Case 6:15-cv-00907-RWS-KNM Document 49 Filed 02/29/16 Page 1 of 48 PageID #: 966
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`TYLER DIVISION
`
`
`
`
`
`
`
`Civil Action No. 6:15-CV-907-JRG-KNM
`
`
`SIPCO LLC, and
`IP CO., LLC (d/b/a INTUS IQ)
`
`Plaintiffs,
`
`
`
`
`
`
`
`v.
`
`EMERSON ELECTRIC CO., EMERSON
`PROCESS MANAGEMENT LLLP,
`FISHER-ROSEMOUNT SYSTEMS, INC.,
`ROSEMOUNT INC., BP PLC, BP
`AMERICA, INC., and BP AMERICA
`PRODUCTION COMPANY
`
`
`
`Defendants.
`
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`
`BP AMERICA PRODUCTION COMPANY’S ANSWER TO FIRST AMENDED
`COMPLAINT
`
`Defendant BP America Production Company, (“BP Production”), answers the First
`
`Amended Complaint of Plaintiffs SIPCO, LLC (“SIPCO”) and IP CO, LLC (d/b/a/INTUS IQ)
`
`(“IP CO”) (collectively, “Plaintiffs”), as follows in the correspondingly numbered paragraphs:
`
`1.
`
`BP Production lacks knowledge or information sufficient to form a belief as to the
`
`truth of the allegations of this Paragraph, and therefore denies them.
`
`2.
`
`BP Production lacks knowledge or information sufficient to form a belief as to the
`
`truth of the allegations of this Paragraph, and therefore denies them.
`
`3.
`
`BP Production lacks knowledge or information sufficient to form a belief as to the
`
`truth of the allegations of this Paragraph, and therefore denies them.
`
`4.
`
`BP Production lacks knowledge or information sufficient to form a belief as to the
`
`truth of the allegations of this Paragraph, and therefore denies them.
`
`

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`Case 6:15-cv-00907-RWS-KNM Document 49 Filed 02/29/16 Page 2 of 48 PageID #: 967
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`5.
`
`BP Production lacks knowledge or information sufficient to form a belief as to the
`
`truth of the allegations of this Paragraph, and therefore denies them.
`
`6.
`
`BP Production lacks knowledge or information sufficient to form a belief as to the
`
`truth of the allegations of this Paragraph, and therefore denies them.
`
`7.
`
`BP Production denies that BP America, Inc. can be served through the CT entity
`
`at the address identified in this Paragraph; and admits the remaining allegations of this
`
`Paragraph.
`
`8.
`
`BP Production denies that BP America Production Company can be served
`
`through the CT entity at the address identified in this Paragraph; and admits the remaining
`
`allegations of this Paragraph.
`
`9.
`
`BP Production admits that BP p.l.c. is a British public limited company with its
`
`corporate headquarters in London, England, SW1Y 4PD and that BP America, Inc. and BP
`
`America Production Company are indirectly wholly-owned subsidiaries of BP p.l.c. BP
`
`Production denies the remaining allegations of this Paragraph.
`
`10. Admitted that, in general, claims for patent infringement arise under the cited
`
`statutes; denied that the Complaint actually asserts a claim for patent infringement under the
`
`cited statutes.
`
`11. Admitted.
`
`12. BP Production denies the allegations in the first sentence of this Paragraph. BP
`
`Production denies the allegations in the second and third sentences of this Paragraph including
`
`allegations that these two sentences are an “example” of the allegations in the first sentence;
`
`except that BP Production admits that BP has reported its largest number of employees were in
`
`Houston, 6000+ employees were in Texas and 28,000+ jobs were supported in Texas, $160
`
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`

