Free Exhibits - District Court of Colorado - Colorado

Case 1:03-cv-02579-RPM

Document 146

Filed 01/11/2007

Page 1 of 16

IN

THE UNITED FOR THE

COURT OF COLORADO
DISTRICT

Civil

VARCO

L.P
Plaintig

vs

PASON
Defendant

DEflNDANTS

TO PLAINTIFFS
ADMISSIONS

FIRST

OF

Pason Systems Admissions
states

its

responses

to

Plaintiffs First

of Requests

for

as follows

Request

for

Admit that Pasons Admits

AutoDriller

an automatic

system

Response

Request

for Admission

No.2
used for
the release

Admit that Pasons

is

of

the drill string

of

drilling

rig

the

of

borehole

Response

Request

for

No
EXHIBIT

L15
8273.0203
vi

Case 1:03-cv-02579-RPM

Document 146

Filed 01/11/2007

Page 2 of 16

Admit that Pasons

AutoDriller

performs

method

for

automatically

the release

of

drill string

Response

Admits

Request

for

No
Pasons
includes
fluid

Admit

pressure

Response
companion
device

Admits
product senses
fluid

to

the following

clarification

the AutoDriller

an Electronic pressure

EDR

connects contain

to

which

Request

for

No
measures
drilling

Admit that Pasons

pressure

Response
companion
device

Admits
product

to

the

clarification

the AutoDriller

called an Electronic

Recorder
fluid

EDR

connects

to

which

contains

and

pressure

Request

No
Admit
that

includes

hookload

sensor

mounted on

the

drilling

rigs

line

Response
companion

Admits
product sensor

to

the

the AutoDriller connects Drilling Recorder

an Electronic

EDR

to

which

contains

hookload

Request

for

No
that

Admit

Pasons

calculates weight

on bit

Case 1:03-cv-02579-RPM

Document 146

Filed 01/11/2007

Page 3 of 16

Response
both

Admits

to

the following

clarification

As

part of the

user interface on called

AutoDriller

EDR

systems

Pasons

products

provide
the

Weight

on

Bit

which

is the calculated

differential

weight of

drill string

bottom

drilling

Request

for Admission

No
AutoDriller pressure

Admit that

Pasons

transducer

Response
incorporated

Admits

to as

the
if

stated

in response

to Request

which

by

reference

fully restated

Request

for

No
Pasons
pressure transducer

Admit

produces

an

electrical

signal

that

with

fluid

pressure

Response
incorporated

Admits
reference

to

the restated

stated

in response

to

Request

is

as if

Request

No
Admit

Pasons AutoDrillers

pressure

transducer

produces

signal

and

milliainps

Response
incorporated

Admits

subject

to

the restated

stated

in

response

to Request

is

by

reference

as if

Case 1:03-cv-02579-RPM

Document 146

Filed 01/11/2007

Page 4 of 16

Request

Admission

No 11
signal produced

Admit

electrical

by Pasons AutoDrillers pressure

transducer

i.e the 4-20 milliamp signal

has

linear

relationship

with the

drilling

fluid

pressure

within

the drilling

rigs standpipe

Response Admits
incorporated

subject

to as

the clarification
if

stated

in

response

to Request

which

is

reference

filly restated

Request

Admission

No
strain

Admit

gauge on the drilling

anchor produces

signal in response to changes

in

the weight

the

drill

string

Response
gauge upon
is

Denies and
continuous

way

of

states

that

signal not

the strain
to

reflection of

variable

responsive

or dependent

change

Request

for Admission

No
measures weight

Admit

on

bit

Response

Denies

and

way

of

reply

to

Request

Request

for Admission

No
produced
pressure transducer

Admit

that

the

passes

through

Response
produced
transducer

Denies by

and

way
to

of explanation

states

that

to
is

20 milliamp

signal

pressure

transducer

Pasons

EDR
to

system
voltage

through

cable

resister converted

signal

The

voltage

signal is then

converted

analogue into

digital

infonnation

which

is

Case 1:03-cv-02579-RPM

Document 146

Filed 01/11/2007

Page 5 of 16

combined
to

in

with other
control

digital
it

information

and

transmitted

cable

the

unit where

processed

Request

Admit

Pasons

AutoDrillers

microcontroller

an algorithm

for

producing

to

measured

drilling

pressure

Response
AutoDriller

Denies
control
in

and by
unit

way

of explanation

states

that

the algorithm
fluid

used which

analyzes

inputs including

pressure

may

or

may not

result

of

signal responsive

to

measured

drilling

pressure

Request

for Admission

No
microcontroller signal that controls

Admit

Pasons

the stepper

motor

Response any 20000
if

and explains
the
to

as follows once the
it

determines
or

movement
up
to

desired

handle
the

sends

volt component

steps per second

stepper

motor driver

off-the-shelf

produced

by

third

party

direction

step clock

and reset

Request

for

No
that

Admit

AutoDrillers microcontroller

signal that

controls

stepper

motor driver

Response

Incorporates

response

to

Request

Case 1:03-cv-02579-RPM

Document 146

Filed 01/11/2007

Page 6 of 16

