shoreline [3] - 100:7,
109:7, 109:8
shores [3] - 104:20,
109:12, 109:18
short [7] - 33:21,
47:19, 59:4, 64:9,
82:9, 99:18, 110:20
short-term [1] - 64:9
shortened [1] - 128:9
shorter [1] - 22:2
shortly [5] - 90:13,
96:17, 117:5,
133:17, 135:22
shouts [1] - 38:13
show [149] - 13:16,
26:23, 27:17, 28:2,
28:16, 32:22, 34:21,
35:19, 36:7, 36:12,
36:20, 39:6, 41:17,
25
41:22, 45:9, 46:11,

46:19, 47:14, 48:14,
48:18, 49:4, 49:14,
49:16, 50:4, 51:16,
52:12, 52:19, 53:16,
54:1, 54:23, 55:10,
55:16, 56:3, 56:12,
56:19, 56:25, 57:16,
57:20, 58:5, 58:14,
59:7, 60:12, 61:20,
63:6, 63:9, 63:18,
64:14, 64:19, 66:4,
66:8, 67:12, 67:22,
67:25, 68:9, 69:12,
72:13, 72:20, 73:2,
73:22, 73:24, 74:6,
74:13, 74:20, 74:25,
75:5, 75:15, 75:16,
75:19, 75:22, 76:14,
76:16, 76:24, 77:3,
77:7, 77:12, 77:16,
77:18, 78:4, 78:16,
78:24, 79:6, 79:9,
79:12, 79:20, 80:16,
80:22, 81:4, 81:9,
81:25, 82:7, 83:1,
86:2, 86:9, 86:22,
87:18, 87:22, 88:2,
88:22, 89:1, 90:5,
90:13, 90:24, 91:9,
91:22, 91:25, 92:16,
93:8, 93:24, 94:3,
94:13, 94:14, 94:23,
95:3, 95:6, 95:17,
95:19, 95:23, 96:2,
96:5, 96:8, 96:11,
96:23, 97:3, 97:5,
97:11, 97:19, 97:25,
98:8, 98:10, 98:18,
98:23, 99:7, 99:15,
101:24, 102:6,
102:10, 105:11,
105:24, 106:10,
107:8, 107:12,
108:1, 112:8, 115:2,
120:18, 122:10,
127:25, 128:5, 139:2
showed [3] - 107:25,
128:7, 128:22
showing [2] - 27:23,
51:1
shown [3] - 65:21,
81:10, 115:5
shows [7] - 18:21,
27:22, 75:11,
116:23, 122:7,
135:13, 139:5
Shushan [2] - 22:6,
103:9
Shut [1] - 99:21
shut [24] - 26:24,

27:16, 27:18, 28:18,
30:11, 32:12, 76:25,
77:4, 80:6, 89:8,
96:6, 96:24, 97:20,
97:21, 112:1,
112:19, 113:9,
125:18, 126:4,
135:17, 136:1,
137:2, 137:17
shut-in [1] - 32:12
shutdown [7] - 37:1,
37:6, 37:8, 37:18,
38:9, 38:11, 125:9
SHUTLER [1] - 4:17
shutting [5] - 30:12,
32:6, 37:13, 137:18,
137:19
side [9] - 11:24, 29:10,
72:10, 90:25, 91:18,
91:19, 92:2, 92:18,
139:23
signal [1] - 50:17
signalling [2] - 37:18,
37:24
signed [2] - 57:15,
133:17
significant [2] - 45:9,
89:22
significantly [3] 39:11, 54:12, 63:4
signs [8] - 51:19,
56:20, 57:3, 57:4,
108:22, 134:10,
134:13, 134:16
silent [1] - 14:10
similar [1] - 115:17
simple [11] - 75:6,
77:8, 82:2, 82:5,
84:14, 90:9, 91:6,
98:1, 99:21, 133:19,
133:21
simplify [1] - 19:10
simply [4] - 14:25,
86:2, 90:22, 139:2
Sims [9] - 60:23,
75:20, 75:23, 76:4,
76:14, 76:16, 77:2,
132:15, 132:16
Sims's [2] - 77:3, 77:7
simultaneous [1] 63:2
SINCLAIR [1] - 5:5
single [17] - 42:6,
42:7, 42:10, 43:9,
48:15, 51:6, 51:7,
55:12, 75:24, 84:7,
85:4, 85:5, 99:13,
120:7, 124:1, 142:1,
142:8
sinking [1] - 20:3

