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` HERRMANN VOLUME 2 - 08/23/16
`UNITED STATES PATENT AND TRADEMARK OFFICE
` ----------------------
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
` ----------------------
` FMC TECHNOLOGIES, INC.,
` Petitioner,
` V.
` ONESUBSEA IP UK LIMITED,
` Patent Owner.
` ------------------------
` Case IPR2016-00328, -00467, -00378, -00495
` U.S. Patent No. 8,540,018
`
` ------------------------
`
` DEPOSITION OF ROBERT HERRMANN, VOLUME 2
` HOUSTON, TEXAS
` AUGUST 23, 2016
`
`Reported by: Susan S. Klinger, RMR-CRR, CSR
`Job No. 111713
`
`TSG Reporting - Worldwide 877-702-9580
`
`OSS Exhibit 2005, pg. 1
`FMC vs. OSS
`IPR2016-00467
`
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` HERRMANN VOLUME 2 - 08/23/16
`UNITED STATES PATENT AND TRADEMARK OFFICE
` ----------------------
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
` ----------------------
` FMC TECHNOLOGIES, INC.,
` Petitioner,
` V.
` ONESUBSEA IP UK LIMITED,
` Patent Owner.
` ------------------------
` Case IPR2016-00328, -00467, -00378, -00495
` U.S. Patent No. 8,540,018
`
` ------------------------
`
` DEPOSITION OF ROBERT HERRMANN, VOLUME 2
` HOUSTON, TEXAS
` AUGUST 23, 2016
`
`Reported by: Susan S. Klinger, RMR-CRR, CSR
`Job No. 111713
`
`TSG Reporting - Worldwide 877-702-9580
`
`OSS Exhibit 2005, pg. 1
`FMC vs. OSS
`IPR2016-00467
`
`
`
` HERRMANN VOLUME 2 - 08/23/16
`
`Page 238
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` August 23, 2016
` 9:12 a.m.
`
` Deposition of ROBERT HERRMANN, held at the
`offices of Fish & Richardson, 1221 McKinney Street,
`Houston, Texas, before Susan S. Klinger, a
`Registered Merit Reporter and Certified
`Realtime Reporter of the State of Texas.
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`FMC vs. OSS
`IPR2016-00467
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`
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`Page 239
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` HERRMANN VOLUME 2 - 08/23/16
`A P P E A R A N C E S:
`
`Attorneys for Petitioner:
` Mr. Michael Kiklis, Esq.
` Mr. Christopher Ricciuti, Esq.
` OBLON McCLELLAND MAIER & NEUSTADT
` 1940 Duke Street
` Alexandria, Virginia 22314
`
`Attorneys for Patent Owner:
` Mr. Bret Winterle, Esq.
` Mr. Joshua Griswold, Esq. (Telephonically)
` FISH & RICHARDSON
` 1717 Main Street
` Dallas, Texas 75201
`
`Also Present:
` Ms. Paula Whitten-Doolen, Schlumberger
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`FMC vs. OSS
`IPR2016-00467
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`Page 240
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` HERRMANN VOLUME 2 - 08/23/16
` I N D E X
`
`WITNESS PAGE
`
`ROBERT HERRMANN
`
`EXAMINATION BY MR. KIKLIS 241
`EXAMINATION BY MR. WINTERLE 317
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`FMC vs. OSS
`IPR2016-00467
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` HERRMANN VOLUME 2 - 08/23/16
` ROBERT HERRMANN,
`having been first duly sworn testified as
`follows:
` EXAMINATION
`BY MR. KIKLIS:
` Q. Welcome back, Mr. Herrmann. We are
`starting the second day of your deposition for
`the four cases that we discussed yesterday. Do
`you understand that?
` A. I do.
` Q. Did you talk to anybody about your
`deposition at all since we started yesterday
`morning?
` A. I did not.
` Q. I would like to direct your
`attention to Kelly. I left it open for you
`right there. Do you remember yesterday you
`marked that up?