Request

for Admission

18
driver signal or signals

Admit that

Pasons

stepper

that

control the stepper

motor

Response
document

Admit
attached
as

to

clarification

that

the

are

described

the

Exhibit

Request

Admission

No
AutoDrillers stepper driver signal or signals

Admit

Pasons

that

drives the stepper

Response

the response to Request

Request

Admission

No
stepper driver produces

Admit

Pasons AutoDrillers

which turn the stepper

Response

response

to

Request

18

Request

Admission

No 21
stepper

Admit

Pasons AutoDrillers

motor

in

either

forward

or backward

upon

the

or signals received

from the stepper motor

driver

Response Admits

Case 1:03-cv-02579-RPM

Document 146

Filed 01/11/2007

Page 7 of 16

Request

for

Admit that

Pasons

AutoDrillers

stepper motor is connected

to

the drilling

rigs

drawworks

brake handle

or maintaining

the

relevant

position

Response
brake lowers

Admits

subject chain

to

the clarification
the

that

stepper spring

is

to

the

handle

by

and
the stepper

to

the brake handle

when

relaxes tension

Request

for Admission

23
rigs drawworks brake varying the

Admit

drilling

braking

to the

drilling

cable

Response Admits

Request

for Admission

No 24
the brake braking force

Admit

that lifting

applied

to

the

drawworks

drilling

cable

drum

Response

Admits

Request

No
Admit borehole the
lifting

of

brake

handle

increases

rate

of release

suing

Case 1:03-cv-02579-RPM

Document 146

Filed 01/11/2007

Page 8 of 16

Response
will depend

Denies on

and

explanation
that

states

that

advancement

of

drill

number
that

include

are not limited to the position

of

brake
reducing
drill

Admits
the friction

the

handle
condition

being equal advancement of the

on the

drum

creates

string

Request

for Admission

No 26
brake handle increases the braking

Admit

that

lowering

applied

to

the

drawworks

drilling

cable

drum

Response
string

Denies on handle

by way of number of
that

states factors that

that the

advancement

of

drill

include but handle
condition

are not
all

limited to the

of the

lowering

other factors being

equal

by
the

increasing

the friction

on the

drum

creates

that inhibits

advancement

Request

Admission

No 27
drilling

Admit

that

during

borehole

of the

brake handle

decreases

rate

of release

of the

drill

Response

Denies

and

way

of

its

reply

to

Request

Request

for

No 28
stepper driver responds to small current

Admit that Pasons

or voltage

volt

producing

70

or pulses

to the stepper

Response

the responses

to

Requests

inclusive

Case 1:03-cv-02579-RPM

Document 146

Filed 01/11/2007

Page 9 of 16

Reguest

for Admission

Admit that Pasons

stepper motor driver

signals

small

voltage

i.e voltages

in milliamps and

is

voltage

signals

approximately

to

the

stepper

motor

Response

Incorporates

the responses

to

Requests

17-20

inclusive

Request

Admission

30
AutoDriller
differential

Admit

when

pressure

mode

i.e

controlling

differential

pressure the stepper motor decreases

rate

of release

the differential

pressure

exceeds

target

differential

pressure

Response
calculated

Denied
figure

In the

operation

of the AutoDriller
user interface see

differential

pressure

is

part of

Pasons answers
herein

to

Varcos
control parameter

Set of Interrogatories
is

no
Because
set

incorporated

by

absolute

pressure

of the
the operator
result

multiple control generation pressure

that

occurs

when
target

the AutoDriller pressure
will

by

increase signal that
inhibits

not

always
string

the

the

advancement

the

Reeuest

Admission

No 31
AutoDriller
is

Admit

that

when

in differential

pressure

mode
of release when

controlling

by

differential

pressure the stepper motor decreases

the rate

the

pressure

exceeds

the selected

target

differential

pressure

Response Redundant

with

30

Case 1:03-cv-02579-RPM

Document 146

Filed 01/11/2007

Page 10 of 16

Request

for

Admission when

No 32
AutoDriller

Admit

that

weight on

bit

i.e controlling

by

weight

on bit

stepper

motor increases the

rate

of release

when

the weight

on

bit

less

than the selected

target weight

on bit

Response Denied Because of set by when the AutoDriller
the target the

of multiple
operator
result to

variables

that

occurs

even from
facilitates

control

weight

on bit
signal

weight

will not

always

in the generation

of the

drill

Request

Admission when

Admit

that

AutoDriller

weight

on

bit

mode

controlling

by

weight

on bit the stepper

decreases

the rate

of release

when

the weight

on

bit

exceeds

selected

target weight

on bit

Response Denied Because of the when AutoDriller set by the operator
the target

multiple
to

variables

that

occurs

control generation

on

bit an increase signal that
inhibits

weight

