I, the below-named Declarant, state as follows:
`
`1. My name is Michael P. Delaney, and I reside in Dallas, Texas.
`
`2.
`
`I am a paralegal at the law firm of Caldwell, Cassady and Curry
`RC.
`
`3. Attached as Exhibit 2003 is a true and correct copy of R. Seale
`et al., Eflective Stimulation ofHorizontal Wells—A New
`Completion Method, SPE 106357, Society of Petroleum
`Engineers (2006). I have confirmed that this article is available
`
`at www.0nepetro.org.
`
`4. Attached as Exhibit 2013 is a true and correct copy of A.
`Casero, Open Hole Multi-Stage Completion System in
`Unconventional Plays: Efficiency, Eflectiveness and Economics,
`SPE 164009 (2013).
`I have confirmed that this article is
`available at www.0nepetro.org.
`
`5. Attached as Exhibit 2015 is a true and correct copy of D.
`Lohoefer, Comparative Study of Cemented versus Uncemented
`Multi-Stage Fractured Wells in the Barnett Shale, SPE 135386,
`Society of Petroleum Engineers (2010). I have confirmed that
`this article is available at www.0nepetro.org.v
`
`6. Attached as Exhibit 2018 is a true and correct copy of Baker
`Hughes, FracPoint Completion System Isolated Openhole
`Horizontal Well in Lower Huron Shale (201 1).
`
`7. Attached as Exhibit 2019 is a true and correct copy of Baker
`Hughes, Enhancing Well Performance Through Innovative
`Completion Technologies, presentation, (Sept. 10-12, 2012).
`
`8. Attached as Exhibit 2039 is a true and correct copy of
`
`Weatherford presentation titled, Openhole Completion Systems.
`
`9. Attached as Exhibit 2045 is a true and correct copy of Westin,
`Scott, Private Property, PwC, (Jan. 2, 2013). It was accessed
`from the URL identified in the exhibit on the date noted on the
`
`exhibit.
`
`Ex. 2082
`
`IPR2016-01517
`1 of 6
`
`
`
`1. My name is Michael P. Delaney, and I reside in Dallas, Texas.
`
`2.
`
`I am a paralegal at the law firm of Caldwell, Cassady and Curry
`RC.
`
`3. Attached as Exhibit 2003 is a true and correct copy of R. Seale
`et al., Eflective Stimulation ofHorizontal Wells—A New
`Completion Method, SPE 106357, Society of Petroleum
`Engineers (2006). I have confirmed that this article is available
`
`at www.0nepetro.org.
`
`4. Attached as Exhibit 2013 is a true and correct copy of A.
`Casero, Open Hole Multi-Stage Completion System in
`Unconventional Plays: Efficiency, Eflectiveness and Economics,
`SPE 164009 (2013).
`I have confirmed that this article is
`available at www.0nepetro.org.
`
`5. Attached as Exhibit 2015 is a true and correct copy of D.
`Lohoefer, Comparative Study of Cemented versus Uncemented
`Multi-Stage Fractured Wells in the Barnett Shale, SPE 135386,
`Society of Petroleum Engineers (2010). I have confirmed that
`this article is available at www.0nepetro.org.v
`
`6. Attached as Exhibit 2018 is a true and correct copy of Baker
`Hughes, FracPoint Completion System Isolated Openhole
`Horizontal Well in Lower Huron Shale (201 1).
`
`7. Attached as Exhibit 2019 is a true and correct copy of Baker
`Hughes, Enhancing Well Performance Through Innovative
`Completion Technologies, presentation, (Sept. 10-12, 2012).
`
`8. Attached as Exhibit 2039 is a true and correct copy of
`
`Weatherford presentation titled, Openhole Completion Systems.
`
`9. Attached as Exhibit 2045 is a true and correct copy of Westin,
`Scott, Private Property, PwC, (Jan. 2, 2013). It was accessed
`from the URL identified in the exhibit on the date noted on the
`
`exhibit.
`
`Ex. 2082
`
`IPR2016-01517
`1 of 6
`
`
`
`10.Attached as Exhibit 2046 is a true and correct copy of Yager,
`
`David, Court Case Now On: It ’s Packers Plus Versus The World
`
`— Here’s What ’s at Stake for Multi—stage Horizontal Completion
`
`Companies, EnergyNow Media (Feb. 23, 2017).
