1
`2
`
`3
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`15
`16
`
`17
`
`18
`19
`20
`21
`22
`23
`24
`
`25
`
`Page 1
`
` MURRAY DALLAS
` IN THE UNITED STATES DISTRICT COURT
` FOR THE EASTERN DISTRICT OF TEXAS
` TYLER DIVISION
`OIL STATES ENERGY §
`SERVICE, L.L.C., f/k/a §
`STINGER WELLHEAD §
`PROTECTION, INC., §
` §
` Plaintiff, §
` §
`VS. § Civil Action No.: 6:12-CV-611
` §
`TROJAN WELLHEAD §
`PROTECTION, INC., f/k/a §
`GUARDIAN WELLHEAD §
`PROTECTION, INC., §
` §
` and §
` §
`GREENE'S ENERGY GROUP, §
`LLC, §
` §
` Defendants. §
`
` ORAL DEPOSITION OF MURRAY DALLAS
` Houston, Texas
` Thursday, March 13, 2014
`
` Reported by:
` RENE WHITE MOAREFI, CSR, CRR, CLR, CCR
` JOB NO. 71428
`
`TSG Reporting - Worldwide 877-702-9580
`
`Greene's Energy Group, LLC v. Oil States Energy Services, LLC, IPR2014-00216, Ex. 2030
`
`

`

`Page 2
`
`Page 3
`
` MURRAY DALLAS
` A P P E A R A N C E S
`
` MORGAN LEWIS & BOCKIUS
` Attorney for Plaintiff
` 1000 Louisiana Street
` Houston, Texas 77002
` BY: CLAY ERIK HAWES, ESQ.
`
` FOLEY & LARDNER
` Attorney for Defendant
` 3000 K Street, N.W.
` Washington, D.C. 20007
` BY: JOHN FELDHAUS, ESQ.
` BRADLEY ROUSH, ESQ.
`
` Also Present:
` MS. MYRA THETFORD - VIDEOGRAPHER
`
`Page 5
`
` MURRAY DALLAS
` EXHIBITS (cont'd.)
` PAGE LINE
` Exhibit 23 ............................. 113 19
` File History for US Patent No.
` 5,927,403
` (no Bates - 86 pages)
`
` PREVIOUSLY MARKED EXHIBITS
`
` Exhibit 3 .............................. 11 19
` Settlement Agreement
` (GEG-0001703 - GEG-0001715)
` Exhibit 7 .............................. 34 9
` Plaintiff's Second Supplemental
` Objections and Responses to Defendant
` Greene's Energy Group's First Set of
` Interrogatories
` (No Bates - 11 pages)
` Exhibit 8 .............................. 38 20
` Brochure entitled Providing
` Quality Wellhead Protection Services
` Worldwide
` (OSES_015945 - OSES_015956)
` Exhibit 10.............................. 84 25
` US Patent No. 6,817,423
` (No Bates - 17 pages)
` Exhibit 11.............................. 60 20
` US Patent No. 6,289,993
` (No Bates - 12 pages)
` Exhibit 12.............................. 35 21
` US Patent No. 5,819,851
` (No Bates - 14 pages)
` Exhibit 13.............................. 96 22
` Canadian Patent No. 2,195,118
` (No Bates - 32 pages)
`
`1
`2
`
`34
`
`5
`6
`
`78
`
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
` MURRAY DALLAS
`
` March 13, 2014
` ORAL DEPOSITION OF MURRAY DALLAS, held at
` the offices of Morgan, Lewis & Bockius, LLP,
` 1000 Louisiana Street, Suite 4000, Houston, Texas,
` from 8:51 a.m. to 2:04 p.m., before Rene White
` Moarefi, Texas Certified Shorthand Reporter,
` Certified Realtime Reporter, Certified LiveNote
` Reporter, Louisiana Certified Court Reporter, and
` Notary Public in and for the State of Texas.
`
`1
`
`234
`
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
`Page 4
`
` MURRAY DALLAS
` I N D E X
`
` PAGE
`
` APPEARANCES.................................. 3
` MURRAY DALLAS
` EXAMINATION
` By Mr. Feldhaus........................... 6
`
` REPORTER'S CERTIFICATION..................... 173
`
` E X H I B I T S
` PAGE LINE
` Exhibit 15 ............................. 12 23
` U.S. Patent No. 4,867,243
` (no Bates - 14 pages)
` Exhibit 16 ............................. 17 15
` US Patent No. 3,830,304
` (no Bates - 8 pages)
` Exhibit 17 ............................. 51 8
` Brochure entitled Providing
` Quality Wellhead Protection Services
` Worldwide with handwritten annotations
` (OSES_015945 - OSES_015956)
` Exhibit 18 ............................. 64 16
` US Patent No. 6,179,053
` (no Bates - 17 pages)
` Exhibit 19 ............................. 87 3
` US Patent file for Patent No.
` 6,179,053
` (no Bates - 106 pages)
` Exhibit 20 ............................. 107 20
` US Patent No. 4,076,079
` (no Bates - 3 pages)
` Exhibit 21 ............................. 108 24
` File History of US Patent
` 5,819,851
` (no Bates - 130 pages)
` Exhibit 22 ............................. 111 15
` US Patent No. 4,076,079
` (no Bates - 9 pages)
`
`1
`2
`3
`
`45
`
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
`TSG Reporting - Worldwide 877-702-9580
`
`2 (Pages 2 to 5)
`
`

