BAKER HUGHES: ALI DANESHY
`
`Page 1
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` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
` ___________________
` BAKER HUGHES INCORPORATED and
` BAKER HUGHES OILFIELD OPERATIONS, INC.
` Petitioners
` v.
` PACKERS PLUS ENERGY SERVICES INC.,
` Patent Owner
` Case IPR2016-00596 - Patent 7,134,505
` Case IPR2016-00597 - Patent 7,543,634
` Case IPR2016-00598 - Patent 7,861,774
` Case IPR2016-00650 - Patent 6,907,936
` Case IPR2016-00656 - Patent 8,657,009
` Case IPR2016-00657 - Patent 9,074,451
`
` ORAL VIDEOTAPED DEPOSITION
` ALI DANESHY
` November 9, 2016
`
` ORAL VIDEOTAPED DEPOSITION OF ALI DANESHY, produced
`as a witness at the instance of the Respondent and duly
`sworn, was taken in the above-styled and numbered cause
`on the 9th day of November, 2016, from 9:27 a.m. to
`2:56 p.m., before Keith L. Vincent, Certified Shorthand
`Reporter in and for the State of Texas, reported by
`computerized stenotype machine at the offices of Norton
`Rose Fulbright, 1301 McKinney Street, Suite 5100,
`Houston, Texas 77010, pursuant to the Federal Rules of
`Civil Procedure and the provisions stated on the record
`or attached hereto.
`
`HG LITIGATION SERVICES
`HGLITIGATION.COM
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`1 of 54
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`Exhibit 2016
`IPR2016-01517
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`

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`BAKER HUGHES: ALI DANESHY
`
`Page 2
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`2 (Pages 2 to 5)
`Page 4
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` APPEARANCES
`
`FOR THE PETITIONERS:
` Mr. Mark T. Garrett
` Mr. Eagle Robinson
` Norton Rose Fulbright, LLP
` 94 San Jacinto Boulevard, Suite 1100
` Austin, Texas 78701-4255
` Telephone: 512-474-5201
` E-mail: mark.garrett@nortonrosefulbright.com
` eagle.robinson@nortonrosefulbright.com
`FOR THE RESPONDENT:
` Mr. Justin Nemunaitis
` Caldwell Cassady Curry
` 2101 Cedar Springs Road, Suite 1000
` Dallas, Texas 75201
` Telephone: 214-888-4853
` E-mail: jnemunaitis@caldwellcc.com
`
`ALSO PRESENT:
` Mr. Darin Duphorne
` Mr. Andrew Jones, Videographer
`
`Page 3
`
` INDEX
` PAGE
`ALI DANESHY
`Examination by Mr. Nemunaitis: 4
`Signature Page ..................................125
`
` EXHIBITS
` (None offered)
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` PROCEEDINGS
` THE VIDEOGRAPHER: We are on the record.
`Today's date is November the 9, 2016. The time is
`9:27 a.m. This is the beginning of deposition of
`Dr. Ali Daneshy. Can I have all the attorneys identify
`themselves for the record.
` MR. NEMUNAITIS: Justin Nemunaitis on
`behalf of Rapid Completions.
` MR. GARRETT: Mark Garrett on behalf of
`Petitioners.
` MR. ROBINSON: Eagle Robinson on behalf of
`Petitioners.
` MR. GARRETT: And we have with us in the
`room Darin Duphorne, who is in-house counsel for
`Petitioners.
` ALI DANESHY,
`having been first duly sworn, testified as follows:
` EXAMINATION
`MR. NEMUNAITIS:
` Q. Could you please state your name.
` A. Ali Daneshy.
` Q. And you're a doctor, right?
` A. Yes.
` Q. Where did you get your PhD?
` A. University of Missouri - Rolla.
`
`Page 5
` Q. Are you an employee of Baker Hughes?
` A. No.
` Q. But you were hired by them to offer some
`opinions in these proceedings on the patents at issue,
`correct?
` A. Yes.
` Q. Have you ever been deposed before?
` A. Yes.
` Q. About how many times?