`
`It was
`
`accessed from the URL identified in the exhibit on the date
`
`noted on the exhibit.
`
`11.Attached as Exhibit 2047 is a true and correct copy of
`BH00364675, CONFIDENTIAL Ball activated sliding sleeves
`report, that was produced by Baker Hughes in the litigation.
`
`12.Attached as Exhibit 2052 is a true and correct copy of Baker
`Hughes Design Documents, that was produced by Baker Hughes
`in the litigation.
`
`13. Attached as Exhibit 2053 is a true and correct copy of Packers
`
`Plus Design Document.
`
`14. Attached as Exhibit 2054 is a true and correct copy of Rigzone,
`Schlumberger Acquires Stake in Packers Plus (Nov. 22, 2005).
`It was accessed from the URL identified in the exhibit on the
`
`date noted on the exhibit.
`
`15.Attached as Exhibit 2055 is a true and correct copy of Britt, L.
`and Smith, M., Horizontal Well Completion, Stimulation
`Optimization, and Risk Mitigation, SPE 125526 (2009). I have
`confirmed that this article is available at www.0nepetro.org.
`
`l6.Attached as Exhibit 2059 is a true and correct Baker Hughes
`FracPoint Video,
`https://www.youtube.com/watch?v=sSZQCRRZZXE.
`
`17.Attached as Exhibit 2065 is a true and correct copy of Stoltz,
`L.R., “Probabilistic Reserves Assessment Using A Filtered
`Monte Carlo Method In a Fractured Limestone Reservoir” SPE
`
`39714 (1998).
`
`I have confirmed that this article is available at
`
`www.0nepetro.org.
`
`Ex. 2082
`
`IPR2016-01517
`2 of 6
`
`
`
`18.Attached as Exhibit 2066 is a true and correct copy of
`Emanuele, M. A., “A Case History: Completion and
`Stimulation of Horizontal Wells with Multiple Transverse
`Hydraulic Fractures in the Lost Hills Diatomite” SPE 39941
`(1998). I have confirmed that this article is available at
`
`www.0nepetro.org.
`
`19.Attached as Exhibit 2067 is a true and correct copy of Gaynor,
`Tom M., “Tortuosity Versus Micro-Tortuosity — Why Little
`Things Mean a Lot” SPE/IADC 67818 (2001). I have confirmed
`that this article is available at www.0nepetro.org.
`
`20.Attached as Exhibit 2068 is a true and correct copy of Cramer,
`David, “Stimulating Unconventional Reservoirs: Lessons
`Learned, Successful Practices, Areas for Improvement” SPE
`114172 (2008). I have confirmed that this article is available at
`
`www.0nepetro.org.
`
`21.Attached as Exhibit 2069 is a true and correct copy of
`Ahmadzamri, A.F., “Development and Testing of Advanced
`Wireline Conveyance Technology for Rugose Open Hole
`Conditions” IPTC 17442 (2014). I have confirmed that this
`article is available at www.0nepetro.org.
`
`22.Attached as Exhibit 2071 is a true and correct copy of Cramer,
`D.D., “The Application of Limited-Entry Techniques in Massive
`Hydraulic Fracturing Treatments” SPE 16189 (1987). I have
`confirmed that this article is available at www.0nepetro.org.
`
`23.Attached as Exhibit 2074 is a true and correct copy of Feng
`Yuan, “Single-Size-Ball Interventionless Multi-Stage
`Stimulation System Improves Stimulated Reservoir Volume and
`Eliminates Milling Requirements: Case Studies, SPE171 183-
`MS, 2014. I have confirmed that this article is available at
`
`www.0nepetro.org.
`
`24. Attached as Exhibit 2075 is a true and correct copy of AB.
`Yost, “Hydraulic Fracturing of a Horizontal Well in a Naturally
`Fractured Reservoir: Gas Study for Multiple Fracture Design,”
`
`Ex. 2082
`
`IPR2016-01517
`3 of 6
`
`
`
`SPE 17759, 1988. I have confirmed that this article is available
`
`at www.0nepetro.org.
`
`25.Attached as Exhibit 2076 is a true and correct copy of A.W.
`Layne, “Insights Into Hydraulic Fracturing of a Horizontal Well
`in a Naturally Fractured Formation,” SPE 18255, 1988.
`I have
`confirmed that this article is available at www.0nepetro.org.