` A. Yes.
` Q. And you put a red circle around
`where the wing block would have to be attached
`to the tree?
` A. Where a wing block would be
`attached.
`
`TSG Reporting - Worldwide 877-702-9580
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`OSS Exhibit 2005, pg. 5
`FMC vs. OSS
`IPR2016-00467
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` Q. Would be attached?
` A. Yes.
` Q. To a tree, yes. So where you
`circled in red is the, I guess, the outer
`bounds of the tree; is that right, where the
`tree ends?
` MR. WINTERLE: Objection to form.
` Q. What would you call it?
` A. It is the outlet, the production
`outlet for the tree.
` Q. So but that is where the tree ends;
`is that right?
` MR. WINTERLE: Objection to form.
` A. No.
` Q. Where does the tree end, in your
`opinion?
` A. Well, vertically it ends at the tree
`cap. Horizontally it has got two boundaries,
`one for the annulus outlet and one for the
`production outlet, this tree, yes.
` Q. And where does, I'm sorry, where
`does the production outlet end in Figure 1?
` MR. WINTERLE: Objection to form.
` A. Could you use a different word than
`
`TSG Reporting - Worldwide 877-702-9580
`
`OSS Exhibit 2005, pg. 6
`FMC vs. OSS
`IPR2016-00467
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` HERRMANN VOLUME 2 - 08/23/16
`"end"? Where is it located?
` Q. Well, I'm trying to figure out --
`I'm trying to find out where the production
`outlet ends?
` MR. WINTERLE: Objection to form.
` Q. Doesn't that make sense?
` A. No.
` Q. So what -- how would you describe
`the beginning and end of the production outlet?
` A. That is a different question.
` MR. WINTERLE: Objection, form.
` A. As we did in our -- either the
`petition or the declaration for this one
`production outlet starts downstream of the
`production valve and ends at the terminus of
`24.
` Q. Now, let me direct your attention to
`column 2.
` A. Go ahead. I'm going to get some
`water. Thank you.
` Q. So I believe it is your testimony
`that the tree comprises the center column, if
`you will, of Figure 1. And you have marked in
`red where the end of that tree would be; right?
`
`TSG Reporting - Worldwide 877-702-9580
`
`OSS Exhibit 2005, pg. 7
`FMC vs. OSS
`IPR2016-00467
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` MR. WINTERLE: Objection to form.
` A. No.
` Q. On the lateral side?
` A. No.
` Q. Okay.
` A. I never talked about the end of a
`tree.
` Q. Well, what would you define the tree
`as in Figure 1?
` A. We have Figure 1 generally looking
`at the tree assembly which includes the branch
`outlet and the choke, the tree cap, everything
`that you run all at once. The tree itself is,
`the Christmas tree itself, the tree body is
`that piece in the middle with the four valves.
` Q. And everything to the right of the
`tree body, so you have got a wing valve; right?
` A. Yes.
` Q. And then to the right of the wing
`valve you have, I believe you called it a T
`block; is that right?
` A. That's the T block, yes, I labeled
`it.
` Q. And then there is where the
`
`TSG Reporting - Worldwide 877-702-9580
`
`OSS Exhibit 2005, pg. 8
`FMC vs. OSS
`IPR2016-00467
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` HERRMANN VOLUME 2 - 08/23/16
`production flow takes its downward turn; is
`that right?
` A. Yes.
` Q. Now, what would you call the piping
`that extends from the T block down to line 20?
` A. I believe we called it part of the
`production branch.
` Q. Production branch?
` A. It is in -- it is --
` Q. You said "we." What would you call
`it as one of ordinary skill?
` MR. WINTERLE: Objection to form.
` A. I have called it something -- may I
`review the declaration and see what I called
`it?
` Q. Sure.
` A. Actually in the petition may I
`review the petition and see what we, how we
`labeled that?