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`Case 6:15-cv-00907-RWS-KNM Document 49 Filed 02/29/16 Page 3 of 48 PageID #: 968
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`million+ royalties, property, production and state income/franchise taxes were paid in Texas,
`
`$9.2 million was spent with vendors, and Texas-based activities included oil and gas exploration
`
`and production, research and innovation, natural gas and power trading, petrochemical
`
`production and wind power generation, but denies that those activities were performed by the
`
`entities specified in this Paragraph or lacks knowledge or information sufficient to form a belief
`
`as to the attribution of the entities specified in this Paragraph and therefore denies them. BP
`
`Production denies the remaining allegations of this Paragraph.
`
`13. BP Production lacks knowledge or information sufficient to form a belief as to the
`
`truth of the allegations of this Paragraph, and therefore denies them.
`
`14. Denied.
`
`15. Denied.
`
`16. Admitted.
`
`17. BP Production lacks knowledge or information sufficient to form a belief as to the
`
`truth of the allegations of this Paragraph, and therefore denies them.
`
`18. BP Production lacks knowledge or information sufficient to form a belief as to the
`
`truth of the allegations of this Paragraph, and therefore denies them.
`
`19. Denied.
`
`20. Admitted.
`
`21. BP Production lacks knowledge or information sufficient to form a belief as to the
`
`truth of the allegations of this Paragraph, and therefore denies them.
`
`22. BP Production lacks knowledge or information sufficient to form a belief as to the
`
`truth of the allegations of this Paragraph, and therefore denies them.
`
`23. Denied.
`
`- 3 -
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`

`

`Case 6:15-cv-00907-RWS-KNM Document 49 Filed 02/29/16 Page 4 of 48 PageID #: 969
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`24. Admitted.
`
`25. BP Production lacks knowledge or information sufficient to form a belief as to the
`
`truth of the allegations of this Paragraph, and therefore denies them.
`
`26. BP Production lacks knowledge or information sufficient to form a belief as to the
`
`truth of the allegations of this Paragraph, and therefore denies them.
`
`27. Denied.
`
`28. Admitted.
`
`29. BP Production lacks knowledge or information sufficient to form a belief as to the
`
`truth of the allegations of this Paragraph, and therefore denies them.
`
`30. BP Production lacks knowledge or information sufficient to form a belief as to the
`
`truth of the allegations of this Paragraph, and therefore denies them.
`
`31. Denied.
`
`32. Admitted.
`
`33. BP Production lacks knowledge or information sufficient to form a belief as to the
`
`truth of the allegations of this Paragraph, and therefore denies them.
`
`34. BP Production lacks knowledge or information sufficient to form a belief as to the
`
`truth of the allegations of this Paragraph, and therefore denies them.
`
`35. Denied.
`
`36. Admitted.
`
`37. BP Production lacks knowledge or information sufficient to form a belief as to the
`
`truth of the allegations of this Paragraph, and therefore denies them.
`
`- 4 -
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`