Site [1] - 74:10
site [28] - 16:24, 61:1,
75:17, 76:5, 76:6,
87:19, 88:17, 92:22,
93:2, 93:14, 93:21,
93:24, 95:4, 95:14,
95:20, 95:24, 96:10,
96:16, 96:21, 98:16,
99:5, 111:20,
115:14, 117:20,
117:25, 125:23,
133:3, 133:7
sitting [2] - 55:4,
130:7
situation [6] - 29:1,
29:21, 40:3, 49:1,
50:3, 60:1
situations [1] - 42:2
six [8] - 21:4, 31:24,
43:24, 62:14, 69:7,
123:1, 123:11, 131:3
skim [1] - 85:11
slashed [1] - 64:22
slice [5] - 83:11,
83:16, 87:1, 89:11,
98:6
slices [4] - 83:22,
88:9, 89:7, 90:4
slide [5] - 90:25,
91:14, 91:19, 92:2,
92:19
SLIDELL [1] - 3:12
slightly [2] - 125:18,
134:11
sliver [2] - 99:15,
122:24
slurries [1] - 121:3
slurry [6] - 52:4, 52:6,
54:17, 55:13,
107:22, 107:25
small [3] - 35:24,
68:24, 122:23
smog [1] - 110:8
smoke [2] - 57:2, 72:1
snapshot [2] - 75:10,
75:11
social [1] - 104:25
sold [3] - 17:5, 50:5,
50:6
sole [3] - 52:1, 65:13,
116:1
solve [1] - 104:11
someone [1] - 71:9
something's [1] - 47:1
sometimes [2] 80:18, 86:3
somewhere [1] 114:15
soon [2] - 76:19,
76:21
sorry [3] - 12:22,
68:17, 73:5
sort [4] - 115:4,
122:10, 138:17,
141:1
sorts [1] - 14:15
souls [1] - 74:21
sound [3] - 40:7, 71:9,
73:6
Sound [1] - 105:4
sounding [2] - 37:5,
37:12
sounds [1] - 73:17
source [3] - 37:10,
37:14, 93:1
SOUTH [1] - 6:24
south [1] - 16:8
space [1] - 25:12
spacer [3] - 62:18,
108:16, 131:24
spacers [2] - 51:22,
121:3
Special [1] - 103:14
specialized [1] - 24:13
specific [4] - 29:24,
52:4, 67:4, 121:20
specifically [2] - 28:6,
37:2
speed [3] - 60:4,
64:10, 66:2
speed-driven [1] 66:2
speeding [1] - 37:13
spend [2] - 128:2,
132:25
spending [2] - 58:22,
78:7
spent [4] - 32:10,
80:9, 93:11, 113:11
Sperry [12] - 27:24,
51:19, 56:3, 56:11,
56:14, 56:16, 56:20,
56:22, 57:1, 71:25,
135:9, 135:11
Sperry-Sun [4] 56:22, 71:25, 135:9,
135:11
spike [1] - 135:16
spill [13] - 10:14,
20:16, 76:2, 81:23,
83:22, 94:20, 97:16,
97:17, 101:13,
101:21, 101:23,
102:8, 113:25
SPILL [1] - 1:5
Spill [1] - 98:4
SPIRO [1] - 4:22
Sprague [1] - 68:1
spring [1] - 45:20
OFFICIAL TRANSCRIPT
sprung [1] - 142:3

SQUARE [1] - 5:21
square [1] - 87:12
squeeze [2] - 80:18,
129:24
squirrelly [1] - 111:24
stability [3] - 55:12,
62:9, 107:24
stable [1] - 138:12
stack [1] - 97:22
staff [5] - 24:5, 24:7,
103:10, 103:11,
103:19
stand [6] - 63:24,
79:16, 80:7, 101:5,
102:25, 123:15
standard [10] - 55:23,
57:22, 57:23, 63:13,
84:24, 85:7, 119:8,
119:9, 120:8, 120:19
standards [7] - 27:9,
27:11, 41:13, 84:18,
120:1, 124:20, 128:7
standdown [1] - 88:4
standing [3] - 73:25,
85:5, 113:4
standpoint [2] - 44:13,
119:5
stands [1] - 130:17
start [8] - 44:3, 44:5,
45:3, 61:18, 69:4,
71:22, 85:19, 133:9
started [4] - 56:7,
56:24, 59:5, 128:11
starting [1] - 63:23
starts [1] - 135:24
startups [1] - 58:24
STATE [3] - 5:3, 5:8,
5:10
State [8] - 11:14,
11:15, 11:22, 11:23,
101:3, 102:24,
109:14, 143:4
state [5] - 27:11,
104:1, 105:15,
110:3, 119:21
statement [2] - 16:2,
79:15
statements [12] 13:10, 13:11, 13:13,
13:17, 13:20, 20:20,
20:24, 25:23, 26:13,
26:15, 142:18,
142:19
STATEMENTS [10] 9:5, 9:6, 9:7, 9:8,
9:9, 26:16, 71:19,
100:25, 103:6,
111:12
states [3] - 81:22,
26
100:20, 105:6
STATES [4] - 1:1,
1:14, 1:22, 4:3
States [22] - 10:17,
11:12, 11:17, 11:19,
15:1, 16:19, 16:20,
19:11, 20:24, 20:25,
21:7, 21:15, 84:13,
100:3, 101:4,
101:16, 104:9,
140:4, 143:5, 143:15
States' [4] - 17:19,
19:15, 71:3, 88:6
static [2] - 42:15,
55:25
STATION [1] - 4:24
station [3] - 81:17,
87:13, 139:12
statute [2] - 17:25,
18:2
stay [1] - 26:10
stayed [3] - 18:8, 78:8,
115:24
Steering [2] - 20:23,
26:19
stemming [2] - 17:11,
89:21
STENOGRAPHY [1] 8:12
step [2] - 14:11, 137:7
Stephanie [2] - 10:11,
71:6
Stephen [4] - 116:19,
117:11, 119:23,
121:13
STEPHEN [1] - 2:7
steps [1] - 43:12
Sterbcow [1] - 11:4
STERBCOW [3] 2:14, 2:14, 11:4
STERNBERG [2] 7:24, 12:18
Sternberg [1] - 12:18
Steve [9] - 11:5, 11:17,
12:7, 41:7, 44:7,
46:24, 114:13,
137:15
Steven [1] - 124:23
STEVEN [2] - 4:10,
6:19
still [12] - 40:3, 46:8,
55:4, 64:15, 71:6,
73:6, 87:25, 93:12,
95:9, 100:9, 110:19,
128:20
stock [1] - 93:3
stop [6] - 37:9, 73:5,
90:19, 96:6, 139:19,
139:21
stopped [4] - 37:11,
94:18, 98:5, 132:6