` A. I can't remember. Two, three, four times
`maybe.
` Q. Do you know if any of those were patent cases
`or IPR proceedings?
` A. No.
` Q. No, they were not?
` A. They were not.
` Q. You're probably a little bit familiar with this
`process, but I'll go over some ground rules in case you
`have some questions before we start. I'm going to keep
`going and ask my questions, but I'll take a break every
`hour or so. If you want to take a break at some other
`time, just let me know and we'll take one. The one
`exception to that would be if I ask you a question, I'd
`like to get an answer before we take the break. Sound
`fair?
`
`HG LITIGATION SERVICES
`HGLITIGATION.COM
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`2 of 54
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`Exhibit 2016
`IPR2016-01517
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`

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`BAKER HUGHES: ALI DANESHY
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`Page 6
`
` A. Sure.
` Q. I think the court reporter mentioned this
`before we started, but it's helpful if we don't talk
`over each other. So I'm going to try to, you know, stop
`and listen to you; and I'd ask that you do the same for
`me. Okay?
` A. Okay.
` Q. And also the court reporter can't take down a
`nod of the head or an "uh-huh," "huh-uh" sort of
`response. So if you can try to phrase your answers so
`they're clear that he can take them on the record, that
`would be helpful. Okay?
` A. Okay.
` Q. And at times, one of your attorneys here, the
`attorneys for Baker Hughes may say "Objection, form",
`something like that, to one of my questions. But if
`that happens, you can still answer the question, as long
`as your attorney doesn't instruct you not to answer.
`Does that make sense?
` A. If that's the rule, that's the rule.
` Q. And lastly, there's a number of overlapping
`proceedings that you're being deposed about today.
`I think there's six proceedings on these instituted
`IPRs. So at times I may ask the same question but tweak
`it a little bit to ask about one patent versus another.
`
`Page 7
`I'm not trying to be repetitive and waste your time.
`I just want to make clear we have a clear Q&A on the
`record, if that makes sense.
` A. Okay.
` Q. Could you tell me at a high level what your
`experience has been in the oil-and-gas industry?
` A. I have been active in the oil-and-gas industry
`since 1969, continuously.
` Q. Can you tell me what your experience has been
`with hydraulic fracking?
` A. All of that period, I've been engaged in
`hydraulic fracking.
` Q. What sort of work have you do with hydraulic
`fracking?
` A. I have done laboratory research, theoretical
`research, operations, and taught courses, published
`papers.
` Q. Do you ever advise companies on how to design a
`fracturing job for a particular well?
` A. Yes.
` Q. About how much of your work over the last few
`years has been that sort of work?
` A. It's hard to put number on it. When I consult
`for a company, I do different tasks for them; and a part
`of it could be design of a fracturing treatment. So
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`3 (Pages 6 to 9)
`Page 8
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`I cannot give you a number.
` Q. When did you start advising companies on
`fracturing work for a particular well?
` A. Just as soon as I was -- I got into oil-and-gas
`industry in 1969.
` Q. And that's something you've done throughout
`your entire career, more or less?
` A. Off and on, yes.
` Q. Do you generally keep up to speed to advances
`or changes in technology in the hydraulic fracturing
`space?
` MR. GARRETT: Objection, form.
` Q. You can answer the question.
` A. To the extent practical, yes.
` Q. And why do you try to do that?
` MR. GARRETT: Same objection.
` A. I think people who are in this business, if
`they want to continue staying, you know, well-informed,
`they need to be abreast of what is available out there.
`Again, to the extent possible.
` Q. Do you think you're an expert in the field of
`the '774 patent that's at issue in these proceedings?
` A. Can you tell me what '774 patent is, please.
` Q. Sure. I can give you a copy of that.
` A. Yes, I understand this patent.
`
`Page 9
` Q. So would you say you're an expert in the field
`of the '774 patent?
` A. Yes.
` Q. If you could think back to what you were doing
`in 2001, do you think you would have been an expert in
`the field of the '774 patent at that time?
` A. It's very difficult for me to go back to 2001;
`but, yeah, I could have given you an expert opinion at
`that time also, yes.