`

`Page 6
`
`Page 7
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
` MURRAY DALLAS
` THE VIDEOGRAPHER: On the record
` at 8:51 a.m., beginning Tape 1.
` (All parties present have hereby
` waived the necessity of the
` reading of the statements by the
` deposition officer as required by
` Rule 30(b)(5).
` THE REPORTER: Any stipulations or
` agreements for the record?
` MR. FELDHAUS: None.
` MURRAY DALLAS,
` having been duly sworn, testified as follows:
` EXAMINATION
` BY MR. FELDHAUS:
` Q. Morning, Mr. Dallas.
` A. Good morning.
` Q. Thank you for coming today.
` A. No problem.
` Q. Would you state your full name for the
` record, sir.
` A. Lloyd Murray Dallas.
` Q. And where do you reside, sir?
` A. Streetman, Texas.
` Q. Are you currently employed?
`
`Page 8
`
` MURRAY DALLAS
` Q. And what was your --
` MR. HAWES: I just want to make
` sure we designate this part of the transcript at
` least as confidential.
` MR. FELDHAUS: Okay.
` Q. (BY MR. FELDHAUS) And what was your
` position with Stinger?
` A. I was -- right now you mean or --
` Q. No, you say you were --
` A. When I owned it?
` Q. Yes, when you owned Stinger.
` A. Well, owner of Stinger and president.
` Q. Were you a founder of Stinger?
` A. Yes.
` Q. When did you find -- when did you found
` Stinger?
` A. I actually filed it in '86.
` Q. And were you -- were you the sole founder?
` A. Yeah.
` Q. Were you employed prior to founding
` Stinger?
` A. Yes.
` Q. With whom?
` A. Directly before that, I was in -- I did
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
` MURRAY DALLAS
` A. Yes.
` Q. With who?
` A. Partly with Stinger on the retainer or Oil
` States, it would be, and I do stuff privately with
` trusts and a couple other oil companies.
` Q. Could you say the name of that trust
` again? What is the name of that?
` A. Trust, Alaskan trust.
` Q. What is your position with Oil States?
` A. I just -- in business development. It's
` kind of like a retainer with them. I've -- I used to
` own Stinger at one time, sold it to them, and then
` they've -- on a retainer to partly look after patents
` and stuff.
` Q. Do you have any equity interest in Oil
` States?
` A. No.
` Q. And what -- what is the -- what are the
` compensation terms of your retainer? Are -- are you
` getting paid a salary?
` A. Yeah, monthly.
` Q. How much is that?
` A. I don't know. It's -- it's not much.
` It's around 6,000, I think, something like that.
`Page 9
`
` MURRAY DALLAS
` some sales stuff for a friend of mine while I was
` getting Stinger started with a firefighting company,
` Covell.
` Q. When did you first learn of the litigation
` that we're taking this deposition in today?
` A. I don't remember the dates. It's been a
` while. I mean, it was last -- last year.
` Q. Have you ever had your deposition taken
` before?
` A. Yeah, I have.
` Q. How many times?
` A. Oh, 10, 12, I don't know, something like
` that.
` Q. And in what capacity?
` A. A lot of it was to do with patents.
` Q. Do you remember how many times you had
` your deposition taken with respect to patents?
` A. Oh, seven, eight times.
` Q. Were those in separate litigations?
` A. Not all separate, but mostly.
` Q. Were -- were these related to patent
` litigations that were filed by Stinger?
` A. Yes.
` Q. And how many patent litigations did
`3 (Pages 6 to 9)
`
`TSG Reporting - Worldwide 877-702-9580
`
`

