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7. Please state all facts which support your contention
that Halliburton’s actions contributed to damage the
Davis No. 1 well.
Answer: A deep hackberry well is an extremely
volatile situation which requires precise
control. When this well blew-out, the damage
was being done to well formation on a
continuous basis. The longer the damage was
allowed to continue, the greater the damage
would be. Since Halliburton could have
controlled the well very quickly had it
performed its obligations as promised, the
damage which was done to the formation may
very well have been minimized, if not
eliminated. Accordingly, Halliburton’s
failure to control the well in an expeditious
and professional manner probably contributed
to the full extent of the damage that
occurred to the formation.
8. Please state the damages you allege were caused by
Halliburton, setting out each element and describe how
you claim it is related to anything done by
Halliburton. Please state specifically the amount you
allege against Halliburton.
Answer: The well formation was damaged and ultimately
the well was incapable of producing from the
formation originally perforated. Therefore
the cost of drilling a new well will have to
be incurred. However that may not result in
restoration of production. CRI and Allen
Burditt owned a significant interest in the
well prior to the blow-out. As a result of
the blow-out and the cost overruns that
necessarily follow it, they were required to
sell a significant part of their interest in
the well. Thus, they have forever lost the
value of the production in place which they
now cannot recover. The amount of this
production is presently being calculated but
is in excess of $2,000,000.00. The cost of
drilling another well [is] in excess of
$1,000,000.00.
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Last modified: May 25, 2011