stopping [2] - 49:19,
77:14
story [5] - 69:15,
77:21, 79:17, 82:13,
129:21
straight [1] - 77:8
STRANGE [3] - 5:4,
11:15, 101:1
Strange [4] - 11:15,
101:3, 103:4, 104:4
STRANGE.................
.. [1] - 9:7
Strategic [1] - 48:11
strategy [1] - 82:13
straws [2] - 133:19,
133:21
STREET [18] - 2:4,
2:11, 2:15, 2:19,
2:22, 3:11, 3:15,
3:22, 5:11, 5:16,
5:22, 6:16, 6:20, 7:4,
7:14, 7:21, 8:5, 8:9
strength [2] - 55:25,
128:6
stress [1] - 78:22
strictly [2] - 14:23,
107:13
striking [1] - 119:19
string [3] - 51:22,
61:24, 127:19
strong [1] - 136:12
strongly [1] - 15:10
structure [3] - 34:17,
38:23, 39:3
stuck [1] - 129:25
students [1] - 92:14
studied [1] - 120:14
studying [1] - 132:4
stuff [7] - 55:6, 55:8,
68:24, 122:2, 132:1,
136:19
subject [4] - 19:7,
22:18, 23:1, 23:6
subjected [1] - 15:2
subjects [2] - 20:17,
48:3
submit [5] - 114:25,
115:7, 116:8,
120:17, 138:5
submitted [2] - 21:21,
22:4
subsequent [1] 33:13
subsequently [1] 74:11
substantial [5] - 45:8,
46:20, 63:7, 66:18,
69:18
substantially [1] -
61:22
subsurface [1] 109:21
subtle [2] - 134:10,
134:16
succeed [4] - 61:9,
76:12, 76:24, 132:14
success [7] - 62:24,
74:4, 83:2, 92:20,
94:2, 95:22, 111:23
successful [6] 55:12, 91:21, 92:11,
94:1, 96:1, 133:15
successfully [2] 50:9, 137:2
succumbed [1] 69:13
sued [1] - 84:14
suffered [2] - 20:10,
100:3
suggest [3] - 70:14,
85:25, 123:2
suggested [2] - 121:6,
122:7
suite [1] - 55:20
SUITE [13] - 2:4, 2:15,
2:19, 3:4, 3:8, 5:22,
6:16, 6:20, 7:8, 7:14,
7:21, 7:24, 8:5
SULLIVAN [1] - 4:17
summarize [1] 101:20
summation [1] - 79:16
summed [3] - 47:24,
70:11, 93:22
Sun [5] - 56:3, 56:22,
71:25, 135:9, 135:11
Sun's [1] - 56:11
Sunday [1] - 26:10
superiors [1] - 124:15
supervised [1] 111:22
supervision [3] - 45:2,
53:7, 53:11
supervisor [1] - 53:13
Supervisor [1] - 44:8
supervisors' [1] - 33:7
support [3] - 21:7,
21:13, 127:5
supported [1] 124:24
supports [1] - 101:17
supposed [5] - 87:2,
96:5, 97:15, 104:5,
141:6
surface [4] - 43:7,
50:18, 62:17, 85:11
survey [2] - 48:2,
125:7
surveyed [2] - 126:25,
127:3
survived [3] - 36:14,
142:2, 142:9
suspect [1] - 131:9
sustain [1] - 100:8
sustains [2] - 100:8,
100:19
SUTHERLAND [1] 6:18
Swaco [1] - 108:14
swath [1] - 81:21
swear [1] - 96:4
sweep [1] - 123:16
sworn [1] - 76:24
system [46] - 32:25,
34:11, 34:14, 34:19,
34:24, 35:22, 35:23,
36:4, 36:9, 36:13,
36:17, 36:22, 36:24,
37:1, 37:2, 37:6,
37:7, 37:8, 37:17,
37:18, 38:4, 38:9,
38:11, 38:20, 38:22,
39:4, 43:1, 43:4,
43:13, 43:21, 45:5,
45:10, 47:12, 50:17,
57:18, 67:8, 67:9,
69:20, 89:17, 108:7,
108:10, 124:4,
131:23, 136:15,
136:17, 140:3
systemic [5] - 63:17,
66:21, 66:22, 82:20,
84:10
systems [6] - 46:16,
47:14, 48:9, 51:5,
67:10
T
table [2] - 31:5, 32:3
tables [2] - 14:20,
25:16
tablets [1] - 14:9
tailored [1] - 121:20
TANNER [2] - 8:3,
12:19
Tanner [1] - 12:19
task [2] - 29:18, 47:25
teaching [1] - 121:23
Team [4] - 53:2, 60:6,
68:14, 70:3
team [15] - 28:22,
28:23, 31:16, 40:5,
44:5, 75:16, 75:19,
77:9, 93:17, 103:13,
108:25, 112:4,
128:16, 129:15,
130:15
OFFICIAL TRANSCRIPT
teams [1] - 29:3

