Hayward Industries, Inc.
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`EXHIBIT 1045
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`Hayward Exhibit 1045
`Hayward v. Pentair, et al.
`IPR2013-00285
`
`

`
`cow
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`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`HAYWARD INDUSTRIES,
`
`INC.
`
`Petitioner
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`PENTAIR WATER POOL AND SPA,
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`INC.,
`
`DANFOSS LOW POWER DRIVES
`
`Patent Owners
`
`Case IPR20l3—O0285
`
`Patent 8,019,479
`
`INC.
`TWIN COURT REPORTING,
`CERTIFIED COURT REPORTERS'
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`ll ELISHA DRIVE
`
`ALLENTOWN, N.J. 08501
`609-259-1228
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`1 of so sheets
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`.
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`Page 1 to 1 of 138
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`Haywan1Exmbfl1045
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`Hayward v. Pentair, et al.
`|PR2013-00285
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`

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`1
`Videotaped deposition was taken at the
`THE
`2
`law offices of Mccarter & English, Four Gateway
`I work for Certified \§ideo¥Pr§g'3kIi§cIl'3TT's,
`Cullen.
`3 Center, 100 Mulberry Street, Newark, New Jersey,
`4
`before DANIELA REYNOLDS, License No. XI01996, a
`132 Franklin Corner Road, Lawrenceville, New
`5 Certified Court Reporter of the State of New
`Jersey.
`6
`Jersey, on June 20, 2014, commencing at 9:35 a.m.
`7
`
`A P P E A R A N c E s
`
`-
`MCCARTER & ENGLISH
`100 Mulberry Street
`Four Gateway Center
`Newark, New Jersey 07101-0652
`‘ BY: STEVEN E. HALPERN, ESQUIRE
`MARK E. NIKOLSKY, ESQUIRE
`SCOTI‘ S. CHRISTIE, ESQUIRE
`COUNSEL FOR THE PETITIONER
`
`QUARLES & BRADY, LLP
`300 North LaSa||e Street, Suite 4000
`Chicago, Illinois 60654-3422
`BY: CHRISTOPHER J. FAHY, ESQUIRE
`JOEL A. AUSTIN, ESQUIRE
`COUNSEL FOR THE PATENT OWNERS
`
`ALSO PRESENT:
`
`Steve Cullen, Certified Video Productions
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`will the attorneys state their
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`appearances.
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`MR. HALPERN: On behalf of petitioner
`
`Hayward, this is Mccarter & English, more
`specifically this is lead counsel Steven Halpern
`and with me is backup counsel Mark Nikolsky.
`MR. FAHY: Christopher Fahy and Joel
`
`Austin with Quarles & Brady for the patent owners.
`THE VIDEOGRAPHER: Will the court
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`reporter swear the witness.
`
`ROBERT P. SCHAAF,
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`HAVING BEEN DULY SWORN ACCORDING TO LAW, WAS
`EXAMINED AND TESTIFIED AS FOLLOWS:
`THE VIDEOGRAPHER: Go ahead.
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`CROSS-EXAMINATION BY
`MR. FAHY:
`
`Q.-
`A.
`
`Q.
`
`Good morning, Mr. Schaaf.
`Good morning.
`
`Thank you for coming today and
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`TWIN COURT REPORTING, INC.
`CERTIFIED COURT REPORTERS
`11 ELISHA DRIVE
`ALLENTOWN, N.J. 08501
`609-259-1228
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`answering our questions.
`Have you ever testified before?
`A.
`Yes.
`
`Q.
`A.
`court or...
`
`About how many times?
`When you say testify, do you mean in
`
`Q.
`A.
`
`Q.
`A.
`
`Let's start with at court.
`Okay.
`I've -- two times, I believe.
`
`In what context were those two times?
`One time was in a patent case where I
`
`was giving information or background information
`about the subject matter, and the second time was
`in a case where there was a drilling problem and I
`
`was discussing the drilling issues involved with
`
`Q.
`
`A.
`
`Q.
`
`of?
`
`In the patent case, do you recall the
`
`, ThruBit and Precision.
`
`And who were you testifying on behalf
`
`A.
`because --
`
`I forget actually which one
`
`Q.