` Q. Well, you understand, you keep using
`the word "we." And I want to be very clear
`that what we're -- what I'm asking you for is
`what your opinion is in terms of what one of
`ordinary skill in the art would think when
`
`TSG Reporting - Worldwide 877-702-9580
`
`OSS Exhibit 2005, pg. 9
`FMC vs. OSS
`IPR2016-00467
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` HERRMANN VOLUME 2 - 08/23/16
`looking at the Kelly patent?
` A. My opinion --
` MR. WINTERLE: Objection to form.
` A. -- is how we labeled it in the
`petition. May I look at the petition?
` Q. You have everything in front of you,
`sir.
` A. Yes, it is on Figure 4 of the
`petition, the '018 petition.
` Q. If you need to refresh your
`recollection that is fine, but I would like to
`focus your testimony on Figure 1 of the Kelly
`patent. And my question to you, sir, is the
`vertical piping extending downwardly from the T
`block, production T block that you have
`identified on line 20, what in your opinion
`would one of ordinary skill in the art call
`that piping?
` MR. WINTERLE: Objection to form.
` A. If you refer -- Figure 1; right?
`You refer to Figure 1 in the petition we call
`that --
` Q. Sir, I'm referring to Figure 1 in
`the Kelly patent. Do you have the Kelly patent
`
`TSG Reporting - Worldwide 877-702-9580
`
`OSS Exhibit 2005, pg. 10
`FMC vs. OSS
`IPR2016-00467
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`
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` HERRMANN VOLUME 2 - 08/23/16
`in front of you?
` A. That is Figure 1 of the Kelly
`patent.
` Q. That is fine, but I'm not talking
`about the petition, I'm talking about Kelly
`Figure 1.
` A. Yes.
` Q. So I want your testimony with
`respect to Kelly Figure 1?
` A. Yes. As shown in the petition,
`Figure 1 for Kelly it shows that vertical part
`to be part of a diverter.
` Q. So one of ordinary skill in the art
`looking at the vertical piping from the T block
`to line 20 in Kelly would just think of that as
`a diverter; is that what your testimony is?
` MR. WINTERLE: Objection to form.
` A. Say that again.
` (Record read.)
` A. No, it is not.
` Q. I'm going to ask you again, sir.
`The vertical piping extending from the T block
`to line 20 in Figure 1 of Kelly what would one
`of ordinary skill in the art call that piping?
`
`TSG Reporting - Worldwide 877-702-9580
`
`OSS Exhibit 2005, pg. 11
`FMC vs. OSS
`IPR2016-00467
`
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` MR. WINTERLE: Objection to form.
` A. We called it part of the diverter
`assembly.
` Q. Again, sir, I'm not asking what we
`called it, FMC called it, your lawyers called
`it or anybody else. I'm asking, and if you
`don't want to provide the testimony just say so
`and I will move on. If you don't have an
`answer to the question just say so and I will
`move on. Can you answer my question?
` A. I did.
` Q. No, you didn't. My question to you,
`sir, was looking at Figure 1 and you are
`looking at the petition. Looking at Figure 1
`the vertical piping that extends from the T
`block, Figure 1 of Kelly all the way down to
`line 20, what would one of ordinary skill in
`the art call that piping?
` MR. WINTERLE: Objection to form.
` A. By itself?
` Q. Yes.
` A. Just by itself without looking at
`something different, something more that tells
`me you would call that part of the discharge,
`
`TSG Reporting - Worldwide 877-702-9580
`
`OSS Exhibit 2005, pg. 12
`FMC vs. OSS
`IPR2016-00467
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`production discharge line.
` Q. Now, one of ordinary skill in the
`art looking at line 20 which extends from the
`production discharge line to collet body 22 in
`Figure 1 of Kelly, what would they call that?
` MR. WINTERLE: Objection to form.
` A. I just answered that.
` Q. No, I was specifically asking you my
`last question, sir, between the vertical pipe
`extending from the T block to line 20, I was
`very clear about that?
` A. What was my answer?