`

`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
`Page 138
`
`Page 139
`
` MURRAY DALLAS
` Q. All right. Where -- where -- what region
` was Stacy Herschap in charge of?
` A. South Texas and -- South Texas and -- and
` a little portion in Mexico just over the border,
` Reynosa, Mexico.
` Q. Okay. Anyone else?
` A. I believe that's all.
` Q. How many district managers were there in
` each region?
` A. I don't know by re -- there's -- I believe
` at the time 20 -- 20 shops in the US, 4 shops in
` Canada, 3 shops in Mexico, 2 shops in Argentina, 2
` shops in Venezuela, 1 shop in Columbia. We had a
` yard in Scotland. We were over in Australia and the
` South China area. That would include Indonesia,
` Thailand, and the Middle East.
` Q. Were the 20 district managers equally
` divided between the -- or the 20 district managers in
` the US, were they equally divided between the US
` regions?
` A. Yeah, the -- the west side -- we -- we
` didn't do a lot of work in Alaska, but we did some
` work in Alaska. We did work over on the West Coast
` basically out of Bakersfield, so that -- those tied
`Page 140
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
` MURRAY DALLAS
` in with what we would call the Rocky Mountain region,
` and that would include Vernal, Utah; Rock Springs,
` Wisconsin; Williston, North Dakota; Casper; and
` Farmington, New Mexico; Artesia. Do you want me to
` do the region for Oklahoma?
` Q. If you remember any of these district
` managers, I'd appreciate that. Can you remember any
` of the district managers in the Rockies?
` A. In the Rockies would be Royce Griffin out
` of -- out of Rock Springs.
` Q. So if I -- if I wanted to ask for a
` particular document from Stinger when you owned it
` that would give me this type of information, what
` would I ask for?
` MR. HAWES: Object to the form of
` the question.
` A. I don't know. I -- I'm going off the top
` of my head.
` Q. (BY MR. FELDHAUS) I know. Normally I
` would ask for an org chart. It --
` A. Well --
` Q. -- seems that maybe you didn't have one.
` I'm just wondering --
` A. Yeah, I don't really know if we had
`
`Page 141
`
` MURRAY DALLAS
` anything to -- to that. If they had any questions,
` they called me or Bob, you know. We split the calls.
` Pretty much everything was taken care of out of the
` regions.
` Q. Uh-huh.
` A. And the reason we did regions is because
` the trucks would work out of a certain region and
` they would get busier in one area, then the trucks
` would move over to another shop in that region.
` They'd keep the revenue to the regions, partly
` because it's closer.
` And the region manager, they kind of run
` their own -- they hired their own people and they run
` their own show.
` Q. Did they have an equity interest in
` Stinger?
` MR. HAWES: Object to the form of
` the question.
` A. No.
` Q. (BY MR. FELDHAUS) Were -- were you the
` sole owner of Stinger?
` A. I had a 10 percent partner.
` Q. Who was that?
` A. Halford Neustetter.
`
` MURRAY DALLAS
` Q. Was he still your partner when you sold
` out to Oil States?
` A. Yeah.
` Q. Do you know where he is today?
` A. No, I haven't kept up. He lives in
` Alberta. He was out of Canada. And he was a -- kind
` of money or he put money into it at an early age
` and -- or early -- earlier on, and he didn't -- he
` had really no working knowledge of anything that we
` did.
` Q. So I'd like to move on now to, you know,
` your process of inventing. Did you have some process
` that you would go through when you came up with a new
` design that you wanted to patent?
` MR. HAWES: Object to the form of
` the question.
` A. Well, there's a lot of different patents.
` Each -- probably each one has its own story.
` Q. (BY MR. FELDHAUS) All right. Well, let's
` try the '851. What's the story with the '851?
` MR. HAWES: Object to the form of
` the question.
` A. That would mean -- what I did is there's
` no sense in having anything out there unless -- or
`36 (Pages 138 to 141)
`TSG Reporting - Worldwide 877-702-9580
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
`