tear [1] - 68:24
tech [3] - 111:8,
111:10, 111:11
technical [8] - 24:14,
53:7, 65:10, 65:11,
71:4, 71:16, 138:20,
138:22
technically [1] - 19:9
technician [1] - 38:5
technology [3] 45:17, 73:15, 111:7
telephone [2] - 74:11,
94:17
temperature [5] 41:15, 46:15, 53:21,
59:13, 128:6
temperatures [1] 46:18
temporarily [3] - 16:6,
61:21, 85:18
temporary [3] - 27:1,
60:22, 85:22
ten [6] - 60:19, 62:2,
75:1, 95:5, 98:9,
99:19
ten-second [2] - 75:1,
99:19
tender [1] - 22:17
tens [3] - 78:4, 100:2,
100:4
tenth [1] - 62:23
term [2] - 47:19, 64:9
terminated [1] 123:24
terms [5] - 24:11,
46:17, 80:2, 117:24,
126:12
terrible [1] - 26:20
test [98] - 27:2, 27:3,
27:8, 28:9, 52:10,
55:13, 56:2, 60:13,
62:4, 62:9, 62:11,
62:21, 62:22, 72:24,
74:4, 78:15, 83:1,
83:3, 83:13, 83:24,
84:6, 86:6, 86:7,
86:8, 86:19, 86:21,
88:8, 90:7, 90:9,
90:15, 90:16, 90:17,
90:22, 91:1, 91:3,
91:5, 91:8, 91:10,
91:16, 91:21, 92:2,
92:11, 92:19, 92:23,
93:25, 94:1, 94:10,
94:16, 95:11, 95:21,
96:1, 96:5, 96:12,
96:16, 96:22, 97:14,
97:19, 97:21, 98:6,
99:6, 99:11, 99:21,
27
106:5, 106:20,
106:22, 107:25,
111:23, 112:8,
112:12, 112:16,
113:13, 115:15,
115:18, 115:21,
116:2, 127:14,
127:15, 129:2,
129:3, 130:18,
130:24, 131:4,
131:11, 131:13,
131:14, 131:17,
132:7, 133:1, 133:9,
133:16, 134:24,
140:17
tested [5] - 42:19,
53:17, 86:7, 140:14,
140:15
testified [5] - 56:22,
92:10, 92:13,
118:16, 135:1
testifies [2] - 22:13,
70:7
testify [17] - 21:25,
34:2, 38:5, 60:9,
66:1, 80:25, 84:3,
86:18, 88:7, 90:8,
92:6, 92:7, 93:5,
93:10, 93:20, 98:13,
124:24
testifying [1] - 34:1
testimony [20] - 14:16,
15:14, 22:15, 22:24,
23:5, 74:25, 76:25,
77:3, 77:7, 79:21,
80:15, 83:20, 87:18,
94:14, 97:5, 110:11,
118:24, 125:15,
137:14, 142:5
testing [9] - 42:20,
42:22, 51:17, 52:1,
54:25, 55:1, 55:16,
55:23, 96:5
tests [11] - 28:12,
55:12, 55:18, 55:21,
56:1, 90:23, 95:7,
107:23, 128:6,
128:7, 131:10
Texas [1] - 104:10
THE [39] - 1:5, 1:5,
1:12, 1:21, 2:3, 4:3,
5:3, 5:8, 5:9, 10:7,
10:8, 10:10, 10:13,
10:19, 11:24, 12:22,
12:25, 13:2, 13:8,
69:23, 70:1, 71:2,
71:7, 71:8, 71:13,
71:15, 72:5, 73:5,
73:13, 73:15, 73:19,
73:21, 100:23,
103:4, 107:15,
111:2, 111:6,
142:15, 142:21
themselves [2] 107:4, 116:7
theories [1] - 132:5
theory [3] - 92:24,
92:25, 93:5
therefore [3] - 49:3,
50:21, 101:17
they've [2] - 120:13,
120:14
They've [1] - 120:15
thick [1] - 59:17
thinking [5] - 26:4,
115:18, 116:5,
135:7, 137:16
THIRD [1] - 5:11
third [9] - 18:12,
18:17, 21:11, 21:12,
21:14, 50:14, 62:5,
88:8, 118:15
third-party [3] - 18:17,
21:11, 21:14
THIS [1] - 1:10
this' [1] - 60:8
THOMAS [1] - 3:11
Thornhill [1] - 11:11
THORNHILL [3] 3:10, 3:11, 11:10
thorough [1] - 63:10
thoroughly [1] - 90:6
thousands [3] - 31:5,
100:2, 102:12
threatening [1] - 92:4
three [23] - 14:1,
16:13, 24:24, 25:11,
26:1, 34:4, 38:17,
60:24, 66:15, 74:15,
75:22, 76:11, 88:12,
94:25, 102:23,
112:3, 113:1, 117:3,
119:22, 125:4,
129:3, 135:17,
142:18
three-day [1] - 34:4
throw [1] - 44:21
Thunder [1] - 61:6
Thursday [3] - 14:3,
22:7, 26:2
tieback [1] - 61:25
Tiger [2] - 60:6, 68:14
time-out [1] - 132:17
timeliness [2] - 52:21,
52:25
timely [3] - 39:5, 40:6,
57:23
tire [1] - 140:7
tires [2] - 87:13, 140:6
TO [4] - 1:10, 10:4,
126:15, 126:16
today [11] - 13:12,
13:18, 20:22, 72:9,
74:15, 74:24, 101:5,
101:12, 104:10,
104:25, 112:2
together [6] - 18:11,
73:3, 73:23, 83:9,
104:11, 106:21
tolerance [1] - 89:25
tolerant [1] - 66:1
tolerated [1] - 80:17
TOLLES [1] - 6:22
Tom [1] - 11:10
tomorrow [2] - 63:23,
110:9
Tony [2] - 63:11, 64:17
took [23] - 16:10,
38:17, 57:2, 67:2,
71:14, 72:1, 74:11,
86:9, 111:16, 121:5,
122:4, 123:11,
123:12, 123:19,
124:3, 124:20,
126:4, 126:20,
127:11, 127:18,
127:23, 130:6, 138:6
toolpusher [8] - 28:8,
31:1, 75:2, 75:3,
97:2, 99:20, 123:22,
137:12
toolpushers [1] 117:6
top [4] - 46:23, 120:5,
130:7, 136:2
TORTS [2] - 4:4, 4:15
total [4] - 20:25, 21:3,
59:12, 61:14
totally [5] - 27:24,
51:1, 105:14,
124:24, 141:19
tour [2] - 118:25,
119:6
towards [1] - 101:23
TOWER [2] - 7:4, 7:20
town [2] - 26:6, 26:9
trace [1] - 83:7
track [1] - 140:7
tracks [2] - 122:18,
122:19
trade [1] - 122:4
tragedy [18] - 26:20,
32:15, 40:1, 70:24,
72:11, 74:14, 74:24,
81:24, 81:25, 83:4,
83:8, 84:8, 97:10,
97:11, 97:12, 98:3,
99:2, 110:9
tragic [2] - 97:12,
104:13
tragically [1] - 102:9