will not

always

result

control

the advancement

of

Request

Admission

No
Autoflriller
is

Admit

that

in

differential pressure

and weight

on bit

mode

i.e controlling

pressure

in

with

on bit the

stepper motor

decreases

the rate of

any one or both

differential

pressure

exceeds

selected

target

differential

pressure

the weight

on

bit

exceeds

target

weight on bit

Response Denied to 34 above

way

of explanation

the

responses

to

Requests

30

10

Case 1:03-cv-02579-RPM

Document 146

Filed 01/11/2007

Page 11 of 16

Request

for Admission

No
differential

Admit

that

when

pressure

and weight on

bit

mode
stepper

controlling

pressure

in

combination

with weight

on

bit the

motor increases

rate of

when any one

both the

differential

pressure

is

the

target

differential

pressure

the weight

on

bit

less

than the

selected

target

weight

on bit

Response
to

Denied and

way

of

responses

to

Requests

30

34

Request

for Admission

No 36
stepper controls release

Admit

that

string

response

to

signals originally generated

Pasons

Electronic

Recorders

drilling

pressure

transducer

and/or

the strain gauge

the

dead

Response Denied and 15 above The
fluid

way

of explanation

incorporates the

its

response

to

Requests

stepper motor never responding

signals generated
after

by

or hookload

sensors and
variables

only

to

the signals

processing

multiple

Request

for Admission

No 37
AutoDrillers stepper driver
to

Admit

that

the

stepper

11

Case 1:03-cv-02579-RPM

Document 146

Filed 01/11/2007

Page 12 of 16

Response

Incorporates

the

responses

to

Requests

17-20 inclusive

Request

for Admission

No 38
algorithm processes signals representing

Admit

Pasons

weight

on bit

drilling

fluid

pressure drawworks

ticks

and rate of penetration

to control

the rate

of release of

string

Response Denies and
16

way

of

incorporates

the responses

to

Requests

14-

and

inclusive

Request

for Admission

No 39
in

Admit

that

Pasons

combination

the

microprocessor

signal based upon

the values

of one or

of

following

signals

on bit

pressure drawworks drum

and rate of

penetration

to

control

rate of release

of

string

Response Denies
referenced Requests

way

of
the

states

that

at

least

three of the responses
to

will influence

generated

17-20

inclusive

Request

for

Admit that Pasons

signal or signals

that

controls

operation

of

stepper

motor driver

Response

responses

to

Requests

inclusive

12

Case 1:03-cv-02579-RPM

Document 146

Filed 01/11/2007

Page 13 of 16

Request

for

Admission

No
stepper motor driver produces signal or signals

Admit

that

controls

operation

of

stepper

Response

Incorporates

the responses

to

Requests

17-20

inclusive

Request

for Admission

No
AutoDrillers stepper motor controls the rate

Admit

of release of

drill

string

Response Denies
and

by way of

its

response

to

Requests

25

26

Request

for

Admission

No
outputted

Admit

Pason AutoDrillers stepper motor driver

controls

operation

of

drill string

brake

Response

Incorporates

responses

to

Requests

17-20

inclusive

Request

for Admission

No
stepper driver
is

Admit

Pasons

responsive

to

the

output

signal

of

microprocessor

to

supply

drill string

control

signal

to the

stepper

motor

Response

Incorporates

responses

to

Requests

17-20

inclusive

13

Case 1:03-cv-02579-RPM

Document 146

Filed 01/11/2007

Page 14 of 16

Request

for

Admission

Admit

stepper motor

is

coupled

to

the stepper motor

driver

Response motor

Denies

The

stepper

motor driver

electrically

to

the stepper

14

Case 1:03-cv-02579-RPM

Document 146

Filed 01/11/2007

Page 15 of 16

VERiFICATION
Greg sworn
states that

General Manager

of

Pason

Systems

USA Corp
best of his

he has reviewed

foregoing

responses

and

that

are

true

the

PASON

USA CORP

By

ci44aanager

STATE

COUNTY OF
Subscribed

and sworn

to

before

me this .5day

of August

2006

Greg

Lindsay

General

Pason

Systems

WITNESS my hand

and

My

expires

_________

MyComm

Expires

O1I1aJ2g

15

Case 1:03-cv-02579-RPM

Document 146

Filed 01/11/2007

Page 16 of 16

CERTIFICATE
hereby certify
that

OF MAILING
true and correct copy

on August 25

of

DEFENDANTS
ADMISSIONS
Via e-mail to

TO PLAINTIFFS
properly
to

OF REQUEST
the individuals

was served

Robert

Bowick

MATrHEWS AL-AZEM
2000 Bering Houston
e-mail

Esq BowicK
700

Texas

77057

Jane Michaels

Esq
3200
80201

Holland
17th

Hart
Street

Denver
e-mail

Colorado

As

to

responsive

documents

via Federal

Express

on August

Guy
Robert

Esq Esq

MATTHEWS AL-AZEM PLLC
Drive Suite 700 Houston Texas 77057
2000

Ba Mark Tim
Ireland

Weil

Laff

Haes
Stapleton

Pryor
Street

and

Pascoe

P.C

1675

2600

Denver

Colorado

80202

303 303
B-mail

Phone

ATTORNEYS FOR DEFENDANT PASON SYSTEMS

16