` Q. Why do you say it's difficult to go back to
`2001.
` A. I wasn't quite sure what your question was.
`I thought that could also mean that, did I know this
`patent at that time. I did not know this patent detail
`at that time; but, yeah, I could have reviewed it and
`given you an expert opinion.
` Q. Right. Are you familiar with the term
`plug-and-perf fracturing?
` A. Yes, I am.
` Q. What does that term mean to you?
` A. Setting your plug to isolate a section of the
`wellbore, perforating upstream of the plug, and then
`fracturing it.
` Q. Are you familiar with the term open-hole
`ball-drop fracturing?
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`HG LITIGATION SERVICES
`HGLITIGATION.COM
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`3 of 54
`
`Exhibit 2016
`IPR2016-01517
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`

`
`BAKER HUGHES: ALI DANESHY
`
`Page 10
`
` A. Yes.
` Q. And that's a fracturing technique where packers
`are used to provide zonal isolation and balls are used
`to open sleeves to fracture through the open-hole
`segment. Fair?
` A. I wasn't catching the details. That's a
`process in which you have sleeves inside a liner, you
`drop a ball. When the ball seats in its designated
`location, it slides open a sleeve and opens a port
`through which you fracture the formation.
` Q. It's possible to do open-hole ball-drop
`fracturing using packers to isolate the zones. Would
`you agree with that?
` A. Yes.
` Q. And would it be okay if today, just so we have
`a shorthand name to talk about that particular type of
`fracturing, to call that open-hole ball-drop fracturing?
` A. Okay. But open-hole ball-drop fracturing has
`got multiple systems attached to it. I usually call
`those ball-activated sliding sleeves.
` Q. Let me ask you this. Just so we have
`something -- there's a catchy name for plug-and-perf
`fracturing, and most people know what that is. I'd like
`to have a shorthand name that we can use for the rest of
`the day to talk about the type of fracturing technique
`
`Page 11
`where you use ball-activated sleeves and packers to
`provide isolation?
` A. That's a very good description. Good.
` Q. Okay.
` A. Ball-activated sliding sleeves is just the
`right term. Thank you.
` Q. Okay. So if I refer to ball-activated sleeve
`fracturing, we can agree that that refers to a type of
`fracturing where you're using ball-activated sleeves and
`packers to provide zonal isolation?
` A. The zonal isolation is provided by packers.
`Ball-activated sliding sleeves is to direct a fluid into
`a particular port within the liner and into the
`formation.
` Q. Right. I agree with that. So if we use -- I'm
`just asking this question. If I use the term
`"ball-activated sleeve fracturing" today, will you
`understand that to mean a fracturing technique where
`you're using ball-activated sleeves and packers for
`zonal isolation?
` MR. GARRETT: Objection, form.
` A. Repeat your question again, please. I want to
`make sure I get the details correct.
` Q. Sure. I'm not trying to quibble with you on
`how these systems work or anything like that. I just
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`Page 12
`want to have -- I'm going to be asking you a bunch of
`questions today and I want to have a name that I can use
`so I don't need to explain this concept in every
`question I ask.
` A. I understand. My intent is to make sure
`I understand your question so I give you the answer to
`the correct question that you intend, not what
`I understood it to mean.
` Q. Right. For purposes of this deposition today,
`if I use the phrase "ball-activated sleeve fracturing,"
`can we agree that that means a type of fracturing where
`you use ball-activated sleeves and packers to provide
`zonal isolation?
` MR. GARRETT: Same objection.
` A. Okay. But as we go -- okay. Let's proceed
`until we get to a point where I need clarification, and
`then I will ask for it.
` Q. Sure. Absolutely.
` When did you first learn about
`ball-activated sleeve fracturing?
` A. I can't remember.
` Q. Do you know if it was before 2001?
` A. Possibly.
` Q. And was it possible it was after 2001?
` A. I was aware of open-hole fracturing by sliding
`
`Page 13
`sleeves, by using sliding sleeves. I was aware of that.