`
`Do you recall if it was the patent
`
`
`
`
`WITN ESSPAGE
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`ROBERT P. SCHAAF
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`L0®\lO\U‘l-hUJl\)I-I»
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` CROSS-EXAMINATION BY MR. FAHY: 4
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`REDIRECT EXAMINATION BY MR. HALPERN: 130
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`owner?
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`A.
`
`I'd have to check.
`I don't.
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`Q. And what was just the general -— what
`was the technology that you were testifying about?
`A.
`Logging technology.
`Q. What do you mean by that?
`A. That's when you go inside a well with
`a, a, a, what's called logging tool that's taking
`readings downhole and try to determine different
`
`parameters of the well reservoir.
`Q. And could you describe exactly what
`that logging tool is?
`A. Well, there are different types of
`logging tools and this was involved with the
`mechanism for taking it down the well because
`there's new mechanisms since we have all these
`
`horizontal wells being drilled now.
`Q. What are the different types of
`logging tools?
`A. Well, when you say different types, I
`don't know what you mean by that.
`Q. Well, Ithought you just told me
`there were different kinds of logging tools; is
`
`that right? _
`A. Well, there are different types of
`logs that you can do --
`Q. Okay.
`.
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`A.
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`-- downhole.
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`Q. What are those?
`A. Well, there's many different types.
`Most common ones are like resistivity and sonic
`
`logs that determine the resistivity of a reservoir
`or how fast sound waves go through a reservoir.
`Q. Any others?
`A. Well, there's many, many others.
`Q.
`Just how many are we talking,
`hundreds or --
`
`Probably if you get through the
`A.
`different types that Halliburton and Schlumberger
`and Weatherford have, there's probably hundreds.
`Q.
`So is the actual tool that you send
`down into the well, is that just sensors?
`
`A. Well, they send out a signal and then
`receive the signal back. So like in the case of a
`sonic tool, it sends out a sound wave and then
`receives it back.
`
`Q. And why, again, why do you go through
`this logging tool procedure?
`‘
`A.
`It gives downhole information on an
`oil reservoir since you can't visually see it or,
`you know, it could be as deep as 20,000 feet below
`the ground if you want to get information of it
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`and they discover correlations between what these
`tools read and what the conditions or the -- what
`
`the oil reservoir actually is composed of and some
`
`of the parameters of the reservoir.
`Q. Could you give me some examples of
`those conditions or parameters?
`A. Well, like porosity, which is amount
`of open space that's in the reservoir, the water
`saturation, how much is water, percentage of the
`fluid that's going through a zone that you're
`logging.
`Q. Any other examples?
`A. Well, then there's also the density,
`just how dense the formation is which could give
`you good example what the permeability or the
`ability for the well to flow is.
`Q. And why is that important?
`A. Well, you want to know how much
`
`oil --
`
`MR. HALPERN: Objection to form and
`objection, foundation. You can answer the
`question.
`
`THE WITNESS: Okay.
`So you could, you could tell how much
`A.
`the ability of the well would be to flow. And
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`that's important because you just want to know,
`you know, is this going to be a very good
`producing well and are you going to be able to get
`enough oil out of it to make it economic.
`Q. And is the economics, is that the
`most important consideration in oilwell drilling?
`MR. HALPERN: Objection to form.
`Objection, foundation. You can answer.
`A. Well, it's certainly one, one aspect
`of it where any oil company is in business to make
`money, so economics are going to be important.
`Q. What could be more important than the
`economics?
`
`Just, I don't know, it depends on
`A.
`what the oil companies‘ objectives might be there
`or what they're trying to find out.
`' Q. Can you think of an example where the
`economics would not be the most important
`
`situation or most important consideration I should
`say?
`
`A. Well, I guess we should go back to
`what do you mean by economics of —- is it of the
`particular well, of ~— there's all kinds of
`economics that you can be talking about there.
`Q. Well, how were you using the term?
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`A. Well, when I was using the term for
`‘permeability, it was just to say okay, we're going
`to get a relative amount of performance
`characteristics out of the well, that would help
`determine whether or not this well could flow at ‘
`an economic rate.
`
`Q. And when you say flow at an economic
`rate, are you referring to the flow of oil?
`A.
`Oil and/or gas.
`Q.