` Q. I believe you know what you
`answered. Do we need to read back your answer?
` (Record read.)
` Q. Now, line 20 of Figure 1 of Kelly
`what would you -- what would one of ordinary
`skill in the art call that?
` MR. WINTERLE: Objection to form.
` A. I'm sorry, I'm confused. I thought
`I just answered that. I thought that is what
`she just read and I just answered it. I'm
`sorry, I'm just not following you.
` Q. Okay. Do you see the T block in
`
`TSG Reporting - Worldwide 877-702-9580
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`FMC vs. OSS
`IPR2016-00467
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`Figure 1 of Kelly?
` A. Yes.
` Q. Do you see the pipe extending
`downwardly from the T block that apparently
`connects to line 20, do you see that?
` MR. WINTERLE: Objection to form.
` A. It doesn't connect to line 20, but
`go ahead.
` Q. What does it do then?
` A. It connects to 22.
` Q. So but there is separate piping it
`looks like 20?
` A. Okay.
` MR. WINTERLE: Objection to form.
` A. Say that again.
` Q. But it looks like there is separate
`piping coming off of the vertical pipe between
`the T block and which constitutes line 20?
` A. That is probably the same pipe. I
`don't think it is separate piping.
` Q. Well, it looks like it is different
`piping.
` MR. WINTERLE: Objection.
` Q. But I'm just asking --
`
`TSG Reporting - Worldwide 877-702-9580
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`FMC vs. OSS
`IPR2016-00467
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` A. How does it look like it is
`different piping?
` Q. Well, the diameters look different.
` A. You are looking at the guidepost.
` Q. Okay. Then it is your testimony
`that line 20 would connect all the way up to
`the T block?
` A. It looks like to me, yes.
` Q. Where are you getting that from?
` A. Figure 1.
` Q. So line 20, in your opinion, is one
`of -- let me start over.
` So in your opinion, one of ordinary
`skill in the art would consider line 20 to be
`the production discharge line?
` MR. WINTERLE: Objection to form.
` A. As I said if you took line -- take
`off everything else and only look at the
`terminus of line 20 consider nothing else,
`suppose nothing else is there and you can see
`nothing else, you would say that it is part of
`the discharge line, production discharge line,
`branch, line.
` Q. And then that terminates at collet
`
`TSG Reporting - Worldwide 877-702-9580
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`FMC vs. OSS
`IPR2016-00467
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`body 22; is that right?
` A. Line 20 does, yes.
` Q. And now what is line 24?
` A. Line 24 is part of the production
`discharge line.
` Q. Now, on line 24, column 2 --
` A. May I review my declaration just for
`a minute? I want to make sure I'm being
`consistent. Yes, okay.
` Q. If you could pick up actually
`again --
` A. Yes.
` Q. -- column 2, line 24. This says,
`"Line 20 connects from the well production
`string to production flowline body or collet
`body 22." Do you see that?
` A. Yes.
` Q. I want to focus you in on those 5
`words, "flowline body or collet body." So in
`that line Kelly is referring to the collet body
`as also a flowline body; is that right?
` MR. WINTERLE: Objection to form.
` A. He refers to it as a production
`flowline body.
`
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` Q. Production flowline body?
` A. Yes.
` Q. Why is that?
` A. I don't know what that is.
` Q. You don't know what a production
`flowline body is?
` A. No, I don't know what that is. I
`bet if you ask somebody in the art what a
`production flowline body is he would shrug his
`shoulders and would say I don't know what he's
`talking about. It is not a commonly used word.
` Q. Is it, is it Kelly's attempt to
`indicate that production flowline bodies
`connected to a flowline?
` MR. WINTERLE: Objection, form.
` A. I don't know what Kelly's intent
`was. I don't know why he used that word.
` Q. But it must have something to do
`with the flowline, shouldn't it?
` A. I don't know.
` Q. You don't know. So you have no
`opinion as to what production flowline body is;
`is that correct?
