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`Ex. PGS 1063
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`Case 4:09-cv-01827 Document 433 Filed in TXSD on 07/25/12 Page 1 of 190
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`454
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`UNITED STATES DISTRICT COURT
`SOUTHERN DISTRICT OF TEXAS
`HOUSTON DIVISION
`
`09-CV-1827
`Houston, Texas
`
`12:11 p.m.
`July 24, 2012
`
`*
`*
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`**
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`***
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`WESTERNGECO LLC
`VS.
`ION GEOPHYSICAL
`CORPORATION, FUGRO
`GEOTEAM, INC., ET AL
`
`JURY TRIAL
`Volume 2
`Afternoon Session
`BEFORE THE HONORABLE KEITH P. ELLISON
`UNITED STATES DISTRICT JUDGE
`
`APPEARANCES:
`FOR THE PLAINTIFF:
`Lee L. Kaplan
`SMYSER, KAPLAN & VESELKA, LLP
`700 Louisiana, Suite 2300
`Houston, Texas 77002
`713.221.2300
`
`Gregg F. LoCascio
`KIRKLAND & ELLIS LLP
`655 Fifteenth Street Northwest
`Washington, DC 20005
`202.879.5290
`
`Sarah Tsou
`Timothy K. Gilman
`KIRKLAND & ELLIS LLP
`Citigroup Center
`153 East 53rd Street
`New York, New York 10022
`212.446.6435
`
`Johnny C. Sanchez, RMR, CRR - jcscourtreporter@aol.com
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`Case 4:09-cv-01827 Document 433 Filed in TXSD on 07/25/12 Page 2 of 190
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`FOR ION GEOPHYSICAL CORPORATION:
`David L. Burgert
`Susan Kopecky Hellinger
`Jonathan M. Pierce
`Jonna N. Stallings
`Ray T. Torgerson
`Eric D. Wade
`PORTER & HEDGES LLP
`Reliant Energy Plaza
`1000 Main Street, 36th Floor
`Houston, Texas 77002
`713.226.6694
`
`FOR FUGRO GEOTEAM, INC.:
`Gordon T. Arnold
`Jason A. Saunders
`Anthony Hong
`ARNOLD KNOBLOCH LLP
`4900 Woodway Drive
`Suite 900
`Houston, Texas 77056
`
`James M. Thompson
`ROYSTON RAYZOR VICKERY & WILLIAMS LLP
`Pennzoil Place
`711 Louisiana Street, Suite 500
`Houston, Texas 77002
`713.890.3218
`
`Court Reporter:
`Johnny C. Sanchez, RPR, RMR, CRR
`515 Rusk, #8016
`Houston, Texas 77002
`713.250.5581
`Proceedings recorded by mechanical stenography. Transcript
`produced by computer-assisted transcription.
`
`Johnny C. Sanchez, RMR, CRR - jcscourtreporter@aol.com
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`Case 4:09-cv-01827 Document 433 Filed in TXSD on 07/25/12 Page 3 of 190
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`I N D E X
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`WITNESS
`THOMAS SCOULIOS
`CROSS-EXAMINATION BY MR. THOMPSON..............
`REDIRECT EXAMINATION BY MR. LOCASCIO...........
`SIMON BITTLESTON
`DIRECT EXAMINATION BY MR. GILMAN ..............
`CROSS-EXAMINATION BY MR. BURGERT...............
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`Case 4:09-cv-01827 Document 433 Filed in TXSD on 07/25/12 Page 125 of 190
`Cross-Bittleston/By Mr. Burgert
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`578
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`making solid streamers and things like that. So we looked
`at the number of different areas. This was one of them.
`And I think you told Mr. Gilman that others before
`Q.
`you had looked at ways to move streamers laterally; is
`that right?
`A.
`Of course, because the streamers are moved laterally
`by monowings, They existed before. In fact, the first
`time people started to move cables sideways like this was
`the second world war for minesweepers. So you know, the
`history of devices that pull cables sideways is a very
`long history.
`So any statement that you invented lateral steering
`Q.
`is just wrong?
`A.
`Yes. I am not the inventor of laterally steering.
`I'm an inventor of a global control system.
`And the global control system is software in a
`Q.
`computer, isn't it?
`A.
`It's rather more than that. There's many components
`of what I call an overall control system. It's the
`methods by which you're going to do it. It's the
`measurements you're going to need to do it and the other
`devices. But it depends on your terminology, I think, and
`how you -- what you encompass in that statement.
`All right. Well, one of the -- and the reason I
`Q.
`asked that is because, in response to one of Mr. Gilman's
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`Johnny C. Sanchez, RMR, CRR - jcscourtreporter@aol.com
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`03:08:58
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`03:09:15
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`03:09:28
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`03:09:44
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`Ex. PGS 1063
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