`

`Page 142
`
`Page 143
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
` MURRAY DALLAS
` coming up with anything unless there's a need for it.
` Q. (BY MR. FELDHAUS) Uh-huh.
` A. And like I was saying, I got a pretty
` extensive background in hydraulic fracturing.
` Q. Uh-huh.
` A. And spent a lot of time traveling, a lot
` of time reading, too. And I would look at potential
` opportunities or potential problems in the oil
` industry that if we had something to fix, a certain
` problem, then you'd think about it, you'd come up
` with the idea, or hopefully you could, and then I
` would design it and we'd do a patent search and then
` we'd go ahead and work on the patent.
` Q. So what -- what was the problem that you
` were addressing with the '851 patent?
` MR. HAWES: Object to the form of
` the question.
` A. Just simply to isolate BOPs and all that
` with -- with a full bore opening into the production
` casing.
` Q. (BY MR. FELDHAUS) So what -- what did you
` consider to be the solution to that problem?
` MR. HAWES: Object to the form of
` the question.
`
`Page 144
`
` MURRAY DALLAS
` position today, that you invented full bore access?
` MR. HAWES: Same objection.
` A. I invented full bore access in putting a
` tool and pulling -- pulling and setting a tool in --
` in and out of BOPs or a wellhead under pressure.
` Q. (BY MR. FELDHAUS) Well, who, then,
` invented full bore access?
` MR. HAWES: Object to the form of
` the question.
` A. You could put BOPs or valves or anything
` over top of casing that was larger than casing, and
` that would be full bore. But it wouldn't isolate
` the -- the well or the BOPs or whatever, you know.
` Q. (BY MR. FELDHAUS) Well, did you invent
` the concept of a wellhead isolation tool with full
` bore access?
` MR. HAWES: Object to the form of
` the question.
` A. Well, I patented -- like, on the '053
` patent or whatever, it's -- is -- it's -- I didn't
` call it -- it was an isolation tool, but it was a
` blowout preventer protector.
` Q. (BY MR. FELDHAUS) Well, are you the
` inventor of the concept of an isolation tool that
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
` MURRAY DALLAS
` A. Every tool that was out there sealed off
` inside the casing, so it wasn't full bore. So the
` solution to it was figure out a way to seal off into
` the tubing head spool and get a -- get full bore
` access, meaning the mandrels and the valves on the
` top and any of the -- any of the frac stack or frac
` equipment. The inside diameter would be larger than
` the inside diameter of the casing that you'd install
` the tools through the BOPs or -- or frac valves or
` whatever.
` Q. (BY MR. FELDHAUS) Why do you keep looking
` at your attorney?
` A. I'm not.
` Q. Oh, okay. So were you aware of any tools
` at the time that allowed full bore access to the
` casing?
` A. No, there's nothing out there.
` Q. So was it your view that you were the
` inventor of a tool that would allow full -- full bore
` access?
` MR. HAWES: Object to the form of
` the question.
` A. Yes.
` Q. (BY MR. FELDHAUS) Is that still your
`Page 145
`
` MURRAY DALLAS
` allows full bore access?
` MR. HAWES: Object to the form of
` the question.
` A. The concept of an isolation tool? I
` didn't call it an isolation tool. I called it a
` BOP -- protect the -- the -- BOPs and all that on the
` wellhead. This is just for casing.
` Q. (BY MR. FELDHAUS) Are you the inventor of
` that concept, then?
` A. Yeah.
` MR. HAWES: Object to the form of
` the question.
` Q. (BY MR. FELDHAUS) So you invented the
` concept of a BOP protector that allows full bore
` access to a casing?
` MR. HAWES: Object to the form --
` Q. (BY MR. FELDHAUS) Is that --
` MR. HAWES: -- of the question.
` Q. (BY MR. FELDHAUS) -- your testimony?
` A. Yeah.
` Q. And that's what you thought you were
` applying for a patent for?
` MR. HAWES: Object to the form of
` the question.
`
`37 (Pages 142 to 145)
`TSG Reporting - Worldwide 877-702-9580
`
`