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`Case 6:15-cv-00907-RWS-KNM Document 49 Filed 02/29/16 Page 5 of 48 PageID #: 970
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`38. BP Production lacks knowledge or information sufficient to form a belief as to the
`
`truth of the allegations of this Paragraph, and therefore denies them.
`
`39. Denied.
`
`40. Admitted.
`
`41. BP Production lacks knowledge or information sufficient to form a belief as to the
`
`truth of the allegations of this Paragraph, and therefore denies them.
`
`42. BP Production lacks knowledge or information sufficient to form a belief as to the
`
`truth of the allegations of this Paragraph, and therefore denies them.
`
`43. Denied.
`
`44. Admitted.
`
`45. BP Production lacks knowledge or information sufficient to form a belief as to the
`
`truth of the allegations of this Paragraph, and therefore denies them.
`
`46. BP Production lacks knowledge or information sufficient to form a belief as to the
`
`truth of the allegations of this Paragraph, and therefore denies them.
`
`47. Denied.
`
`48. Admitted.
`
`49. BP Production lacks knowledge or information sufficient to form a belief as to the
`
`truth of the allegations of this Paragraph, and therefore denies them.
`
`50. BP Production lacks knowledge or information sufficient to form a belief as to the
`
`truth of the allegations of this Paragraph, and therefore denies them.
`
`51. Denied.
`
`52. Admitted.
`
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`Case 6:15-cv-00907-RWS-KNM Document 49 Filed 02/29/16 Page 6 of 48 PageID #: 971
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`53. BP Production lacks knowledge or information sufficient to form a belief as to the
`
`truth of the allegations of this Paragraph, and therefore denies them.
`
`54. BP Production lacks knowledge or information sufficient to form a belief as to the
`
`truth of the allegations of this Paragraph, and therefore denies them.
`
`55. Denied.
`
`56. Admitted.
`
`57. BP Production lacks knowledge or information sufficient to form a belief as to the
`
`truth of the allegations of this Paragraph, and therefore denies them.
`
`58. BP Production lacks knowledge or information sufficient to form a belief as to the
`
`truth of the allegations of this Paragraph, and therefore denies them.
`
`59. BP Production lacks knowledge or information sufficient to form a belief as to the
`
`truth of the allegations of this Paragraph, and therefore denies them.
`
`60. BP Production lacks knowledge or information sufficient to form a belief as to the
`
`truth of the allegations of this Paragraph, and therefore denies them.
`
`61. BP Production lacks knowledge or information sufficient to form a belief as to the
`
`truth of the allegations of this Paragraph, and therefore denies them.
`
`62. BP Production lacks knowledge or information sufficient to form a belief as to the
`
`truth of the allegations of this Paragraph, and therefore denies them.
`
`63. BP Production lacks knowledge or information sufficient to form a belief as to the
`
`truth of the allegations of this Paragraph, and therefore denies them.
`
`64. BP Production lacks knowledge or information sufficient to form a belief as to the
`
`truth of the allegations of this Paragraph, and therefore denies them.
`
`- 6 -
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`

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`Case 6:15-cv-00907-RWS-KNM Document 49 Filed 02/29/16 Page 7 of 48 PageID #: 972
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`65. BP Production lacks knowledge or information sufficient to form a belief as to the
`
`truth of the allegations of this Paragraph, and therefore denies them.
`
`66. BP Production lacks knowledge or information sufficient to form a belief as to the
`
`truth of the allegations of this Paragraph, and therefore denies them.
`
`67. BP Production lacks knowledge or information sufficient to form a belief as to the
`
`truth of the allegations of this Paragraph, and therefore denies them.
`
`68. BP Production lacks knowledge or information sufficient to form a belief as to the
`
`truth of the allegations of this Paragraph, and therefore denies them.
`
`69. BP Production denies all allegations in this paragraph, or lacks knowledge or
`
`information sufficient to form a belief as to the truth of the allegations of this Paragraph, and
`
`therefore denies them, except BP Production admits that BP Production operates wellheads in
`
`this judicial district but not the greater than 800 wells identified.
`
`70. Denied.
`
`71. BP Production lacks knowledge or information sufficient to form a belief as to the
`
`truth of the allegations of this Paragraph, and therefore denies them.
`
`72. BP Production lacks knowledge or information sufficient to form a belief as to the
`
`truth of the allegations of this Paragraph, and therefore denies them.
`
`73. BP Production lacks knowledge or information sufficient to form a belief as to the
`
`truth of the allegations of this Paragraph, and therefore denies them.
`
`74. BP Production lacks knowledge or information sufficient to form a belief as to the
`
`truth of the allegations of this Paragraph, and therefore denies them.
`
`75. BP Production lacks knowledge or information sufficient to form a belief as to the
`
`truth of the allegations of this Paragraph, and therefore denies them.
`
`- 7 -
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`