` A. I don't really know. If somebody
`
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`asked me --
` MR. WINTERLE: Objection.
` A. -- what a production flowline body
`was, I wouldn't have a clue. It could be a lot
`of things. I know the words, I know what they
`mean. And I can conjure a bunch of things that
`it could be, what you would call a production
`flowline body, but it is not a phrase that you
`would see commonly.
` Q. So just to reiterate, you have no
`understanding of what a production flowline
`body is; right?
` MR. WINTERLE: Objection to form.
` A. Because he, he equates it to a
`collet body. I know what he's trying to,
`trying to say, but I wouldn't call it a
`production flowline body. I don't know what
`that means.
` Q. Let's go back to Figure 1. You have
`described what the tree body is. Now, there
`are tree guides, wing valve tree guide, T
`block, what would you call that infrastructure
`or that structure?
` MR. WINTERLE: Objection to form.
`
`TSG Reporting - Worldwide 877-702-9580
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`OSS Exhibit 2005, pg. 18
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` Q. It isn't part of the tree body;
`right?
` MR. WINTERLE: Same objection.
` A. You said two things, tree guides and
`what was the other one?
` Q. So you have identified the tree body
`in Figure 1; right?
` A. Yes.
` Q. And then next to the tree body you
`have got a wing valve, you have got a T block,
`you have got other structures. What would that
`be considered part of?
` MR. WINTERLE: Objection, form.
` A. What other structures?
` Q. Wing valve and T block?
` A. They're part of the tree assembly.
` Q. Tree assembly. So where does the
`tree assembly end in Figure 1? Let me start
`this way. Does the tree assembly include the
`tree body?
` A. Yes, it does.
` Q. What else does the tree assembly
`include in Figure 1?
` A. Tree assembly is generally
`
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`everything that you would run to land on the
`wellheads. So it would include the tree body,
`it would include the choke, it would include
`the hub outlet, production hub outlet.
` Q. So I'm speaking specifically with
`Figure 1. So what elements of Figure 1 would
`you consider to be the tree assembly?
` A. 10, so that would include 10, 18,
`26, 28, 22, 24, everything in between and part
`of 22 that is not shown. It would include
`that, that hub looking up, that hub connection
`includes the connector, of course, but that is
`bolted to the tree. It would include the tree
`cap, maybe not, tree cap is debatable.
` Q. The tree cap is debatable?
` A. Yes.
` Q. Why is that?
` A. You run it on two or three tree caps
`off of it, probably not.
` Q. So the tree cap is not landed on the
`wellhead?
` MR. WINTERLE: Objection to form.
` A. No, the tree cap is not landed on
`the wellhead.
`
`TSG Reporting - Worldwide 877-702-9580
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` Q. And is the choke landed on the
`wellhead?
` A. No, the choke is not landed on the
`wellhead.
` Q. But you are still calling the choke
`part of the tree assembly?
` A. Yes, the choke is part of the tree
`assembly.
` Q. But you could remove the choke. I
`mean the whole purpose behind Kelly is a
`retrievable choke; is that right?
` MR. WINTERLE: Objection to form.
` A. I can remove a choke, yes, I can
`remove the Kelly choke.
` Q. Where does the flowline begin?
` A. The flowline?
` Q. In Figure 1, yes.
` MR. WINTERLE: Objection to form.
` A. The flowline is not shown in Figure
`1.
` Q. Well, the production discharge line
`directly communicates with the flowline; right?
` A. Yes, eventually.
` Q. Well, wouldn't you then call the
`
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`production discharge line the flowline?
` MR. WINTERLE: Objection to form.
` A. No, the flowline means something
`else to somebody skilled in the art.
` Q. But you made it very clear
`yesterday, sir, that if something is in fluid
`communication with something else, it likewise
`can be called that other thing?
` MR. WINTERLE: Objection.
` Q. So in this situation isn't the
`production discharge line --
` MR. WINTERLE: Objection,
` mischaracterizes prior testimony.