`So is it fair to say you're trying to
`maximize the flow of oil and/or gas?
`A. Well, that wouldn't, that wouldn't
`kind of correlate to that, what we were talking
`about earlier, but that's —— what the oil
`companies do is, is try and optimize the flow of
`oil and/or gas.
`Q. You mentioned earlier that you had
`testified the two times in court. Have you
`
`testified at deposition?
`A. Yes.
`
`Q. Q About how many times?
`A.
`Not -- in the past -— in my CV I
`believe I had listed about three or four times.
`
`I
`
`had testified or done depositions while I was with
`Chevron which was quite a while back.
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`So about three or four times?
`Q.
`A. Yes, in the last few years.
`Q.
`Did all those have to do with the oil
`industry?
`A. Yes, they were somehow related to the
`oil industry, yes.
`Q. Were any of them patent cases?
`A.
`Just the one that we've been talking
`about where I gave trial testimony.
`Q. Besides that patent case, have you
`testified in any other patent case whether it be
`deposition or at trial?
`A.
`No.
`
`Q. Have you provided any expert
`consulting services in any other patent cases
`besides the one that we've described and the
`
`matter that we're here today for?
`A. Yeah, one other.
`Q.
`So you did not testify in the one
`other?
`
`No, I did not testify or give a
`A.
`deposition in that one.
`Q.
`Do you recall who you were engaged by
`in that one other matter?
`
`A.
`
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`though.
`Q. About how long?
`A.
`Six or seven years ago.
`Q.
`Do you recall the subject matter
`generally?
`'
`A. Yeah, it was, it was offshore
`
`drilling and drilling equipment.
`Q. Do you recall the nature of your
`' consulting work, was it to analyze patents?
`A.
`No, it was not.
`It was to give them
`background on the oil, oil industry and oil
`drilling.
`Did it have anything to do with
`Q.
`artificial lift systems of the type that are in
`your declaration for this matter?
`A.
`No.
`
`Q. And did the patent case that you did
`testify in, did that have anything to do with
`artificial lift systems?
`'
`A.
`No.
`
`Q. Have you ever done any consulting for
`the pool and spa industry?
`'
`A.
`No.
`
`Q. Have you ever had a judge rule that
`your testimony should be excluded?
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`A.
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`No.
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`Q. And you understand that we're here
`today because you provided a declaration on behalf
`of Hayward in this matter; is that right?
`A. That's correct.
`'
`
`In fact, I believe you executed it
`Q.
`just on June 9th; is that right?
`A. That sounds right.
`Q.
`Explain for me how you became to be
`engaged by Hayward in this matter.
`A.
`I was contacted by a firm called IMS
`that handles expert witnesses and -— for the legal
`industry and they put me in contact with counsel
`for Hayward.
`Q. And do you recall when about that
`
`was?
`
`year.
`
`A.
`
`I believe it was about April of this
`
`Q. And then were you contacted by Mr.
`Halpern originally?
`A.
`I was put in contact with him through
`
`IMS.
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`So this is the only time you've ever
`Q.
`been engaged by Hayward Industries?
`A. That's correct.
`_
`I don't recall, it's been a while,
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`Q. And is it the only time you've ever
`been engaged by McCarter & English?
`A.
`That's correct.
`
`Q. What, if anything, did you do to
`prepare for your deposition today?
`A. \ Well, I reviewed the Wooley
`declaration and I reviewed my declaration.
`Q.
`Did you do anything else, did you
`meet with the attorneys?
`Yes.
`
`And when was that about?
`
`_
`Yesterday.
`About for how long?
`I think we started at about 9:00 a.m.
`.
`and went till about 5.
`
`Q. And was that just Mr. Halpern?
`A. Well, he was there the whole time and
`Mr. Christie was there for part of the time.
`Q. Anybody else?
`A.
`I think that was it. Yeah, that was
`
`it.
`
`So besides the two declarations you
`Q.
`mentioned, did you review any other documents to
`
`prepare for the deposition today?
`A.
`Not —— just recently I -- during
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`my -— just the recent deposition, no other
`documents.
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`Q. What do you mean the recent
`deposition?
`A. Well, in fact, the last few days, if
`that's what we're, if that's what we're referring
`to.