`

`Case 6:15-cv-00907-RWS-KNM Document 49 Filed 02/29/16 Page 8 of 48 PageID #: 973
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`76. BP Production lacks knowledge or information sufficient to form a belief as to the
`
`truth of the allegations of this Paragraph, and therefore denies them.
`
`77. BP Production lacks knowledge or information sufficient to form a belief as to the
`
`truth of the allegations of this Paragraph, and therefore denies them.
`
`78. BP Production lacks knowledge or information sufficient to form a belief as to the
`
`truth of the allegations of this Paragraph, and therefore denies them.
`
`79. BP Production lacks knowledge or information sufficient to form a belief as to the
`
`truth of the allegations of this Paragraph, and therefore denies them.
`
`80. BP Production lacks knowledge or information sufficient to form a belief as to the
`
`truth of the allegations of this Paragraph, and therefore denies them.
`
`81. BP Production lacks knowledge or information sufficient to form a belief as to the
`
`truth of the allegations of this Paragraph, and therefore denies them.
`
`82. BP Production lacks knowledge or information sufficient to form a belief as to the
`
`truth of the allegations of this Paragraph, and therefore denies them.
`
`83. BP Production lacks knowledge or information sufficient to form a belief as to the
`
`truth of the allegations of this Paragraph, and therefore denies them.
`
`84. BP Production lacks knowledge or information sufficient to form a belief as to the
`
`truth of the allegations of this Paragraph, and therefore denies them.
`
`85. BP Production lacks knowledge or information sufficient to form a belief as to the
`
`truth of the allegations of this Paragraph, and therefore denies them.
`
`86. BP Production lacks knowledge or information sufficient to form a belief as to the
`
`truth of the allegations of this Paragraph, and therefore denies them.
`
`- 8 -
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`

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`Case 6:15-cv-00907-RWS-KNM Document 49 Filed 02/29/16 Page 9 of 48 PageID #: 974
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`87. These paragraphs assert a count against Emerson alone, for which BP Production
`
`is not required to respond. If, however, a response is required, BP Production restates and
`
`incorporates the answers set forth in the preceding paragraphs and answers that BP Production
`
`lacks knowledge or information sufficient to form a belief as to the truth of the allegations of the
`
`Paragraphs of this Count, and therefore denies them.
`
`88. These paragraphs assert a count against Emerson alone, for which BP Production
`
`is not required to respond. If, however, a response is required, BP Production restates and
`
`incorporates the answers set forth in the preceding paragraphs and answers that BP Production
`
`lacks knowledge or information sufficient to form a belief as to the truth of the allegations of the
`
`Paragraphs of this Count, and therefore denies them.
`
`89. These paragraphs assert a count against Emerson alone, for which BP Production
`
`is not required to respond. If, however, a response is required, BP Production restates and
`
`incorporates the answers set forth in the preceding paragraphs and answers that BP Production
`
`lacks knowledge or information sufficient to form a belief as to the truth of the allegations of the
`
`Paragraphs of this Count, and therefore denies them.
`
`90. These paragraphs assert a count against Emerson alone, for which BP Production
`
`is not required to respond. If, however, a response is required, BP Production restates and
`
`incorporates the answers set forth in the preceding paragraphs and answers that BP Production
`
`lacks knowledge or information sufficient to form a belief as to the truth of the allegations of the
`
`Paragraphs of this Count, and therefore denies them.
`
`91. These paragraphs assert a count against Emerson alone, for which BP Production
`
`is not required to respond. If, however, a response is required, BP Production restates and
`
`incorporates the answers set forth in the preceding paragraphs and answers that BP Production
`
`- 9 -
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`Case 6:15-cv-00907-RWS-KNM Document 49 Filed 02/29/16 Page 10 of 48 PageID #: 975
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`lacks knowledge or information sufficient to form a belief as to the truth of the allegations of the
`
`Paragraphs of this Count, and therefore denies them.
`
`92. These paragraphs assert a count against Emerson alone, for which BP Production
`
`is not required to respond. If, however, a response is required, BP Production restates and
`
`incorporates the answers set forth in the preceding paragraphs and answers that BP Production
`
`lacks knowledge or information sufficient to form a belief as to the truth of the allegations of the
`
`Paragraphs of this Count, and therefore denies them.
`
`93. These paragraphs assert a count against Emerson alone, for which BP Production
`
`is not required to respond. If, however, a response is required, BP Production restates and
`
`incorporates the answers set forth in the preceding paragraphs and answers that BP Production
`
`lacks knowledge or information sufficient to form a belief as to the truth of the allegations of the
`
`Paragraphs of this Count, and therefore denies them.
`
`94. These paragraphs assert a count against Emerson alone, for which BP Production
`
`is not required to respond. If, however, a response is required, BP Production restates and
`
`incorporates the answers set forth in the preceding paragraphs and answers that BP Production
`
`lacks knowledge or information sufficient to form a belief as to the truth of the allegations of the
`
`Paragraphs of this Count, and therefore denies them.
`
`95. These paragraphs assert a count against Emerson alone, for which BP Production
`
`is not required to respond. If, however, a response is required, BP Production restates and
`
`incorporates the answers set forth in the preceding paragraphs and answers that BP Production
`
`lacks knowledge or information sufficient to form a belief as to the truth of the allegations of the
`
`Paragraphs of this Count, and therefore denies them.
`
`- 10 -
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`