` Q. -- in fluid communication with the
`production flowline?
` MR. WINTERLE: Objection,
` mischaracterizes prior communication.
` A. The discharge line --
` MR. KIKLIS: Excuse me, one word
` objections is all you get.
` MR. WINTERLE: I disagree.
` MR. KIKLIS: Look at the trial
` guide.
` MR. WINTERLE: I did.
`
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` MR. KIKLIS: It is one word
` objections. And if you sit here and try to
` coach the witness, then we're going to call
` the board and we will read your objections
` to the board. Got it?
` MR. WINTERLE: I understand.
` Q. Now, sir, my question to you,
`Mr. Herrmann, is the production discharge line
`is in fluid communication with the flowline;
`right?
` A. It is.
` Q. Would you call that direct
`communication with the flowline?
` MR. WINTERLE: Objection to form.
` A. It is in direct communication --
`well, no, it is not, I'm sorry, not necessarily
`in direct communication with the flowline.
` Q. Why not?
` A. Well, it can go through a manifold
`and commingle with some other wells. The
`flowline would be in direct communication with
`the manifold.
` Q. But if there were a single -- if
`there were not a manifold and line 24 were
`
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` HERRMANN VOLUME 2 - 08/23/16
`communicating directly to the production
`facility, then in that case line 24 would be
`considered a flowline; right?
` MR. WINTERLE: Objection to form.
` A. Well, no, it would be considered
`the, the production outlet from the tree
`assembly and the flowline connects to it.
` Q. In that situation the production
`discharge line would communicate directly with
`the flowline?
` A. In that situation where there was no
`other wells and there was only -- no manifold,
`and this, yes, it would communicate directly
`with the flowline.
` Q. One of ordinary skill in the art,
`therefore, could consider any part along the
`production discharge line part of the flowline;
`right?
` MR. WINTERLE: Objection to form.
` A. No. In fact, anybody skilled in the
`art would not consider that part of the
`flowline. The flowline means something special
`to somebody skilled in the art.
` Q. And what does that mean?
`
`TSG Reporting - Worldwide 877-702-9580
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` A. It is the line that conveys the
`production to the production facility.
` Q. So everything on Figure 1, in your
`opinion, is part of what is known as a tree
`assembly?
` A. No.
` Q. What on Figure 1 is not part of tree
`assembly?
` A. Well, the wellhead, the guidepost,
`the guide frame, probably the tree cap is
`arguably that is not part of the tree assembly.
` Q. The guideposts are not considered
`part of the tree assembly?
` A. No.
` Q. Why is that?
` A. They're on a separate frame that is
`run on the wellhead. As I explained yesterday,
`the guideposts are used to orient the BOP
`stack. They're there. They don't have
`anything to do with the -- they were there when
`the well was drilled. They're remnant of some
`other operation.
` Q. So the tree guides, I believe 14 is
`that one of the tree guides? They're the
`
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`vertical columns depicted on the -- actually,
`let's look at Figure 2. Could you mark in red
`-- you can use this red pen where the tree
`guides are. Does Figure 2 depict the tree
`guides?
` A. It shows the guideposts, yes.
` Q. The guideposts. Can you circle the
`guideposts in Figure 2 of Kelly?
` A. Okay.
` Q. Could you mark all four guideposts?
` A. (Witness complies.)
` Q. So now, you have marked the four
`guideposts in Figure 2; right? Is that
`correct?
` A. Yes.
` Q. Now, when the tree body is lowered
`to the wellhead, is it lowered with the
`guideposts or not?
` A. No guideposts are there.
` Q. Then the tree body is lowered inside
`the guideposts?
` MR. WINTERLE: Objection to form.
` A. I will explain in Figure 1.
` Q. Yes.
`
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` A. There is some funnels. The funnels
`are long. Those are the guide funnels and
`they're attached to a connector which is
`attached to the tree. And they capture -- the
`guidepost captures the funnels and then they
`will be able to land.