`
`Q. Correct. Specifically to prepare for
`this deposition?
`A.
`Right.l
`Q. And could you just give me kind of a
`thumbnail sketch of your experience working in the
`oil industry? I know it's been quite extensive.
`A. Okay.
`MR. HALPERN: Objection to form.
`
`A. Okay. Yes, after graduating from
`college in 1979 from the University of Southern
`California, I went to work in the oil industry.
`On paper now it shows that I was working for
`Chevron from that time on through 2004.
`I, I was
`actually —- started with Gulf Oil which was bought
`by Chevron and so —— and then I also worked with
`Gulf companies in that time period that were also
`part of Chevron, Cabinda Gulf Oil and Zaire Gulf
`Oil, so this Gulf Oil and Chevron kind of got
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`intermixed, but on paper I was working with
`Chevron in that period of time. And I've worked-
`in California, in Texas, in West Africa and in the
`Middle East doing a variety of things from
`production engineering to production supervisor to
`planning to reservoir engineering and to
`production engineering to —— and do various
`functions through all these different companies
`within Chevron. And after that I spent some time A
`
`working with Aera Energy, which is a California
`company, as a project manager.
`Q. And now you do consulting?
`A.
`I do consulting and project
`management work.
`Q. And how long have you been doing
`consulting and project management work?
`A.
`Since about 2011.
`
`So essentially you went directly from
`Q.
`university into the oil industry and you've been
`there ever since?
`
`That, that's correct.
`A.
`So then do you have any experience in
`Q.
`the actual manufacture of pumps?
`A.
`Justin seeing pumps taken apart and
`put back together again as far as quality control.
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`But you never worked for a pump
`Q.
`manufacturer?
`
`A.
`
`That's correct.
`
`Q. Have you -- do you have any
`experience in designing pumps?
`A.
`I guess you're going to have to be
`more specific on the question.
`Q. Yeah, the designing of the pump
`I understand that you've got experience
`itself.
`choosing appropriate pumps for larger pumping
`systems; is that accurate?
`A. Yeah, you know, I've helped design,
`you know, how big, how much output, part -- you
`know, what internal materials would be with pumps,
`so I've done that kind of thing. As actually, you
`
`know, being the one that's the actual designer and
`doing the drawings for the pump itself, I have
`not.
`
`So you would go to a manufacturer, a
`Q.
`designer of pumps with the specifications that you
`need for the pump; is that accurate?
`A. Yeah, that would be correct. Then we
`would typically -- I would look at it as design
`the pump together because I'm giving them what
`kind of specifications I need to be put into it
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`Q. Good. And that's how I will refer it
`today. So when I say ESP, I mean electrical
`submersible pump.
`A. Yeah.
`
`Q. What is an ESP?
`A.
`An ESP, as it's stated, is electrical
`
`submersible pump, and the motor and the pump are
`downhole in the well, so at the bottom of the well
`or_ towards the bottom of the well, and a cable
`comes up to the surface that connects the power
`from the surfacerdown to the well downhole, and
`
`
`
`this pump is typically a centrifugal pump that has
`multiple stages in order to pump that, the fluids
`from the bottom of the hole up to the top of the
`hole.
`
`
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`
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`1- O0
`I-*KO
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`Q. And what do you mean by multiple
`stages?
`A. Well, they're -- in a centrifugal
`pump you know you'll have like a thing that goes
`around and around, well, this has many things that
`
`
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`go round and round and they're all in a casing
`. that goes inside the well itself.
`Q. And about how big are these ESPs?
`A. Well, they. can be as big or as small
`as you want them, that's one of the nice things
`Do you have any experience in the
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`and they would actually do the assembly of it and
`make sure it's a good pump and reliable pump.
`Q.
`So you've had pumps designed and
`manufactured to order essentially?
`MR. HALPERN: Objection to form.
`
`Objection to foundation.
`A.
`Yeah.
`I, I don't think I would agree
`with that entirely, what you said there.
`
`Q. What don't you agree with?
`A. Well, I think you -- it's —- the
`
`question makes it sound like I did the whole
`design of the pump and I would just be part. of a
`team that would be designing that pump.
`
`Q. Okay. And what I was getting at is
`I'm sure at times you'd buy a pump off the shelf,
`right?