`But you attached a particular combination ball-activated
`sliding sleeves with open-hole packers. That is not the
`name which was used at that time. The sliding sleeves
`generally were called port collars; and the packers, of
`course, were used for isolating zones.
` Q. When was the first time you can remember
`hearing about a system that used both ball-activated
`sliding sleeves and open-hole packers to do fracturing?
` A. I can't remember. It is a long time ago.
` Q. But you're not sure if it's before or after
`2001?
` A. No. After you have been in the industry for
`50 years and read as many papers and have as many
`discussions, sometimes events, the time of events become
`blurred occasionally.
` Q. Do you ever advise companies on whether to use
`ball-activated sleeve fracturing versus some
`alternative?
` A. Yes, I have.
` Q. And how often do you recommend ball-activated
`sleeve fracturing?
` MR. GARRETT: Objection. 611(b).
` A. That is such a broad question that -- because
`there's so many elements involved in that
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`HG LITIGATION SERVICES
`HGLITIGATION.COM
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`4 of 54
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`Exhibit 2016
`IPR2016-01517
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`

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`BAKER HUGHES: ALI DANESHY
`
`Page 14
`decision-making process. If you are prepared for a
`dissertation, then we can go ahead; but I have
`recommended it. Correct. Yes, I have. And when I make
`that recommendation, it is because a number of
`parameters that are involved in that decision-making
`have been satisfied.
` Q. What would you say are the main fracturing
`techniques that you consider when talking to a client
`about what type of fracturing technique to use on a
`well?
` MR. GARRETT: Objection. 611(b).
` A. Techniques are generally divided into open-hole
`liner completions and cemented liner completions. You
`start from that point; and then for each, you branch off
`into available systems.
` Q. And what parameters do you consider when
`deciding between open-hole versus cemented liners?
` MR. GARRETT: Same objection.
` A. Borehole stability, well stability, and
`properties of the formation. There are too many
`parameters involved in that decision. Making that
`decision sometimes takes one, two, sometimes even
`three days to look at all of the parameters that are
`involved and then arrive at what system is a good
`compromise for that environment.
`
`Page 15
` Q. I just handed you an exhibit marked
`Exhibit 2002. Could you tell me what this is?
` A. This is an article I wrote for an encyclopedia
`which was published by ENI&I.
` Q. Why did you write this article?
` A. They asked me to.
` Q. Do you know why they asked you as opposed to
`someone else?
` A. They considered me an expert in the area.
` Q. Who is the intended audience for this article?
` A. General public.
` Q. When you say general public, do you mean
`laypersons or people that are actually working in the
`oil-and-gas business?
` A. This is an encyclopedia which is published and
`is available to anyone who wants to access it.
`Obviously you accessed it, and you are not in the
`oil-and-gas business the same as I am.
` Q. Right. What was your purpose in writing this
`article?
` A. They asked me to write it, and I wrote it.
` Q. What is the article Exhibit 2002 about?
` A. Exhibit 2002 is about describing new
`technologies that were being introduced into the
`oil-and-gas business and basically could change -- and
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`5 (Pages 14 to 17)
`Page 16
`they actually have changed -- the way oil-and-gas
`reservoirs are produced. A particular aspect of this
`was application of some of the automated systems, remote
`sensing, remote control, all of which was for the
`purpose of controlling the flow stream out of an
`oil-and-gas well. The main emphasis in those
`applications is to control the flow of excessive water.
`These types of completions are generally very expensive
`and they are deployed in prolific reservoirs where
`you're expecting flow rates in excess of several
`thousand barrels of oil per day. The article is
`specifically written for that particular application.
` Q. Is there some examples of formations or an
`explanation in here along the lines of what you just
`told me?
` A. I provide examples of this application, for
`example. I give -- in the paper I show an example of a
`system like that because it was used in Saudi Arabia, as
`an example. When you publish an article, the cases that
`you refer in the article generally are somewhat limited
`to what the company either has published before or gives
`you permission to publish, to include in the article,
`because of copyrights. So the example which is in this
`paper is from Saudi Arabian reservoir, the full system.