train [6] - 29:14,
32:21, 32:23, 35:15,
36:18, 124:6
trained [15] - 28:6,
28:17, 34:9, 34:10,
34:13, 36:8, 40:6,
56:4, 116:22, 117:1,
119:15, 127:9,
136:14, 141:25
training [34] - 27:21,
28:10, 29:19, 29:24,
30:1, 30:10, 31:12,
33:8, 34:3, 34:22,
35:6, 35:10, 36:16,
39:4, 40:13, 56:18,
62:22, 116:24,
119:22, 119:24,
120:2, 120:4, 120:5,
120:8, 120:15,
120:18, 120:20,
121:17, 121:19,
121:22, 124:16,
127:5
TRANSCRIPT [2] 1:20, 8:12
transcript [2] - 21:24,
143:7
transcripts [3] - 21:21,
22:18, 23:13
transferred [1] - 17:24
translated [1] - 43:23
transmitting [1] 14:24
TRANSOCEAN [3] 6:12, 6:12, 6:14
Transocean [161] 12:7, 12:8, 12:9,
12:10, 12:11, 12:12,
12:13, 13:7, 17:1,
17:5, 17:15, 18:15,
18:17, 18:19, 19:5,
19:9, 19:13, 19:18,
21:1, 21:9, 26:21,
26:23, 27:3, 27:19,
27:23, 28:3, 28:5,
28:6, 28:16, 29:17,
30:6, 30:9, 30:15,
30:17, 30:18, 31:9,
31:14, 31:15, 31:20,
31:25, 32:8, 32:11,
32:14, 32:17, 32:23,
33:21, 34:23, 35:15,
36:20, 38:4, 38:8,
39:8, 39:13, 39:24,
40:2, 40:3, 40:5,
40:20, 40:25, 41:3,
41:8, 41:11, 41:18,
41:19, 42:1, 42:3,
42:6, 42:9, 42:11,
OFFICIAL TRANSCRIPT
42:17, 42:23, 43:3,

43:5, 43:8, 43:14,
43:20, 43:22, 43:25,
44:2, 45:3, 45:7,
45:14, 45:17, 45:21,
45:22, 46:3, 46:20,
46:23, 46:25, 47:9,
47:15, 47:16, 47:22,
47:25, 48:10, 49:5,
49:14, 49:16, 51:10,
70:16, 70:19, 89:20,
90:14, 93:1, 99:4,
99:8, 99:10, 102:21,
102:23, 106:8,
106:10, 106:12,
106:15, 106:18,
106:21, 107:2,
107:3, 107:6, 107:7,
107:10, 108:7,
111:3, 111:14,
113:19, 113:21,
114:3, 114:11,
114:18, 114:22,
115:3, 115:11,
115:17, 115:25,
116:10, 116:14,
116:19, 116:23,
117:12, 119:14,
119:16, 119:21,
120:12, 121:17,
121:18, 122:8,
122:11, 122:14,
124:22, 125:10,
125:12, 129:9,
130:16, 130:18,
134:14, 134:18,
136:16, 138:3,
142:12
Transocean's [31] 16:22, 19:17, 20:6,
27:11, 27:17, 28:10,
28:20, 29:2, 30:19,
30:23, 31:1, 31:17,
32:20, 33:5, 33:24,
35:19, 36:3, 37:16,
40:16, 41:7, 41:14,
45:5, 46:23, 47:12,
47:23, 48:8, 48:17,
49:23, 113:1, 113:7,
120:18
transparent [1] 63:12
travel [3] - 26:8, 26:9,
26:10
traveled [1] - 88:11
treads [1] - 140:6
treating [1] - 32:5
tremendous [1] 137:23
trend [1] - 31:21
28
TRIAL [1] - 1:20

trial [69] - 10:20,
13:14, 13:18, 13:22,
13:25, 14:2, 14:5,
14:14, 14:16, 14:24,
15:7, 15:21, 16:3,
16:18, 17:14, 17:23,
19:11, 19:25, 20:13,
20:18, 21:5, 21:19,
21:22, 21:23, 22:4,
22:12, 22:14, 22:20,
22:24, 22:25, 23:6,
23:22, 24:12, 24:17,
24:25, 25:25, 36:22,
70:24, 72:13, 78:20,
79:16, 81:14, 82:4,
82:15, 82:23, 84:19,
84:22, 85:21, 92:9,
94:19, 95:17,
100:10, 100:16,
102:22, 103:11,
103:22, 105:9,
105:10, 107:16,
114:18, 115:2,
118:24, 121:6,
124:2, 124:24,
128:2, 138:4,
139:15, 142:5
trials [1] - 103:20
tried [6] - 19:17, 50:7,
100:9, 114:16,
116:9, 138:14
trigger [1] - 43:13
Triton [1] - 10:16
TRITON [1] - 1:12
troubling [1] - 108:10
true [2] - 41:21, 143:7
truly [1] - 115:11
trust [3] - 113:16,
114:9
trusted [1] - 33:1
truth [2] - 110:18,
130:23
try [8] - 24:16, 25:7,
42:14, 49:17, 54:21,
63:8, 72:10, 104:11
trying [7] - 49:8, 61:7,
76:10, 113:11,
116:3, 134:4, 141:4
turn [6] - 37:9, 48:22,
58:9, 64:18, 93:14,
118:3
turned [4] - 14:10,
28:25, 93:14, 135:19
turns [1] - 136:8
twice [2] - 113:9,
118:13
two [39] - 16:12,
17:14, 19:22, 24:21,
59:4, 61:15, 64:18,
72:7, 74:4, 74:20,

