Allen Burditt II and Sarah Maunee S. Burditt - Page 3




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          covering a previously completed oil and gas well and obtained               
          authorization to reenter the well.                                          
               Before perforating the well, CRI needed certain items to               
          complete the well, including a “packer”.  A packer is an                    
          expandable device that is run either in an open well, in a cased            
          hole, or in tubing to counteract pressure exerted by underground            
          oil and gas and prevent such fluids from flowing vertically.  CRI           
          purchased the packer from Lindsey Completion Services, Inc.                 
          (“Lindsey”).  The Lindsey packer did not function effectively.              
          On October 3, 1988, after attempts to obtain a pressure test of             
          its seals were unsuccessful, the Lindsey packer was removed from            
          the well.  Lindsey then provided a replacement packer, which was            
          placed in the well.                                                         
               On October 4, 1988, CRI perforated the well at 9:30 a.m.  At           
          approximately 11:00 a.m., the well developed a gas leak at the              
          wellhead,2 which indicated that high pressure was being exerted             
          from the production zone below.  As a result of this leak, gas              
          and liquid began escaping into the atmosphere in an uncontrolled            
          manner, a condition referred to as a “blowout”.  The well emitted           
          large quantities of gas and oil, placing the lives of the 20 to             
          30 workers in the surrounding area, as well as Mr. Burditt’s, at            
          imminent risk due to the possibility that a spark from static               

               2  A “wellhead” is the portion of the well above ground that           
          seals the top of the well onto the surface casing or conductor              
          pipe.                                                                       




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