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`Case 6:15-cv-00907-RWS-KNM Document 49 Filed 02/29/16 Page 11 of 48 PageID #: 976
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`96. These paragraphs assert a count against Emerson alone, for which BP Production
`
`is not required to respond. If, however, a response is required, BP Production restates and
`
`incorporates the answers set forth in the preceding paragraphs and answers that BP Production
`
`lacks knowledge or information sufficient to form a belief as to the truth of the allegations of the
`
`Paragraphs of this Count, and therefore denies them.
`
`97. These paragraphs assert a count against Emerson alone, for which BP Production
`
`is not required to respond. If, however, a response is required, BP Production restates and
`
`incorporates the answers set forth in the preceding paragraphs and answers that BP Production
`
`lacks knowledge or information sufficient to form a belief as to the truth of the allegations of the
`
`Paragraphs of this Count, and therefore denies them.
`
`98. These paragraphs assert a count against Emerson alone, for which BP Production
`
`is not required to respond. If, however, a response is required, BP Production restates and
`
`incorporates the answers set forth in the preceding paragraphs and answers that BP Production
`
`lacks knowledge or information sufficient to form a belief as to the truth of the allegations of the
`
`Paragraphs of this Count, and therefore denies them.
`
`99. These paragraphs assert a count against Emerson alone, for which BP Production
`
`is not required to respond. If, however, a response is required, BP Production restates and
`
`incorporates the answers set forth in the preceding paragraphs and answers that BP Production
`
`lacks knowledge or information sufficient to form a belief as to the truth of the allegations of the
`
`Paragraphs of this Count, and therefore denies them.
`
`100.
`
`BP Production restates and incorporates the answers set forth in the
`
`preceding paragraphs.
`
`101.
`
`Denied.
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`Case 6:15-cv-00907-RWS-KNM Document 49 Filed 02/29/16 Page 12 of 48 PageID #: 977
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`102.
`
`103.
`
`104.
`
`105.
`
`Denied.
`
`Denied.
`
`Denied.
`
`BP Production restates and incorporates the answers set forth in the
`
`preceding paragraphs.
`
`106.
`
`107.
`
`108.
`
`109.
`
`110.
`
`Denied.
`
`Denied.
`
`Denied.
`
`Denied.
`
`BP Production lacks knowledge or information sufficient to form a belief
`
`as to the truth of the allegations of the Paragraphs of this Count, and therefore denies them.
`
`111.
`
`These paragraphs assert a count against Emerson alone, for which BP
`
`Production is not required to respond. If, however, a response is required, BP Production
`
`restates and incorporates the answers set forth in the preceding paragraphs and answers that BP
`
`Production lacks knowledge or information sufficient to form a belief as to the truth of the
`
`allegations of the Paragraphs of this Count, and therefore denies them.
`
`112.
`
`These paragraphs assert a count against Emerson alone, for which BP
`
`Production is not required to respond. If, however, a response is required, BP Production
`
`restates and incorporates the answers set forth in the preceding paragraphs and answers that BP
`
`Production lacks knowledge or information sufficient to form a belief as to the truth of the
`
`allegations of the Paragraphs of this Count, and therefore denies them.
`
`113.
`
`These paragraphs assert a count against Emerson alone, for which BP
`
`Production is not required to respond. If, however, a response is required, BP Production
`
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`Case 6:15-cv-00907-RWS-KNM Document 49 Filed 02/29/16 Page 13 of 48 PageID #: 978
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`restates and incorporates the answers set forth in the preceding paragraphs and answers that BP
`
`Production lacks knowledge or information sufficient to form a belief as to the truth of the
`
`allegations of the Paragraphs of this Count, and therefore denies them.