`
`A.
`
`That's occasionally, but a lot of
`
`times we have to have pumps specially made for our
`applications.
`Q.
`And that's the process you were just
`explaining?
`A.
`
`Yes.
`
`MR. HALPERN: Objection to form.
`BY MR. FAHY:
`
`Q.
`
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`about them because you can design them for as much
`or as little fluid as you want to produce from a
`particular well.
`Q. And you mentioned there's the pump
`itself and the motor and the cable for the power.
`
`Are there any other components to an ESP?
`A. Well, those are the major components
`
`of it.
`
`But there are others?
`Q.
`A. Well, you have a seal section between
`the motor and the pump.
`Q. And what's the seal section comprised
`
`of?
`
`'
`
`A. Well, that's just to isolate the
`motor from the pump and make sure that you don't
`get any extraneous fluids into the motor itself.
`Q. About how big is that seal section
`relative to the pump and motor?
`A.
`It's very small. The motor, the
`motor and the pump take up a vast majority of the
`actual structure of that pump or the contraption
`itself.
`
`Q. And they're directly coupled
`together -—
`'
`A.
`
`
`
`Yes.
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`manufacturing or design of the drives used with
`the pumps?
`MR. HALPERN: Objection to lack of
`
`foundation.
`
`It would, again, it would be just a
`A.
`matter of fact of giving specifications and
`meeting needs so we —- I'd be part-of the team
`that would put it together, but...
`Q.
`Do you have any experience designing
`pump systems outside of the oil industry?
`A.
`No, not outside the oil industry.
`
`Have you ever done consulting work
`Q.
`for a pump manufacturer or designer?
`A.
`No.
`
`Have you ever done consulting work
`Q.
`for drive manufacturer or designer?
`A.
`No.
`
`Are you familiar with electrical
`Q.
`submersible pumps?
`A.
`Yes.
`
`Q. What is —— is that commonly referred
`to as an ESP?
`
`Yeah. That's, well, that's so you
`A.
`don't have to say electrical submersible all the
`time.
`
`
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`
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`
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`Q.
`A.
`
`-- with the seal section?
`Uh-huh.
`
`Q. Are you familiar with a protector?
`A. Well, I know of protectors, I don't
`know specifically what you're referring to.
`Q.
`‘Well, what do you know of protectors?
`MR. HALPERN: Objection to form.
`Okay. Sometimes they put protectors
`A.
`around these pumps in order to shield them from
`
`_
`damage.
`But you're not -- are you familiar
`Q.
`with the protector that goes between the pump and
`the motor in an ESP?
`
`MR. HALPERN: Objection, lack of
`
`foundation.
`
`I, I don't know what specifically
`A.
`you're referring to, no.
`Q.
`So you're not familiar with any ESP
`configuration that has anything besides the seal
`section you mentioned between the pump and the
`motor?
`
`MR. HALPERN: Objection to form and
`lack of foundation.
`
`I don't know specifically what you're
`A.
`referring to there.
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`
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`So the answer is no, you're not
`Q.
`familiar with?
`
`MR. HALPERN: Objection to form and
`lack of foundation.
`
`Okay. Well, yeah, I_ don't know
`A.
`specifically what you're referring to there.
`Q.
`How about an intake, are you familiar
`with that term with regard to ESPs?
`A. Well, there's a pump intake if that's
`what you're referring to.
`Q. And that's just where the fluid
`enters the pump?
`A.
`That's correct.
`
`And where is that-located in the
`Q.
`configuration of the ESP?
`A. Well, it would be at the bottom of
`the pump section.
`Q.
`And could you describe that
`configuration then of an ESP, so the bottom is the
`pump, the intake of the pump towards the bottom of
`that section; is that accurate?
`A. Well, the pump section where the
`fluid goes into the pump, that's the pump intake.
`Q.
`But then where is the motor in
`relation to that?
`
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`A.
`pump.
`
`The motor is usually set below the
`
`So other than the motor, the pump,
`Q.
`the cable, and the seal section, there are no
`other components to an ESP?
`.
`MR. HALPERN: Objection to form and
`lack of foundation.
`
`A.
`of an ESP.
`
`Those are the main, major components
`
`Q. What are the other components that
`are not, the major components?
`A.