`The example of the full system is from a Saudi Arabian
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`Page 17
`reservoir, and it is shown on page 199 and it says
`typical well completion in Shaybah Field. And Shaybah
`Field is in Saudi Arabia. The intent of this article
`was to discuss what led to development of this and the
`different components and a description of those
`components.
` Q. When was the last time you read this article?
` A. Well, just now you gave it to me.
` Q. I mean besides today.
` A. I read it last week also.
` Q. There's a copyright date on this of 2007. Is
`that about when this was written?
` A. If it says 2007, the copyright, that's when it
`was published, yes.
` Q. I just handed you Exhibit 1005. Can you tell
`me what that is?
` A. That's one of my declarations.
` Q. Can you turn to Paragraph 28 on page 11.
` A. Okay.
` Q. You see the second sentence that begins "In
`cased completions." Do you see that?
` A. Okay.
` Q. And the sentence says: "In cased completions,
`casing (or liner) is cemented -- the annulus between the
`casing and the wall of the wellbore is filled with
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`HG LITIGATION SERVICES
`HGLITIGATION.COM
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`5 of 54
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`Exhibit 2016
`IPR2016-01517
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`

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`BAKER HUGHES: ALI DANESHY
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`Page 18
`cement." And then it provides some reasons as to why
`that's done. See that?
` A. Yes.
` Q. The first reason is "to protect the environment
`and near-surface formations from leakage of reservoir
`fluids." Do you see that?
` A. Yes.
` Q. Does that reason have much application when
`you're talking about the portion of the well that's
`going to be fractured?
` MR. GARRETT: Objection, form.
` A. It could.
` Q. How so?
` MR. GARRETT: Same objection.
` A. You cement the casing basically to prevent the
`fluid, which is injected downhole into the formation,
`does not go around the casing and come all the way to
`the surface. You do not want the casing to leak.
` Q. Why is that?
` A. For the reason you just mentioned.
` Q. Would you agree that another way to prevent
`fluid from leaking around the casing and going up hole
`would be to use external casing packers?
` A. Yes. That's another technique being used.
` Q. Another reason you offer in the declaration as
`
`Page 19
`to why casing might be cemented in place is to improve
`wellbore stability. Is that right?
` A. Correct.
` Q. Can you also improve wellbore stability by
`using casing with external casing packers?
` A. Generally, no.
` Q. Why is that?
` A. Because the wellbore is open.
` Q. What do you mean by that?
` A. The hole is an empty space. The wellbore is an
`empty space in the formation. Unless it is protected,
`there is a possibility that pieces of rock can just fall
`in as slough; and if that happens, then that limits or
`sometimes prohibits any kind of activity inside the
`wellbore.
` Q. Why would external casing packers as well as
`casing not prevent that from happening?
` A. Because you are not covering the entire
`wellbore. You are covering a section of it.
` Q. What section is not covered?
` A. The section which is between the two external
`casing packers.
` Q. If the rock falls into that section, it would
`fall into the annulus but it wouldn't crush the casing,
`right?
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`Page 20
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` A. It can.
` Q. Is that a big problem?
` A. It can.
` Q. Another reason you give in your declaration as
`to why casing might be cemented in place is to control
`the location of fracture initiation. Is that right?
` A. Correct.
` Q. And what does that mean?
` A. When you cement the liner inside the wellbore
`in order to fracture the formation, you have to create
`perforations in the liner. And when you create the
`perforations inside the liner, the location of the
`fracture is generally at the vicinity of those
`perforations.
` Q. Why is that?
` A. That's the way fractures propagate.
` Q. And do you know why fractures propagate that
`way?
` A. Because that's the only place there is access
`to the fluid. If you are going to inject fluid from
`inside the liner, a sealed pipe to outside of it, you
`need to have a hole in the pipe or liner to get fluid
`out of it; and that hole is perforations.
` Q. Why use cemented casing to control the location
`of fracture initiation as opposed to just casing with
`
`Page 21
`
`external casing packers?
` A. You are talking about two different subjects.
`Let's narrow it down a little bit more so I can give you
`a more correct answer.
` Q. What do you mean by that?