`
`114.
`
`These paragraphs assert a count against Emerson alone, for which BP
`
`Production is not required to respond. If, however, a response is required, BP Production
`
`restates and incorporates the answers set forth in the preceding paragraphs and answers that BP
`
`Production lacks knowledge or information sufficient to form a belief as to the truth of the
`
`allegations of the Paragraphs of this Count, and therefore denies them.
`
`115.
`
`These paragraphs assert a count against Emerson alone, for which BP
`
`Production is not required to respond. If, however, a response is required, BP Production
`
`restates and incorporates the answers set forth in the preceding paragraphs and answers that BP
`
`Production lacks knowledge or information sufficient to form a belief as to the truth of the
`
`allegations of the Paragraphs of this Count, and therefore denies them.
`
`116.
`
`These paragraphs assert a count against Emerson alone, for which BP
`
`Production is not required to respond. If, however, a response is required, BP Production
`
`restates and incorporates the answers set forth in the preceding paragraphs and answers that BP
`
`Production lacks knowledge or information sufficient to form a belief as to the truth of the
`
`allegations of the Paragraphs of this Count, and therefore denies them.
`
`117.
`
`These paragraphs assert a count against Emerson alone, for which BP
`
`Production is not required to respond. If, however, a response is required, BP Production
`
`restates and incorporates the answers set forth in the preceding paragraphs and answers that BP
`
`Production lacks knowledge or information sufficient to form a belief as to the truth of the
`
`allegations of the Paragraphs of this Count, and therefore denies them.
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`- 13 -
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`Case 6:15-cv-00907-RWS-KNM Document 49 Filed 02/29/16 Page 14 of 48 PageID #: 979
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`118.
`
`These paragraphs assert a count against Emerson alone, for which BP
`
`Production is not required to respond. If, however, a response is required, BP Production
`
`restates and incorporates the answers set forth in the preceding paragraphs and answers that BP
`
`Production lacks knowledge or information sufficient to form a belief as to the truth of the
`
`allegations of the Paragraphs of this Count, and therefore denies them.
`
`119.
`
`These paragraphs assert a count against Emerson alone, for which BP
`
`Production is not required to respond. If, however, a response is required, BP Production
`
`restates and incorporates the answers set forth in the preceding paragraphs and answers that BP
`
`Production lacks knowledge or information sufficient to form a belief as to the truth of the
`
`allegations of the Paragraphs of this Count, and therefore denies them.
`
`120.
`
`These paragraphs assert a count against Emerson alone, for which BP
`
`Production is not required to respond. If, however, a response is required, BP Production
`
`restates and incorporates the answers set forth in the preceding paragraphs and answers that BP
`
`Production lacks knowledge or information sufficient to form a belief as to the truth of the
`
`allegations of the Paragraphs of this Count, and therefore denies them.
`
`121.
`
`These paragraphs assert a count against Emerson alone, for which BP
`
`Production is not required to respond. If, however, a response is required, BP Production
`
`restates and incorporates the answers set forth in the preceding paragraphs and answers that BP
`
`Production lacks knowledge or information sufficient to form a belief as to the truth of the
`
`allegations of the Paragraphs of this Count, and therefore denies them.
`
`122.
`
`These paragraphs assert a count against Emerson alone, for which BP
`
`Production is not required to respond. If, however, a response is required, BP Production
`
`restates and incorporates the answers set forth in the preceding paragraphs and answers that BP
`
`- 14 -
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`