75:3, 84:18, 91:3,
91:10, 92:22, 93:2,
94:22, 95:4, 95:13,
98:1, 98:18, 101:20,
101:22, 102:21,
112:23, 114:17,
119:16, 120:23,
121:12, 121:22,
124:11, 127:10,
129:1, 131:6,
131:10, 133:7,
133:19, 133:21,
139:10
Two [1] - 20:18
TX [8] - 3:5, 3:19,
6:20, 7:8, 7:15, 7:21,
7:25, 8:5
type [4] - 14:22, 29:4,
31:24, 51:21
typically [1] - 19:11
U
U.S [4] - 4:4, 4:8, 4:15,
4:21
ultimate [1] - 28:2
ultimately [3] - 32:19,
49:17, 136:21
unabated [1] - 32:14
unaccounted [1] 109:9
unambiguous [1] 114:24
unbroken [1] - 83:17
unchecked [1] - 90:20
unconscionable [1] 127:11
uncontrolled [5] 30:16, 32:2, 88:24,
90:2, 90:20
uncorrected [3] 31:15, 32:14, 36:19
under [36] - 17:16,
17:19, 17:21, 17:24,
19:8, 19:16, 21:20,
34:9, 34:10, 36:1,
38:22, 41:3, 42:12,
42:18, 42:19, 42:21,
50:5, 57:6, 57:25,
58:19, 59:10, 84:14,
84:20, 85:8, 88:20,
94:10, 99:4, 105:22,
106:10, 107:13,
108:18, 108:20,
113:18, 122:16,
123:16, 131:18
underbalanced [1] 94:5
underestimating [1] 104:17

UNDERHILL [9] - 4:5,
11:18, 71:20, 72:6,
73:11, 73:14, 73:18,
73:20, 73:22
Underhill [6] - 11:19,
71:18, 101:18,
105:15, 108:18,
127:17
UNDERHILL..............
... [1] - 9:6
understaffed [1] 55:14
understood [5] 33:13, 44:6, 89:22,
95:20, 112:7
undersupervised [1] 55:15
undertaken [1] - 86:16
underwater [1] - 42:25
underway [2] - 97:8,
103:2
undetected [2] - 53:8,
56:14
undisputed [2] 92:21, 138:23
undo [1] - 96:19
unemployment [1] 104:24
unexplained [1] 93:18
unfair [4] - 123:3,
123:4, 138:6
unfit [1] - 41:18
unforgiveable [1] 79:15
unfortunate [1] 48:12
unfortunately [1] 139:16
unique [2] - 46:17,
105:5
unit [3] - 16:5, 65:3,
65:12
Unit [1] - 48:11
United [18] - 10:17,
11:12, 11:17, 11:19,
15:1, 16:19, 17:19,
19:11, 19:15, 20:24,
21:7, 71:3, 84:13,
88:6, 101:16, 140:4,
143:5, 143:15
UNITED [4] - 1:1, 1:14,
1:22, 4:3
universally [2] 116:22, 117:14
unless [2] - 68:25,
93:18
unloaded [1] - 31:22
unloading [7] - 28:15,