`

`Page 170
`
`Page 171
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
` MURRAY DALLAS
` MR. HAWES: Object to the form of
` the question.
` A. Stuff like rig reports, drilling reports.
` At -- when this is all going on, this was basically
` the advent of -- basically started with a fellow by
` the norm -- name of George Mitchell, Mitchell Energy.
` And he later sold to a company called Devon Energy.
` They're --
` Q. (BY MR. FELDHAUS) When you say "this was
` going on," what -- when what was going on?
` A. The drilling -- horizontal drilling
` with -- with multiple stage fraccing.
` Q. Okay.
` A. So the rates -- what I seen at the time,
` because we -- we were running tools in wells for
` George Mitchell and Devon Energy and several other
` companies, that these jobs were getting bigger and
` bigger, higher -- extremely high rates, and we're
` using casing savers and sealing off in the casing.
` And it just got to the point that your --
` what we call the spurt on the bottom of the -- of the
` coming out of our mandrel or cup tools that sat
` inside the casing where it's such a high rate that
` they could actually go and wash out the casing during
`Page 172
`
` MURRAY DALLAS
` MR. FELDHAUS: No further
` questions.
` MR. HAWES: I don't have any
` questions at this point.
` MR. FELDHAUS: Okay. Thank you,
` Mr. Dallas.
` THE WITNESS: Thanks.
` THE VIDEOGRAPHER: Off the record
` at 2:02 p.m., ending the deposition, Tape 3.
` THE REPORTER: Before I announce
` the deposition is complete, pursuant to the
` Federal Rules, are there any stipulations
` regarding custody of the transcript, exhibits
` and/or any other pertinent matters?
` MR. HAWES: No, we'll just read
` and sign.
` (Deposition concluded.)
`
` _____________________
` MURRAY DALLAS
` Subscribed and sworn to before me this ____ day
` of _________, 2014.
`
` ____________________________
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
` MURRAY DALLAS
` the course of a fracture treatment.
` And this was a huge problem, so we had to
` slow down the rates. And you slow down the rates in
` the hydraulic treatment. That means in your
` horizontal section, you're going -- you've got to
` have so much rate to fracture, so that would mean
` instead of doing at 50 barrels a minute, you might do
` four jobs at 50 barrels a minute as opposed to two
` jobs at 100. So then you'd have to remove the tools.
` So this is where it all come -- come about
` was to be able to make a tool that sealed off into
` the -- into the tubing head spool with full bore
` access that would go in and out of -- out of the BOPs
` or frac valve sections under pressure and the frac
` crew could tie onto it and then you would not have to
` remove the tool because it's a low profile. And
` they'd have adapters on there to go back to wireline
` or go back with frac heads and leave the frac lines
` hooked up and be able to go between the stages and
` set -- they run liners, frac ball assemblies,
` whatever, and do the different stages without having
` to take the hour, hour and a half to remove the
` setting tool and then put it back on the well. It
` sped up the whole fracturing process.
`
`Page 173
`
` MURRAY DALLAS
` C E R T I F I C A T E
` IN THE UNITED STATES DISTRICT COURT
` FOR THE EASTERN DISTRICT OF Texas
` TYLER DIVISION
`OIL STATES ENERGY §
`SERVICE, L.L.C., f/k/a §
`STINGER WELLHEAD §
`PROTECTION, INC., §
` §
` Plaintiff, §
` §
`VS. § Civil Action No.: 6:12-CV-611
` §
`TROJAN WELLHEAD §
`PROTECTION, INC., f/k/a §
`GUARDIAN WELLHEAD §
`PROTECTION, INC., §
` §
` and §
` §
`GREENE'S ENERGY GROUP, §
`LLC, §
` §
` Defendants. §
`
` REPORTER'S CERTIFICATION
` DEPOSITION OF MURRAY DALLAS
` TAKEN MARCH 13, 2014
`
` I, RENE WHITE MOAREFI, Certified Shorthand
` Reporter and Notary Public in and for the State
` of Texas, hereby certify to the following:
` That the witness, MURRAY DALLAS, was duly sworn
` by the officer and that the transcript of the
` oral deposition is a true record of the testimony
` given by the witness;
`
`44 (Pages 170 to 173)
`TSG Reporting - Worldwide 877-702-9580
`
`

`

`Page 174
`
`Page 175
`
` MURRAY DALLAS
` ERRATA SHEET
` Case Name:
` Dep. Date:
` Deponent:
`
` CORRECTION:
` Pg. Ln. Now Reads Should Read Reason
` __ __ ________ ____________ __________
` __ __ ________ ____________ __________
` __ __ ________ ____________ __________
` __ __ ________ ____________ __________
` __ __ ________ ____________ __________
` __ __ ________ ____________ __________
` __ __ ________ ____________ __________
` __ __ ________ ____________ __________
` __ __ ________ ____________ __________
` __ __ ________ ____________ __________
` __ __ ________ ____________ __________
` __ __ ________ ____________ __________
` __ __ ________ ____________ __________
` __ __ ________ ____________ __________
` __ __ ________ ____________ __________
`
`1
`2
`3
`4
`5
`
`678
`
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
` MURRAY DALLAS
` That the original deposition was delivered to
` ____________________;
` That a copy of this certificate was served on
` all parties and/or the witness shown herein on
` March 25, 2014.
` I further certify that pursuant to FRCP No.
` 30(f)(i) that the signature of the deponent was
` requested by the deponent or a party before the
` completion of the deposition and that the
` signature is to be returned within 30 days from
` date of receipt of the transcript. If returned,
` the attached Changes and Signature Page contains
` any changes and the reasons therefor;
` I further certify that I am neither counsel
` for, related to, nor employed by any of the
` parties in the action in which this proceeding
` was taken, and further that I am not financially
` or otherwise interested in the outcome of the
` action.
` Certified to by me this 25th day of March, 2014.
`
` __________________________________________
` RENE WHITE MOAREFI, CSR, CRR, RPR, CLR, CCR
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`
`25
`
`45 (Pages 174 to 175)
`TSG Reporting - Worldwide 877-702-9580
`
`