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`Case 6:15-cv-00907-RWS-KNM Document 49 Filed 02/29/16 Page 15 of 48 PageID #: 980
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`Production lacks knowledge or information sufficient to form a belief as to the truth of the
`
`allegations of the Paragraphs of this Count, and therefore denies them.
`
`123.
`
`These paragraphs assert a count against Emerson alone, for which BP
`
`Production is not required to respond. If, however, a response is required, BP Production
`
`restates and incorporates the answers set forth in the preceding paragraphs and answers that BP
`
`Production lacks knowledge or information sufficient to form a belief as to the truth of the
`
`allegations of the Paragraphs of this Count, and therefore denies them.
`
`124.
`
`BP Production restates and incorporates the answers set forth in the
`
`preceding paragraphs.
`
`125.
`
`126.
`
`127.
`
`128.
`
`129.
`
`Denied.
`
`Denied.
`
`Denied.
`
`Denied.
`
`BP Production restates and incorporates the answers set forth in the
`
`preceding paragraphs.
`
`130.
`
`131.
`
`132.
`
`133.
`
`134.
`
`Denied.
`
`Denied.
`
`Denied.
`
`Denied.
`
`BP Production lacks knowledge or information sufficient to form a belief
`
`as to the truth of the allegations of the Paragraphs of this Count, and therefore denies them.
`
`135.
`
`These paragraphs assert a count against Emerson alone, for which BP
`
`Production is not required to respond. If, however, a response is required, BP Production
`
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`Case 6:15-cv-00907-RWS-KNM Document 49 Filed 02/29/16 Page 16 of 48 PageID #: 981
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`restates and incorporates the answers set forth in the preceding paragraphs and answers that BP
`
`Production lacks knowledge or information sufficient to form a belief as to the truth of the
`
`allegations of the Paragraphs of this Count, and therefore denies them.
`
`136.
`
`These paragraphs assert a count against Emerson alone, for which BP
`
`Production is not required to respond. If, however, a response is required, BP Production
`
`restates and incorporates the answers set forth in the preceding paragraphs and answers that BP
`
`Production lacks knowledge or information sufficient to form a belief as to the truth of the
`
`allegations of the Paragraphs of this Count, and therefore denies them.
`
`137.
`
`These paragraphs assert a count against Emerson alone, for which BP
`
`Production is not required to respond. If, however, a response is required, BP Production
`
`restates and incorporates the answers set forth in the preceding paragraphs and answers that BP
`
`Production lacks knowledge or information sufficient to form a belief as to the truth of the
`
`allegations of the Paragraphs of this Count, and therefore denies them.
`
`138.
`
`These paragraphs assert a count against Emerson alone, for which BP
`
`Production is not required to respond. If, however, a response is required, BP Production
`
`restates and incorporates the answers set forth in the preceding paragraphs and answers that BP
`
`Production lacks knowledge or information sufficient to form a belief as to the truth of the
`
`allegations of the Paragraphs of this Count, and therefore denies them.
`
`139.
`
`These paragraphs assert a count against Emerson alone, for which BP
`
`Production is not required to respond. If, however, a response is required, BP Production
`
`restates and incorporates the answers set forth in the preceding paragraphs and answers that BP
`
`Production lacks knowledge or information sufficient to form a belief as to the truth of the
`
`allegations of the Paragraphs of this Count, and therefore denies them.
`
`- 16 -
`
`