` A. You are talking about two systems which are
`very different in the way they fracture. In a cemented
`liner completion, as I mentioned, when you create a
`fracture, it is where the perforations are. When you
`use external casing packers, the fracture -- with ports,
`with fracture ports -- the fracture can be anywhere
`between the two external casing packers.
` Q. Why does that difference matter?
` MR. GARRETT: Objection, form.
` A. Because the location of the fracture influences
`where productivity and how the reservoir is being
`depleted. You want uniform depletion of reservoir fluid
`so that you get as much of the oil or gas out of the
`formation; and so for that, it is better to know more
`accurately where the fractures are located.
` Q. Is that a new understanding that you developed
`over the years, or is that the way you felt for, you
`know, more or less your entire career?
` MR. GARRETT: Objection, form.
` A. Horizontal well fracturing has got, has been in
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`HG LITIGATION SERVICES
`HGLITIGATION.COM
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`6 of 54
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`Exhibit 2016
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`

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`BAKER HUGHES: ALI DANESHY
`
`Page 22
`practice for the last 20, 25 years. I've been in the
`industry for 50 years. So when I started with my
`business, at that time 50 years ago there were not many
`horizontal wells and they were not being fractured. So
`understanding of that subject was limited. However,
`I actually -- you're asking a question which is not
`anywhere in these documents. I actually published a
`paper related to that, early on.
` Q. And what was the purpose of that paper?
` A. It was part of my research work.
` Q. Around what time was that?
` A. Oh, that would be '73 -- I can't remember
`exactly these days. I don't have a good memory for
`these dates, but it was in the '70s. It's in the open
`literature. You can access it.
` Q. Why do you mention that paper now?
` MR. GARRETT: Objection, form.
` A. You asked a specific question, when did I learn
`about it; and I'm just trying to answer your question,
`when I learned about it. Whether it's pertinent to this
`patent or not, I don't know. You lawyers know that
`better than I do. I'm just trying to be responsive to
`your question.
` Q. We were talking about how there's a big
`difference between the way fractures form in open-hole
`
`Page 23
`wells where you're using external casing packers versus
`cemented perforations, and you've known about that
`difference since whenever you wrote this paper in the
`'70s, '80s. Is that fair to say?
` MR. GARRETT: Objection, form.
` A. No, that is not the question I answered.
` Q. Maybe I misunderstood. What were you answering
`then?
` A. I was answering the question, when did I learn
`about how fractures propagate in an open-hole, in a long
`segment of open-hole, if the well is not vertical.
` Q. When you're considering whether to use cemented
`casing for a frac job versus open-hole segments for a
`frac job, how do you make a determination between those
`two different options?
` MR. GARRETT: Objection, form.
` A. The primary consideration -- one of the primary
`considerations is borehole stability. If the borehole
`is not stable, I generally recommend them to consider a
`cemented liner. If the formation is stable, then you
`can use open-hole completion with a liner and external
`casing packers or any -- you know, a suitable type of
`packer. You can. And I have recommended it.
` Q. If you're considering a well that you think is
`in a stable formation, is there any reason why you would
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`7 (Pages 22 to 25)
`Page 24
`recommend a cemented liner versus open-hole segments for
`a frac job?
` MR. GARRETT: Objection, form.
` A. Can I rephrase your question? Formations are
`always stable. We're not talking about formation
`stability; we are talking about stability of a well in a
`formation. Okay.
` Q. Fair point. I'll re-ask my question. Okay?
` A. Very good. I didn't mean to be picking on you.
`I just wanted to make sure I answer the correct
`question.
` Q. Right. If you're designing a frac job for a
`well that is stable and you're not worried about it
`collapsing, are there reasons why you would choose to
`use cemented casing versus open-hole segments with a
`frac job?
` MR. GARRETT: Objection, form.
` A. Yes. There are reasons I would, yes.
` Q. What are those reasons?
` MR. GARRETT: Same objection.
` A. Well productivity. I'm trying to maximize
`production of the well; and if we are maximizing the
`production of the well, a cemented liner is a better
`option. I would recommend a cemented liner.