`I would have to do some more research
`
`to give you a good, thorough answer to that.
`MR. HALPERN: Objection to form and
`lack of foundation.
`BY MR. FAHY:
`
`How about a pump monitoring unit, are
`Q.
`you familiar with that term?
`A. Well, that's a very generalized term,
`but it's talking about monitoring the pump itself
`and some of the parameters of the pump as, it
`operates.
`
`In relation to an ESP, is that
`Q.
`pump-monitoring unit connected to the motor or the
`pump in any way that you're aware of?
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`
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`A.
`
`It could be.
`
`Q. And what would that consist of, is it
`just a sensor or is it a computer?
`MR. HALPERN: Objection to form and
`objection to lack offoundation.
`A.
`It could be a lot of things.
`
`It's
`
`just a matter of how elaborate a system you might
`want to make it.
`Q. Have you personally -- do you
`personally have any experience with
`pump-monitoring units that are coupled to an ESP? —
`MR. HALPERN: Objection to form and
`lack of foundation.
`V
`
`I -- you would have to get
`A. Yeah.
`more specific about what you mean by that or
`specific examples because that's a very
`generalized term.
`Q. Well, you testified that the major
`components of the ESP are the pump, the motor and
`the cable and the seal section between the pump
`and the motor.
`A. Uh-huh.
`
`.
`
`Q. And I'm asking you, I guess, for the
`example. Are you aware or have you ever seen the
`specific ESP that had a pump-monitoring unit
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`Q. What's that, what's the tubing string
`made of?
`Steel, orI should say typically it's
`A.
`made of steel. There are other situations that it
`
`26
`
`attached to it?
`
`A.
`
`I've seen that have, that have units
`
`that monitor different parameters of the pump and
`what's going on down, downhole.
`Q. And they were attached to the ESP?
`MR. HALPERN: Objection to form and
`lack of foundation.
`
`They were part of the -- they were
`A.
`part, you know, attached to the system I guess
`would be the best way to describe it.
`Q.
`How so?
`A. Well, they were all integral to what
`was, what was being put down there.
`Q.
`But they were -~ were they in the
`same casing as the pump and motor?
`A. Well, it all goes down as part of the
`tubing, so it's all going down into the hole as a
`unit.
`
`MR. HALPERN: Objection to form and
`lack of foundation.
`
`BY MR. FAHY:
`
`So then the unit, the ESP does not
`Q.
`come assembled; do you do that in the field?
`MR. HALPERN: Objection to form and
`lack of foundation.
`
`
`
`
`
`k)l\JU1-I>
`
`
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`
`
`609-259-1228
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`
`so for picking -4 making sure that the pump will
`It comes in pieces as you get there
`A.
`be able to withstand those pressures and
`and you do have to do some assembly out in the
`field.
`temperatures, and then any other information about
`the water, oil and gas that's being produced that
`might be harmful to the pump, so you get the right
`materials that you design the pump for.
`Q. Anything else?
`A.
`I'm sure there's other things that
`
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`could be other things, but in a typical oil field
`application, it would be steel.
`Q.
`So then the cable that you run down‘
`with the ESP has to be as long as the well is
`
`deep?
`
`A.
`
`That's correct.
`
`Q. And that's the power cable?
`~ A.
`That's correct.
`
`Q. What information do you need to know
`in order to choose the appropriate design for an
`ESP?
`
`A.
`
`You need to know the downhole
`
`pressures and you'd want to have an expected
`production rate or at least a range of production
`that's possible.
`Q.
`Is that all you need to know?
`A. Well, you'd also want to know
`temperatures and pressures downhole that it might
`encounter.
`
`Q. What was that last piece?
`A.
`Pressures and temperatures downhole,
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`you would consider, but it would depend on the
`particular well itself and some of the things that
`go with that particular well that would be of
`importance.
`.
`Q. Can you just give me some examples?
`A. Well, like how much water it's going
`to produce, if it's going to be a high water cut;
`how much gas it's going to be produce, is it going
`to be a lot of gas with it; what the —— the
`structure of the well is itself, meaning is it
`
`deviated, is it horizontal, is it vertical.
`Q. Anything else?
`A.
`I think that's a pretty good list
`I'm sure there's other things that could
`
`there.