`

`Case 6:15-cv-00907-RWS-KNM Document 49 Filed 02/29/16 Page 17 of 48 PageID #: 982
`
`140.
`
`These paragraphs assert a count against Emerson alone, for which BP
`
`Production is not required to respond. If, however, a response is required, BP Production
`
`restates and incorporates the answers set forth in the preceding paragraphs and answers that BP
`
`Production lacks knowledge or information sufficient to form a belief as to the truth of the
`
`allegations of the Paragraphs of this Count, and therefore denies them.
`
`141.
`
`These paragraphs assert a count against Emerson alone, for which BP
`
`Production is not required to respond. If, however, a response is required, BP Production
`
`restates and incorporates the answers set forth in the preceding paragraphs and answers that BP
`
`Production lacks knowledge or information sufficient to form a belief as to the truth of the
`
`allegations of the Paragraphs of this Count, and therefore denies them.
`
`142.
`
`These paragraphs assert a count against Emerson alone, for which BP
`
`Production is not required to respond. If, however, a response is required, BP Production
`
`restates and incorporates the answers set forth in the preceding paragraphs and answers that BP
`
`Production lacks knowledge or information sufficient to form a belief as to the truth of the
`
`allegations of the Paragraphs of this Count, and therefore denies them.
`
`143.
`
`These paragraphs assert a count against Emerson alone, for which BP
`
`Production is not required to respond. If, however, a response is required, BP Production
`
`restates and incorporates the answers set forth in the preceding paragraphs and answers that BP
`
`Production lacks knowledge or information sufficient to form a belief as to the truth of the
`
`allegations of the Paragraphs of this Count, and therefore denies them.
`
`144.
`
`These paragraphs assert a count against Emerson alone, for which BP
`
`Production is not required to respond. If, however, a response is required, BP Production
`
`restates and incorporates the answers set forth in the preceding paragraphs and answers that BP
`
`- 17 -
`
`

`

`Case 6:15-cv-00907-RWS-KNM Document 49 Filed 02/29/16 Page 18 of 48 PageID #: 983
`
`Production lacks knowledge or information sufficient to form a belief as to the truth of the
`
`allegations of the Paragraphs of this Count, and therefore denies them.
`
`145.
`
`These paragraphs assert a count against Emerson alone, for which BP
`
`Production is not required to respond. If, however, a response is required, BP Production
`
`restates and incorporates the answers set forth in the preceding paragraphs and answers that BP
`
`Production lacks knowledge or information sufficient to form a belief as to the truth of the
`
`allegations of the Paragraphs of this Count, and therefore denies them.
`
`146.
`
`These paragraphs assert a count against Emerson alone, for which BP
`
`Production is not required to respond. If, however, a response is required, BP Production
`
`restates and incorporates the answers set forth in the preceding paragraphs and answers that BP
`
`Production lacks knowledge or information sufficient to form a belief as to the truth of the
`
`allegations of the Paragraphs of this Count, and therefore denies them.
`
`147.
`
`These paragraphs assert a count against Emerson alone, for which BP
`
`Production is not required to respond. If, however, a response is required, BP Production
`
`restates and incorporates the answers set forth in the preceding paragraphs and answers that BP
`
`Production lacks knowledge or information sufficient to form a belief as to the truth of the
`
`allegations of the Paragraphs of this Count, and therefore denies them.
`
`148.
`
`BP Production restates and incorporates the answers set forth in the
`
`preceding paragraphs.
`
`149.
`
`150.
`
`151.
`
`152.
`
`Denied.
`
`Denied.
`
`Denied.
`
`Denied.
`
`- 18 -
`
`

`

`Case 6:15-cv-00907-RWS-KNM Document 49 Filed 02/29/16 Page 19 of 48 PageID #: 984
`
`153.
`
`BP Production restates and incorporates the answers set forth in the
`
`preceding paragraphs.
`
`154.
`
`155.
`
`156.
`
`157.
`
`158.
`
`Denied.
`
`Denied.
`
`Denied.
`
`Den