` Q. Anything else you would consider?
`
`Page 25
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` MR. GARRETT: Same objection.
` A. There are lots of parameters.
` Q. Can you give me a few more examples?
` MR. GARRETT: Same objection.
` A. Availability of systems, costs, other
`operational conditions, to name just three of them.
` Q. If we're looking at a wellbore that's stable,
`how can using cemented line for a frac job maximize
`production better than using open-hole segments?
` MR. GARRETT: Same objection.
` A. With a cemented liner, you can put 100, 200
`fractures in a horizontal well. Within an open-hole
`completion, there could be a limit to how many of those
`you could induce in the formation. And generally the
`more fractures you have in the formation, the higher
`your production, at least during the early life of the
`well.
` Q. Any other reasons?
` MR. GARRETT: Same objection.
` A. Yes. I would prefer if you ask me specifically
`and I can tell you, yes, it is a good reason to do it
`or, no, it's not a good reason.
` Q. Well, you're the expert. I don't know all the
`reasons; that's why I'm asking you what are the reasons.
`So maybe you can give me a few more examples.
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`BAKER HUGHES: ALI DANESHY
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`Page 26
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` MR. GARRETT: Same objection.
` A. For example, if you are doing this well,
`completing this well in an environment in which you
`always cemented the other wells, then you would go ahead
`and cement this well, too. If -- another, for example,
`reason you would use cemented liner is because your
`neighbors are using cemented liner and you're getting a
`better production and you say, "I don't know why they're
`doing it but they're getting better production. I'm
`going to use what they are using."
` Q. Do you think that kind of thinking actually
`influences how companies design their well completions?
` A. Absolutely, yes.
` MR. GARRETT: Same objection, 611(b).
`Foundation.
` Q. Are there other examples you can think of as to
`why you would want to use a cemented liner as opposed to
`open-hole segments to maximize production in a stable
`well?
` MR. GARRETT: Objection, form.
` A. Not at this time. If you give me a specific
`case, I can tell you whether it will or will not be.
`But not right now.
` Q. Would the type of fracturing fluid you use or
`whether or not you're using proppant factor into that
`
`Page 27
`
`analysis at all?
` MR. GARRETT: Same objection.
` A. Generally not.
` Q. When you're designing a frac job, do you try to
`design the path the fractures will take away from the
`wellbore?
` MR. GARRETT: Objection, form. 611(b).
` A. The fractures are generally created to extend
`away from the wellbore so you can drain points in the
`reservoir which are not right next to the wellbore.
`That's the intent of fracturing, to reach deeper into
`the reservoir.
` Q. Can the way you place perforations in a
`cemented liner affect how a fracture will grow,
`propagate?
` MR. GARRETT: Same objections.
` A. To a very limited extent near the wellbore. On
`a larger scale, usually not.
` Q. Then how is it that perforations can influence
`or control the location of fracture initiation, as you
`say?
` MR. GARRETT: Same objection.
` A. Because the fracture has to be near the
`perforations because that's where the fluid enters from
`the wellbore into the formation. The perforation is the
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`8 (Pages 26 to 29)
`Page 28
`only connection between the wellbore and the formation.
`So since that's the only connection, the fracture
`generally has to stay in that vicinity.
` Q. It sounded like what you were saying is the
`placement of perforations doesn't have much of an effect
`on the large-scale growth of the fracture. If that's
`the case, I'm wondering why would it even be accurate to
`say that, you know, you should consider controlling the
`location of fracture initiation when deciding between
`cemented liners versus using external casing packers?
` MR. GARRETT: Same objection.
` A. The first statement on which you built your
`question, that first statement was not correct.
` Q. How so?
` MR. GARRETT: Same objections.
` A. The location of the perforation influences the
`location of the fracture, and the location of the
`fracture influences the production of the well. So if
`you want to provide a particular pattern for well
`production, you need to place your fractures in
`particular location to optimize that production. So it
`is important to know where your fractures are, if you
`can.
` Q. How do you know where your fractures are?
` MR. GARRETT: Sa