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Case 1:98-cv-00314-EJD

Document 93-3

Filed 03/14/2007

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EXHIBIT Q

Case 1:98-cv-00314-EJD

Document 93-3

Filed 03/14/2007

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UNITED STATES DEPARTMENT OF JUSTICE
CENTRA PINES LAD CO., et al.,

Plaintiffs,
v.
THE UNITED STATES, et al.,

Docket No. 98-314L

Defendants.

Deposition of:
GARY S. DUNLAP

a witness of lawful age, taken o~behalf of the
Defendant, pursuant to notice, in the offices of the
U.S. Department of Justice, Room 3508, 601 D Street, N.W.
Washington, D.C., 20004, 'on Thursday, July 6, 2006,
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at 3: 02 p.m., before Bernadette Herboso, Notary Public
in and for the District of Columbia, when were present:
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APPEARCES:
On behalf of Plaintiffs:

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A. J. GRAY, III, Esquire The Gray Law Firm Hibernia Tower One Lakeshore Drive

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P . o. Box 1467
Lake Charles, Louisiana 70602-1467
(337) 494-0694

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Heri tage Reporting Corporation
(202) 628-4888

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Case 1:98-cv-00314-EJD

Document 93-3

Filed 03/14/2007

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APPEARCES:

(Cont'd)

On behalf of Defendant:

ALEX KRIEGSMA, Esquire

u. S. Department of Justice

Environment & Natural Resources Division General Litigation Section 601 D Street, N.W. Washington, D. C. 20004 (202) 305-3022
On behalf of the Witness:

FRED GIPSON, Esquire Chesapeake Energy Corporation 6100 North Western Avenue Oklahoma City, Oklahoma 73118 (405) 879-9257

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Case 1:98-cv-00314-EJD

Document 93-3

Filed 03/14/2007

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20

1 misunderstand that?
2
3

A
Q

No, it's a separate issue.

Okay.
We were interested in knowing that if we

4

A

5 acquired the lease that we could drill it.
6
Q

Ah, I see. Okay. And what happened at the

7 meeting with the Army? I understand you weren't
8 there, but what's your understanding?
9

A

The report back to me is they were concerned

10 wi th their training operations, rigs running at night

11 with lights for night vision and their helicopters and
12 just invading their territory so to speak, that they
13 would have to work aróund us instead of us working 14 around them, and we were trying to convince them that
15 we would work around them.
16
17
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Q

Were you able to convince them of that?
I think the general consensus after the

A

18 meeting was that it went well, but it just seemed to
19 die on the vine and nothing ever happened. We got no
official responses, and the property was never put up
for bid as far as I know.

Q So when you say there was "no official
response," does that mean there was an official

request?
MR. GIPSON: Obj ect to the form. You can
Heritage Reporting Corporation (202) 628-4888

Case 1:98-cv-00314-EJD
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Document 93-3

Filed 03/14/2007

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answer if you can.

21

2
3

MR. KRIEGSMA: Okay. That's a fair

obj ection obviously.
THE WITNESS: My recollection is that we
were prohibited from operations on the base at all.
Now where that carne from, that was our understanding.

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6
7
8

BY MR. KRIEGSMA:

Q Okay. Let me back up because that's a fair
obj ection. Was there .an official request made of the

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10 11
12
13 14

Army by Chesapeake?

A We thought the official request had been
made at the meeting, that that was what the meeting
was all about, that we wanted to have their consent to
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working with us on an op~ational basis.

15

Q And that was your understanding, that that
meeting was an official request?
A
Q

16

Yes.
Okay.
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And what's the basis for that

unders tanding?

A We asked for the meeting to make a decision
whether we could have operations on the base.

(Pause. )

Q If I could just ask you to tUrn to Exhibit
2 . No, I'm sorry. This would be Exhibi t 3. The page, I believe it's the second to the last. It's

Heri tage Reporting Corporation
(202) 628-'4888

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