` Q. Now, on Figure 2 there seems to be
`cross-sectional support between the guideposts,
`doesn't there?
` A. Yes, that is shown in Figure 1. It
`is shown a little better in Figure 1.
` Q. What is the cross-sectional support
`used for?
` A. Have you got something I can mark?
`I'm going to use your words, it isn't what we
`would use.
` Q. What would you call it?
` A. Part of the guide frame, but I will
`put that guide frame support.
` Q. But in Figure 2 it shows that there
`is not only -- well, there is diagonal support,
`do you see that?
` A. Figure 2. Yes, that is what I
`marked in Figure 1.
`
`TSG Reporting - Worldwide 877-702-9580
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` Q. Figure 2?
` A. Yes, that is what I just --
` Q. Diagonal support?
` A. Yes.
` Q. That is lowered with the guideposts,
`too?
` A. No, that is on the tree.
` Q. That is on the --
` A. That is connected to the connector,
`I said that.
` Q. So the guideposts and the guideposts
`supports including the guidepost diagonal
`supports are all already on the wellhead?
` A. No, they would be part -- this is
`what we did in the '80s. The guide frame would
`be part of the tree assembly.
` Q. So the guide frame is part of the
`tree assembly?
` A. Uh-huh.
` Q. But it is not lowered with the tree
`body?
` A. Yes.
` Q. Right?
` A. It is lowered with the tree. It is
`
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`connected -- the guide frame is connected to
`the connector and that is connected to the tree
`body. It is all together, the way this one
`shows. Sometimes you can have retrievable
`guide frames, but this one shows the permanent
`guide frame connected to the tree.
` Q. So in Kelly the tree guide frame is
`part of the tree assembly?
` A. Yes.
` Q. And it is lowered when the tree body
`is -- it is lowered with the tree body when it
`is being installed in the wellhead?
` MR. WINTERLE: Objection to form.
` A. It is all part of the tree assembly
`and the tree body is part of the tree assembly.
`It is all run together onto the wellhead.
` Q. This Figure 2 looks like the tree
`guides and supports and the tree body are all
`interconnected?
` MR. WINTERLE: Objection to form.
` Q. Right?
` A. No, they're not. There is clearance
`between the funnel and the post. You were
`probably trying to say something else that was
`
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`right, but the way you said it is wrong.
` Q. What was -- then tell me what I
`should have said?
` A. The posts are connected permanently
`to the wellhead on a guide frame. It is
`connected permanently to the wellhead, so you
`kind of do that all together with the guide
`frame and the guideposts and it is on the
`wellhead, the posts are.
` Q. Posts are on the wellhead?
` A. Yes, yes.
` Q. What part of Figure 1 are the
`guideposts?
` A. You see down here these are the
`guideposts, I've already marked that. This is
`the connection to the wellhead, the guidepost
`connection to the wellhead.
` Q. What is the part that lands on top
`of the wellhead?
` MR. WINTERLE: Objection to form.
` Q. Everything above that?
` A. The connector lands on to the
`wellhead, and then these funnels are connected
`to the connector. So here are the posts -- I
`
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`just -- we will do one, here is the funnel. So
`if the post is setting there I'm trying to find
`it with the wire I find it and I land it, so
`this is the funnel. This is the post, so this
`is the post. This is the funnel that part
`here.
` Q. Where is the funnel?
` A. This part here. So it slides on to
`the post.
` Q. Could you -- could you mark with
`brackets what the funnel is that lands so
`everything from that line above?
` A. This is going back to the '80s, so I
`hope I'm getting it right.
` Q. I'm trying to get at what Kelly
`does. Is that the way Kelly would be
`installed?
` A. Kelly shows a guide, a guide
`frame --
` Q. Everything --
` A. -- guideline stack.
` Q. So everything --
` A. The guideline tree.
` Q. So everything from the post funnel
`
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` HERRMANN VOLUME 2 - 08/23/16
`above is
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