Free Notice (Other) - District Court of Colorado - Colorado

Case 1:01-cv-00413-JLK-BNB

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO

M.D. MARK, INC.

* * VS. * * KERR-MCGEE CORPORATION AND * ORYX ENERGY COMPANY *

C.A. NO. 01-K-413

************************************************* DEPOSITION OF DAN HAHN JUNE 18, 2002 *************************************************

REPORTED BY: CAROL JENKINS, CSR CERTIFICATE NO. 2660

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Deposition of Dan Hahn, Page 6 line 5
08:57 5 Q. Mr. Hahn...

Deposition of Dan Hahn, Page 9 line 4 through Page 11, line 16
4 09:01 5 6 7 8 9 09:01 10 11 12 13 14 09:01 15 16 17 18 19 09:01 20 21 22 23 24 09:02 25 Q. Tell me about I guess your educational

background. A. Educational, I went to a trade school, and out Went to work for

of trade school, computer science.

Sun Oil Company at the time in computer operations. Worked up through processing, geophysical processing. You asked about education. I went into work. So would

you like for me to continue on? Q. You went to the university of life and college

of experience? A. Q. Sun? A. Q. A. Q. In 1976. And what was your job then? Computer operations and geophysical processing. And I take it they taught you how to do Absolutely, after that. That's fine. When did you first go to work for

geophysical processing? A. Q. Correct. And did Sun at the time have their own

processing centers? A. Yes.

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Q.

And would they reprocess seismic data?

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A. Q.

Through acquisition and reprocessing, yeah. So from 1976 on, you had some experience

obviously with seismic data and other kinds of exploration data; is that correct? A. Q. Correct. And then tell me what happened after 1976 with

your work experience. A. Between there and the early '80s was all in About '84, I guess

geophysical processing, operations.

is when it was, I became kind of a supervisor, manager of the geophysical data itself for all of the Sunoco, Sun E & P at that time, the storage of it and so forth. I did that for a number of years. In '89 I was still in the processing center, the geophysical services side of things. began a massive project on getting everything digitized, the shotpoint locations digitized so that we could move into a digital era. And in '91, when James Fuller retired as data sales manager, took over that job for about a year and then took a package. And then I assumed his role We

as well as all my previous duties as data sales manager. So that's kind of how I got involved with

knowing what the market side of seismic data is all

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about. In '95 I took over being manager of all

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geoscience data, geological and geophysical and the warehouses, a couple of different warehouses that housed that data and the databases and all that kind of thing. Q. A. Q. Okay. Up until the merger. And then how long were you with Kerr-McGee

after the merger? A. Q. A. Q. SEI? A. Yeah. About a year and a half. And then why did you leave? Opportunity. So you had an opportunity to come to work for

Deposition of Dan Hahn, Page 13 line 9 through Page 14, line 7
9 Q. I want to talk about storage facilities. did Oryx store all their seismic data? A. Q. At what period of time? Well, tell me for what you know from day one Where

09:07 10 11 12 13 14 09:07 15 16 17 18 19 09:08 20 21

until the merger. A. The geophysical data was stored in a place

called Kestrel Data Storage or Data Services. Q. A. Q. A. Q. A. K-a-s-t-r-o-l? K-e-s-t-r-e-l, yeah. And was that a separate company? Yes. Okay. From there it was moved to an onsite facility That was in Irving.

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of Sun E & P onsite facility at Waterview in Richardson, Waterview Parkway in Richardson. Q. A. And when was that done? In '91.

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Q.

So then was all of the onshore geophysical data

at that location then in '91? A. it. Yes. At that point, I'd say the majority of

Let me back up and say that in Denver -- in '86,

we shut down the Denver office, and they had their own facility up there. our building. I think most of that was onsite in

Deposition of Dan Hahn, Page 29 line 9 through Page 31, line 6
9 09:33 10 11 12 13 14 09:34 15 16 17 18 19 09:34 20 21 Tell me what your involvement when you first -- let me ask this. Tell me what your

involvement was in the merger between Oryx and Kerr-McGee. A. Pretty much the same role. It didn't change.

I was the geoscience data manager, you know. Q. All right. When was it that you first became

aware that there was a potential merger in the works between Oryx and Kerr-McGee? A. When I was driving in to work and heard it on

the radio the day of the announcement. Q. A. You didn't know before then? No.

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Q. A.

And so that was in February or March of 1999? Well, that was when it took place. No. That

was November, maybe. Q. November of '98?

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A.

Yeah.

We had a -- yeah, about like that, I

think is when it was. Q. Did anyone at Oryx or Kerr-McGee ask you to do

anything relating to seismic data for part of the merger? A. Q. No. Who was charged with the responsibility of

gathering all the license agreements to see what they all said? A. Q. A. In respect of the merger? Yeah. Prior to the merger, I don't think anyone was

that I'm aware of. Q. Were you talking to any -- let me ask you this:

Before the merger took place, did you have conversations with any people on behalf of any data owners about the transferability of seismic data in the merger? A. Q. None. Did you ever have conversations with any data

owner concerning the transferability of seismic data as part of the merger? A. Prior to or afterwards?

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Q. A.

Well, let's talk about both. Prior, none.

Okay.

I mean, the merger was a

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blindside, if you want to say that. prior to that.

I knew nothing

I mean, they kept that very secretive

up to that point. Afterwards, my role was typically either Glenn Morton or Carlos would call me and say, can you find --

Deposition of Dan Hahn, Page 31 line 16 through Page 31, line 20
16 17 18 19 09:37 20 A. I was contacted, they would ask me, do we have

specific data and how much of it do we have and can you find any agreements on that, any license agreements. Q. (By Mr. Pelz) Now, when did these

conversations take place?

Deposition of Dan Hahn, Page 32 line 2 through Page 32, line 15
2 3 4 09:37 5 6 7 8 9 09:37 10 11 A. When a letter was written and sent to

Kerr-McGee and passed on to Glenn Morton, Glenn would then either e-mail me or call me and say, can you locate what we've got. Q. Well, you know there were some letters that

were sent out by Oryx before the merger talking about the transferability of seismic data. any of those letters? A. Q. I was not aware of any of that. Now, before the merger, I just want to get Did you ever see

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these dates right, you first heard about the merger on the way into the office and you heard it on the radio and it was some time in November of 1998? A. I believe that's correct.

Deposition of Dan Hahn, Page 40 line 13 through Page 41, line 20
13 14 09:52 15 16 17 18 19 09:52 20 21 22 23 24 09:52 25 Q. And did you go through the process of

determining how much PGI data Oryx had or Kerr-McGee had? A. Yes. In producing what our database said we

had and what was on our mapping system. Q. And there was a map that was provided to us. Did you prepare that map or I

didn't bring it with me.

have that map printed out? A. Since I don't know what map you're referring

to, I can't say. Q. A. Well, did you have any -I made a map. Whether it's the one you're

talking about, I don't know.

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Q. A.

What did you do with your map? It just had all the data sets in it. I

prepared what I thought we had in terms of what was in our database and what was on the map and I forwarded that to Glenn. Q. A. And did you talk about it with Glenn? Not in any detail.

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Q.

All right.

Did you have any other

conversations with Glenn about M.D. Mark and the PGI database? A. Q. In terms of? In terms of whether Kerr-McGee wanted to keep

the data or what its policy was going to be towards M.D. Mark or the return of the data or anything like that? A. No. Usually I gave all that to Glenn, they did

their thing, they came back and they'd say, send it back or keep it, you know, or they didn't say keep it, I never really -- it was mainly, here's this data, send it back to this company.

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