28:18, 29:16, 30:3,
31:24, 32:3, 32:16
unmanned [1] - 57:2
unmistakable [1] 102:16
unprecedented [2] 27:13, 101:14
unresolved [1] - 19:6
unseaworthiness [2] 18:23, 19:2
unseaworthy [1] 70:15
unstable [3] - 53:18,
59:14, 107:25
unsuccessful [2] 27:16, 86:3
untried [1] - 62:18
unused [2] - 55:4,
131:18
unusual [1] - 133:25
up [60] - 13:11, 25:11,
28:22, 31:5, 31:18,
32:15, 35:24, 38:7,
44:3, 44:5, 44:15,
45:3, 47:24, 49:10,
51:12, 52:23, 56:5,
62:3, 62:7, 69:24,
70:11, 72:21, 74:8,
74:21, 79:14, 81:2,
83:5, 83:11, 83:16,
83:22, 87:4, 88:12,
91:1, 91:2, 91:13,
91:21, 92:18, 93:22,
95:12, 97:6, 97:23,
98:19, 111:4,
112:16, 113:14,
119:23, 123:15,
124:19, 126:10,
126:22, 127:18,
130:17, 130:24,
131:2, 133:1, 135:2,
135:24, 136:8,
139:4, 139:17
Up [1] - 88:14
update [1] - 57:12
updated [2] - 58:6,
120:15
upgrade [2] - 40:17,
42:4
upper [2] - 32:13,
139:6
upside [1] - 141:12
urgency [1] - 59:25
USA [1] - 21:15
useless [1] - 55:17
uses [1] - 124:8
utilize [1] - 55:23
utilized [1] - 43:14
utter [1] - 115:16
OFFICIAL TRANSCRIPT
utterly [1] - 100:14
V
VA [1] - 2:19
vacation [1] - 121:9
value [2] - 18:5, 19:21
valve [1] - 135:19
variable [3] - 137:1,
137:10, 139:9
variables [1] - 128:4
various [4] - 20:7,
20:8, 22:19, 104:23
variously [1] - 60:16
vast [1] - 122:23
verbal [1] - 14:15
verbatim [1] - 34:9
verbatim] [1] - 140:8
Veritas [1] - 39:18
versa [1] - 43:7
versus [2] - 10:17,
42:15
vessel [26] - 18:2,
18:5, 18:6, 18:7,
18:11, 18:14, 18:20,
18:24, 19:3, 34:11,
34:18, 35:1, 35:4,
35:7, 36:11, 36:15,
39:1, 39:10, 39:19,
40:20, 45:24, 46:5,
46:12, 56:7, 68:11,
106:13
vessel's [1] - 34:14
vessels [4] - 32:9,
66:11, 67:14, 67:22
via [1] - 16:16
vice [6] - 29:2, 32:20,
43:7, 65:1, 65:6,
70:10
vice-president [5] 29:2, 32:20, 65:1,
65:6, 70:10
victims [2] - 103:1,
115:11
video [6] - 14:22, 22:2,
117:22, 118:8,
126:1, 126:18
Vidrine [38] - 74:10,
75:1, 75:17, 81:3,
92:22, 94:17, 95:4,
95:6, 95:7, 95:10,
96:6, 96:10, 97:5,
97:7, 97:13, 97:14,
98:8, 111:19,
111:22, 112:9,
112:11, 112:12,
112:14, 112:24,
115:19, 115:24,
116:12, 121:14,
29
133:7, 133:9,
133:15, 134:5,
134:8, 134:23,
135:4, 137:12,
138:13
Vidrine's [2] - 81:13,
114:7
view [3] - 43:22,
119:10, 130:9
viewed [1] - 40:23
vigilant [1] - 30:20
Village [1] - 76:22
violated [2] - 79:21,
108:18
violates [1] - 15:2
violation [3] - 41:12,
43:16, 80:5
VIRGINIA [1] - 2:19
virtually [5] - 53:9,
66:22, 111:16,
117:15, 124:9
visible [1] - 109:17
visited [1] - 134:23
vital [1] - 47:4
voiced [1] - 52:24
VOICES [1] - 10:9
void [1] - 114:24
volume [4] - 22:23,
23:10, 36:10, 75:8
volumes [2] - 51:22,
125:20
Von [1] - 12:18
VON [2] - 7:24, 12:18
voyage [1] - 117:5
W
wait [2] - 62:8, 62:12
waited [1] - 128:20
waiting [2] - 128:11,
129:3
waived [1] - 105:22
waking [1] - 38:7
walk [1] - 75:2
walked [2] - 112:25
WALKER [1] - 2:18
walking [1] - 142:7
Walter [1] - 11:7
WALTER [1] - 2:22
Walz [2] - 53:3, 129:15
wanton [1] - 105:25
wants [1] - 61:4
warn [4] - 86:21, 97:1,
97:2
warned [4] - 39:13,
39:14, 41:11, 86:20
warning [3] - 108:22,
127:13, 129:13
warnings [3] - 28:23,
86:11, 127:16
warrant [1] - 105:20
WASHINGTON [4] 4:13, 4:19, 4:24, 6:5
waste [1] - 131:20
watch [1] - 35:7
watched [1] - 133:14
watching [3] - 103:21,
110:24, 135:14
Water [7] - 17:21,
19:16, 19:20, 84:14,
84:21, 84:24, 85:8
water [3] - 14:19,
59:11, 101:25
waters [3] - 105:3,
109:14, 110:3
Watts [1] - 11:9
WATTS [3] - 3:3, 3:3,
11:9
ways [2] - 115:9,
129:24
wealth [1] - 27:22
weapons [1] - 77:23
website [8] - 15:9,
23:16, 23:17, 23:18,
23:19, 23:24, 23:25,
24:6
Webster [2] - 34:1,
43:19
week [9] - 22:8, 22:12,
23:14, 23:15, 24:23,
25:1, 25:4, 25:6
week-to-week [1] 25:6
weekend [2] - 26:3,
26:11
weekly [3] - 23:20,
109:18, 120:21
weeks [4] - 33:4,
52:23, 102:19, 131:2
well's [1] - 90:15
well-trained [2] 119:15, 127:9
wellbore [3] - 49:25,
50:2, 141:9
wellhead [2] - 17:7,
129:25
wells [10] - 58:23,
59:4, 59:16, 59:20,
59:22, 59:24,
118:11, 121:2,
122:14, 127:21
whatsoever [2] - 32:7,
93:13
WHEREUPON [6] 71:14, 117:21,
118:7, 125:25,
126:17, 142:22
whisper [1] - 82:19
whistleblower [1] -
124:14
Whitby [1] - 48:24
WHITELEY [1] - 5:14
whole [1] - 110:24
wholesale [1] - 110:12
wholly [1] - 105:14
wide [2] - 48:2, 141:9
widely [1] - 130:4
widespread [1] - 32:8
wildlife [1] - 110:2
willful [23] - 19:19,
19:24, 27:19, 40:16,
48:18, 49:6, 70:22,
73:4, 73:24, 75:7,
80:17, 84:12, 84:15,
84:20, 84:25, 85:3,
85:6, 85:8, 85:13,
99:1, 99:23, 102:20,
105:25
willfully [7] - 32:23,
36:20, 42:20, 45:22,
51:8, 66:10, 67:12
William [1] - 70:5
WILLIAMS [3] - 3:7,
3:7, 10:25
Williams [2] - 11:1,
38:5
WILLIAMSON [3] 3:17, 3:18, 11:8
Williamson [1] - 11:8
window [1] - 59:19
windows [1] - 137:20
WINFIELD [1] - 5:5
withheld [1] - 117:2
witness [7] - 13:19,
21:25, 22:17, 92:6,
92:7, 92:9, 110:11
witness's [2] - 14:16,
21:23
witnesses [13] 21:18, 21:19, 76:25,
80:25, 84:4, 86:17,
87:5, 90:8, 91:5,
93:4, 98:13, 103:17,
107:3
wits [3] - 76:5, 132:9,
132:12
wits' [1] - 61:2
WITTMANN [1] - 13:3
Wittmann [1] - 13:3
woefully [2] - 34:9,
47:13
woman [1] - 142:1
women [3] - 140:23,
142:3, 142:6
wonderful [1] - 73:15
word [4] - 53:10,
76:17, 96:4, 107:2
words [15] - 39:7,
49:20, 50:24, 64:5,
66:4, 77:5, 77:13,