`
`26.Attached as Exhibit 2077 is a true and correct copy of AB.
`Yost, “Air Drilling and Multiple Hydraulic Fracturing of a 72
`Slant Well in Devonian Shale,” SPE 21264, 1990.
`I have
`confirmed that this article is available at www.0nepetro.org.
`
`27.Attached as Exhibit 2078 is a true and correct copy of H.H.
`Abass, A Case History of Completing and Fracture Stimulating
`a Horizontal Well, SPE 29443.
`I have confirmed that this article
`is available at www.0nepetro.org.
`
`28.Attached as Exhibit 2079 is a true and correct copy of AP.
`Damgaard, “A Unique Method for Perforating, Fracturing, and
`Completing Horizontal Wells, SPE 19282.
`I have confirmed
`that this article is available at www.0nepetro.org.
`
`29.Attached as Exhibit 2080 is a true and correct copy of
`
`CONFIDENTIAL, Weatherford Sales Data provided by
`Weatherford in this proceeding.
`
`30.Attached as Exhibit 2086 is a true and correct copy of Rigzone
`TRAINING, How Does Acidizing Work to Stimulate
`Production?,
`http://Www.rigzone.com/training/insight.asp?insight_id=320.
`It was accessed from the URL identified in the exhibit on the
`
`date noted on the exhibit.
`
`31.Attached as Exhibit 2087 is a true and correct copy of Carl T.
`Montgomery, Hydraulic Fmaturing—History ofan Enduring
`Technology, 2010.
`
`Ex. 2082
`
`IPR2016-01517
`4 of 6
`
`
`
`32.Attached as Exhibit 2088 is a true and correct copy of RE.
`Hurst, Development and Application of ‘Frac’ Treatments in the
`Permian Basin, SPE 405 (1954).
`I have confirmed that this
`article is available at www.0nepetro.org.
`
`33.Attached as Exhibit 2092 is a true and correct copy of V. Rao,
`1984 and Beyond: The Advent ofHorizontal Wells (JPT Oct.
`2007).
`
`34.Attached as Exhibit 2093 is a true and correct copy of V. Rao &
`R. Rodriguez, Accelerating Technology Acceptance: Hypotheses
`and Remedies for Risk-Averse Behavior in Technology
`Acceptance, SPE 98533 (2005).
`I have confirmed that this
`article is available at www.0nepetro.org.
`
`35.Attached as Exhibit 2094 is a true and correct copy of First
`Supplemental Berryman Report, that was submitted to the patent
`office during prosecution.
`
`36.Attached as Exhibit 2096 is a true and correct copy of a redacted
`CONFIDENTIAL Weatherford Sales Playbook that was
`provided by Weatherford in its Inter Partes Reviews.
`
`37.Attached as Exhibit 2097 is a true and correct copy of Canadian
`trial transcript excerpt submitted as ex. 1027 in IPR2016-00598.
`
`38.Attached as Exhibit 2098 is a true and correct copy of Austin et
`al. Simultaneous Multiple Entry Hydraulic Fracture Treatments
`ofHorizontally Drilled Wells, SPE 18263 (1988). I have
`confirmed that this article is available at www.0nepetro.org.
`
`39.Attached as Exhibit 2099 is a true and correct copy of Owens et
`al., Practical Considerations ofHorizontal Well Fracturing in
`the “Danish Chalk, ” SPE25058 (1992).
`I have confirmed that
`this article is available at www.0nepetro.org.
`
`40.Attached as Exhibit 2100 is a true and correct copy of Murray et
`al., A Case Studyfor Drilling and Completing a Horizontal Well
`in the Clinton Sandstone, SPE 37354 (1996).
`I have confirmed
`that this article is available at www.0nepetr0.org.
`
`Ex. 2082
`
`IPR2016-01517
`5 of 6
`
`
`
`Further, Declarant sayeth not.
`
`I, the above-named Declarant, hereby declare that all statements made
`
`herein of my own knowledge are true and that all statements made on
`
`information and belief are believed to be true; and further that these statements
`
`were made with the knowledge that Wlllfill false statements and the like so
`
`made are punishable by fine or imprisonment, or both, under Section ‘1001 of
`
`Title 18 of the United States.
`
`Date: May 31, 2017
`
`
`
`
`Signature of Declar
`Michael P. Delaney
`
`Ex. 2082
`
`IPR2016-01517
`6 of 6
`
`
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