`
`be thought of or could be considered, but that --
`those -- that's kind of a general thing that you
`look for.
`'
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`Q. Does the pump come coupled to the
`motor or do you have to do that in the field?
`A. Well, it depends on how big the pump
`is and the situation that you have there, how big
`a pump, how big a motor, because you can have
`multiple pump stages and multiple motor stages and
`just depending how big it is.
`Q. Could you describe that process
`generally for me, the installation of the ESP into
`the well?
`
`In general terms you, you take the
`A.
`pump and you put it together, and this is done
`with the rig crew and the pump manuf -- or the
`pump supplier, and you start running it in the
`hole along with, then you attach the cabling that
`goes with it and you run the pump on the bottom of
`the tube and run it into the hole with the cable.
`
`
`
`So you're unwinding the cable as you're lowering
`this pump into the well on the bottom of the
`tubing string that's going to go into the well.
`And the tubing string is the string where the
`fluid is going to be produced from.
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`
`Q. And you mentioned water cut, what
`does that mean?
`A.
`I A typical well in the United States
`produces a lot of water and we -- and they -- and
`when we produce wells wherever we produce them,
`they typically ask for what is the water cut or
`what is the percentage of water that's being
`produced in that particular well. So like, you
`know, like in California we have wells that
`produce 96 percent, 95, 96, 98 percent water, so
`that's what the water cut is is 98 percent in
`that.
`
`Q. And is that over the lifetime of the
`
`well?
`
`It, it varies from when you first put
`.
`A.
`a well on to —- and then it varies by the —— how
`
`old the field is itself or are you water flooding
`the field. So it depends on a lot of factors.
`Q. How much does it vary from the 96 to
`98 percent you mentioned?
`A. Well, I mean, when they first put
`some of these fields on, the field may be
`producing all oil, but by the time it gets older,
`it can go all the way up to 98,- 99 percent water.
`Q. And it's still productive at that
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`point from a oil-producing standpoint?
`A.
`It, it could be.
`Q. How is that; how can it be?
`A. Well, it depends on how much oil
`you're actually producing from the well itself.
`So if you're producing 5,000 barrels of fluid and
`2 percent of that is oil, then you're -— what does
`that come out to, that's —- let's see,. 10 percent
`would be 500, so 2 per —— or 1 percent would be
`50, so that would be a hundred barrels of oil a
`day. So most people in the United States anyways
`[sic] are happy with a-hundred-barrel-a—.day oil
`well.
`
`So we were talking about kind of the
`Q.
`general list of things that you would want to know
`in designing or picking the proper ESP fora
`particular oil well application. How do you
`collect all that data?
`
`MR. HALPERN: Objection to form, lack
`of foundation and mischaracterization of prior
`
`testimony.
`A. Well, the data -- the oil companies
`generally collect data throughout the history of a
`field, and so they get information and can —— and
`know what a well potentially can make, and if you
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`have a field and wells throughout a field, yoifcan
`get a general idea, not specific but a general
`idea of how much that well -- a new well can
`
`potentially make.
`Q.
`So is that data collected through
`sensors?
`
`It's collected by a wide variety of
`A.
`pieces of equipment.
`'
`Q. Can you give me --
`A.
`Sensors, meters, gauges, logs.
`Q. What was that last one?
`A.
`Logs.
`Q. Oh, logs. Are you familiar with the
`term loss of prime as it relates to an ESP in an
`oil well application?
`’
`A. Yes.
`
`Q. What is loss of prime in that
`context?
`A.
`
`It's the diminished flow of fluid
`
`into a pump and where you're getting -— or --
`and/or getting too much gas into the pump itself
`so you've lost, lost fluid into the pump.
`Q. When you say lost fluid Into the
`pump, do you mean you lost all the fluid?
`A. Well, you lost a significant portion
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`'
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`It could be all of it, but it could be a
`of it.
`vast majority of it.
`Q.
`Is there any way to put a percentage
`on where that loss of prime is?
`A.
`I wouldn't, I wouldn't know. That's
`kind of a relative term to the pump itself.
`Q.
`So if an ESP lost 50 percent of the
`fluid, could it have lost prime?
`A.
`In, in —- I don't know. It's ——
`that's -- what happensvis it