78:1, 78:19, 81:9,
81:11, 87:21, 88:4,
96:15, 99:22
workers [4] - 44:23,
102:14, 103:24,
105:9
workforce [1] - 33:9
works [3] - 73:13,
73:16, 121:17
world [9] - 33:2,
43:15, 51:14,
104:15, 110:24,
118:10, 118:11,
118:13, 120:17
worldwide [6] - 64:25,
67:11, 122:14,
124:17, 125:7, 125:8
Worldwide [1] - 63:19
worry [2] - 68:23, 69:1
worse [5] - 40:10,
76:20, 96:17,
112:24, 129:5
worst [2] - 82:7,
106:16
worth [1] - 79:10
wracked [1] - 74:5
wreck [1] - 32:21
wrecks [2] - 29:14,
124:6
wrestle [1] - 115:8
WRIGHT [1] - 2:3
writing [1] - 57:8
written [5] - 62:21,
81:11, 121:7,
123:17, 123:21
wrote [1] - 29:3
www.laed.uscourts.
gov [1] - 24:1
www.MDL2179
trialdocs.com [1] 23:16
Y
Yancy [2] - 35:6, 40:11
year [8] - 29:15, 31:23,
58:20, 58:25, 68:10,
92:14, 122:13
years [19] - 28:17,
31:12, 36:19, 39:15,
39:23, 40:1, 43:18,
44:11, 48:16, 64:18,
67:2, 70:16, 89:21,
117:4, 117:8,
117:12, 121:23,
123:11
yelled [1] - 38:13
yellow [1] - 131:8
OFFICIAL TRANSCRIPT
YOAKUM [1] - 3:18

YORK [1] - 12:15
York [1] - 12:15
YOUNG [1] - 4:23
yourself [1] - 117:18
Z
zero [15] - 91:14,
91:19, 91:23, 91:24,
92:1, 92:12, 92:15,
92:17, 95:8, 95:11,
96:12, 97:23, 109:5,
112:15, 113:13
zillions [1] - 119:18
zone [1] - 25:9
MIKE [1] - 6:4

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1

UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF LOUISIANA

IN RE: OIL SPILL BY THE OIL

CIVIL ACTION NO. 10-MD-2179 "J"

THIS DOCUMENT RELATES TO:

TRANSCRIPT OF NONJURY TRIAL PROCEEDINGS

FOR THE PLAINTIFFS:

DOMENGEAUX WRIGHT ROY & EDWARDS

HERMAN HERMAN & KATZ

LEWIS, KULLMAN, STERBCOW & ABRAMSON

BREIT DRESCHER IMPREVENTO & WALKER

LEGER & SHAW

WATTS, GUERRA, CRAFT

WILLIAMS LAW GROUP

THORNHILL LAW FIRM

DEGRAVELLES PALMINTIER HOLTHAUS & FRUGE

WILLIAMSON & RUSNAK

IRPINO LAW FIRM

FOR THE UNITED STATES

U.S. DEPARTMENT OF JUSTICE

U.S. DEPARTMENT OF JUSTICE

U.S. DEPARTMENT OF JUSTICE

FOR THE STATE OF

ALABAMA ATTORNEY GENERAL'S OFFICE

FOR THE STATE OF

KANNER & WHITELEY

FOR BP EXPLORATION &

COVINGTON & BURLING

KIRKLAND & ELLIS

FOR TRANSOCEAN HOLDINGS

SUTHERLAND ASBILL & BRENNAN

MUNGER TOLLES & OLSON

MAHTOOK & LAFLEUR

HUGHES ARRELL KINCHEN

FOR CAMERON INTERNATIONAL

BECK REDDEN & SECREST

FOR M-I L.L.C.:

MORGAN, LEWIS & BOCKIUS

OFFICIAL COURT REPORTER:

CATHY PEPPER, CRR, RMR, CCR

PROCEEDINGS RECORDED BY MECHANICAL STENOGRAPHY.

OPENING STATEMENTS BY MR. ROY........................

OPENING STATEMENTS BY MR. UNDERHILL..................

OPENING STATEMENTS BY MR. STRANGE.................... 100

OPENING STATEMENTS BY MR. CALDWELL................... 103

OPENING STATEMENTS BY MR. BRIAN...................... 111

LUNCHEON RECESS...................................... 142

MONDAY, FEBRUARY 25, 2013

(COURT CALLED TO ORDER)

THE DEPUTY CLERK:

Mexico on April 20, 2010; Civil Action 10-2771, In re:

Complaint and Petition of Triton Asset Leasing GmbH, et al.;

Civil Action 10-4536, United States of America versus

BP Exploration and Production, Incorporated, et al.

those counsel who will be appearing during the trial to make an

appearance on the record right now, please.

Good morning, everyone.

Good morning, Your Honor.